Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 1 of 72
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`Robert W. Dickerson, Jr. (SBN 089367)
`E-mail: rdickerson@bwslaw.com
`BURKE, WILLIAMS & SORENSEN, LLP
`444 South Flower Street, Suite 2400
`Los Angeles, CA 90071-2953
`Tel: 213.236.0600
`
`Fax: 213.236.2700
`
`Patricia L. Peden (SBN 206440)
`E-mail: ppeden@bwslaw.com
`BURKE, WILLIAMS & SORENSEN, LLP
`1901 Harrison Street, Suite 900
`Oakland, California 94612-3501
`Tel: 510-273-8780
`
`Fax: 510-839-9104
`
`Lenny Huang (SBN 264386)
`E-mail: lhuang@bwslaw.com
`BURKE, WILLIAMS & SORENSEN, LLP
`60 South Market Street, Suite 1000
`San Jose, California 95113-2336
`Tel: 408-606-6300
`
`Fax: 408-606-6333
`
`Attorneys for Plaintiff
`RUMBLE, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`
`RUMBLE, INC.,
`Plaintiff,
`
`v.
`GOOGLE LLC and DOES 1-10,
`inclusive,
`
`Defendants.
`
`Case No. 4:21-cv-00229-HSG
`FIRST AMENDED COMPLAINT
`FOR DAMAGES AND INJUNCTIVE
`RELIEF DUE TO ANTITRUST
`VIOLATIONS
`
`Judge:
`
`Hon. Haywood S. Gilliam, Jr.
`
`For its first amended complaint against defendant Google LLC (“Google” or
`“Defendant”), plaintiff Rumble, Inc. (“Rumble”) alleges as follows:
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 2 of 72
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`INTRODUCTION
`Rumble brings this action under Section 2 of the Sherman Act, (15
`1.
`U.S.C. §2), and Sections 4 and 15 of the Clayton Act (15 U.S.C. §§ 4 and 15),
`against Google for monetary damages well in excess of $2,000,000,000 that
`Rumble has sustained and continues to sustain as a proximate result of Google’s
`antitrust violations, and for injunctive relief to prevent Google from monopolizing,
`attempting to monopolize, and continuing unlawfully to maintain its monopoly in
`the relevant market – online video sharing and viewing services or platforms (the
`“online video platform market”) – through anticompetitive and exclusionary
`practices.
`These practices include Google rigging searches purposefully and
`2.
`unlawfully to always give preference to Google’s YouTube video platform over
`Rumble (and other platforms) in Google search results, such that the Google search
`page result for online videos lists links to the YouTube site as the first search
`results, even if the search specified Rumble, such as “dog videos on rumble.”
`By unfairly rigging its search algorithms (or through other means or
`3.
`mechanisms) such that YouTube is the first-listed links “above the fold” on its
`search results page, Google, through its search engine, was able to wrongfully
`divert massive traffic to YouTube, depriving Rumble of the additional traffic, users,
`uploads, brand awareness and revenue it would have otherwise received.
`Google has also engaged in exclusionary conduct by which it has
`4.
`wrongfully achieved and has maintained its dominance and monopoly power in
`search in the increasingly mobile ecosystem and has also thereby attempted to
`monopolize and has monopolized the online video platform market. Google’s
`conduct in this regard is similar to a “bait and switch” scheme, whereby Google
`acquired the Android operating system, and made it “open source,” meaning that it
`was free for anyone to use. That was the “bait.” Otherwise skeptical
`manufacturers of smart devices such as mobile phones were lured by that bait, and
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 3 of 72
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`assuming they could adopt the now-open-source Android operating system for their
`devices without having to pay a licensing fee, develop their own system, or
`relinquish control over their own devices, did so, such that all but Apple adopted
`the Android operating system. This in turn caused independent, third party app
`developers, who of course wanted their apps to have the largest possible potential
`consumer pool, to develop their apps to be compatible with the Android system.
