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7 UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

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UNITED STATES OF AMERICA, CASE NO. 

9 

Plaintiff, STIPULATED ORDER FOR 

10 v. PERMANENT INJUNCTION, CIVIL 

PENALTY JUDGMENT, AND 

11 AMAZON.COM, INC., a corporation, and OTHER RELIEF 

12 AMAZON.COM SERVICES LLC, a 

limited liability company, 

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Defendants. 

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15 Plaintiff, the United States of America, acting upon notification and authorization to the 

16 Attorney General by the Federal Trade Commission (“Commission”), filed its Complaint for 

17 Civil Penalties, Permanent Injunction, and Other Relief (“Complaint”) in this matter, pursuant to 

18 Sections 13(b), 16(a)(1), and 19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. 

19 §§ 53(b), 56(a)(1), and 57b, the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6502(c) 

20 and 6505(d), and the Commission’s Children’s Online Privacy Protection Rule (“COPPA Rule”),

21 16 C.F.R. Part 312. Defendants have waived service of the summons and the Complaint. 

22 Plaintiff and Defendants stipulate to the entry of this Stipulated Order for Permanent Injunction 

23 and Civil Penalty Judgment (“Order”) to resolve all matters in dispute in this action between 

24 them. 

STIPULATED ORDER - 1 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 2 of 21 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants violated the COPPA Rule and the FTC Act with 

respect to Alexa by misrepresenting that they would delete voice transcripts and 

geolocation information of users of their Alexa voice assistant service upon request and 

limit employees’ access to Alexa users’ voice information; by failing to delete children’s 

personal information at the request of parents; and by retaining children’s personal 

information longer than reasonably necessary to fulfill the purpose for which the 

information was collected. 

3. Defendants neither admit nor deny any of the allegations in the Complaint, except as 

specifically stated in this Order. Only for purposes of this action, Defendants admit the 

facts necessary to establish jurisdiction. 

4. Defendants waive any claim that they may have under the Equal Access to Justice Act, 

28 U.S.C. § 2412, concerning the prosecution of this action through the date of this 

Order, and agree to bear their own costs and attorney fees. 

5. Defendants and Plaintiff waive all rights to appeal or otherwise challenge or contest the 

validity of this Order. Notwithstanding this waiver, such waiver shall not extend to any 

right to appeal or otherwise challenge or contest the validity of any court or 

administrative action arising out of this Order. 

DEFINITIONS 

For the purpose of this Order, the following definitions apply: 

A. “Alexa” means the Alexa voice assistant service or any comparable successor or 

replacement service Amazon may offer by another name. 

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700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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B. “Alexa App” means the Amazon Alexa mobile application available to consumers 

through which any Defendant collects any Voice Information or Geolocation Information 

from Alexa users. 

C. “Alexa App Geolocation Information” means Geolocation Information collected via 

the Alexa App for the provision of Alexa services; provided, however, that any such 

record shall not be considered Alexa App Geolocation Information if such record 

(1) does not contain, is not stored with, and is not otherwise reasonably linkable to any 

other element of Personal Information and (2) has less than three decimal places of 

precision. 

D. “Child” or “Children” means an individual or individuals under the age of 13. 

E. “Child Profile” means any user profile created for use by a Child and for which Amazon 

has actual knowledge that the user is a Child. 

F. “Clear(ly) and Conspicuous(ly)” means that a required disclosure is difficult to miss 

(i.e., easily noticeable) and easily understandable by ordinary consumers, including in all 

of the following ways: 

1. In any communication that is solely visual or solely audible, the disclosure must be 

made through the same means through which the communication is presented. 

2. A visual disclosure, by its size, contrast, location, the length of time it appears, and 

other characteristics, must stand out from any accompanying text or other visual 

elements so that it is easily noticed, read, and understood. 

3. An audible disclosure, including by streaming video must be delivered in a volume, 

speed, and cadence sufficient for ordinary consumers to easily hear and understand it. 

4. In any communication using an interactive electronic medium, such as the Internet or 

software, the disclosure must be designed to be prominent and easily noticeable. 

STIPULATED ORDER - 3 UNITED STATES ATTORNEY 

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SEATTLE, WASHINGTON 98101 

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5. The disclosure must use diction and syntax understandable to ordinary consumers and 

must appear in each language in which the representation that requires the disclosure 

appears. 

