Peters v. Amazon Services LLC, 2 F. Supp. 3d 1165

Amazon moved to compel arbitration under the FAA after plaintiffs sued for breach-related claims.
Plaintiffs are former Amazon seller accounts (Lane and Peters) alleging improper timely remittance of funds and related misconduct.
Lane signed multiple BSA-based agreements granting arbitration and a class-action waiver; Peters signed the BSA in 2012.
BSA contains broad arbitration provision and a forum selection clause; Participation Agreement is distinct but not used by all sellers.
The court must determine if a valid arbitration agreement exists and whether the claims fall within its scope, staying the case if arbitration is compelled.
The court found Lane and Peters validly agreed to arbitration and that the claims fall within the arbitration scope, issuing a 6-month stay or pending arbitration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence of a valid arbitration agreement	Plaintiffs contend no binding agreement binds them to arbitration.	BSA and participation-based assent created a valid arbitration agreement.	Valid arbitration agreement exists.
Scope of the arbitration clause	Claims relate to past conduct not covered by the arbitration clause.	Clause broadly covers any dispute related to the agreement or use of services, including post-signing claims.	Claims fall within arbitration scope.

AT&T Technologies, Inc. v. Communications Workers of Am., 475 U.S. 643 (1986) (arbitration presumptively covers disputes)
Green Tree Fin. Corp.-Ala. v. Randolph, 531 U.S. 79 (2000) (burden on party resisting arbitration)
Chiron Corp. v. Ortho Diagnostic Sys., Inc., 207 F.3d 1126 (9th Cir. 2000) (valid agreement to arbitrate and scope analysis)
Three Valleys Mun. Water Dist. v. E.F. Hutton & Co., 925 F.2d 1136 (9th Cir. 1991) (evidence for interpreting arbitration agreements)
Rep. of Nicaragua v. Std. Fruit Co., 937 F.2d 469 (9th Cir. 1991) (most minimal indication of intent to arbitrate must be given effect)