`Google then created apps (such as Google Play, which is an online app superstore)
`and other functionalities (that will be described in detail below) that became gotta-
`have items for manufacturers and distributors of smart devices if they wanted to be
`able to compete in the marketplace. This allowed Google to do what had generally
`been thought to be impossible – control that which it had given away to all for free
`(i.e., the basic Android operating system).
`Now came the “switch.” These manufacturers and distributors found
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`themselves in a position that in order to obtain these gotta-have items which could
`only be obtained from Google, they had to agree to various Google-imposed
`agreements. For example, one such agreement forced Android-based smartphone
`manufacturers to include, among others, YouTube as a preinstalled app on their
`phones (and to give it a preferred location on the phone’s default opening page, and
`make it undeletable by the user).
`This conduct has damaged and continues to damage Rumble by further
`6.
`self-preferencing YouTube over Rumble (and other platforms, which harms
`competition generally in the online video platform market, damages Rumble
`specifically, and harms consumers). Because much of the online searching for
`videos is now done on smartphones, this further ensures that Google’s YouTube
`platform receives unfair preferential treatment. Google thus engaged in
`exclusionary conduct to wrongfully acquire and maintain a monopoly over the
`online video platform market. Google’s exclusionary conduct has included
`contractual and other vertical restrictions that limit competitors’ access to, and
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`BURKE, WILLIAMS &
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`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`ability to compete in, the online vide platform market.
`Rumble is unique among companies attempting to compete in the
`7.
`online video platform market in that it has an extensive catalog of exclusively-
`assigned original content videos, thus differentiating itself from other online video
`platforms. Rumble receives between $10 and $30 per thousand views of its
`exclusive videos on its platform, but when that search traffic has been diverted to
`YouTube through Google’s wrongful conduct, Rumble has received only forty-
`eight cents ($0.48) on average per thousand views of its videos from
`Google/YouTube. It is Google’s unlawfully acquired monopoly power in the
`relevant market that has allowed it to pay so little, and keep so much, of the
`advertising revenue.
`Unlike other websites or video platforms, Rumble, with its thousands
`8.
`of high value exclusive video assets which it has syndicated to YouTube (which
`have generated billions of views on YouTube), has the unique ability to discover,
`track and determine its damages both on its exclusive and on its non-exclusive
`catalog, which have been proximately caused by Google’s unlawful conduct.
`Notably, this conduct is also in violation of Google’s own duplicate content and
`original sourced reporting best practices which it purports to follow, but evidently
`does not.
`Set forth below are screenshots (Figures 1 and 2) showing a recent
`9.
`example of this unlawful self-preferencing by Google of its own video platform,
`YouTube. The searched-for video is entitled “Baby preciously cuddles cat for nap
`time.” It is a Rumble exclusive video, so Rumble is the original source for that
`video. That title – “Baby preciously cuddles cat for nap time” – is verbatim how it
`is listed on the Rumble platform. Because Rumble is the original source, it was
`able to syndicate (i.e., release) the video to whom and when it chose. In this
`instance, to test whether the Google search algorithms were rigged (and/or Google
`was otherwise manipulating the search results) to give unfair preference to
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 5 of 72
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`YouTube, Rumble “handicapped” YouTube by releasing the video to
`Google/YouTube last.
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`Figure 1
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`10. Figure 1 depicts the Google search results page for a search for “Baby
`preciously cuddles cat for nap time.” This search was made after Rumble released
`this video only to MSN and Yahoo, and before Rumble released it to YouTube. As
`seen, Yahoo is listed first, followed by MSN and then followed by multiple
`miscellaneous unrelated YouTube videos that do not contain, in fact, are not even
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`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`close to, the searched-for title, and are quite dated; for example, a YouTube video
`from 2016 entitled “5 ways to make your cat more affectionate.” Significantly, a
`link to this exclusive Rumble video is not even listed on the Google search page
`results, even though the MSN listing provides a canonical URL referring to
`Rumble’s original page and identifying Rumble as the original source. Google
`even lists its dated and unrelated YouTube videos ahead of Rumble.com’s listing.
`In fact, Rumble.com’s listing is nowhere to be found despite all the credit,
`linkbacks, canonicals and submission to Google Webmaster Tools that identified
`Rumble as the original source for this video prior to the Google search, the results
`of which are shown in Figure 1.