6. The disclosure must comply with these requirements in each medium through which 

it is received, including all electronic devices and face-to-face communications. 

7. The disclosure must not be contradicted or mitigated by, or inconsistent with, 

anything else in the communication in which the disclosure is made. 

8. When the representation or sales practice targets a specific audience, such as children, 

the elderly, or the terminally ill, “ordinary consumers” includes ordinary members of 

that group. 

9. “Data Product” means any model, derived data, or other tool developed using Alexa 

App Geolocation Information, Voice Information, or a Child’s Personal Information. 

Data Product includes but is not limited to any data produced via inference (manual 

or automated) or predictions from such Alexa App Geolocation Information, Voice 

Information, or Children’s Personal Information, application programming interfaces 

that incorporate, or are improved or enhanced by, such data, or services or other 

products that incorporate, or are improved or enhanced by, such data. 

G. “Defendants” means Defendant Amazon, Defendant Amazon Digital Services; and 

Defendant A2Z individually, collectively, or in any combination. 

1. Defendant Amazon means Amazon.com, Inc. and its successors and assigns. 

2. Defendant Amazon Digital Services means Amazon Digital Services LLC and its 

successors and assigns. 

3. Defendant A2Z means A2Z Development Center, Inc. and its successors and assigns. 

STIPULATED ORDER - 4 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

 

 

 

 

 

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H. “Internet” means collectively the myriad of computer and telecommunication facilities, 

including equipment and operating software, which comprises the interconnected worldwide network of networks that employ the Transmission Control Protocol/Internet 

Protocol, or any predecessor or successor protocols to such protocol, to communicate 

information of all kinds by wire, radio, or other methods of transmission. 

I. “Geolocation Information” means the location of a mobile device sourced from a GPS 

chip, in latitude-longitude format. 

J. “Inactive Alexa Child Profile” means a Child Profile that has interacted with Alexa but 

that has not been used for 18 months or more. Inactive Alexa Child Profiles include 

profiles of individuals who are under the age of 13 when the 18 month period starts and 

who turn 13 before the 18 months has elapsed. 

K. “Online Contact Information” means an email address or any other substantially 

similar identifier that permits direct contact with a person online, including but not 

limited to, an instant messaging user identifier, a voice over Internet protocol (VOIP) 

identifier, or a video chat identifier. 

L. “Operator” means any Person who operates a Web site located on the Internet or an 

online service and who collects or maintains Personal Information from or about the 

users of or visitors to such Web site or online service, or on whose behalf such 

information is collected or maintained, or offers products or services for sale through the 

Web site or online service, where such Web site or online service is operated for 

commercial purposes involving commerce among the several States, or with one or more 

foreign nations; in any territory of the United States or in the District of Columbia, or 

between any such territory and another such territory or any State or foreign nation; or 

between the District of Columbia and any State, territory, or foreign nation. 

STIPULATED ORDER - 5 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

 

 

 

 

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M. “Parent” includes a legal guardian. 

N. “Persistent Identifier” means an identifier that can be used to recognize a user over time 

and across different Web sites or online services. Such persistent identifier includes, but 

is not limited to, a customer number held in a cookie, an Internet Protocol (IP) address, a 

processor or device serial number, or unique device identifier. 

O. “Person” means any individual, partnership, corporation, trust, estate, cooperative, 

association, or other entity. 

P. “Personal Information” means individually identifiable information about an individual 

collected online, including: (1) a first and last name; (2) a home or other physical address 

including street name and name of a city or town; (3) Online Contact Information; (4) a 

screen or user name where it functions in the same manner as Online Contact 

Information; (5) a telephone number; (6) a Social Security number; (7) a Persistent 

Identifier that can be used to recognize a user over time and across different Web sites or 

online services. Such persistent identifier includes, but is not limited to, a customer 

number held in a cookie, an Internet Protocol (IP) address, a processor or device serial 

number, or unique device identifier; (8) a photograph, video, or audio file where such file 

contains a Child’s image or voice; (9) Geolocation Information; or (10) information 

concerning the Child or the Parents of that Child that the Operator collects online from 

the Child and combines with an identifier described in this definition. 

Q. “Voice Information” means any audio file of an individual’s voice communications or 

audio communications collected by or through Alexa, as well as any related full-text 

transcripts of such audio file, provided, however, that any such record shall not be 

considered Voice Information if: (1) such record does not contain, is not stored with, and 

is not otherwise reasonably linkable to any other element of Personal Information; or 

STIPULATED ORDER - 6 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

 

 

 

 

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(2) such record was sent to or otherwise shared with another Person by the applicable 

individual (e.g., a voice message sent by one user to another via Alexa). 

