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Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 1 of 144
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`Stephen Geary (SBN 172875)
`Assistant Attorney General
`UTAH OFFICE OF THE ATTORNEY GENERAL
`160 East 300 South, Sixth Floor
`Salt Lake City, Utah 84114
`Telephone: (801) 366-0100
`E-Mail: swgeary@agutah.gov
`
`David N. Sonnenreich (USB No. 4917)
`dsonnenreich@agutah.gov
`Brian Christensen (USB No. 12059)
`bchristensen1@agutah.gov
`Scott R. Ryther (USB No. 5540)
`sryther@agutah.gov
`UTAH OFFICE OF THE ATTORNEY GENERAL
`160 East 300 South, Fifth Floor
`P.O. Box 140874
`Salt Lake City, UT 84114
`Telephone: (801) 366-0375
`(Applications for Pro Hac Vice Pending)
`Attorneys for Plaintiff State of Utah
`(Additional Counsel on Signature Page)
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
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`STATE OF UTAH
`160 E 300 S, 5th Floor
`P.O. Box 140872
`Salt Lake City, UT 84114
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`STATE OF NEW YORK
`28 Liberty Street
`New York, NY 10005
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`STATE OF NORTH CAROLINA
`P.O. Box 629
`Raleigh, NC 27602
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`STATE OF TENNESSEE
`P.O. Box 20207
`Nashville, TN 37202
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`Case No. 3:21-cv-05227
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 2 of 144
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`STATE OF ARIZONA
`2005 North Central Avenue
`Phoenix, AZ 85004
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`STATE OF COLORADO
`1300 Broadway, 7th Floor
`Denver, CO 80203
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`STATE OF IOWA
`1305 E. Walnut St., 2nd Floor
`Des Moines, IA 50319
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`STATE OF NEBRASKA
`2115 Nebraska State Capitol
`Lincoln, NE 68509-8920
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`STATE OF ALASKA
`1031 W. Fourth Avenue, Suite 200
`Anchorage, AK 99501
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`STATE OF ARKANSAS
`323 Center Street, Suite 200
`Little Rock, AR 72201
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`STATE OF CALIFORNIA
`455 Golden Gate Ave, Suite 11000
`San Francisco, CA 94102
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`STATE OF CONNECTICUT
`165 Capitol Avenue
`Hartford, CT 06106
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`STATE OF DELAWARE
`820 N. French St., 5th Floor
`Wilmington, DE 19801
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`DISTRICT OF COLUMBIA
`400 6th Street, N.W, 10th Floor
`Washington, D.C. 20001
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`STATE OF FLORIDA
`PL-01, The Capitol
`Tallahassee, FL 32399
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 3 of 144
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`STATE OF IDAHO
`954 W. Jefferson Street, 2nd Floor
`P.O. Box 83720
`Boise, ID 83720
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`STATE OF INDIANA
`302 West Washington Street
`IGCS – 5th Floor
`Indianapolis, IN 46204
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`COMMONWEALTH OF KENTUCKY
`1024 Capital Center Drive, Suite 200
`Frankfort, KY 40601
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`STATE OF MARYLAND
`200 St. Paul Place, 19th Floor
`Baltimore, MD 21202
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`COMMONWEALTH OF
`MASSACHUSETTS
`One Ashburton Place, 18th Fl.
`Boston, MA 02108
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`STATE OF MINNESOTA
`445 Minnesota Street, Suite 1400
`St. Paul, MN 55101
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`STATE OF MISSISSIPPI
`P.O. Box 220
`Jackson, MS 39205
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`STATE OF MISSOURI
`P.O. Box 899
`Jefferson City, MO 65102
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`STATE OF MONTANA
`P.O. Box 200151
`Helena, MT 59620
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`STATE OF NEVADA
`100 N. Carson St.
`Carson City, NV 89701
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`STATE OF NEW HAMPSHIRE
`33 Capitol Street
`Concord, NH 03301
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 4 of 144
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`STATE OF NEW JERSEY
`124 Halsey Street, 5th Floor
`Newark, NJ 07102
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`STATE OF NEW MEXICO
`408 Galisteo St.
