Multi-State Coalition Seeks Comprehensive Relief Against Amazon for Antitrust Violations

X. REQUEST FOR RELIEF

WHEREFORE Plaintiffs request that this Court, as authorized by 15 U.S.C. § 53(b); 15 U.S.C. § 26; Conn. Gen. Stat. §§ 35-32(a) and 42-110m; 10 M.R.S.A. § 1104; Maryland Commercial Law Code Ann. § 11-209; Mich. Comp. Laws § 445.777; Nev. Rev. Stat. §§ 598A.070 and 598A.160; N.J.S.A. 56:8-8, 56:8-11, 56:8-19, 56:9-6, 56:9-7, 56:9-10(a), and 56:9-12; New York Executive Law § 63(12); Oklahoma Statutes §§ 79-203 and 15-756.1; Oregon Revised Statutes 646.760 and 646.770; Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 P.S. § 201-4, Pennsylvania common law antitrust doctrine, and the Commonwealth Attorneys Act, 71 P.S. § 732-204(c); R.I. Gen. Laws § 6-36-10; Wis. Stat. §§ 133.03, 133.16, and 133.17; and its own equitable powers, enter final judgment against Amazon, declaring, ordering, and adjudging:

1. that Amazon’s conduct violates Section 5(a) of the FTC Act, 15 U.S.C. § 45(a);

2. that Amazon’s conduct violates Section 2 of the Sherman Act, 15 U.S.C. § 2;

   
   

3. that Amazon’s conduct violates the Connecticut Antitrust Act, General Statutes § 35-24 et seq., and the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. § 42-110b et seq.;

   
   

4. that Amazon’s conduct violates Section 1102 of the Maine Monopolies and Profiteering Law, 10 M.R.S.A. § 1102;

   
   

5. that Amazon’s conduct violates the Maryland Antitrust Act, Maryland Commercial Law Code Ann. § 11-201 et seq.;

6. that Amazon’s conduct violates the Michigan Antitrust Reform Act, Mich. Comp. Laws § 445.771 et seq.;

   
   

7. that Amazon’s conduct violates the Nevada Unfair Trade Practices Act, Nev. Rev. Stat. § 598A.060;

   
   

8. that Amazon’s conduct violates N.J.S.A. 56:8-1 to –227, and N.J.S.A. 56:9-1 to – 19;

   
   

9. that Amazon’s conduct violates New York Executive Law § 63(12);

   
   

10. that Amazon’s conduct violates the Oklahoma Antitrust Reform Act, 79 O.S. §§ 201, et seq., and the Oklahoma Consumer Protection Act, 15 O.S. §§ 751, et seq.;

    
    

11. that Amazon’s conduct violates the Oregon Antitrust Law, Oregon Revised Statutes 646.705 to 646.836;

    
    

12. that Amazon’s conduct violates the Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 P.S. § 201-3, and Pennsylvania common law antitrust doctrine;

    
    

13. that Amazon’s conduct violates the Rhode Island Antitrust Act, R.I. Gen. Laws § 6-36-1, et seq.;

    
    

14. that Amazon’s conduct violates Wis. Stat. § 133.03 et seq.;

    
    

15. that Amazon is permanently enjoined from engaging in its unlawful conduct;

    
    

16. that Amazon is permanently enjoined from engaging in similar or related conduct, or any conduct with the same or similar purpose and effect;

    
    

17. any preliminary or permanent equitable relief, including but not limited to structural relief, necessary to redress and prevent recurrence of Amazon’s violations of the law, as alleged herein;

18. any preliminary or permanent equitable relief, including but not limited to structural relief, necessary to restore fair competition and remedy the harm to competition caused by Amazon’s violations of the law;

19. that the Court grant Plaintiff States equitable monetary relief pursuant to all applicable law;

20. that the Court grant Plaintiff States the costs of suit, including all available fees and costs; and

21. that the Court grant any additional relief the Court finds just and proper.