United States of America v. Google LLC., Court Filing, retrieved on April 30, 2024, is part of HackerNoon’s Legal PDF Series. You can jump to any part of this filing here. This is the table of links with all parts.
Case Number: 1:20-cv-03010-APM
Plaintiffs: United States of America
Defendant: Google LLC.
Filing Date: April 30, 2024
Location: United States District Court for the District of Columbia
Table of Content
Citations to Witness Testimony
I. INTRODUCTION TO THE PARTIES
II. Introduction To Third Parties
III. Industry Background
- A. General Search Engines
- B. General Search Competition
- C. Advertising, Including Search And Text Ads
- D. Search Access Points
- E. Scale Is Vital For General Search Engines
- F. Google’s Distribution Agreements
IV. MARKET DEFINITIONS
- A. General Search Services In The United States Is A Relevant Market
- B. Search Ads In The United States Compose A Relevant Market
- D. Google Makes No Attempt To Identify An Alternate Advertising Market And Fails To Undermine The Search Ad And Text Ad Markets
V. Google’s Monopoly Power In Each Market
- A. Google Has Monopoly Power In The U.S. General Search Services Market
- B. Google Has Monopoly Power In The U.S. Search Ads Market
- C. Google Has Monopoly Power In The U.S. Text Ads Market
- VI. Google’s Contracts Lock Up Important Access Points
- A. Google’s Apple Contract Is Exclusive
- B. Google’s Android Contracts Are Exclusive
- C. Google’s Browser Contracts Are Exclusive
- D. Defaults Have A Powerful Effect On Users’ Search Behavior, Particularly On Mobile Devices
VII. Google’s Rivals Are Foreclosed From Distribution
- A. Google’s Conduct Forecloses A Substantial Share Of General Search Queries Performed In The United States
- B. Google’s Conduct Forecloses A Substantial Share Of Text Ads And Search Ads In The United States
- C. The Foreclosure Created By Google’s Agreements Is Enhanced By Google’s Ownership Of The Chrome Browser
VIII. Anticompetitive Effects Arising From Google’s Conduct
- A. Google’s Contracts Prevent General Search Services From Accessing Scale And Reduced Scale Directly Reduces The Quality Of Rivals To The Detriment Of Consumers And Advertisers
- B. Google’s Contracts Reduce Investment And Innovation Among Market Participants Including Google
- C. Reduced Competition Reduces Search Quality And The Options Available To Consumers In General Search Services
- D. Google Reduced The Quality And Increased The Prices Of Its Search Ads Products 401
IX. GOOGLE ADOPTED POLICIES FOR DESTROYING OR HIDING DOCUMENTS TO AVOID PRODUCING THEM TO REGULATORS AND LITIGANTS
- A. Google Adopted And Implemented An “Off The Record” Chats Default To Destroy Substantive And Relevant Written Communications
- B. Google Trains Its Employees To Shield Emails And Other Documents From Review And Production In Investigations And Litigation
X. GOOGLE’S PRO-COMPETITIVE JUSTIFICATIONS LACK FACTUAL SUPPORT AND DO NOT OUTWEIGH HARMS IN RELEVANT MARKETS
- A. Google Failed To Show Effective “Competition For The Contract”
- B. Purported Pass-Through Benefits Are Unsubstantiated And Do Not Justify Competitive Harms To Consumers In Relevant Markets
- C. Google’s MADAs And RSAs Are Not Necessary For Android’s Success And Do Not Benefit Search Consumers By Improving Device Quality
XI. Google’s Embedded Hearsay Objections Are Meritless
Appendix: Cited Exhibits Used With A Witness
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