ORDER 

I. DELETION OF CHILDREN’S PERSONAL INFORMATION 

ASSOCIATED WITH INACTIVE ALEXA CHILD PROFILES 

IT IS ORDERED that, in compliance with COPPA’s requirements concerning the 

retention and deletion of Children’s Personal Information, see 16 C.F.R. § 312.10, for as long as 

that provision is in effect and is therefore applicable to Defendants, 

A. Defendants and Defendants’ officers, agents, employees, and attorneys, and all other 

persons in active concert or participation with any of them, who receive actual notice of 

this Order shall, within six (6) months of entry of this Order, implement a process to 

identify Inactive Alexa Child Profiles; and 

B. Following identification of any Inactive Alexa Child Profile, Defendants shall delete any 

Personal Information collected from a Child associated with that Inactive Alexa Child 

Profile within 90 days, unless the Parent of the applicable Child requests that such 

information be retained or the applicable Child Profile becomes active again prior to such 

deletion. 

II. PROHIBITION AGAINST MISREPRESENTATIONS 

ABOUT PRIVACY OF GEOLOCATION INFORMATION AND VOICE 

INFORMATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice of this Order, whether acting directly or indirectly, are permanently 

restrained and enjoined from misrepresenting, expressly or by implication: 

STIPULATED ORDER - 7 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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A. The extent to which any Defendant retains, limits or permits access to, or deletes any 

Alexa App Geolocation Information or Voice Information; 

B. The extent to which a consumer may exercise control over any Defendant’s retention, 

deletion, or access to Alexa App Geolocation Information or Voice Information, and the 

steps a consumer must take to implement such controls; or 

C. The extent to which a Parent may exercise control over any Defendant’s retention or 

deletion of a Child’s Voice Information, and the steps a Parent must take to implement 

such controls. 

III. MANDATED DELETION OF INFORMATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice of this Order, must: 

A. Delete all Alexa App Geolocation Information and Voice Information collected from a 

consumer where the consumer has requested that any Defendant delete such information 

via a mechanism any Defendant has made available for that purpose; 

B. Delete all Personal Information collected by Alexa from a Child where the Child’s Parent 

has requested that any Defendant delete such information via a mechanism any 

Defendant has made available for that purpose; 

C. After processing the deletion of Alexa App Geolocation Information, Voice Information, 

or Children’s Personal Information as provided for in Sections I, IV(A) and IV(B), 

Defendant shall not subsequently use such information for the creation or improvement 

of any Data Product. For the avoidance of doubt, the foregoing provision does not limit 

Defendant’s use of any Data Product created prior to the processing of the deletion of 

STIPULATED ORDER - 8 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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Alexa App Geolocation Information, Voice Information, or Children’s Personal 

Information as provided for in Section I, IV(A) and IV(B). 

IV. MANDATED NOTICE OF RETENTION AND DELETION 

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice of this Order, must, within ninety (90) days of entry of this order, 

document, adhere to, and make publicly available: 

A. Clearly and Conspicuously, when a consumer is prompted to grant Defendant permission 

to access Alexa App Geolocation Information, a link to a retention and deletion 

disclosure for Alexa App Geolocation Information (“Geolocation Information 

Disclosure”), setting forth: (1) the purpose for which such information is collected, used, 

or maintained; and (2) the mechanisms, if any, by which consumers may request deletion 

of such information; 

B. In the Alexa and Alexa Devices FAQs (or a similarly prominent location) a retention and 

deletion disclosure for Voice Information (“Voice Information Disclosure”), that includes 

an explanation of: (1) the purposes for which such information is collected, used, or 

maintained; (2) the mechanisms, if any, by which consumers may request deletion of 

such information; and (3) the mechanisms by which Parents of Children may request 

deletion of Personal Information that Alexa collects from children. 

