
Mr. Jeffrey P. Bezos, President and CEO August
18, 2009
Amazon.com
Inc.
1200 12th Ave.
South, Ste. 1200
BY
CERTIFIED MAIL
Seattle, WA
98144-2734
RECEIPT
REQUESTED
RE: Notice of Potential Legal
Liability for Continuing Sale of “Illegal” E-Cigarettes
Dear Mr. Dutta:
As the legal-action antismoking organization whose legal complaints [1] about the facilitation – by credit card companies and others – of the illegal Internet sales of cigarettes led to a crackdown by many attorneys general, [2] we write to advise your company of its potential legal liability related to its continuing sale of e-cigarettes.
As noted in an NPR piece [3] in which I participated, the FDA has clearly announced that “e-cigarettes are subject to FDA approval as a drug or medical device, much like nicotine patches, gums and inhalers — and therefore they are illegal until they are cleared.”[4] [emphasis added] Despite this, Amazon.com is continuing to sell these devices in interstate commerce, and in apparent violation of consumer protection laws in many individual states.[5]
Recently ASH wrote to all 50 attorneys general asking them to take legal action against the illegal sales of such products. To date, at least one state has forced two different companies to cease selling these illegal products. PayPal, after being warned by ASH, has stopped facilitating their sale, and Facebook is refusing their ads.[6]
As the FDA [7] and others [8] have noted, e-cigarettes pose a wide variety of potential dangers to users,[9] and perhaps also to those around them, both of whom inhale a mixture of nicotine (a dangerous addictive drug) and propylene glycol (which is used in antifreeze and may cause respiratory tract irritation). Thus, in addition to liability for selling an illegal product, Amazon.com might well be named as a defendant should an e-cigarette user or a family member claim that some medical problem was caused by an e-cigarette allegedly sold by Amazon.com.
Yours truly,
Law Professor John F. Banzhaf III
Executive Director and Chief Counsel
CC: Thomas J. Szkutak, CFO; Werner Vogels, CTO; Michelle Wilson, Counsel; Tom Alberg; John Seely Brown; John Doerr; Bing Gordon; Alain Monie; Tom Ryder; Patty Stonesifer
FOR NOTES, SEE
[1] ASH Urges Attorneys General to Go after Illegal Internet Sales,
http://ash.org/agtaxletter.html
[2] Credit Card Companies Agree to Ban Transactions From Online Cigarette Sales [11/10-1],
http://ash.org/no-smoking/nov05/11-10-05-1.html
[3] E-Cigarettes: The New Frontier In War On Smoking,
http://www.npr.org/templates/story/story.php?storyId=111578997
[4] See also,
FDA to Regulate E-Cigarettes as Toxins are Found - Law Prof's NBC-TV Appearance and Petition Played Big Role,
http://www.pr-inside.com/fda-to-regulate-e-cigarettes-as-toxins-r1403601.htm
FDA Warns of Health Risks Posed by E-Cigarettes,
http://www.fda.gov/downloads/ForConsumers/ConsumerUpdates/UCM173430.pdf
Transcript for FDA's Media Briefing on Electronic Cigarettes,
http://www.fda.gov/downloads/NewsEvents/Newsroom/MediaTranscripts/UCM173405.pdf
[5] See, e.g., http://ash.org/ORecig1
[6] PayPal Warned About E-Cigarette Legal Liability - Facebook Bans Ads; Now Cialis is in E-Cigarettes.
http://www.pr-inside.com/paypal-warned-about-e-cigarette-legal-r1430452.htm
See also, FDA Begins Regulating E-Cigarettes as Drug-Delivery Devices
// ASH's Legal Petition Spurs/Explains Action,
http://www.pr-inside.com/fda-begins-regulating-e-cigarettes-as-r1262323.htm
[7] See generally, FDA's Links re E-Cigarettes,
http://www.fda.gov/NewsEvents/PublicHealthFocus/ucm172906.htm
[8] See, e.g., Concerns Voiced by the Public Health Experts About Electronic Cigarettes - No Demonstrated Public Health Benefit,
http://www.fda.gov/NewsEvents/PublicHealthFocus/ucm173175.htm
Positions of Other Organizations Regarding E-Cigarettes,
[9] E-Cigarette Sales Banned by Court Order // More Bans Planned in Oregon and Elsewhere,
http://www.pr-inside.com/e-cigarette-sales-banned-by-court-order-r1418417.htm
FDA Warns of Health Risks Posed by E-Cigarettes,
http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm173401.htm
FDA Warns Against E-Cigarettes,
http://www.healthnews.com/alerts-outbreaks/fda-warns-against-e-cigarettes-3499.html
This information is presented as a public service by:
Action on Smoking and Health
(ASH)
2013 H Street NW / Washington, DC
20006 / (202) 659-4310
A national nonprofit, scientific and educational organization founded
in 1967.
All donations are fully tax deductible.
Material on this page may be freely reproduced,
distributed, and circulated
with attribution given to Action on Smoking and
Health.
Dedicated to Mr. and Mrs. Warren Wells