Filed: 2022 AUG 09 09:00 AM King County Superior Court Clerk E-Filed CASE #: 22-2-12549-7 SEA

1 FILED
2022 AUG 09 09:00 AM

2 KING COUNTY
SUPERIOR COURT CLERK
3 E-FILED
CASE #: 22-2-12549-7 SEA
4
7 SUPERIOR COURT OF THE STATE OF WASHINGTON

KING COUNTY
8
9 AMAZON.COM, INC., a Delaware corporation; No.

and AMAZON.COM SERVICES LLC, a
10 Delaware limited liability company, COMPLAINT FOR DAMAGES
11 AND INJUNCTIVE RELIEF
Plaintiffs,
12
v.
13
DOES 1–5, d/b/a Accfarm.com,
14
15 Defendants.
16
17 COMPLAINT
18 Plaintiffs Amazon.com, Inc. and Amazon.com Services LLC (collectively, “Amazon”)
19 bring this action against defendants Does 1–5 (collectively, “Defendants”), who are responsible
20 for the website Accfarm.com (“AccFarm”), for injunctive relief and damages as follows:
21 I. SUMMARY
22 1. Every day, millions of consumers who shop in Amazon’s stores use customer
23 product reviews to assist with purchasing decisions. Customer trust and fair competition in
24 Amazon’s stores depend, in part, on the authenticity of those reviews. The bad actors who pay
25 for product reviews erode that customer trust, compete unfairly with the millions of honest
26 entrepreneurs who sell in Amazon’s stores, and tarnish Amazon’s brand.
27 2. Amazon devotes extensive efforts to combat product reviews that are false,
Davis Wright Tremaine LLP
920 Fifth Avenue, Suite 3300
COMPLAINT - 1 Seattle, WA 98104-1610
206.622.3150 main · 206.757.7700 fax
1 inauthentic, or incentivized (“fake reviews”). Incentivized reviews that are not identified as such
2 are inherently false and misleading because they are motivated by compensation, withhold that
3 key information from consumers, and therefore are likely to mislead consumers into believing
4 they are from unbiased and independent customers. In 2020, Amazon intercepted more than 200
5 million suspected fake reviews, leveraging machine learning models and teams of employees
6 dedicated to keeping Amazon’s stores free of fake reviews.
7 3. Despite Amazon’s efforts, fake reviews persist because sales of fake reviews are
8 perpetrated largely on third-party websites like AccFarm, or in dedicated groups on social media
9 sites, as opposed to within Amazon’s stores where the fake reviews are ultimately posted.
10 4. Amazon is bringing this action against the owners and operators of AccFarm,
11 which sells fake reviews, in order to shut down the website and seek disgorgement of
12 Defendants’ ill-gotten gains from selling fake reviews and other fraudulent services.
13 5. Upon information and belief, Defendants are fully aware that AccFarm provides
14 services that are illegal and unfair to honest Amazon selling partners, to customers, and to
15 Amazon itself. Defendants succinctly describe the nature of their business: “AccFarm generates
16 fake reviews but gears mostly on the positive side of reviews.”1 At prices ranging from $39.99 to
17 $199.99, Defendants offer sellers the opportunity to buy packages of fake reviews for their
18 products in Amazon’s stores.
19
20
21
22
23 6. Defendants advertise “5-Star Ratings,” “Option to Choose A Custom Rating,” and

2
24 “Option To Leave Your Own Text” for fake reviews. On information and belief, Defendants use
25 fraudulent Amazon customer accounts to post the fake Amazon reviews on sellers’ product
26 1
“Buy Amazon Reviews,” https://accfarm.com/buy-positive-reviews/amazon-reviews (accessed July 6, 2022)
(emphasis added).
27 2
Id.

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1 listing pages in exchange for a fee.
7
7. Defendants know that Amazon has contractual prohibitions against fake reviews
8
and therefore that Defendants are incentivizing sellers to violate their contracts with Amazon.
9
Indeed, AccFarm cautions sellers that “Amazon takes the integrity of reviews seriously.”3
10
11
12
13
8. Further, Defendants acknowledge that “[t]echnically speaking, it is illegal to buy
14
Amazon product reviews. Apart from getting banned [by Amazon], you might also be sued when
15
the system finds out that you are forging reviews.”4
16
17
18
19
9. Defendants know and intend that their business of selling fake reviews will
20
improperly manipulate the published ratings and rankings of products listed for sale in Amazon’s
21
stores, resulting in the deception of Amazon’s customers and the erosion of customer trust in
22
Amazon’s stores. Indeed, Defendants advertise their services as a way for sellers to “boost sales,
23
turnover and ranking!”5
24
10. Defendants also provide other fraudulent services designed to deceive Amazon
25
3
26 Id. (emphasis added).
4
Id. (emphasis added).
27 5
Id.

