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AMERICAN ARBITRATION ASSOCIATION
AMAZON.COM, INC., a Delaware corporation, Claimant, v. AROBO TRADE, INC., Respondent.  No. ____________________
AMAZON.COM, INC.’S
DEMAND FOR ARBITRATION
Amazon.com, Inc. (“Amazon”), for its demand for arbitration, states as follows:
I. SUMMARY
 1.
 
Each day, millions of consumers use Amazon’s website to assist with their
 purchasing decisions. In order to make those decisions more informed, Amazon provides customer reviews of products and services available on Amazon.com. Amazon pioneered customer reviews 20 years ago and is now home to hundreds of millions of unique reviews. Reviews provide a forum for sharing authentic feedback about products and services
 — 
 positive or negative. Amazon does not remove reviews because they are
critical of products; Amazon believes all helpful information can inform its customers’
 buying decisions. Whether positive, negative, or anywhere in between, Amazon takes the credibility of its customer reviews very seriously. 2.
 
A very small minority of sellers attempt to gain an unfair competitive advantage by creating false, misleading, and inauthentic customer reviews for their
 
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 products on Amazon.com. While small in number, these reviews threaten to undermine the trust that customers, and the vast majority of sellers and manufacturers, place in
Amazon, thereby tarnishing Amazon’s brand. Amazon strictly prohibits any attempt to
manipulate customer reviews and actively polices its website to remove false, misleading, and inauthentic reviews. Despite substantial efforts to stamp out the practice, a small number of bad actors continue to endeavor to utilize inauthentic reviews to boost their sales. 3.
 
Since the beginning of 2015, Amazon has filed lawsuits against over 1,000 respondents who offered to post fake reviews in exchange for payment. Through these
efforts, as well as analysis of Amazon’s own data, Amazon has identified sellers who have
 paid for fake reviews and taken enforcement action against those sellers such as suspending or blocking their accounts. This demand for arbitration is a continuation of those actions and is intended to eliminate the incentives for sellers to engage in abuse. 4.
 
Respondent has engaged in an extensive and concerted effort to mislead
Amazon’s customers and to manipulate customer reviews for his products. Respondent has knowingly violated Amazon’s rules for seller behavior, and has used deception and
artifice in an attempt to circumvent
Amazon’s investigative and enforcement efforts, by
creating multiple customer accounts and posting fake reviews. 5.
 
Respondent’s deceptive conduct has damaged Amazon, Amazon’s customers, and the many honest sellers who use Amazon’s marketplace. This damage
will continue unless Respondent is immediately and permanently enjoined from using
Amazon’s website, in any fashion whatsoever.
 6.
 
In this proceeding, Amazon brings claims for violations of §43 of the Lanham Act, 15 U.S.C. §1125(a) (Unfair Competition/False Advertising); violations of
 
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the Washington Consumer Protection Act (RCW Ch. 19.86); and breach of contract and violation of Washington common law.
II. THE PARTIES
 7.
 
Amazon is a Delaware corporation with its principal place of business in Seattle, Washington. Amazon owns and operates the Amazon.com website, and equivalent international websites. Amazon has more than two hundred and fifty million active customers. 8.
 
Respondent Arobo Trade Inc., aka Aumax Direct, aka Aumax Corp.
(“Arobo Trade”), is a Delaware corporation with a registered agent in San Carlos,
California. Respondent is the owner and operator of, and is responsible for the actions of,
Amazon seller “Arobo Trade INC/Aumax Direct” (“Amazon Seller Arobo Trade”).
9.
 
Respondent has agreed that any dispute with Amazon will be resolved by  binding arbitration conducted by the American Arbitration Association (AAA) under its rules. A true and correct copy of the applicable agreement is attached hereto.
III.
AMAZON’S PRODUCT REVIEW SYSTEM
 
10.
 
Amazon encourages its customers to review products and services available on its websites. These reviews are made available on the detail pages of those  products and services. Consumers rely on this customer feedback to make informed  purchasing decisions. Customers trust that these reviews will be honest, helpful, and authentic. 11.
 
Each product review comprises the reviewer’s textual comments and a “star rating” that ranges from on
e star to five stars. Amazon compiles these product reviews, summarizes the compiled star ratings, and publishes those results alongside the advertised product for shoppers to see.
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