FTC v. Amazon Court Filing, retrieved on Sep 26, 2023, is part of . You can jump to any part in this filing . This part is 6 of 30. HackerNoon’s Legal PDF Series here Prime’s Four-Page, Six-Click, Fifteen-Option Iliad Cancellation Process 113. Under substantial pressure from the Commission, Amazon changed its Iliad cancellation process in or about April 2023, shortly before the filing of this Complaint. Prior to that point, there were only two ways to cancel a Prime subscription through Amazon: a) through the online labyrinthine cancellation flow known as the “Iliad Flow” on desktop and mobile devices; or b) by contacting customer service. 114. The Iliad Flow required consumers intending to cancel to navigate a four-page, six-click, fifteen-option cancellation process. In contrast, customers could enroll in Prime with one or two clicks. 115. Although consumers may have enrolled in Prime through devices other than computers and smartphones, such as through the Prime Video application on the Amazon FireStick and Fire TV, they could not cancel via these same technologies. Instead, they had to use the Iliad Flow or call customer service. 116. Amazon launched the Iliad Flow in 2016, and did not substantially change it in the United States until in or about April 2023. 117. To cancel via the Iliad Flow, a consumer had to first locate it, which Amazon made difficult. Consumers could access the Iliad Flow from Amazon.com by navigating to the Prime Central page, which consumers could reach by selecting the “Account & Lists” dropdown menu, reviewing the third column of dropdown links Amazon presented, and selecting the eleventh option in the third column (“Prime Membership”). This took the consumer to the Prime Central Page. 118. Once the consumer reached Prime Central, the consumer had to click on the “Manage Membership” button to access the dropdown menu. That revealed three options. The first two were “Share your benefits” (to add household members to Prime) and “Remind me before renewing” (Amazon then sent the consumer an email reminder before the next charge). See Attachment Q, at 1-2. 119. The last option was “End Membership.” The “End Membership” button did not end membership. Rather, it took the consumer to the Iliad Flow. See Attachment Q, at 2-3. It was impossible to reach the Iliad Flow from Amazon.com in fewer than two clicks. 120. Consumers could also reach the Iliad Flow by contacting customer service, asking to cancel, (Redacted) 121. Consumers could also reach the Iliad Flow from Amazon.com by typing “cancel membership” in the search bar. This produced an “Alexa” answer that included an “End Your Amazon Prime Membership” link. See Attachment T, at 2. 122. Clicking the link did not end Prime membership. Instead, it took the consumer to 7 another page with a heading that read: “End Your Amazon Prime Membership.” The page 8 contained a button labelled “End Your Prime Membership.” Pressing the button did not end 9 Prime Membership. Instead, it took the consumer to the Iliad Flow. See Attachment T, at 3-4. The search bar pathway to the Iliad Flow varied somewhat depending on what 0 search the consumer ran. For instance, searching “how to turn off Prime,” or “cancel prime” 1 (rather than “how to cancel Prime”) took the consumer to a page with a link to Prime Central, 2 from which the consumer had to then locate the path to the Iliad Flow. Searching “End Membership” took the consumer to a page with three blue links under the heading “Closing your Amazon account,” and a subheading “Get information on how to close your Amazon account.” The middle link was “cancel membership.” Clicking “cancel membership” did not cancel membership. Instead, it took the consumer to the Iliad Flow. 124. Typing “cancel membership” in the search bar on a mobile device brought the consumer to the Iliad Flow through similar steps. See Attachment S. 125. Thus, to reach the Iliad Flow, consumers had to do one of the following: 1) contact customer service and inform a customer service agent that they wanted to cancel (Redacted); 2) navigate from Amazon.com to the Prime account management page (Prime Central), locate the “manage membership” dropdown, and press a button labelled “End Membership”; or 3) search “How to cancel membership” in the Amazon search bar, then move through subsequent steps to reach the Iliad Flow—frequently, selecting a link reading “End Your Amazon Prime Membership” and then pressing a button reading “End Your Prime Membership.” 