V. NOTICE TO USERS 

IT IS FURTHER ORDERED that, on or before thirty (30) days after the date of the entry 

of this Order, Defendant Amazon must: 

A. Post in the Alexa and Alexa Devices FAQs (or a similarly prominent location), which can 

be accessed on the Web and in the Alexa App, for a period of six (6) months after the 

STIPULATED ORDER - 9 UNITED STATES ATTORNEY 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 10 of 21 

effective date of this Order, a link to an exact copy of the notice attached hereto as 

Exhibit A (“Exhibit A Notice”); and 

B. Post Clearly and Conspicuously on the home page of the Amazon Parent Dashboard for a 

period of six (6) months after the effective date of this Order, a link to an exact copy of 

the Exhibit A Notice. 

VI. MANDATED PRIVACY PROGRAM 

IT IS FURTHER ORDERED that Defendants, and any business that any Defendant 

controls directly, or indirectly, in connection with the collection, maintenance, use, or disclosure 

of, or provision of access to, Alexa App Geolocation Information, must, within ninety (90) days 

of entry of this order and for a period of twenty (20) years thereafter, establish, implement, and 

thereafter maintain or, if such a program already exists, maintain a comprehensive privacy 

program to protect the privacy of Alexa App Geolocation Information (the “Program”). To 

satisfy this requirement, Defendants must: 

A. Document in writing the content, implementation, and maintenance of the 

Program; 

B. Provide the written program and any evaluations thereof or updates thereto to a 

senior officer of Defendants responsible for the Program at least once every 

twelve (12) months; 

C. Designate a qualified employee or employees to coordinate and be responsible for 

the Program; 

D. Assess and document, at least once every twelve (12) months, internal and 

external risks to the privacy of Alexa App Geolocation Information that could 

result in the (1) unauthorized collection, maintenance, alteration, use, or 

disclosure of, or provision of access to, Alexa App Geolocation Information; or 

STIPULATED ORDER - 10 UNITED STATES ATTORNEY 

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the (2) misuse, loss, theft, alteration, destruction, or other compromise of such 

information; 

E. Design, implement, maintain, and document safeguards that control for the 

internal and external risks Defendants identify to the privacy of Alexa App 

Geolocation Information identified in response to Provision VII.D. Each 

safeguard must be based on the volume and sensitivity of Alexa App Geolocation 

Information that is at risk, and the likelihood that the risk could be realized and 

result in the (1) unauthorized collection, maintenance, use, or disclosure of, or 

provision of access to, Alexa App Geolocation Information; or the (2) misuse, 

loss, theft, alteration, destruction, or other compromise of such information. Such 

safeguards must also include: 

1. Conducting a privacy review and producing a written report (“Privacy 

Review Statement”) for Alexa’s collection, maintenance, use, or 

disclosure of Alexa App Geolocation Information. The Privacy Review 

Statement must describe: 

a) How Alexa collects, maintains, uses, or discloses Alexa App 

Geolocation Information; 

b) For how long Alexa App Geolocation Information is retained; 

c) The risks of the (1) collection, maintenance, alteration, use, or 

disclosure of, or provision of access to; or the (2) misuse, loss, 

theft, alteration, destruction, or other compromise of Alexa App 

Geolocation Information, and the safeguards in place or to be 

implemented that are intended to control identified risks; 

STIPULATED ORDER - 11 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

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d) Any other known, reasonable safeguards or other procedures that 

would mitigate the identified risks of the (1) collection, 

maintenance, alteration, use, or disclosure of, or provision of 

access to; or the (2) misuse, loss, theft, alteration, destruction, or 

other compromise of Alexa App Geolocation Information that 

were not implemented, and each reason that such alternatives were 

not implemented; and 

e) Any decision made as a result of the review (e.g., whether a 

practice was approved, approved contingent upon safeguards or 

other recommendations being implemented, or rejected). 

2. Implementing controls to limit access to unencrypted Alexa App 

Geolocation Information only to authorized services; 

3. Training of all employees whose responsibilities include access to 

unencrypted Alexa App Geolocation Information, at least every twelve 

(12) months, on how to safeguard Alexa App Geolocation Information; 

4. Training of all employees whose responsibilities include deletion of Alexa 

App Geolocation Information, at least every twelve (12) months, on how 

to comply with deletion requests; 

5. Implementing data access controls for all databases and assets storing 

unencrypted Alexa App Geolocation Information; and 

6. Reviewing and adjusting as appropriate at least once every twelve (12) 

months, employee access to unencrypted Alexa App Geolocation 

Information to ensure that the employee needs continued access to the 

STIPULATED ORDER - 12 UNITED STATES ATTORNEY 

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Alexa App Geolocation Information to perform the employee’s specific 

job function; 

