Amazon Spoliation Motion Denied as Court Rules Duty Extends to Data, Not Static Webpage Snapshots

The dispute centers on a putative class action brought by Anita Medal and three other named plaintiffs, who allege Amazon violated California consumer protection laws by selling dietary supplements without mandatory structure/function disclaimers. The plaintiffs allege that Amazon systematically omitted the required warnings on product detail pages, or PDPs, misleading consumers about the products’ therapeutic efficacy.

The crux of the litigation involves the visual appearance of these PDPs. Plaintiffs contend that Amazon failed to preserve the pages as they appeared to consumers, seeking an adverse inference instruction that would deem Amazon liable for the alleged labeling violations.

Amazon’s defense relied on the technical nature of its website. According to a declaration by Amazon employee Adam Duncan, a PDP is not a static document but a dynamic interface generated for each customer they visit the page.

Duncan declared that a PDP is not equivalent to a page inside a traditional shopping catalog and is not a static representation.

Because the layout and content are assembled in real-time, Amazon does not maintain copies of individual PDP renderings for every customer course of business. Instead, the company preserves the underlying structured data and code used to generate the pages.

Plaintiffs argued that Amazon’s preservation duty was triggered on August 24, 2022, when the company received pre-complaint notice of their claims. They contended that Amazon took no steps to preserve the PDPs as static snapshots despite having the capability to do so, characterizing the failure as ordinary-course destruction practices that should have been suspended.

The plaintiffs sought a hefty sanction, asking the court to draw an irrebuttable adverse inference that Amazon is liable for unlawful and deceptive labeling for all dietary supplements sold on its platform during the liability period.

Amazon responded that it had not destroyed evidence but had preserved it in its native format. The company argued that the underlying data contains all the Non-Variable PDP Content relevant to the plaintiffs’ claims, including product descriptions, images, and safety warnings.

U.S. District Judge James C. Hill, who authored the order, rejected the plaintiffs’ argument that Amazon was required to produce PDPs in a PDF or snapshot format.

The native format of the PDPs, and thus the way they are kept course, is not in static, snapshot form akin to a PDF but as underlying, structured data, Robart wrote.

Hill noted that requiring Amazon to produce static snapshots would obligate the company to generate upwards of hundreds of millions of PDFs or snapshots, one for each instance when a consumer or potential class member viewed the PDP.

The judge also found plaintiffs’ concerns about the usability of the underlying data to be largely unfounded, though he acknowledged a technical gap regarding image rendering.

The Court finds it implausible that consumers purchasing dietary supplements from Amazon would look solely, or even predominantly, at images of the bottle or package itself on the web page rather than the information provided on the product web page, Robart wrote.

However, the judge noted that the data provided by Amazon to generate an exemplar PDP did not render all images, leaving grey boxes where there should be images.

Hill directed the parties to continue meet-and-confers to resolve the technical challenge of accurately rendering PDP exemplars using the source code so that all images are displayed.

Because the court determined that Amazon’s preservation duty encompassed the underlying data and code, it concluded that the company did not fail to preserve ESI.

Amazon neither spoliated nor destroyed evidence, Robart wrote. Thus, sanctions are unwarranted here.

The plaintiffs’ case relies on claims under California’s Unfair Competition Law, Consumer Legal Remedies Act, and False Advertising Law. The named plaintiffs allege they relied on Amazon’s reputation and the omissions from product labels, and were misled thereby.

The order follows a previous ruling in April 2026 where Hill denied Amazon’s motion to dismiss, finding the plaintiffs’ claims colorable at the pleadings stage because the text of the PDPs lacked the required disclaimers, even if the product images contained an asterisk linking to them.