EXHIBIT 18.1

LETTER REGARDING CHANGE IN ACCOUNTING PRINCIPLE

July 28, 2000

Mark S. Peek
Chief Accounting Officer and Vice President, Finance
Amazon.com, Inc.
1200 12th Avenue South, Suite 1200
Seattle, Washington 98144-2734

Dear Sir:

Note 1 of Notes to Financial Statements (Unaudited) Of Amazon.com, Inc.,
included in its Form 10-Q for the quarterly period ended June 30, 2000,
describes a change in the method of accounting for the classification of certain
investments as cash equivalents. We conclude that such change in the method of
accounting is to an acceptable alternative method which, based on your business
judgment to make this change and for the stated reasons, is preferable in your
circumstances. We have not conducted an audit in accordance with generally
accepted auditing standards of any financial statements of the Company as of any
date or for any period subsequent to December 31, 1999, and therefore we do not
express any opinion on any financial statements of Amazon.com, Inc., subsequent
to that date.

                                       Very truly yours,

                                       /s/ Ernst & Young LLP

                                       ERNST & YOUNG LLP