DEFENDANT’S BUSINESS ACTIVITIES
15. Consumers pay $139 per year or $14.99 monthly to subscribe to Prime. Prime subscription fees account for $25 billion of Amazon’s annual revenue.
16. Approximately 70% of Amazon’s revenue comes from American consumers.
17. Subscribers are critical to Amazon’s overall ecommerce business because Prime subscribers spend more than (Redacted) as much shopping on Amazon as compared to non-Prime shoppers.
18. Consequently, one of Amazon’s primary business goals—and the primary business goal of Prime—is increasing subscriber numbers.
19. Within Amazon’s corporate structure, the Prime organization or department (“Prime Organization”) operates Prime. Amazon evaluates the Prime Organization’s performance based on the (Redacted).
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