`11. Prior to the search shown in Figure 1, Google was made aware that
`this “Baby preciously cuddles” video was a Rumble exclusive and original asset by
`multiple means; for example, no webpages prior to Rumble had duplicate metadata;
`MSN’s canonical URL pointed to Rumble.com as the original source; Yahoo also
`references Rumble; there is even a linkback to Rumble’s URL on the YouTube
`video; and by an automatic sitemap submission to Google Webmaster Tools.
`Pursuant to Google’s publicly stated policies, Rumble should have been elevated in
`the search results (actually should have been listed first), and even though the
`search was for the exact title for the video as on Rumble’s platform, the Rumble
`platform is not even listed at all on the Google search page for this specific Rumble
`video.
`12. Once the Rumble URL was documented to be indexed in Google
`according to Webmaster Tools, and both Yahoo and MSN took the lead on the
`search results, Rumble decided to provide the video to YouTube with credit and
`linkbacks to the Rumble.com website. As shown in Figure 2 below, which is a
`screen shot of the Google search and search page results for the search on
`November 24, 2020, about 2 hours after Figure 1 was taken (and after Rumble
`released the video to YouTube), Google immediately gives the top listing to
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 7 of 72
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`YouTube, de-ranks both Yahoo and MSN, lists a very different and very dated
`YouTube video with dissimilar title in the 4th spot, and still avoids listing Rumble:
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`Figure 2
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`13. Amazingly, even though Rumble is the original source for this video,
`even though Google was aware of that fact, even though the search term was
`verbatim the title for the video as on Rumble’s platform, even though all sources
`point back to Rumble as the original content source, and even though the video was
`released to Google/YouTube last in time, the Google search results still listed
`YouTube’s platform first, and doesn’t list Rumble at all on its first page of search
`results, clearly evidencing Google’s self-preference of YouTube over competitors.
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 8 of 72
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`RUMBLE AND THE SERVICE IT PROVIDES
`FOR INDIVIDUAL CONTENT CREATORS
`14. Since 2013, Rumble has operated an online video platform. Today,
`Rumble is one of the most respected independent and privately owned companies in
`the online video platform industry and market, and its business model is premised
`upon helping the “little guy/gal” video content creators monetize their videos.
`15. Video content creators upload their copyright-protected videos to the
`Rumble platform (rumble.com or app), many of whom exclusively assign to
`Rumble the licensing and enforcement rights in the uploaded video. Rumble in turn
`makes these videos (“Rumble Videos”) available under license to other companies
`who have websites or other social media sites, and who want to make those videos
`available to visitors to their sites in order to generate advertising revenue.
`16. Since its launch in 2013, Rumble Videos have received approximately
`9.3 billion views worldwide just on YouTube alone according to YouTube’s
`Analytics.
`17. The original author (the content-creator) of the video should be
`compensated for the publication of his or her video. More often than not in the
`past, however, he or she was not. This is where Rumble came and comes into the
`picture.
`18. Rumble provides an important service to the untold number of “little
`guy/gal” videographers who create the video content that is uploaded to the
`internet, enjoyed by millions, and monetized by only a few. By themselves, these
`individual content-creators cannot effectively monetize their videos, even those that
`go “viral” and obtain millions of views within the first few days of being available
`online.
`19. Rumble provides a platform for those individual content-creators to
`monetize their copyrighted videos. By simply appointing Rumble as their exclusive
`licensee to their copyrighted video(s), and then uploading their video(s) to
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`Rumble’s platform, Rumble takes over and does all the rest. Rumble makes its
`portfolio of exclusively-licensed videos available to others to use for a fee (and a
`portion of the downstream revenue collected by the user), monitors that use,
`collects the fee (and revenue), and shares it with the content-creator. There are
`some individual content-creators who are receiving royalties in the 6-figures
`annually, and many that are receiving annual 5-figure royalties from Rumble.
`20. Rumble’s platform and proprietary software sources, validates,
`provides clearance management, distribution and monetization for video content.
