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Aintiff, ) ) v. ) ) KENNETH R. LAY, in his official capacity as ) Secretary of the North Carolina Department of ) Revenue, ) ) ) Defendant. 19 20 COMPLAINT FOR DECLARATORY RELIEF PURSUANT TO THE DECLARATORY JUDGMENT ACT, 28 U.S.C. 2201 -2202 Plaintiff Amazon.com, LLC ( Amazon ) alleges for its Complaint as follows: 17 18 No. NATURE OF THE ACTION 1. The North Carolina Department of Revenue (the DOR ) is demanding that Amazon turn over the name and address of virtually every.

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