F. Assess, at least once every twelve (12) months, the sufficiency of any safeguards 

in place to address the internal and external risks of the (1) collection, 

maintenance, alteration, use, or disclosure of, or provision of access to; or the 

(2) misuse, loss, theft, alteration, destruction, or other compromise of Alexa App 

Geolocation Information, and modify the Program as needed based on the results; 

G. Test and monitor the effectiveness of the safeguards at least once every twelve 

(12) months, and modify the Program as needed based on the results; 

H. With respect to service providers who may have access to or receive Alexa App 

Geolocation Information through or from Defendants, take reasonable efforts to 

select and retain service providers capable of implementing and maintaining 

safeguards sufficient to address the internal and external risks of the 

(1) collection, maintenance, alteration, use, or disclosure of, or provision of access 

to; or the (2) misuse, loss, theft, alteration, destruction, or other compromise of 

Alexa App Geolocation Information; and 

I. Evaluate and adjust the Program in light of any changes to Defendants’ operations 

or business arrangements, new or more efficient technological or operational 

methods that are intended to control for the risks identified in Provision VII.D of 

this Order, or any other circumstances that Defendants know or have reason to 

know may have an impact on the effectiveness of the Program. At a minimum, 

Defendants must evaluate the Program at least once every twelve (12) months and 

modify the Program based on the results as needed. 

// 

STIPULATED ORDER - 13 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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VII. CERTIFICATIONS 

IT IS FURTHER ORDERED that Defendants must: 

A. One year after the entry date of this Order, and each year thereafter for ten (10) years 

after the entry date of this Order, provide the Commission with a certification from a 

Vice President with oversight responsibilities involving the Alexa service, that: 

(1) Defendants have established, implemented, and maintained the requirements of this 

Order; and (2) Defendants are not aware of any material noncompliance that has not been 

(a) corrected or (b) disclosed to the Commission. The certification must be based on the 

personal knowledge of the senior corporate manager, senior officer, or subject matter 

experts upon whom the signatory reasonably relies in making the certification; and 

B. Unless otherwise directed by a Commission representative in writing, submit all annual 

certifications to the Commission pursuant to this Order via email to DEbrief@ftc.gov or 

by overnight courier (not the U.S. Postal Service) to Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue 

NW, Washington, DC 20580. The subject line must begin, “United States v. 

Amazon.com, Inc., FTC File No. 1923128.” 

VIII. MONETARY JUDGMENT FOR CIVIL PENALTY 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of twenty-five million dollars ($25,000,000) is entered in favor 

of Plaintiff against Defendants as a civil penalty. 

B. Defendants are ordered to pay to Plaintiff, by making payment to the Treasurer of the 

United States, twenty-five million dollars ($25,000,000), which as Defendants stipulate, 

its undersigned counsel holds in escrow for no purpose other than payment to Plaintiff. 

STIPULATED ORDER - 14 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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Such payment must be made within seven (7) days of entry of this Order by electronic 

fund transfer in accordance with instructions provided by a representative of Plaintiff. 

C. Defendants relinquish dominion and all legal and equitable right, title, and interest in all 

assets transferred pursuant to this Order and may not seek the return of any assets. 

D. The facts alleged in the Complaint will be taken as true, without further proof, in any 

subsequent civil litigation by or on behalf of the Commission to enforce its rights to any 

payment or monetary judgment pursuant to this Order. 

E. Defendants acknowledge that their Taxpayer Identification Numbers (Employer 

Identification Numbers), which Defendants previously submitted to the Commission, 

may be used for collecting and reporting on any delinquent amount arising out of this 

Order, in accordance with 31 U.S.C. § 7701. 

IX. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of this 

Order: 

A. Defendants, within ten (10) days after the effective date of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury. 

B. For ten (10) years after entry of this Order, Defendants must deliver a copy of this Order 

to: (1) all principals, officers, directors, and LLC managers and members of the Alexa 

business within the Defendant entities; (2) all employees and agents having managerial 

responsibilities for the deletion of Alexa App Geolocation Information or Voice 

Information; and (3) any business entity resulting from any change in structure as set 

forth in the Section titled Compliance Reporting. Delivery must occur within ten (10) 

days of entry of this Order for current personnel. For all others, delivery must occur 

before they assume their responsibilities. 