126. Once consumers reached the Iliad Flow, they had to proceed through its entirety—spanning three pages, each of which presented consumers several options, beyond the Prime Central page—to cancel Prime. See Attachment Q. 127. On the first page of the Iliad Flow, Amazon forced consumers to “[t]ake a look back at [their] journey with Prime” and presented them with a summary showing the Prime services they used. Amazon also displayed marketing material on Prime services, such as Prime Delivery, Prime Video, and Amazon Music Prime. Amazon placed a link for each service and encouraged consumers to access them immediately, i.e., “Start shopping today’s deals!”, “You can start watching videos by clicking here!”, and “Start listening now!” See Attachment Q, at 3. Clicking on any of these options took the consumer out of the Iliad Flow. 128. Also, on page one of the Iliad Flow, Amazon presented consumers with three buttons at the bottom. “Remind Me Later,” the button on the left, sent the consumer a reminder three days before their Prime membership renews (an option Amazon had already presented the consumer once before, in the “Manage Membership” pull-down menu through which the consumer entered the Iliad Flow). The “Remind Me Later” button took the consumer out of the Iliad Flow without cancelling Prime. “Keep My Benefits,” on the right, also took the consumer out of the Iliad Flow without cancelling Prime. Finally, “Continue to Cancel,” in the middle, also did not cancel Prime but instead proceeded to the second page of the Iliad Flow. See Attachment Q, at 3. Therefore, consumers could not cancel their Prime subscription on the first page of the Iliad Flow. 129. On the second page of the Iliad Flow, Amazon presented consumers with alternative or discounted pricing, such as the option to switch from monthly to annual payments (and vice-versa), student discounts, and discounts for individuals with EBT cards or who receive government assistance. Amazon emphasized the option to switch from monthly to annual payments by stating the amount a consumer would save at the top of this page in bold. Clicking the orange button (“Switch to annual payments”) or the links beneath took the consumer out of the Iliad Flow without cancelling. See Attachment Q, at 4. 130. Right above these alternatives, Amazon stated “Items tied to your Prime membership will be affected if you cancel your membership,” positioned next to a warning icon. See Attachment Q, at 4. 131. Amazon also warned consumers that “[b]y cancelling, you will no longer be eligible for your unclaimed Prime exclusive offers,” and hyperlinked to the Prime exclusive offers. See Attachment Q, at 4. Clicking this link took the consumer out of the Iliad Flow without cancelling. 132. Finally, at the bottom of Iliad Flow page two, Amazon presented consumers with buttons offering the same three options as the first page: “Remind Me Later,” “Continue to Cancel,” and “Keep My Membership” (labelled “Keep My Benefits” on the first page). See Attachment Q, at 4. Once again, consumers could not cancel their Prime subscription on the second page of the Iliad Flow. Choosing either “Remind Me Later” or “Keep My Membership” took the consumer out of the Iliad Flow without cancelling. Consumers had to click “Continue to Cancel” to access the third page of the Iliad Flow. 133. On the third page of the Iliad Flow, Amazon showed consumers five different options, only one of which, “End Now”—presented last, at the bottom of the page— immediately cancelled a consumer’s Prime membership. See Attachment Q. Pressing any of the first four buttons took the consumer out of the Iliad Flow without immediately cancelling. 134. On the third page of the Iliad Flow, the first and second options—“Remind Me Later” and “Keep My Membership”—were substantially identical to the buttons on the Iliad Flow’s first two pages. Therefore, Amazon forced consumers who reach the Iliad Flow’s last page to view the “Remind Me Later” option four times (including once to enter the Iliad Flow) and the “Keep My Membership” option three times. See Attachment Q, at 5. 