Lee v. Amazon.com, Inc.

Issue: Whether Amazon was strictly liable for injuries caused by a defective product sold through the Amazon Marketplace by a third-party seller, consistent with Bolger and Loomis.

The plaintiff purchased a children's product from a third-party seller through Amazon's marketplace and was injured when the product was defective. The Court of Appeal applied the developing California strict liability standard for marketplace platforms, consistent with Bolger and Loomis, and held that Amazon's facilitation of the commercial transaction was sufficient to subject it to strict products liability as a seller in the chain of distribution.

Part of the trilogy of California appellate decisions (Bolger, Loomis, Lee) establishing that Amazon and similar marketplace platforms can face strict products liability in California, regardless of § 230. These cases reflect a significant strand of platform liability doctrine that operates entirely outside the § 230 framework by focusing on the platform's role in commercial transactions rather than its role in hosting user speech.