STIPULATED ORDER - 15 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 16 of 21 

C. From each individual or entity to which Defendants delivered a copy of this Order, 

Defendants must obtain, within thirty (30) days, a signed and dated acknowledgment of 

receipt of this Order. 

X. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

A. One year after entry of this Order, Defendants must submit a compliance report, sworn 

under penalty of perjury. Defendants must: (1) identify the primary physical, postal, and 

email address and telephone number, as designated points of contact, which 

representatives of the Commission and Plaintiff may use to communicate with 

Defendants; (2) identify all of Defendants’ businesses that collect, maintain, alter, use, or 

disclose, or provide access to, Alexa App Geolocation Information or Voice Information 

by all of their names, telephone numbers, and physical, postal, email, and Internet 

addresses; (3) describe the activities of each such business, including the goods and 

services offered, the means of advertising, marketing, and sales; (4) describe whether and 

how Defendants are in compliance with each Section of this Order; and (5) provide a 

copy of each Order Acknowledgment obtained pursuant to this Order, unless previously 

submitted to the Commission. 

B. For ten (10) years after entry of this Order, Defendants must submit a compliance notice, 

sworn under penalty of perjury, within fourteen (14) days of any change in: (1) any 

designated point of contact; or (2) the structure of Defendants or any entity that 

Defendants have any ownership interest in or control directly or indirectly that may affect 

compliance obligations arising under this Order, including: creation, merger, sale, or 

STIPULATED ORDER - 16 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 17 of 21 

dissolution of the entity or any subsidiary, parent, or affiliate that engages in any acts or 

practices subject to this Order. 

C. Defendants must submit to the Commission notice of the filing of any bankruptcy 

petition, insolvency proceeding, or similar proceeding by or against Defendants within 

fourteen (14) days of its filing. 

D. Any submission to the Commission required by this Order to be sworn under penalty of 

perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: “I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. Executed on: _____” and supplying the 

date, signatory’s full name, title (if applicable), and signature. 

Unless otherwise directed by a Commission representative in writing, all submissions to 

the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by overnight 

courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of 

Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, 

DC 20580. The subject line must begin, “United States v. Amazon.com, Inc., FTC File No. 

1923128.” 

XI. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for ten (10) 

years after entry of the Order, and retain each such record for five (5) years. Specifically, 

Defendants must create and retain the following records: 

A. Personnel records showing, for each person having managerial responsibility for the 

deletion of Alexa App Geolocation Information or Voice Information, whether as an 

employee or otherwise, that person’s: name; job title or position; and dates of service; 

STIPULATED ORDER - 17 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

 

 

 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 18 of 21 

B. Records of all consumer complaints and refund requests related to collection, retention or 

deletion of Alexa App Geolocation Information or Voice Information received through 

Defendants’ customer service channels, and any response thereto based on a reasonable 

search criteria that accounts for the volume of such communications Defendants receive 

through its customer service channels; 

C. Records of all deletion requests made by individuals or Parents regarding the deletion of 

Alexa App Geolocation Information or Voice Information via a mechanism or 

mechanisms that any Defendant has made available for that purpose; the response to such 

requests; and any actions taken in response to such requests based on reasonable search 

criteria that account for the volume of such communications or requests Defendants 

receive through appropriate channels; 

D. All records necessary to demonstrate material compliance with this Order, including all 

submissions to the Commission; and 

E. A copy of each unique advertisement or other marketing material related to collection, 

retention or deletion of Alexa App Geolocation Information or Voice Information. 

XII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’ compliance 

with this Order: 

A. Within thirty (30) days of receipt of a written request from a representative of the 

Commission or Plaintiff, Defendants must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; and produce 

documents for inspection and copying. 

B. For matters concerning this Order, the Commission and Plaintiff are authorized to 

communicate directly with Defendants. Defendants must permit representatives of the 

STIPULATED ORDER - 18 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 19 of 21 

Commission and Plaintiff to interview any employee or other person affiliated with 

Defendants who has agreed to such an interview. The person interviewed may have 

counsel present. 

C. The Commission and Plaintiff may use all other lawful means, including posing, through 

their representatives, as consumers, suppliers, or other individuals or entities, to 

Defendants or any individual or entity affiliated with Defendants, without the necessity of 

identification or prior notice. Nothing in this Order limits the Commission’s lawful use 

of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 

57b-1. 

XIII. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order. 