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1 and its customers. For example, Defendants advertise the sale of fake Amazon customer
2 accounts at prices ranging from $29.99 for a fake “Amazon Buyer Account” to $499.99 for a
3 fake “Amazon Business Buyer Tax-Exempt Account.”6
4 11. Defendants are actively deceiving Amazon’s customers and tarnishing Amazon’s
5 brand for their own profit, as well as for the profit of dishonest sellers who purchase their
6 services. Through their actions, Defendants intentionally mislead and cause harm to Amazon, its
7 customers, and its honest selling partners. Amazon is bringing this action to protect its customers
8 and selling partners from this misconduct by stopping Defendants and shutting down the fake
9 review and other fraudulent schemes in which they participate.
10 12. In this action, Amazon brings claims for violations of the Washington Consumer
11 Protection Act (RCW Ch. 19.86) and Washington common law.
12 II. JURISDICTION AND VENUE

13 13. This Court has personal jurisdiction over Defendants, all of whom have conducted
14 business activities in and directed to Washington and are primary participants in tortious acts in
15 and directed to Washington. Defendants affirmatively undertook to manipulate reviews, ratings,
16 and rankings of products sold in stores operated by Amazon, a corporation with its principal
17 place of business in Washington, and posted fake reviews in the Amazon.com store (the
18 “Amazon Store”). Amazon employs a team of analysts and data scientists who are primarily
19 based in Washington and analyze product reviews.
20 14. Defendants’ acts deceived consumers who purchased products in the Amazon
21 Store and harmed Amazon. Defendants knowingly committed or facilitated the commission of
22 tortious acts in and directed to Washington and have wrongfully caused Amazon substantial
23 injury in Washington.
24 15. Personal jurisdiction is also proper in this Court because Defendants consented to
25 exclusive jurisdiction in the state and federal courts in King County, Washington, when they
26 agreed to Amazon’s Conditions of Use in order to create customer accounts and post reviews in
27 6
“Buy Amazon Accounts,” https://accfarm.com/amazon-accounts/ (accessed July 10, 2022).
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1 the Amazon Store, among other activities.
2 16. Venue is proper in this Court pursuant to RCW §§ 4.12.010–.025 in that a
3 substantial part of the events or omissions giving rise to the claims pled herein occurred in King
4 County, Amazon seeks damages for personal injury or damage to personal property in King
5 County, and Amazon’s causes of action arose in King County. Venue is also proper because
6 Defendants consented to jurisdiction in this Court as set forth in Paragraph 15.
7 III. THE PARTIES

8 17. Amazon.com, Inc. is a Delaware corporation with its principal place of business
9 in Seattle, Washington. Amazon.com Services LLC is a Delaware company with its principal
10 place of business in Seattle, Washington. Amazon owns and operates the Amazon Store and
11 website and equivalent international stores and websites. Amazon has over three hundred million
12 active customers.
13 18. Defendants sued herein as Does 1–5 own, operate, or maintain Accfarm.com, or
14 are otherwise responsible for AccFarm’s operations. Amazon is unaware of the true names and
15 capacities of Defendants, and therefore Amazon sues these Defendants by such fictitious names.
16 Amazon will amend this Complaint to allege Defendants’ true names and capacities when
17 ascertained. Amazon is informed and believes and therefore alleges that each of the fictitiously
18 named Defendants is responsible in some manner for the occurrences alleged and that Amazon’s
19 injuries as herein alleged were proximately caused by said Defendants.
20 IV. AMAZON’S PRODUCT REVIEW SYSTEM

21 19. Amazon pioneered online customer reviews 25 years ago, and Amazon’s stores
22 are now home to billions of unique reviews. Reviews provide a forum for customers to share
23 authentic opinions about products—positive or negative. As long as Amazon’s customers abide
24 by Amazon’s Community Guidelines,7 which prohibit illegal, obscene, infringing, and other
25
26 7
“Community Guidelines,”
https://www.amazon.com/gp/help/customer/display.html?nodeId=GLHXEX85MENUE4XF (accessed July 21,
27 2022).

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1 abusive reviews, they may review and rate any product available in Amazon’s stores. Amazon
2 does not remove reviews if they are critical of the product; Amazon believes all helpful
3 information relevant to a product can inform its customers’ buying decisions. Honest and
4 unbiased reviews allow customers to trust that they can shop with confidence in Amazon’s
5 stores, and reviews also help fulfill Amazon’s mission to be Earth’s most customer-centric
6 company. In short, Amazon takes the integrity and authenticity of its customer reviews very
7 seriously.
8 20. Amazon encourages its customers to review products available in its stores.
9 Amazon displays these reviews on the detail pages for the products. Consumers rely on these
10 reviews to make informed purchasing decisions. Customers trust that these reviews will be
11 honest, authentic, and unbiased.
12 21. Each product review is comprised of a “star rating” that ranges from one star to
13 five stars and can also include textual comments and product images or video. Amazon compiles
14 these product reviews, summarizes the compiled star ratings, and displays those results alongside
15 the listed product for shoppers to see while they are shopping. An example of product reviews
16 for the Amazon Echo follows:
17
18
19
20
21
22
23
24
25
26
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1
10
11
22. Reviews can impact product sales in multiple ways. Most immediately, positive
12
reviews can encourage customers to purchase a product. In addition, reviews can influence a
13
product’s sales ranking: Amazon records and publishes “rankings” of products sold in its stores,
14
which are based on sales. Amazon uses product sales data to create its Best Seller Rank (“BSR”),
15
and also provides best seller lists for categories and subcategories of products. This information
16
is updated hourly to reflect recent and historical sales of nearly every product sold. This
17
information helps consumers understand which products are popular and how their sales are
18
trending, which may help influence shopping decisions. As such, reviews can indirectly increase
19
a product’s sales rank.
20
23. Additionally, where a customer decides to sort results of a search by average
21
customer rating, the reviews and star ratings of a product directly impact the order in which that
22
customer sees products, with the product containing the highest average star rating appearing at
23
the top of the list.
24
V. BUYER AND SELLER POLICIES AGAINST FAKE REVIEWS AND
25 AMAZON’S PREVENTION EFFORTS
26 24. Amazon strictly prohibits any attempt to manipulate product reviews and
27 expressly prohibits compensated reviews.