`It is a content-creator-centric platform, whose main goal and core business model
`has always been to help video creators increase distribution and monetize their
`videos. Rumble allows video creators to create channels, host, share, monetize and
`distribute their video content from one centralized account on the Rumble platform.
`21. Rumble has working relationships with some of the most respected
`video creators, and Rumble licenses video content through its revenue-share video
`player and, if licenses permit, through other video players to many very well-known
`websites, including some of the largest and most well-known companies and
`websites in the world.
`22. Rumble currently has more than 2 million amateur and professional
`video content-creators that now contribute to more than 100 million streams per
`month. Some of the top video content-creators use Rumble’s platform. Rumble’s
`creator-centric platform has enabled more of these amateur and professional video
`content-creators, media companies, and celebrities to distribute and monetize their
`social videos more than ever before.
`23. Rumble’s success, however, has been far less than it could and should
`have been as a direct result of Google’s unlawful anticompetitive, exclusionary and
`monopolistic behavior, and coincided with Google’s unlawful rise to monopoly
`prominence in the search engine market as detailed in the recently filed case United
`States of America et. al. v. Google LLC, Case 1:20-cv-03010, Document No. 1,
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 10 of 72
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`10/20/2020 (D.D.C.) (“the DOJ Complaint”). Using that ill-gotten prominence,
`Google promoted YouTube to the exclusion of other online video platforms,
`including specifically Rumble, to obtain and maintain an unlawfully-achieved
`monopoly in that market as well.
`24. When video content creators upload their videos to Rumble’s platform,
`those videos are then available for viewing on Rumble’s website, generating
`advertising revenue. Unlike most video platforms, Rumble obtains an exclusive
`license for many of the uploaded videos. Even though Rumble has the exclusive
`license to these videos, because of the monopoly Google has obtained for its
`YouTube platform through its unlawful anti-competitive conduct, Rumble must
`syndicate its exclusive videos to YouTube in order to survive. Notably, other video
`platforms do not have a large exclusive catalog to syndicate. Rather, their revenue
`depends on non-exclusive licenses for the videos uploaded by their creators – the
`same way YouTube operates. Those other video platforms solely depend on
`growth from search traffic to their non-exclusively uploaded videos, which they
`will monetize.
`25. Google’s conduct in this regard has not only harmed Rumble, but also
`other similarly situated online video platforms throughout the world, who have
`been deprived of the views, users, uploads, traffic and brand awareness needed to
`survive and prosper. As testament to this fact, since Google purchased YouTube in
`2006, the number of competitive video platforms has dwindled dramatically as
`other platforms were not able to survive as a direct result of Googles’ unlawful and
`exclusionary conduct.
`Indeed, the extensive unlawful and exclusionary tactics and willful
`26.
`misconduct as meticulously detailed in the DOJ Complaint (and also herein) expose
`the many ways in which Google illegally achieved and now maintains monopoly
`power in the internet search engine market, and equally expose Google’s game
`plan, mindset and goal that have motivated it to do so across the entire expanse of
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`its empire, including the relevant market here. Google has executed that illegal
`game plan to near perfection to achieve and maintain a monopoly in the online
`video platform market, and thereby to achieve a monopolist’s profits and to drive
`out meaningful competition, to the great disadvantage and damage to Rumble (and
`the content creators for its exclusive videos) and to competition in the online video
`platform market.
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`GOOGLE’S UNLAWFUL ANTICOMPETITIVE CONDUCT
`27. Google has willfully and unlawfully created and maintained a
`monopoly in the online video platform market by pursuing at least two
`anticompetitive and exclusionary strategies. First, by manipulating the algorithms
`(and/or other means and mechanisms) by which searched-for-video results are
`listed, Google insures that the videos on YouTube are listed first, and that those of
`its competitors, such as Rumble, are listed way down the list on the first page of the
`search results, or not on the first page at all. Second, by pre-installation of the
`YouTube app (which deters smart phone manufacturers from pre-installing any
`competitive video platform apps) as the default online video app on Google smart
`phones, and by entering into anti-competitive, illegal tying agreements with other
`smartphone manufacturers to do the same (in addition to requiring them to give the
`YouTube app a prime location on their phones’ opening page and making it not-
`deletable by the user), Google assures the dominance of YouTube and forecloses
`competition in the video platform market.