135. The third option, “Pause on [date],” would “pause” or put on hold—but not cancel—a consumer’s Prime membership. Amazon did not charge “paused” members for Prime but made it simple for “paused” members to re-join Prime through a single “quick-resume” click. Amazon presented the “pause” option adjacent to a warning icon and text stating that, “[b]y pausing, [consumers] will no longer be eligible for [their] unclaimed Prime exclusive offers,” and provided links to “Prime exclusive offers” (which if clicked exit the Iliad Flow without canceling). See Attachment Q, at 5. Redacted 137. Above the fourth and fifth options—the “End on [date]” and “End Now” options—Amazon also added a warning icon and text that states “[b]y cancelling, [consumers] will no longer be eligible for [their] unclaimed Prime exclusive offers.” See Attachment Q, at 5. 138. The fourth option, “End on [date],” turned off Prime’s auto-renew feature. It did not immediately cancel the consumer’s membership. Instead, the membership would end when the current billing cycle concluded, and the consumer would not receive a refund. See Attachment Q, at 5. 140. Therefore, to complete the Iliad Flow and cancel a Prime membership, the consumer needed to click a minimum of six times from Amazon.com: Prime Central  “Manage Membership”  “End Membership” → “Continue to Cancel” → “Continue to Cancel” → “End Now.” See Attachment Q. 141. Amazon limited refunds available through the Iliad Flow to one monthly charge, although Amazon did not disclose this to subscribers entering the flow. Consequently, a Nonconsensual Enrollee who discovered Prime charges after a few months could not obtain a full refund online. (Redacted) 142. The Iliad Flow was also accessible through a mobile device. Similar to the Iliad Flow on desktop, the Iliad Flow on mobile was also difficult for consumers to locate and presented a complex array of options across multiple pages. Cancelling via the Iliad Flow on a mobile device was an eight-page, eight-click minimum process. 143. On a mobile device, a consumer entered the Iliad Flow by 1) tapping on “My Account,” 2) selecting “Manage Prime Membership” from a dropdown menu on the second page, 3) selecting “Manage membership” on the third page, 4) selecting “Manage membership” on the fourth page, and 5) selecting “End my Membership” on the fifth page. See Attachment R, at 1-5. 144. On the sixth page, the consumer seeking to cancel began the mobile equivalent of the Iliad Flow. Specifically, on this page, Amazon presented benefits information similar to the desktop Iliad Flow, and stated at the top of the page “[Name], thank you for being a member with us. Take a look back at your journey with Prime.” See Attachment R, at 6. Amazon included the same three options—“Keep My Benefits,” “Continue to Cancel,” and “Remind Me Later”—although consumers had to scroll down to view them. None of these options ended the Prime membership. Consumers who selected “Continue to Cancel” proceeded to a seventh page. See Attachment R, at 6. 145. On the seventh page, Amazon presented alternate payment options similar to those in the desktop Iliad Flow: Amazon placed the three options at the bottom of the page in the same order. See Attachment R, at 7. Pressing “Continue to Cancel” did not end the membership. It took the consumer to an eighth and final page. See Attachment R, at 7. 146. On the eighth and final page, Amazon presented five buttons. The first three were “Pause on [date],” “Keep My Membership,” and “Remind Me Later.” The consumer had to scroll down to view the fourth and fifth. The fourth (“End on [date]”) turned off auto-renew, but did not immediately cancel, and consumers who chose this option did not receive a refund. Only the fifth and final button (“End Now”) immediately cancelled the membership. Amazon refunded consumers who pressed this button a pro-rated amount for the balance of the monthly billing cycle. See Attachment R, at 8. 147. Amazon designed the Iliad Flow (both desktop and mobile) to inform consumers about a) Prime benefits they would lose by cancelling Prime, and b) alternative payment methods available to them to keep Prime. 148. Amazon did not design the Iliad Flow to be simple or easy for consumers. The Iliad Flow inhibits or prevents many consumers who intend to cancel from cancelling their membership. Redacted Continue Reading . Here About HackerNoon Legal PDF Series: We bring you the most important technical and insightful public domain court case filings. This court case 2:23-cv-00932 retrieved on September 28, 2023, from is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction. ftc.gov

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