Why Sponsored Products is central
Sponsored Products is a cost-per-click advertising product used to promote individual product listings. Amazon’s current materials say eligible users include professional sellers, vendors, book vendors, Kindle Direct Publishing authors, and agencies. Current eligibility should not be used to infer that every historical campaign was affected. Amazon Ads
The complaint alleges reserves were introduced for Sponsored Products around mid-2019 and then expanded in sophistication and reach. Plaintiffs say the mechanism could replace a lower GSP-derived CPC with a higher Amazon-selected price, without exceeding the advertiser’s bid. U.S. District Court filing via FTC
Government’s alleged full-bid incidence
The government describes auctions in which the winning advertiser paid its own maximum bid as “first-price” outcomes. Its clean annual figures are:
| Year | Government allegation | Status |
|---|---|---|
| 2021 | Approximately 30%–40% | Alleged from Amazon internal data |
| 2022 | Approximately 70% | Alleged from Amazon internal data |
| 2024 | 79.1% | Complaint figure; FTC release rounds to about 80% |
Do not interpolate a 2023 annual rate. The public record reviewed describes experiments and interim measurements but does not provide one clean 2023 annual average suitable for publication.
High-volume events and CPC changes
The complaint alleges more aggressive treatments during high-volume periods including Prime Day and Black Friday. For Prime Day 2023, it describes an internal “Prime Day RoAS Maintenance” project and a proposed change after Day One CPC growth was reportedly lower than expected. Several treatment levels, surcharge ceilings, and projected revenue figures are redacted.
Plaintiffs also cite advertiser and agency reports of CPC spikes during the 2021 holiday period and internal discussions about making changes less detectable. These are allegations based on internal material quoted in the complaint. Amazon disputes the government’s interpretation and says isolated communications do not establish a deceptive program.
Sponsored Brands and Display Ads are also named
The challenged ecosystem is not limited to Sponsored Products. The complaint alleges Sponsored Brands implemented a soft-floor reserve pricing mechanism in 2019, and the FTC announcement also identifies Display Ads. The record should not be stretched to cover every Amazon DSP or open-internet display auction. Federal Trade Commission
Amazon’s response on Sponsored Products
Amazon says relevance, rather than raw bid amount alone, plays a central role; a bid is the advertiser’s maximum CPC; and reserves are normal. It also says inflation-adjusted Sponsored Products search CPC was approximately flat from 2019 through 2024, average winning bids fell about 50% from 2019 through 2025, and conversion rates improved approximately 24% from 2021 through 2025. Amazon’s figures are part of its defense, not court findings. Amazon
What has not been established
No court has ruled that the challenged Sponsored Products pricing was deceptive or unfair, that any particular campaign paid an unlawful overcharge, or that the government’s aggregate estimate is correct. There is no product-specific refund process or eligibility period.