The FTC released previously redacted details in its Amazon advertising lawsuit on November 5. The allegations concern how auction prices were calculated, which makes them worth reading before you commit more budget to holiday campaigns.

This is new public evidence in a contested case. Not a ruling, not a fee change, not a refund program.

What the Unredacted Allegations Say

The FTC's November 5 announcement alleges increases of as much as 50% above auction results on ordinary days and 250% on major shopping days. It also describes alleged attempts to explain higher prices to advertisers as increased competition.

Those are maximum alleged increases relative to auction outcomes. They do not claim every advertiser's bill rose by those percentages, and they are not a forecast for this Black Friday.

The case record shows the original lawsuit was filed August 31. November's development is additional detail becoming public, not a new case.

Amazon Disputes It

In its August 31 response, Amazon denies misleading advertisers. It defends reserve pricing, says relevance influences which ads win, and states that advertisers never pay more than their bid.

Amazon describes a soft reserve as its estimated value for a placement. A winning advertiser can pay that reserve when its bid exceeds it, or pay its bid when that bid falls below the soft reserve but clears the hard minimum.

That explanation matters regardless of who wins in court. Do not set a bid above what your business can afford on the assumption the auction will charge substantially less.

Equally, do not read an expensive click as proof of wrongdoing. Your campaign report cannot reconstruct competing bids, relevance calculations, or pricing inputs.

Calculate the Click Price Your Margin Supports

Start with contribution per order before advertising, after product cost, referral and fulfillment fees, discounts, and a returns allowance. Then connect that to your observed conversion rate.

A product produces $10 of contribution before advertising. At a 10% click-to-order conversion rate, 100 clicks generate ten orders and $100 of contribution, making the break-even click cost $1 before fixed overhead.

If the average click costs $1.25, those clicks cost $125. You lose $25 across the expected orders before overhead, even though the campaign still produces sales.

A holiday discount reduces the contribution allowance while conversion typically improves. Calculate both effects rather than assuming stronger conversion makes a larger bid profitable on its own.

Calculating Amazon ACoS and break-even advertising costs covers the underlying math. Set your target from current economics rather than adopting a general percentage.

Separate Your Decisions From Auction Outcomes

Build a review distinguishing changes you made from changes you observed. Record starting bid, automated adjustments, placement settings, daily budget, realized CPC, conversion rate, and contribution after advertising.

Keep comparable periods together. A discounted holiday offer should not be judged against a full-price week without acknowledging the difference, and stock availability, delivery promises, and product mix belong in the analysis too.

If CPC rises while conversion holds steady, the extra cost comes straight out of what is left per order. If both rise, work out whether the conversion gain actually covers the higher click price.

Avoid changing every campaign at once. A controlled adjustment on a defined product group gives you interpretable results; a broad reaction to a headline does not.

Preserve Records Without Assuming a Recovery

Save historical campaign exports, invoices, agency reports, and correspondence about unexplained pricing changes. Keep original files and dates, particularly when an agency or employee might stop managing the account.

That is sensible housekeeping. It does not establish that your business suffered a recoverable loss, and the November disclosure specifies no automatic payment or claim deadline.

The actionable deadline is your own holiday budget approval. Require a documented profitability threshold before raising bids, and watch the court record for actual decisions or remedies rather than treating allegations as money owed.