Frequently Asked Questions

1. What is the Notice and why should I read it?

The Court authorized the Notice to inform you that you may be a member of a Class of current and former Amazon employees who worked for Amazon between January 1, 2020, and September 4, 2025; made less than the statutory threshold set forth in RCW 49.62.020(1)(b), as annually adjusted in accordance with RCW 49.62.040; and entered into a CIAA or other agreement with the same language as defined below. If you meet these criteria, you have legal rights and options that you may act on before the Court rules on the merits of this Lawsuit. This Notice explains the Lawsuit and your legal rights.

You may have entered into a CIAA or another agreement with Amazon containing the following language:

• Non-Solicitation. During Employment and for 18 months after the Separation Date, Employee will not, directly or indirectly, whether on Employee’s own behalf or on behalf of any other entity (for example as an employee, agent, partner, or consultant): (a) accept or solicit business from any Customer of any product or service that Employee worked on or supported during the final 18 months of Employee’s employment with Amazon, or about which Employee obtained or received Confidential Information by virtue of, and during the final 18 months of, Employee’s employment with Amazon; or (b) encourage any Customer or Business Partner to cease doing business with Amazon or to terminate or limit an existing relationship or arrangement with Amazon. For purposes of this Agreement, “Customer” means any individual or entity that was a customer or client of Amazon during Employee’s employment, or with which Amazon engaged in discussions before the Separation Date related to the possibility that such party might become a customer or client of Amazon, and “Business Partner” means any individual or entity with which, before the Separation Date, Amazon was involved in any business arrangement or engaged in discussions regarding the possibility of entering into such an arrangement.

Judge Jennifer Petersen of King County Superior Court is overseeing this Lawsuit. Mr. Burns and Ms. Garner are the Plaintiffs or Class Representatives. The companies they sued, Amazon.com Services LLC and Amazon Retail LLC, are the Defendants.

2. What is this Lawsuit about?

Plaintiffs claim that Amazon violated Washington law, RCW 49.62.020, by requiring employees making less than the statutory threshold to enter into a CIAA or other agreement containing the same language as defined above, which Plaintiffs claim restricted their job mobility and prevented them from working for Amazon’s competitors and customers if they were to leave Amazon’s employment. Amazon denies that it has imposed an unlawful noncompetition covenant and denies that it is or can be held liable for the claims in the Lawsuit.

3. How do I know if I am in the Class?

Amazon’s records show you may be a part of the Class because you are a current or former employee who earned less than the applicable statutory threshold between January 1, 2020, and September 4, 2025, and you may have entered into a CIAA or other agreement containing the same language as defined above. If you meet these criteria and entered into a CIAA or other agreement containing the same language as defined above, you are a member of the Class. If you are not sure whether you are included, you can contact the Class Administrator, Simpluris, Inc., toll-free by calling (833) 647-9004.

4. Do I have an attorney in this case?

Yes, the Court appointed Timothy Emery, Patrick B. Reddy, and Paul Cipriani of Emery Reddy, PC as Class Counsel to represent the Class. Their contact information is:

Emery Reddy,
600 Stewart Street, Suite 1100
Seattle, WA 98101
www.emeryreddy.com

Should I get my own attorney? You don’t need to hire your own attorney because Class Counsel are working on your behalf. These attorneys and their firm are experienced in handling similar cases. You will not be charged for these attorneys. You can ask your own attorney to appear in Court for you, at your own expense, if you want someone other than Class Counsel to represent you.

5. What happens if I do nothing?

If you do nothing, you will still be in the Class and be bound by all orders and judgments of the Court. Unless you exclude yourself, you won’t be able to file a lawsuit or be part of any other lawsuit against Amazon for the claims or legal issues resolved in the Lawsuit.

6. What happens if I request to be excluded?

If you submit a timely, valid request for exclusion from the Class, you will not be in the Class. You will not release claims against Amazon, and you will not be legally bound by the Court’s judgments in this Lawsuit. Similarly, you will not receive any benefit if Plaintiffs are successful.