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1 25. In order to review a product, an individual must have an Amazon customer
2 account. When signing up for an Amazon customer account, the user is notified on the “Create
3 Account” screen that “[b]y creating an account you agree to Amazon’s Conditions of Use,” and
4 is provided with a hyperlink to Amazon’s Conditions of Use.8 As a result, each person who
5 reviews products has agreed to and is bound by the Conditions of Use.
6 26. By agreeing to the Conditions of Use, each product reviewer enters into a
7 contractual relationship with Amazon.
8 27. The Conditions of Use provide that in posting content in the Amazon Store, such
9 content is accurate and will not cause injury to any person or entity. The Conditions of Use
10 further provide that, in posting content in the Amazon Store, users “may not use a false e-mail
11 address, impersonate any person or entity, or otherwise mislead as to the origin of . . . content.”9
12 28. Furthermore, any person who uses Amazon’s “community features”—which
13 include providing reviews and star ratings—agrees to and is bound by Amazon’s Community
14 Guidelines.10
15 29. Amazon’s Community Guidelines prohibit:
16  Creating, editing, or posting content about the seller’s own products or services.
17  Creating, modifying, or posting content in exchange for compensation of any kind or
on behalf of anyone else.
18
 Offering compensation or requesting compensation in exchange for creating,
19 modifying, or posting content.11
20 30. Separately, each seller who lists a product for sale in the Amazon Store has
21 agreed to and is bound by the Amazon Services Business Solutions Agreement (“BSA”).12
22 31. By agreeing to the BSA, each seller enters into a contractual relationship with
23 8
“Conditions of Use,”
https://www.amazon.com/gp/help/customer/display.html?nodeId=GLSBYFE9MGKKQXXM (accessed June 30,
24 2022).
9
Id.
25 10
Community Guidelines.
26 11
Id.
12
“Amazon Services Business Solutions Agreement,”
27 https://sellercentral.amazon.com/gp/help/external/G1791?language=en_US, (accessed July 6, 2022).

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1 Amazon. The BSA incorporates Amazon’s Community Guidelines.
2 32. The BSA also incorporates Amazon’s Customer product reviews policies, which
3 expressly warn sellers that they may not offer a financial reward, discount, free products, or other
4 compensation in exchange for a review, and may not offer to provide a refund or reimbursement
5 after the buyer writes a review.13
6 33. Amazon’s seller-facing website Seller Central provides additional guidelines to
7 sellers:14
8 If you decide to ask a buyer to leave a review, you may not ask for a positive
review or ask for reviews only from buyers who had a positive experience, nor
9 may you ask customers to change or remove their review, or attempt to influence
the review. For example, you may not offer any compensation for a review,
10 including money or gift cards, free or discounted products, refunds or
reimbursements, or any other future benefits.
11
12 Can I offer a voucher or a free gift?
13 We do not permit reviews or votes on the helpfulness of reviews that are posted in
exchange for compensation of any kind, including any of the following:
14
 Payment (including money or gift cards)
15  Refund or reimbursement, including through non-Amazon payment methods
16  Free product
 Entry to a prize drawing or competition
17  Discounts on future purchases
 Other gifts
18
34. Amazon’s Seller Code of Conduct, which is also incorporated into the BSA,
19
makes clear that sellers “may not attempt to influence or inflate customers’ ratings, feedback,
20
and reviews.”15 Among the conduct the Seller Code of Conduct prohibits is “[p]ay[ing] for or
21
offer[ing] an incentive (such as coupons or free products) in exchange for providing or removing
22
23
24 13
“Customer product reviews policies,”
https://sellercentral.amazon.com/gp/help/external/GYRKB5RU3FS5TURN?language=en_US&ref=efph_GYRKB5
25 RU3FS5TURN_cont_521 (accessed July 6, 2022).
14
“Answers to Questions About Product Reviews,”
26 https://sellercentral.amazon.com/gp/help/external/G201972160?language=en_US (accessed July 6, 2022).
15
“Seller Code of Conduct,” https://sellercentral.amazon.com/gp/help/external/G1801?language=en_US (accessed
27 July 6, 2022).

206.622.3150 main · 206.757.7700 fax
1 feedback or reviews” and “[r]eview[ing] your own products or a competitors’ products.”16
2 35. Thus, the contracts that govern sellers’ and customers’ access to the Amazon
3 Store prohibit creating, posting, offering, or soliciting fake reviews.
4 36. Unfortunately, at times, dishonest sellers try to gain unfair competitive advantages
5 for their products in Amazon’s stores by paying for false, misleading, and inauthentic customer
6 reviews. These reviews can significantly undermine the trust that consumers, sellers, and
7 manufacturers place in Amazon, which in turn tarnishes Amazon’s brand.
8 37. Amazon takes the integrity of its customer reviews extremely seriously.
9 Amazon’s goal is to detect and remove a fake review before a customer ever sees it, and thus
10 Amazon invests significant financial and personnel resources to protect its stores from abuse. As
11 part of its efforts to ensure the authenticity of reviews, Amazon has developed sophisticated
12 solutions to detect and remove such reviews from its stores. Amazon analyzes reviews that are
13 submitted and continues to scour its stores for published fake reviews, stops and/or removes fake
14 reviews when it finds them, and takes enforcement actions against bad actors that post and/or
15 purchase fake reviews. Amazon is constantly innovating to improve its ability to identify and
16 remove fake reviews, but when that abuse takes place away from Amazon’s stores, bad actors
17 are emboldened to act in direct contravention of Amazon’s policies and the law.
18 VI. DEFENDANTS’ DECEITFUL ACTS

19 38. Beginning at a time unknown to Amazon, Defendants obtained the domain name
20 Accfarm.com, a website through which they operate their illicit business of selling fake Amazon
21 product reviews and fake Amazon customer accounts.
22 39. Defendants expressly target their services to Amazon sellers. They advertise that
23 sellers can “Boost Your Amazon Profile By Buying Reviews in AccFarm,” and emphasize that,
24 “[i]f you are a seller, having positive reviews is what you aim for. As they say, word of mouth is
25 powerful.”17
26
16
Id.
27 17
“Buy Amazon Reviews,” https://accfarm.com/buy-positive-reviews/amazon-reviews (accessed July 5, 2022).