`28. Google’s first anticompetitive and exclusionary strategy has been
`recently confirmed and reported in the Wall Street Journal:
`When choosing the best video clips to promote from around the web,
`Alphabet Inc.’s Google gives a secret advantage to one source in
`particular: itself.
`Or, more specifically, its giant online-video service, YouTube.
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`Take a clip of basketball star Zion Williamson that the National
`Basketball Association posted online in January, when he made his
`highly anticipated pro debut. The clip was popular on Facebook Inc.,
`drawing more than one million views and nearly 900 comments as of
`March. A nearly identical YouTube version of the clip with the same
`title was seen about 182,000 times and garnered fewer than 400
`comments.
`But when The Wall Street Journal’s automated bots searched Google
`for the clip’s title, the YouTube version featured much more
`prominently than the Facebook version.
`The Journal conducted Google searches for a selection of other videos
`and channels that are available on YouTube as well as on competitors’
`platforms. The YouTube versions were significantly more prominent
`in the results in the vast majority of cases.
`This isn’t by accident.
`Engineers at Google have made changes that effectively preference
`YouTube over other video sources, according to people familiar with
`the matter. Google executives in recent years made decisions to
`prioritize YouTube on the first page of search results, in part to drive
`traffic to YouTube rather than to competitors, and also to give
`YouTube more leverage in business deals with content providers
`seeking traffic for their videos, one of those people said.
`“All else being equal, YouTube will be first,” the person said.
`Reprinted from article entitled “Searching for Videos? Google Pushes YouTube
`Over Rivals”, The Wall Street Journal, by Sam Schechner, Kirsten Grind and John
`///
`///
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 13 of 72
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`West, posted online July 14, 2020 at 12:47 pm EDT (“the WSJ Article”).1
`29. Similarly, a Report issued by the House of Representatives also found
`that Google has engaged in the unlawful anti-competitive self-preferencing activity:
`Although these four corporations [including Google] differ in
`important ways, studying their business practices has revealed
`common problems. First, each platform now serves as a gatekeeper
`over a key channel of distribution. By controlling access to markets,
`these giants can pick winners and losers throughout our economy.
`They not only wield tremendous power, but they also abuse it by
`charging exorbitant fees, imposing oppressive contract terms, and
`extracting valuable data from the people and businesses that rely on
`them. Second, each platform uses its gatekeeper position to maintain
`its market power. By controlling the infrastructure of the digital age,
`they have surveilled other businesses to identify potential rivals, and
`have ultimately bought out, copied, or cut off their competitive
`threats. And, finally, these firms have abused their role as
`intermediaries to further entrench and expand their dominance.
`Whether through self- preferencing, predatory pricing, or
`exclusionary conduct, the dominant platforms have exploited
`their power in order to become even more dominant.
`To put it simply, companies that once were scrappy,
`underdog startups that challenged the status quo have become
`the kinds of monopolies we last saw in the era of oil barons and
`railroad tycoons. Although these firms have delivered clear benefits
`to society, the dominance of Amazon, Apple, Facebook, and Google
`
`1 https://www.wsj.com/articles/google-steers-users-to-youtube-over-rivals-
`11594745232.
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 14 of 72
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`has come at a price. These firms typically run the marketplace
`while also competing in it—a position that enables them to write
`one set of rules for others, while they play by another, or to
`engage in a form of their own private quasi regulation that is
`unaccountable to anyone but themselves.2
`30. The House Report also included a section that was especially damning
`as to Google’s conduct at issue here:
`In July, the Wall Street Journal reported that Google also gives
`preferential treatment to YouTube. Tests conducted by the Journal
`found that searching Google for videos delivered YouTube in results
`much more prominently than competing video providers, even when
`competitor videos had more engagement. Reflecting interviews with
`those familiar with the matter, the piece stated that Google engineers:
`[M]ade changes that effectively preference YouTube over
`other video sources. Google executives in recent years made
`decisions to prioritize YouTube on the first page of search results,
`in part to drive traffic to YouTube rather than to competitors,
`and also to give YouTube more leverage in business deals with
`content providers seeking traffic for their videos.”