7. How do I request to be excluded?

If you do not want to remain a member of the Class in this Lawsuit, you must send an “Exclusion Request” in the form of a letter sent by mail, stating that you want to be excluded from Burns v. Amazon.com Services LLC, et al., No. 24-2-22574-9 SEA. Be sure to include your name, address, and phone number, and sign the letter. You must submit your Exclusion Request by mail before March 31, 2026, to:

Simpluris, Inc.
P.O. Box 26170
Santa Ana, CA 91799
Phone: (833) 647-9004

If you do not request to be excluded before the deadline, you will automatically be included in this Lawsuit.

8. If I don’t exclude myself, can I sue Amazon for the same thing later?

No. Unless you exclude yourself, you give up any right to sue Amazon for the claims being resolved by this Lawsuit even if you do nothing.

9. If I exclude myself, can I get anything from the Lawsuit?

No. If you exclude yourself, you will not receive any monetary benefit from the Lawsuit.

10. What is the class definition ordered by the Court?

On October 10, 2025, the Court issued an Order certifying the following class (“Class”):

• All current and former Washington employees of Amazon.com Services LLC or Amazon Retail LLC, whose annual earnings were less than the threshold set forth in RCW 49.62.020(1)(b), as annually adjusted in accordance with RCW 49.62.040, and who entered into an agreement with Amazon at any time between January 1, 2020, and September 4, 2025, that contains the following language:

  Non-Solicitation. During Employment and for 18 months after the Separation Date, Employee will not, directly or indirectly, whether on Employee’s own behalf or on behalf of any other entity (for example, as an employee, agent, partner, or consultant): (a) accept or solicit business from any Customer of any product or service that Employee worked on or supported during the final 18 months of Employee’s employment with Amazon, or about which Employee obtained or received Confidential Information by virtue of, and during the final 18 months of, Employee’s employment with Amazon; or (b) encourage any Customer or Business Partner to cease doing business with Amazon or to terminate or limit an existing relationship or arrangement with Amazon. For purposes of this Agreement, “Customer” means any individual or entity that was a customer or client of Amazon during Employee’s employment, or with which Amazon engaged in discussions before the Separation Date related to the possibility that such party might become a customer or client of Amazon, and “Business Partner” means any individual or entity with which, before the Separation Date, Amazon was involved in any business arrangement or engaged in discussions regarding the possibility of entering into such an arrangement.

Current and former Amazon employees who signed an updated CIAA (and who were never subject to any prior versions) are not included within the class definition. The updated CIAA includes a written exemption from the Non-Solicitation provision for employees who earn less than the threshold established by RCW 49.62.040

11. When and where will the Court hold a hearing on the merits of the Lawsuit?

Trial is currently scheduled for September 10, 2026 at 9:00 A.M. in King County Superior Court, Maleng Regional Justice Center, 401 4th Avenue North, Room 3C, Kent, WA 98032. The purpose of trial is for the finder of fact to determine the merits of Plaintiffs’ claims.

Note: The date and time of Trial are subject to change by court order. Any changes will be available through the Court’s publicly available docket. You should check this docket to confirm the date and time have not been changed.

12. Do I have to come to the trial?

No. Class Counsel will represent your interest, but you are welcome to attend the trial at your own expense. You may also hire an attorney to attend on your behalf at your own expense, but you don’t have to.

13. May I speak at the trial?

Yes. If you do not exclude yourself from the Class, you may ask the Court for permission to speak at trial concerning any part of your claims against Amazon.

14. How can I get additional information?

Any questions you have concerning this website or the Notice may be directed to the Class Administrator at (833) 647-9004.

PLEASE DO NOT CALL THE COURT, THE CLERK OF THE COURT, THE JUDGE, OR DEFENDANTS WITH QUESTIONS ABOUT THE ACTION OR NOTICE PROCESS.

Any questions you have concerning this Notice may be directed to the Class Administrator at (833) 647-9004.