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1 40. Defendants outline three steps for their fake reviews scheme: (1) “You [the seller]
2 leave your contact email, link to your business page and note everything we should take into
3 account regarding your needs,” (2) “We start posting high-quality reviews on your business
4 page,” and (3) “Your rating increases, which helps you turn your potential customers into loyal
5 clients with ease by building trust in your brand.”18
6 41. Defendants sell several types of fake Amazon reviews at different price points,
7 including “Verified Amazon Reviews: from $39.99,” “Amazon Book Review: from 49.99$,” and
8 “Verified Amazon Video Reviews: from 199.99$,” among others.19
10
11
12
13
42. Defendants advertise that they can target their fake reviews to customers in
14
specific countries, including customers in the United States.20
15
43. Defendants boast that they “can produce bulk orders” of fake reviews, and that
16
“busy sellers find this scheme very helpful … [because they can] get bulk reviews … without a
17
hitch and hassle.”21 They emphasize that “[i]n terms of buying reviews,” “the more, the
18
merrier.”22
19
20
21
22
23
24
18
Id.
25 19
Id.
20
26 Id.
21
Id.
27 22
Id.

206.622.3150 main · 206.757.7700 fax
1 44. AccFarm offers escalating discounts for higher volumes, with “50% off” for “200
2 Verified Amazon Reviews” (at a total price of $7,999.99).23
10
11
12
13
14
15
45. Defendants also advertise “5-Star Ratings” and the “Option To Choose A Custom
16
Rating.”24 According to its website, “AccFarm generates fake reviews but gears mostly on the
17
positive side of reviews.”25
18
19
20
21 46. Defendants also advertise that their reviews include “High-Quality Texts,” and
22 offer customers the “Option to Leave Your Own Text.”26
23 47. Defendants further claim that their fake reviews are from “100% Real People.”27
24
23
Id.
25 24
Id.
25
26 Id.
26
Id.
27 27
Id.

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1 However, they do not disclose who these purported “Real People” are, and it is apparent from
2 AccFarm’s website that Defendants’ reviews do not reflect the experiences of real customers of
3 products sold in Amazon’s stores. Instead, as the website admits, Defendants “generate[] fake
4 reviews” through fake customer accounts that they control.
5 48. Defendants separately advertise the sale of fake Amazon customer accounts
6 through the AccFarm website.28
7 49. For example, Defendants offer an “Amazon Buyer Account” for $29.99, an
8 “Amazon Business Buyer Account” for $299.99, and an “Amazon Business Buyer Tax-Exempt
9 Account” for $499.99.29 Defendants advertise these fake accounts as “cheap” and in “bulk.”30 On
10 information and belief, these fake accounts are purchased by sellers in order to post fake reviews
11 of their own products or of their competitors’ products.
12
13
14
15
16
17
18
19
20
21 50. In summary, Defendants provide services that are intended to defraud Amazon
22 and its customers, including the sale of fake reviews and fake customer accounts in violation of
23 Amazon policies, and for the express purpose of deceptively manipulating published ratings and
24 rankings of products for sale in Amazon’s stores.
25 51. Defendants know that Amazon maintains contractual relationships with sellers
26 28
“Buy Amazon Accounts,” https://accfarm.com/amazon-accounts (accessed June 17, 2022).
29
Id.
27 30
Id.
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1 and with product reviewers.
2 52. Defendants also know that Amazon’s policies (and thus Amazon’s contracts with
3 sellers and product reviewers) prohibit fake reviews and fake customer accounts, and know and
4 intend that their efforts in selling such fake reviews and fake customer accounts will violate
5 Amazon’s policies and improperly manipulate the published ratings and ranking of products
6 listed for sale in Amazon’s stores.
7 VII. REPUTATIONAL HARM TO AMAZON AND HARM TO THE PUBLIC