SO ORDERED this ______ day of ___________, 2023. 

UNITED STATES DISTRICT JUDGE 

STIPULATED ORDER - 19 UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 
 

 

 

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Case 2:23-cv-00811 Document 2-1 Filed 05/31/23 Page 20 of 21 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF THE UNITED STATES 

OF AMERICA 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General 

Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General 

AMANDA LISKAMM 

Director 

Consumer Protection Branch 

LISA K. HSIAO 

Assistant Director 

By: 

s/ Rachael Doud 

RACHAEL L. DOUD 

Assistant Director 

JAMES T. NELSON 

Senior Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, D.C. 20044

(202) 305-4499 

s/ Kayla C. Stahman 

KAYLA C. STAHMAN, CA #228931 

Assistant United States Attorneys 

United States Attorney’s Office 

700 Stewart Street, Suite 5220 

Seattle, Washington 98101-1271 

Phone: 206-553-7970 

Email: kayla.stahman@udsdoj.gov 

OF COUNSEL: 

FOR THE FEDERAL TRADE 

COMMISSION 

BENJAMIN WISEMAN 

Acting Associate Director 

Division of Privacy & Identity Protection 

ELISA JILLSON 

ANDREW HASTY 

JULIA HORWITZ 

Attorneys

Division of Privacy & Identity Protection 

UNITED STATES ATTORNEY 

700 STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 

STIPULATED ORDER - 20 
II 

DocuSign Envelope ID: B5C9~~~~!~rJCM£iCB~~ument 2-1 Filed 05/31/23 Page 21 of 21 

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FOR DEFENDANTS AMAZON.COM, 

INC. AND AMAZON.COM SERVICES 

LLC: 

i1am~;~ 1~,.Pt-V~n., Dated: May 24, 

Title: Authorized Representative for 

Amazon.com, Inc. and Amazon.com 

Services LLC 

Isl Laura Kim Dated: 5/24/23 

Lama Kim (pro hac viceforthcominK) 

Nikhil Singhvi (pro hac vice forthcoming) 

Covington & Bmling LLP 

One CityCenter, 850 Tenth Street, NW 

Washington, DC 20001-4956 

Telephone: (202) 662-6000 

lkim@cov.com 

nsinghvi@cov.com 

Isl Lindsey Tonsager Dated: 5/24/23 

Lindsey T onsager (pro hac vice forthcoming) 

Covington & Bmling LLP 

Salesforce Tower, 4 15 Mission Street, Suite 

5400 

San Francisco, CA 94105-2533 

Telephone: (415) 591-6000 

ltonsager@cov.com 

Isl Jeanne Jeong _ Dated: 5/24/23 

Jeanne Jeong (pro hac vice forthcoming) 

Covington & Bmling LLP 

The New York Times Building 

620 Eighth A venue 

New York, NY 10018-1405 

Telephone: (212) 841-1062 

jjeong@cov.com 

2023 

Isl Karen Dunn Dated: 5/24/23 

Karen Dunn (pro hac viceforthcominK) 

Jeannie Rhee (pro hac vice forthcoming) 

Paul, Weiss, Rifkind, 

Wha1ton & Ganison LLP 

2001 K Street, N.W. 

Washington, D.C. 20006-1047 

Telephone: (202) 223-7300 

Fax: (202) 223-7420 

kdunn@paulweiss.com 

jrhee@paulweiss.com 

512412 Isl Meredith R. Dearborn Dated: 3

Meredith R. Dearborn (pro hac vice 

forthcoming) 

Paul, Weiss, Rifkind, 

Wha1ton & Ganison LLP 

535 Mission Street 24th Floor 

San Francisco, CA 94105 

Telephone: (628) 432-5100 

Fax: (628) 232-3101 

mdearbom@paulweiss.com 

Isl Carter E. Greenbaum Dated: 5/24/23 

Carter E. Greenbaum (pro hac vice 

forthcoming) 

Paul, Weiss, Rifkind, 

Wha1ton & Ganison LLP 

1285 Avenue of the Americas 

New York, NY 10019-6064 

Telephone: (212) 373-3000 

Fax: (212) 757-3990 

cgreenbaum@paulweiss.com 

Counselfor Defendants 

UNITED STATES ATTORNEY 700 

STEWART STREET, SUITE 5220 

SEATTLE, WASHINGTON 98101 

(206) 553-7970 

STIPULATED ORDER - 21