Amazon Isn’t Liable for Merchant’s Display of Bogus Contact Info–Hillman v. Amazon

June 3, 2025 · by · in Content Regulation, Derivative Liability

Hillman says that an Amazon merchant, Cozy Castle Furniture, mistakenly displayed Hillman’s contact information on its page as if it were the merchant’s contact info. As a result, Hillman says she got hundreds of complaints per day about the furniture merchant. Hillman said the flood of complaints prevented her from running her business and disrupted her personal life. Hillman says she called Amazon 15 times and wrote Amazon 11 letters to get it to correct the bad contact info, all to no avail.

(I’m having serious flashbacks to the facts of the old Zeran case, which also involved a disruptive deluge of complaints due to the misreporting of the plaintiff’s contact info. Except in the Zeran case, the misreporting appeared to be an intentional attack on Zeran).

Hillman sued Amazon for the intentional infliction of emotional distress (IIED), among other things, and the court dismisses the IIED claim per Section 230.

ICS Provider. “In this third-party marketplace, Amazon acts as a passive host. It is, thus, an interactive computer service.” [My standard teeth-gnashing over the oxymoronic “passive host” phrase.]

Third-Party Content. “someone—but not Amazon—listed false information about Plaintiffs. The misinformation was ‘provided by another information content provider.'”

Publisher/Speaker Claim. “Plaintiffs allege that Amazon listed inaccurate information on its website and that it failed to correct that inaccuracy.”

An easy Section 230 dismissal.

I’ll add that IIED would also lose on the merits because, based on these facts, Hillman cannot show Amazon had the requisite “intent.” But Section 230 leads to the same outcome.

Case Citation: Hillman v. Amazon.com Services LLC, 2025 WL 1556090 (D. Md. June 2, 2025)