8 53. Fake reviews significantly undermine the trust that customers, sellers, and
9 manufacturers place in Amazon, which in turn tarnishes Amazon’s brand.
10 54. Product reviews are an important part of a customer’s shopping experience, and
11 customers rely on the accuracy and authenticity of reviews to inform their shopping decisions.
12 Fake reviews harm customers by providing misleading information about the quality,
13 authenticity, and nature of products. When reviews are false, inaccurate, or misleading,
14 customers’ expectations for product quality and performance are not fulfilled.
15 55. When reviews are not trustworthy, consumers lose confidence in the quality and
16 performance of products and associated ratings in Amazon’s stores and are less likely to
17 purchase products. This loss of confidence damages the goodwill Amazon has built with its
18 customers and harms Amazon’s reputation.
19 56. Similarly, fake reviews threaten to undermine the trust of honest sellers who sell
20 products in Amazon’s stores. When dishonest sellers use fake reviews to gain a competitive
21 advantage, they harm honest sellers who play by the rules and earn positive reviews by offering
22 high-quality products and excellent customer service. In turn, these honest sellers lose faith in the
23 integrity of Amazon’s stores. Multiple sellers have complained to Amazon about fake reviews,
24 with comments like, “It is very disadvantageous to compete with sellers who manipulate the
25 reviews in this way.”
26 57. As a result of reviews abuse perpetuated in Amazon’s stores by bad actors, there
27 has been widespread media and government attention to fake reviews in Amazon’s stores.
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1 58. The Wall Street Journal published a story regarding fake reviews in Amazon’s
2 stores on June 13, 2021, titled, “Fake Reviews and Inflated Ratings Are Still a Problem for
3 Amazon.”31 The article focuses on sellers and third parties who encourage reviews abuse against
4 Amazon policies.
5 59. Two days later, Amazon received its first inquiry from Congress, by Senator
6 Roger Wicker, Ranking Member of the Senate Commerce Committee, regarding the work
7 Amazon does to ensure reviews are authentic and inquiring whether reviews abuse in Amazon’s
8 stores detailed in the Wall Street Journal article is widespread.
9 60. Customers who become aware of these articles and investigations, as well as
10 those to whom bad actors offer incentives to leave fake reviews, could lose trust in Amazon as a
11 resource for unbiased product reviews.
12 61. In sum, as a result of bad actors’ perpetuation of reviews abuse, Amazon and its
13 customers have suffered substantial harm.
14
FIRST CLAIM FOR RELIEF
15 Consumer Protection Act (RCW Ch. 19.86)
16 62. Amazon incorporates by reference the allegations of each and every one of the
17 preceding paragraphs as though fully set forth herein.
18 63. Defendants have engaged in unfair and deceptive acts and practices occurring in
19 trade or commerce in violation of the Washington Consumer Protection Act, RCW Ch. 19.86.
20 64. Defendants’ actions were injurious to the public interest. The acts were committed
21 in the course of Defendants’ business and caused the public dissemination of false customer
22 reviews designed to trick consumers. Defendants’ acts had the capacity to and did harm
23 consumers.
24 65. Defendants’ unfair and deceptive business practices have unjustly harmed
25
26 31
“Fake Reviews and Inflated Ratings Are Still a Problem for Amazon,” Wall Street Journal,
https://www.wsj.com/articles/fake-reviews-and-inflated-ratings-are-still-a-problem-for-amazon-11623587313
27 (accessed July 6, 2022).

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1 Amazon and are causing Amazon to suffer damages.
2 66. Amazon is entitled to treble damages, attorneys’ fees, and costs, pursuant to
3 RCW 19.86.090.
4 67. As a result of Defendants’ unfair and deceptive acts and practices, Amazon has
5 also suffered irreparable injury and, unless Defendants are enjoined from such unfair
6 competition, will continue to suffer irreparable injury whereby Amazon has no adequate remedy
7 at law.
8
SECOND CLAIM FOR RELIEF
9 Breach of Contract
12 69. By signing up for customer accounts in the Amazon Store and posting reviews in
13 the Amazon Store (among other activities), Defendants have accepted and at all relevant times
14 were bound by Amazon’s Conditions of Use and Community Guidelines.
15 70. Amazon fully performed all of its obligations under the Conditions of Use and
16 Community Guidelines.
17 71. Defendants have materially breached Amazon’s Conditions of Use and
18 Community Guidelines by, among other actions, (1) requesting and accepting compensation for
19 creating and posting fake reviews in the Amazon Store, (2) posting fake reviews in the Amazon
20 Store that are misleading and injurious to others; and (3) selling fake Amazon customer
21 accounts.
22 72. Defendants’ breaches of Amazon’s Conditions of Use and Community Guidelines
23 have resulted in damage to Amazon.
24
THIRD CLAIM FOR RELIEF
25 Intentional Interference with Contractual Relations

206.622.3150 main · 206.757.7700 fax
1 74. Amazon maintains contracts with each seller of goods in the Amazon Store, as
2 each such seller agreed to the Amazon Services Business Solutions Agreement.
3 75. Amazon maintains contracts with each reviewer of goods in the Amazon Store, as
4 each such user agreed to the Amazon Conditions of Use and Community Guidelines.
5 76. Defendants have knowledge of these contracts and the contractual prohibitions
6 against fake and paid reviews.
7 77. Defendants intended to disrupt and, with malice and through unfair means, did
8 interfere with the performance of these contracts.
9 78. As a result of Defendants’ actions, Amazon has been harmed.
10
FOURTH CLAIM FOR RELIEF
11 Unjust Enrichment/Restitution
14 80. Defendants unjustly received benefits in the form of payments from Amazon
15 sellers in exchange for their deceptive services, at Amazon’s expense through their wrongful
16 conduct, including their interference with Amazon’s business relationships and other unfair
17 business practices. Defendants continue to unjustly retain these benefits at Amazon’s expense. It
18 would be unjust for Defendants to retain any value they obtained as a result of their wrongful
19 conduct.
20 81. Amazon is entitled to the establishment of a constructive trust consisting of the
21 benefit conferred upon Defendants by the revenues derived from their wrongful conduct at
22 Amazon’s expense and all profits derived from that wrongful conduct. Amazon is further entitled
23 to full restitution of all amounts in which Defendants have been unjustly enriched at Amazon’s
24 expense.
25 PRAYER FOR RELIEF
26 WHEREFORE, Amazon respectfully requests judgment as follows:
27
206.622.3150 main · 206.757.7700 fax
1 1. That the Court issue injunctive relief against Defendants and that Defendants,
2 their officers, agents, representatives, servants, employees, attorneys, successors and assigns, and
3 all others in active concert or participation with Defendants, be enjoined and ordered to:
4 (a) Cease and desist from selling or facilitating the sale of Amazon reviews;
5 (b) Provide information sufficient to identify each Amazon review created in
6 exchange for payment and the accounts and persons who created or paid for such
7 reviews; and
8 (c) Cease and desist from selling or facilitating the sale of fake Amazon
9 customer accounts;
10 (d) Provide information sufficient to identify each fake Amazon customer
11 account created and/or sold and the persons who created or paid for such accounts; and
12 (e) Cease and desist from assisting, aiding, or abetting any other person or
13 business entity in engaging in or performing any of the activities referred to in
14 subparagraphs (a) and (c) above; and
15 (f) Disable the Accfarm.com domain and transfer it to Amazon.
16 2. That the Court enter an Order requiring Defendants to disgorge their profits and
17 declaring that Defendants hold in trust, as constructive trustees for the benefit of Amazon, their
18 illegal profits gained from the sale of fake reviews, and requiring Defendants to provide Amazon
19 with a full and complete accounting of all amounts obtained as a result of Defendants’ illegal
20 activities;
21 3. That the Court enter an Order instructing Defendants, jointly and severally, to pay
22 Amazon’s general, special, actual, and statutory damages, including treble damages pursuant to
23 RCW Ch. 19.86;
24 4. That the Court order Defendants to pay Amazon both the cost of this action and
25 attorneys’ fees incurred in prosecuting this action; and
26 5. That the Court grant Amazon such additional and further relief as is just and
27 proper.
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1 DATED this 9th day of August, 2022.
2 Davis Wright Tremaine LLP