`In response to Questions for the Record from Subcommittee
`Chairman David N. Cicilline (D-RI), the company denied that Google
`
`
`2 Report entitled Investigation of Competition in Digital Markets, Majority Staff
`Report and Recommendations, released on October 6, 2020, by the United States
`Congress, House of Representatives, Subcommittee on Antitrust, Commercial and
`Administrative Law of the Committee on the Judiciary (“the House Report”), pages
`6-7 (emphasis added).
`
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 15 of 72
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`Search is designed to favor YouTube. Although Google stated that it
`disagreed with the methodology used by the Journal, Google did
`not provide the Subcommittee with any data or internal reports
`that would support its claim.3
`31. Google did not provide the Subcommittee with any such refuting data
`or internal reports because it could not do so – the statements made in the WSJ
`Article are true, which Rumble has confirmed through its own tests as detailed in
`this First Amended Complaint. Significantly, it appears that Google’s denials were
`part and parcel of its ongoing attempt to conceal its unlawful anticompetitive and
`exclusionary behavior.
`32. Google has engaged and continues to engage in this unlawful conduct
`which has proximately caused and continues to cause tremendous damage to
`Rumble (and to others seeking to compete in the online video platform market), to
`competition and to consumers.
`In this regard, the House Report also includes this relevant section,
`33.
`which addresses one of the ways that Google’s unlawful anti-competitive conduct
`injures its competitors:
`Numerous market participants noted that Google’s favoring
`of its own sites and demoting those of third parties has
`effectively increased their cost of distribution. Since demoted
`sites can generally only recover traffic through advertising on
`Google, the platform “essentially requires competitors to pay for
`their websites to appear above Google’s own links,” according
`to one market participant. Another business recalled that in 2016
`Google demoted one of its vertical offerings, citing a policy of
`diversifying content. The firm stated that once it was penalized
`
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`3 The House Report, page 191 (emphasis added) (footnotes omitted).
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`BURKE, WILLIAMS &
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 16 of 72
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`in organic rankings, it “could not get an appropriate customer
`service response for months” and ultimately “had to increase
`[marketing spend on Google] to regain lost traffic—a win-win
`for Google but a loss for [our business] and its users.
`Meanwhile, Google’s own competing vertical “is always
`listed at the top” of search results. The incident highlights
`how demoting rivals can enrich Google in two ways: first,
`through diverting greater traffic and business to its own
`products; and second, through earning ad revenues from the
`penalized sites that are subsequently scrambling to recover
`their search placement. When demoting firms that Google
`views as actual or potential competitive threats, Google is
`effectively raising rivals’ costs.4
`34. The second way Google has unlawfully achieved, expanded,
`maintained and continues to maintain its monopoly in the online video platform
`market is to ensure that its YouTube app is preinstalled on as many new
`smartphones as possible. This anticompetitive and exclusionary conduct has also
`been recently reported:
`Google's apps are front-and-center on newer Android phones
`for a reason: Google wants you to use its services on Android,
`and it has contracts in place to that end.
`According to confidential contracts obtained by The
`Information, phonemakers like Samsung and HTC need to
`include a whole lot of Google-branded widgets and icons to be
`allowed to include Google's Play Store. The requirements in the
`
`
` 4 The House Report, pages 191-192 (emphasis added) (footnotes omitted).
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`BURKE, WILLIAMS &
`SORENSEN, LLP
`ATTO RN EY S AT LAW
`LOS A NG EL ES
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`Case 4:21-cv-00229-HSG Document 21 Filed 04/30/21 Page 17 of 72
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`contracts show that Google is demanding cushier placement for
`its apps and services than it used to.
`One requirement: Phones need to show a "Google" icon that
`opens to a collection of 13 apps. Some are genuinely useful,
`like YouTube, Google Maps, Google Drive, Gmail, and Google
`Chrome.5
`35. This unlawful antic