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•  Reuters reports that "a New York state appeals court on Tuesday dismissed state Attorney General Letitia James' lawsuit accusing Inc. of failing to adequately protect thousands of workers at two New York City facilities against COVID-19.

"The Appellate Division in Manhattan said federal law preempted James' claims that Amazon violated state labor law by retaliating against two employees, Christian Smalls and Derrick Palmer, who protested against working conditions.

"It said issuing a ruling could also pose a 'substantial risk of interference' with the National Labor Relations Board, which is considering essentially the same allegations of retaliation against Amazon, the second-largest U.S. private employer.

"The four-judge panel also said James' effort to require Seattle-based Amazon to comply with state COVID-19 workplace guidelines was moot, because the state had withdrawn the guidance that she sought to enforce."

•  Variety reports that "Netflix may dive into the ad-supported VOD space as soon as the fourth quarter of 2022 — sooner than it originally signaled.

"Last month, as Netflix reported an unexpected drop in streaming subscribers in Q1 and forecast a 2 million sub loss for the second quarter, the company announced plans to roll out a lower-cost version of its streaming service with ads."  While the timeline originally was said to be "the next year or two," Netflix "has evidently accelerated that timeline: Netflix informed employees of a Q4 target date for the ad-supported tier in a recent memo … No details have come to light about what Netflix’s AVOD tier would cost or how advertising would be presented. In the U.S., Netflix’s standard two-stream HD plan is $15.49/month."