3 Attorneys for Plaintiffs
4 By /s/ Scott Commerson

Scott Commerson, WSBA #58085
5 865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
6 Tel: (213) 633-6800
Fax: (213) 633-6899
7 Email: [email protected]
8 /s/ Eric Franz
Eric Franz, WSBA #52755
9 920 5th Avenue, Suite 3300
Seattle, WA 98104-1610
10 Tel: (206) 622-3150
Fax: (206) 757-7700
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206.622.3150 main · 206.757.7700 fax
KING COUNTY SUPERIOR COURT
CASE ASSIGNMENT AREA DESIGNATION and CASE INFORMATION COVER SHEET
(CICS)
Pursuant to King County Code 4A.630.060, a faulty document fee of $15 may be assessed to new case
filings missing this sheet.
CASE NUMBER: _______________________________________________________________

(Provided by the Clerk)
CASE CAPTION: Amazon.com, Inc. and Amazon.com Services LLC v. Does 1‐5 d/b/a AccFarm.com
(New case: Print name of person starting case vs. name of person or agency you are filing against.)
(When filing into an existing family law case, the case caption remains the same as the original filing.)
Please mark one of the boxes below:

☒ Seattle Area, defined as:
All of King County north of Interstate 90 and including all of the

Interstate 90 right-of-way; all the cities of Seattle, Mercer Island,
Bellevue, Issaquah and North Bend; and all of Vashon and Maury
Islands.
☐ Kent Area, defined as:

All of King County south of Interstate 90 except those
areas included in the Seattle Case Assignment Area.
I certify that this case meets the case assignment criteria, described in King County LCR 82(e).
/s Scott Commerson 58085 August 9, 2022

Signature of Attorney WSBA Number Date
or
Signature of person who is starting case Date
865 South Figueroa Street, Suite 2400, Los Angeles, CA 90017 2566
Address, City, State, Zip Code of person who is starting case if not represented by attorney
KING COUNTY SUPERIOR COURT
CASE ASSIGNMENT AREA DESIGNATION and CASE INFORMATION COVER SHEET
CIVIL
Please check the category that best describes this case.
APPEAL/REVIEW
☐ Administrative Law Review (ALR 2)
(Petition to the Superior Court for review of ☐ Third Party Collection (COL 2)*
rulings made by state administrative (Complaint involving a third party over
agencies.( e.g. DSHS Child Support, Good to a money dispute where no contract is
Go passes, denial of benefits from involved.)
Employment Security, DSHS)
JUDGMENT
☐ Board of Industrial Insurance Appeals – ☐ Abstract, Judgment, Another County (ABJ 2)
Workers Comp (ALRLI 2)*
(A certified copy of a judgment docket from
(Petition to the Superior Court for review of another Superior Court within the state.)
rulings made by Labor & Industries.)
☐ Confession of Judgment (CFJ 2)*
☐ DOL Revocation (DOL 2)* (The entry of a judgment when a defendant
(Appeal of a DOL revocation Implied consent- admits liability and accepts the amount of
Test refusal ONLY.) RCW 46.20.308(9) agreed-upon damages but does not pay or
perform as agreed upon.)
☐ Subdivision Election Process Review (SER 2)*
(Intent to challenge election process) ☐ Foreign Judgment (from another State or
Country) (FJU 2)
☐ Voter Election Process Law Review (VEP 2)* (Any judgment, decree, or order of a court of
(Complaint for violation of voting rights act) the United States, or of any state or territory,
which is entitled to full faith and credit in this
☐ Petition to Appeal/Amend Ballot Title (BAT 2) state.)
CONTRACT/COMMERCIAL ☐ Tax Warrant or Warrant (TAX 2)

