Ligeri v. Amazon.com Services LLC
2:25-cv-00796
| W.D. Wash. | Jul 30, 2025Background
- Plaintiff Benjamin Joseph Ligeri, proceeding pro se, filed three related lawsuits against Amazon entities alleging wire fraud, bank fraud, conversion, and trademark infringement related to Amazon's actions against his seller accounts and brands.
- Ligeri claims Amazon unlawfully withheld funds, sabotaged his brands, deactivated his seller account, and facilitated infringement of his trademarks by others on the Amazon platform.
- Amazon sought to consolidate the cases, compel arbitration based on the Business Solutions Agreement (BSA), and dismiss the intellectual property claims.
- Ligeri contested consolidation, assignment to a single judge, and arbitration, arguing his claims post-date seller status and are legally distinct.
- Prior litigation in Connecticut federal court had already ruled the BSA’s arbitration clause to be valid and enforceable as to Ligeri’s disputes with Amazon.
- The three cases are in early procedural stages and share common underlying facts concerning Ligeri’s activities as a third-party seller and brand owner on Amazon.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial reassignment/consolidation | Cases are unrelated; reassignment and consolidation prejudicial | Same facts/parties justify judicial efficiency | Consolidation appropriate and granted |
| Compel arbitration | Arbitration doesn’t apply to post-seller conduct | Arbitration clause survives termination, covers claims | Arbitration compelled; arbitrability issue delegated to arbitrator |
| Preclusive effect of prior arbitration order | Prior order not final; no preclusion | Collateral estoppel applies due to prior order | No preclusive effect, but arbitration provision still enforceable |
| Trademark infringement & related dismissal | Amazon engaged in or induced infringement | Ligeri fails to allege Amazon directly used marks | IP claims dismissed w/o prejudice; leave to amend |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requirement for facial plausibility)
- Henry Schein, Inc. v. Archer & White Sales, Inc., 586 U.S. 63 (delegation of arbitrability to arbitrator)
- Johnson v. Manhattan Ry. Co., 289 U.S. 479 (case consolidation standard)
- Levi Strauss & Co. v. Blue Bell, Inc., 778 F.2d 1352 (trademark infringement elements)
- Inwood Labs., Inc. v. Ives Labs., Inc., 456 U.S. 844 (contributory trademark infringement)
- Safeworks, LLC v. Teupen Am., LLC, 717 F. Supp. 2d 1181 (CPA claim congruous to trademark claims)
- Warren v. Guelker, 29 F.3d 1386 (Rule 11 sanctions apply to pro se litigants)
- Taylor v. Sturgell, 553 U.S. 880 (collateral estoppel standard)
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (who decides arbitrability)