Heck v. Amazon.com Inc

CourtDistrict Court, W.D. Washington
DecidedJanuary 8, 2025
Docket2:23-cv-01219
StatusUnknown

This text of Heck v. Amazon.com Inc (Heck v. Amazon.com Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heck v. Amazon.com Inc, (W.D. Wash. 2025).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 JULIA HECK, on behalf of herself and all CASE NO. 2:23-cv-01219-JHC 8 others similarly situated, ORDER DENYING MOTION TO DISMISS 9 Plaintiff, 10 v. 11 AMAZON.COM, INC.; AUDIBLE, INC., 12

13 Defendants. 14

15 I 16 INTRODUCTION 17 This matter comes before the Court on Defendants Amazon.com, Inc. and Audible, Inc.’s 18 Motion to Dismiss Plaintiff’s Third Amended Complaint (TAC). Dkt. # 95. 19 Plaintiff Julia1 Heck brings this action individually and on behalf of a putative class of 20 similarly situated individuals. She alleges that Amazon offered its Prime members “a digital 21

22 1 Plaintiff is called “Julie Heck” in the caption of the TAC (Dkt. # 94), and in the caption of her opposition papers to Defendants’ motion to dismiss (Dkt. # 97), but she is called “Julia Heck” in the body 23 of the TAC and the caption of Defendants’ motion to dismiss. See Dkts. ## 94, 95. Given the lack of clarity, the Court uses “Julia Heck” because the Docket and the Court’s prior orders use the same. See 24 Dkts. # 48, 91. 1 reward” in exchange for choosing “FREE No-Rush Shipping.” Dkt. # 94 at 2 ¶ 5. But when a 2 Prime member redeemed the “digital reward,” Amazon sent the member’s personal information, 3 including payment information, to Audible2 who enrolled them in a 30-day trial membership 4 that, without affirmative cancellation, automatically became a paid membership with a monthly 5 fee. Id. Heck brings claims under California law. See generally Dkt. # 94. Defendants seek 6 dismissal, contending that the TAC fails to state a claim upon which relief can be granted. For 7 the reasons below, the Court DENIES the motion. 8 II BACKGROUND 9 The factual background in this section derives from Heck’s allegations in the TAC, see 10 Dkt. # 94, which the Court accepts as true for a Rule 12(b)(6) motion to dismiss. 11 Defendant Amazon is an internet-based company that provides goods and services to 12 consumers in areas such as “e-commerce, logistics, payment, hardware, data storage, and 13 media.” Dkt. # 94 at 1 ¶ 1. Amazon offers its customers “Prime Membership,” which provides 14 “shipping shopping, streaming, reading, and other benefits.” Id. at 1 ¶ 2. “One of the benefits of 15 Prime Membership is free 2-day shipping on many items.” Id. at 3 ¶ 14. Amazon also offers 16 Prime members “FREE No-Rush Shipping.” Id. If a Prime member selects the No-Rush 17 Shipping option, they can “receive a reward toward e-books, digital movies, and music.” Id. at 18 3, 12 ¶¶ 14, 55 (internal citation omitted). 19 Defendant Audible “is a wholly owned subsidiary of Amazon” that provides customers 20 with “downloadable and streaming audio content for a monthly fee.” Id. at 2 ¶ 3. Heck says 21 22

23 2 Audible is a wholly-owned subsidiary of Amazon and describes itself as “the leading creator and provider of premium audio storytelling” and “the largest producer of audiobooks in the world.” Dkt. 24 # 94 at 3 ¶ 12 (internal citation omitted). 1 that, for years, Amazon and Audible “targeted Prime members for enrollment in Audible through 2 a process that was likely to deceive reasonable consumers.” Id. at 2 ¶ 4. 3 Heck states that around June 29, 2017, she became an Amazon Prime member. Id. at 8

4 ¶ 36. Thereafter, Amazon emailed her, confirming her membership and detailing Prime benefits, 5 including “access to . . . original audio series from Audible.” Id. (internal citation omitted) 6 (alteration in original). She contends that during the checkout process for her purchases through 7 Prime, Amazon gave her the option of selecting “FREE No-Rush Shipping” that provided a “$1 8 reward for select digital purchases.” Id. at 8 ¶ 37. She says that on or before March 1, 2021, she 9 “purchased items from Amazon for which she thought she received ‘digital rewards’ by selecting 10 the ‘FREE No-Rush Shipping’ option.” Id. at 9 ¶ 40. Heck alleges that after she used the 11 purported “digital rewards,” Amazon provided Audible with her information, and Audible 12 enrolled her in a “free trial membership without her knowledge or permission.” Id. at 9 ¶¶ 40,

13 42. Heck says that the credit card connected with the Audible membership was her American 14 Express credit card that she had saved in her Amazon “digital Wallet” and had used to buy the 15 items through Prime’s No-Rush Shipping. Id. at 9 ¶ 41. After the 30-day free trial membership 16 ended, Audible charged Heck $14.95 a month starting on April 1, 2021, and until July 1, 2021. 17 Id. at 9–10 ¶ 43. Heck says she was charged $59.80 for an “unknown, unwanted, and 18 unauthorized” Audible membership. Id. 19 Heck alleges that she “was never informed that by using what she thought was a ‘digital 20 reward’ by selecting the ‘FREE No-Rush Shipping’ option on her Amazon Prime purchases, that 21 she would be enrolled in an Audible membership.” Id. at 10 ¶ 46. She did not know that she 22 was subscribed to Audible until July 22, 2021, after which she contacted Audible and cancelled

23 the membership. Id. Heck says that before and after she was enrolled in the Audible 24 subscription, she did not receive any emails or other written communications from Amazon 1 informing her “of the terms of any offer for a subscription to Audible, the cancellation policy, or 2 information regarding how to cancel the subscription.” Id. at 10 ¶ 47. 3 On March 18, 2024, Heck filed the TAC. See Dkt. # 95. She contends, on behalf of

4 herself and a class of similarly situated individuals, that Defendants violated (1) California’s 5 Consumers Legal Remedies Act (CLRA), California Civil Code § 1750, et seq.; and (2) 6 California’s Unfair Competition Law (UCL), California Business and Professions Code § 17200, 7 et seq. Id. Amazon moves to dismiss, contending that the TAC fails to state a claim upon which 8 relief can be granted. See Fed. R. Civ. P. 12(b)(6); Dkts. ## 95, 99. 9 III DISCUSSION 10 Rule 12(b)(6). When considering a motion to dismiss under Federal Rule of Civil 11 Procedure 12(b)(6), a court construes the complaint in the light most favorable to the nonmoving 12 party. Chubb Custom Ins. Co. v. Space Sys./Loral, Inc., 710 F.3d 946, 956 (9th Cir. 2013). The 13 court must accept all well-pleaded facts as true and draw all reasonable inferences in favor of the 14 plaintiff. Wyler Summit P’ship v. Turner Broad. Sys., Inc., 135 F.3d 658, 661 (9th Cir. 1998). 15 “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as 16 true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 17 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial 18 plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable 19 inference that the defendant is liable for the misconduct alleged.” Id. at 678 (citing Twombly, 20 550 U.S. at 556). “Dismissal is proper only where there is no cognizable legal theory or an 21 absence of sufficient facts alleged to support a cognizable legal theory.” Navarro v. Block, 250 22 F.3d 729, 732 (9th Cir. 2001). A court may also “consider certain materials—documents 23 attached to the complaint, documents incorporated by reference in the complaint, or matters of 24 1 judicial notice—without converting the motion to dismiss into a motion for summary judgment.” 2 United States v. Ritchie, 342 F.3d 903

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