☐ Breach of Contract (COM 2)* (A notice of assessment by a state agency or
(Complaint involving money dispute where a self-insured company creating a
breach of contract is involved.) judgment/lien in the county in which it is
filed.)
☐ Commercial Contract (COM 2)*
(Complaint involving money dispute where a
☐ Transcript of Judgment (TRJ 2)
contract is involved.) (A certified copy of a judgment from a court
of limited jurisdiction (e.g. District or
☐ Commercial Non-Contract (COL 2)* Municipal court) to a Superior Court.)
(Complaint involving money dispute where
PROPERTY RIGHTS
no contract is involved.)
☐ Condemnation/Eminent Domain (CON 2)*
Page 2 of 6
Civil-CICS Revised 04/2022
(Complaint involving governmental taking of ☐ Birth Certificate Change(PBC 2)
private property with payment, but (Petition to amend birth certificate)
not necessarily with consent.)
☐ Foreclosure (FOR 2)*
☐ Bond Justification (PBJ 2)
(Complaint involving termination of
(Bail bond company desiring to transact
ownership rights when a mortgage or tax
surety bail bonds in King County facilities.)
foreclosure is involved, where ownership
is not in question.)
☐ Change of Name (CHN 5)
☐ Land Use Petition (LUP 2)* (Petition for name change, when domestic
violence/anti-harassment issues require
(Petition for an expedited judicial review
confidentiality.)
of a land use decision made by a local
jurisdiction.) RCW 36.70C.040 ☐ Certificate of Rehabilitation (CRR 2)
☐ Property Fairness Act (PFA 2)* (Petition to restore civil and political rights.)
(Complaint involving the regulation of private
property or restraint of land use by a ☐ Certificate of Restoration Opportunity(CRP 2)
government entity brought forth by Title 64.) (Establishes eligibility requirements
for certain professional licenses)
☐ Quiet Title (QTI 2)*
(Complaint involving the ownership, use, ☐ Civil Commitment (sexual predator) (PCC 2)
or disposition of land or real estate other (Petition to detain an individual
than foreclosure.) involuntarily.)
☐ Residential Unlawful Detainer (Eviction) ☐ Notice of Deposit of Surplus Funds (DSF 2)

(UND 2)
(Deposit of extra money from a foreclosure
(Complaint involving the unjustifiable after payment of expenses from sale and
retention of lands or attachments to land, obligation secured by the deed of trust.)
including water and mineral rights.)
☐ Emancipation of Minor (EOM 2)
☐ Non-Residential Unlawful Detainer (Eviction) (Petition by a minor for a declaration
(UND 2) of emancipation.)
(Commercial property eviction.)
☐ Foreign Subpoena (OSS 2)
OTHER COMPLAINT/PETITION
(To subpoena a King County resident
☐ Action to Compel/Confirm Private or entity for an out of state case.)
Binding Arbitration (CAA 2)
(Petition to force or confirm private binding ☐ Foreign Protection Order (FPO 2)
arbitration.) (Registering out of state protection order)
☐ Assurance of Discontinuance (AOD 2) ☐ Frivolous Claim of Lien (FVL 2)

(Filed by Attorney General’s Office to (Petition or Motion requesting a
prevent businesses from engaging in determination that a lien against a mechanic
improper or misleading practices.) or materialman is excessive or unwarranted.)
Page 3 of 6
☐ Application for Health & Safety Inspection (The process of appointment by a court of
(HSI 2) a receiver to take custody of the property,
business, rents and profits of a party to a
lawsuit pending a final decision on
☐ Injunction (INJ 2)* disbursement or an agreement.)
(Complaint/petition to require a person to ☐ Relief from Duty to Register (RDR 2)
do or refrain from doing a particular thing.) (Petition seeking to stop the requirement
to register.)
☐ Interpleader (IPL 2)
(Petition for the deposit of disputed earnest ☐ Restoration of Firearm Rights (RFR 2)
money from real estate, insurance proceeds, (Petition seeking restoration of firearms
and/or other transaction(s).) rights under RCW 9.41.040 and 9.41.047.)
☐ Malicious Harassment (MHA 2)* ☐ School District-Required Action Plan (SDR 2)

(Suit involving damages resulting from (Petition filed requesting court selection of a
malicious harassment.) RCW 9a.36.080 required action plan proposal relating
to school academic performance.)
☐ Non-Judicial Filing (NJF 2)
(See probate section for TEDRA agreements.
☐ Seizure of Property from the Commission
of a Crime-Seattle (SPC 2)*
To file for the record document(s) unrelated
to any other proceeding and where there will (Seizure of personal property which was
be no judicial review.) employed in aiding, abetting, or
commission of a crime, from a defendant
☐ Other Complaint/Petition (MSC 2)* after conviction.)
(Filing a Complaint/Petition for a cause
of action not listed)
☐ Seizure of Property Resulting from a
Crime-Seattle (SPR 2)*
☐ Minor Work Permit (MWP 2) (Seizure of tangible or intangible property
(Petition for a child under 14 years of age which is the direct or indirect result of a
to be employed) crime, from a defendant following criminal
conviction. (e.g., remuneration for, or
☐ Perpetuation of Testimony (PPT contract interest in, a depiction or account
of a crime.))
2) (Action filed under CR 27)
☐ Structured Settlements- Seattle (TSS 2)*
☐ Petition to Remove Restricted Covenant
(RRC 2) (A financial or insurance arrangement
Declaratory judgment action to strike whereby a claimant agrees to resolve a
discriminatory provision of real property personal injury tort claim by receiving
contract. periodic payments on an agreed schedule
rather than as a lump sum.)
☐ Public records Act (PRA 2)*
☐ Vehicle Ownership (PVO 2)*
(Action filed under RCW 42.56)
(Petition to request a judgment awarding
ownership of a vehicle.)
☐ Receivership (RCVR 2)
TORT, ASBESTOS
Page 4 of 6
☐ Personal Injury (ASP 2)* (Complaint involving injury resulting from
other than professional medical treatment.)
(Complaint alleging injury resulting
from asbestos exposure.) ☐ Personal Injury (PIN 2)*
(Complaint involving physical injury not
☐ Wrongful Death (ASW 2)* resulting from professional medical
treatment, and where a motor vehicle is
(Complaint alleging death resulting
not involved.)
from asbestos exposure.)
TORT, MEDICAL MALPRACTICE ☐ Products Liability (TTO 2)*

☐ Hospital (MED 2)* (Complaint involving injury resulting from
a commercial product.)
(Complaint involving injury or death resulting
from a hospital.)
☐ Property Damages (PRP 2)*
☐ Medical Doctor (MED 2)* (Complaint involving damage to real or
personal property excluding motor vehicles.)
from a medical doctor.)
☐ Property Damages-Gang (PRG 2)*
☐ Other Health care Professional (MED 2)* (Complaint to recover damages to property
related to gang activity.)
from a health care professional other than a
medical doctor.) ☒ Tort, Other (TTO 2)*
(Any other petition not specified by
TORT, MOTOR VEHICLE other codes.)
☐ Death (TMV 2)*
(Complaint involving death resulting from
☐ Wrongful Death (WDE 2)*
an incident involving a motor vehicle.) (Complaint involving death resulting from
other than professional medical treatment.)
☐ Non-Death Injuries (TMV 2)*
(Complaint involving non-death injuries WRIT
resulting from an incident involving a ☐ Habeas Corpus (WHC 2)
motor vehicle.) (Petition for a writ to bring a party
before the court.)
☐ Property Damages Only (TMV 2)*
(Complaint involving only property damages ☐ Mandamus (WRM 2)**
resulting from an incident involving a motor (Petition for writ commanding performance
vehicle.) of a particular act or duty.)
☐ Victims Vehicle Theft (VVT 2)* ☐ Review (WRV 2)**

(Complaint filed by a victim of car theft (Petition for review of the record or decision
to recover damages.) RCW 9A.56.078 of a case pending in the lower court; does
not include lower court appeals or
TORT, NON-MOTOR VEHICLE administrative law reviews.)
☐ Other Malpractice (MAL 2)*
Page 5 of 6
⃰ The filing party will be given an appropriate case schedule at time of filing. **
Case schedule will be issued after hearing and findings.
Page 6 of 6

Filed: 2022 AUG 09 09:00 AM King County Superior Court Clerk E-Filed CASE #: 22-2-12549-7 SEA

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Filed: 2022 AUG 09 09:00 AM King County Superior Court Clerk E-Filed CASE #: 22-2-12549-7 SEA

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Filed: 2022 AUG 09 09:00 AM King County Superior Court Clerk E-Filed CASE #: 22-2-12549-7 SEA

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1 FILED

2022 AUG 09 09:00 AM

7 SUPERIOR COURT OF THE STATE OF WASHINGTON

9 AMAZON.COM, INC., a Delaware corporation; No.

18 Plaintiffs Amazon.com, Inc. and Amazon.com Services LLC (collectively, “Amazon”)

26 entrepreneurs who sell in Amazon’s stores, and tarnish Amazon’s brand.

6 dedicated to keeping Amazon’s stores free of fake reviews.

18 products in Amazon’s stores.

23 6. Defendants advertise “5-Star Ratings,” “Option to Choose A Custom Rating,” and

Davis Wright Tremaine LLP

Davis Wright Tremaine LLP

3 fake “Amazon Business Buyer Tax-Exempt Account.”6

9 review and other fraudulent schemes in which they participate.

11 Protection Act (RCW Ch. 19.86) and Washington common law.

12 II. JURISDICTION AND VENUE

15 and directed to Washington. Defendants affirmatively undertook to manipulate reviews, ratings,

19 based in Washington and analyze product reviews.

2 16. Venue is proper in this Court pursuant to RCW §§ 4.12.010–.025 in that a

6 Defendants consented to jurisdiction in this Court as set forth in Paragraph 15.

7 III. THE PARTIES

19 injuries as herein alleged were proximately caused by said Defendants.

20 IV. AMAZON’S PRODUCT REVIEW SYSTEM

23 authentic opinions about products—positive or negative. As long as Amazon’s customers abide

Davis Wright Tremaine LLP

11 honest, authentic, and unbiased.

16 for the Amazon Echo follows:

27 expressly prohibits compensated reviews.

5 reviews products has agreed to and is bound by the Conditions of Use.

7 contractual relationship with Amazon.

12 28. Furthermore, any person who uses Amazon’s “community features”—which

15 29. Amazon’s Community Guidelines prohibit:

Davis Wright Tremaine LLP

5 after the buyer writes a review.13

6 33. Amazon’s seller-facing website Seller Central provides additional guidelines to

12 Can I offer a voucher or a free gift?

Davis Wright Tremaine LLP

3 Store prohibit creating, posting, offering, or soliciting fake reviews.

7 manufacturers place in Amazon, which in turn tarnishes Amazon’s brand.

18 VI. DEFENDANTS’ DECEITFUL ACTS

21 product reviews and fake Amazon customer accounts.

Davis Wright Tremaine LLP

5 clients with ease by building trust in your brand.”18

8 “Verified Amazon Video Reviews: from 199.99$,” among others.19

Davis Wright Tremaine LLP

2 Verified Amazon Reviews” (at a total price of $7,999.99).23

Davis Wright Tremaine LLP

4 reviews” through fake customer accounts that they control.

6 through the AccFarm website.28

11 of their own products or of their competitors’ products.

24 rankings of products for sale in Amazon’s stores.

6 listed for sale in Amazon’s stores.

7 VII. REPUTATIONAL HARM TO AMAZON AND HARM TO THE PUBLIC

9 manufacturers place in Amazon, which in turn tarnishes Amazon’s brand.

18 customers and harms Amazon’s reputation.