`Santa Fe, NM 87504
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`STATE OF NORTH DAKOTA
`1050 E Interstate Ave, Ste 200
`Bismarck, ND 58503-5574
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`STATE OF OKLAHOMA
`313 NE 21st St
`Oklahoma City, OK 73105
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`STATE OF OREGON
`1162 Court St NE
`Salem, OR 97301
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`STATE OF RHODE ISLAND
`150 South Main Street
`Providence, RI 02903
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`STATE OF SOUTH DAKOTA
`1302 E. Hwy. 14, Suite 1
`Pierre, SD 57501
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`COMMONWEALTH OF VIRGINIA
`202 North 9th Street
`Richmond, VA 23219
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`STATE OF VERMONT
`109 State Street
`Montpelier, VT 05609
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`STATE OF WASHINGTON
`800 Fifth Ave., Suite 2000
`Seattle, WA 98104
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`STATE OF WEST VIRGINIA
`812 Quarrier St., First Floor
`P.O. Box 1789
`Charleston, WV 25326
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 5 of 144
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`Plaintiffs,
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`v.
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`GOOGLE LLC, GOOGLE IRELAND
`LIMITED, GOOGLE COMMERCE LIMITED,
`GOOGLE ASIA PACIFIC PTE. LIMITED,
`GOOGLE PAYMENT CORP., and ALPHABET
`INC.,
`
`
`Defendants.
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 6 of 144
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`TABLE OF CONTENTS
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`COMPLAINT ................................................................................................................................. 9
`NATURE OF THIS ACTION ........................................................................................................ 9
`JURISDICTION, PARTIES, AND VENUE ................................................................................ 16
`FACTUAL ALLEGATIONS ....................................................................................................... 19
`I. Google Unlawfully Maintains its Monopoly in the Market for Android App
`Distribution ....................................................................................................................... 19
`A. Google Has a Monopoly in the Market for Licensable Mobile Operating Systems .... 19
`B. Google Monopolizes the Market for Android App Distribution.................................. 21
`1. The Market for Android App Distribution Is a Relevant Antitrust Market ............ 22
`2. The Relevant Geographic Market is the United States ........................................... 26
`3. Google Has Monopoly Power in the Android App Distribution Market ................ 26
`C. Google Closes the Android App Distribution Market to Competitors......................... 27
`1. Google Imposes Technical Barriers to Effectively Prevent Third Parties from
`Distributing Apps Outside the Google Play Store ................................................ 27
`2. Google Uses Contracts to Prevent OEMs from Circumventing Technical Barriers 35
`3. Google Uses Contracts to Block Competing App Stores from Distribution on the
`Play Store .............................................................................................................. 36
`4. Google Unlawfully Ties Advertising with Google App Campaigns to the Google
`Play Store .............................................................................................................. 37
`D. Google Uses Exclusionary Contracts to Foreclose Competing App Distribution
`through Pre-Installation ............................................................................................. 38
`1. Google Forces OEMs to enter MADAs that Effectively Block the Entry of
`Competing App Stores .......................................................................................... 39
`a. Google Forces OEMs to Enter MADAs .......................................................... 39
`b. Google’s MADAs Discourage the Entry of Competing App Stores ............... 40
`2. Google Shares its Monopoly Profits with OEMs and MNOs to Disincentivize the
`Entry of Competing App Stores ............................................................................ 42
`E. Google Disincentivizes the Creation of Competing App Stores with Payments to
`and Restrictive Contracts with Potential Competitors ............................................... 44
`
`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 7 of 144
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`1. Google Offered to Buy Off Samsung to Keep It from Developing Its Competing
`App Store .............................................................................................................. 44
`2. Google Bought Off Key App Developers to Stifle Competition in the Android App
`Distribution Market ............................................................................................... 49
`F. Anticompetitive Effects in the Android App Distribution Market .............................. 51
`II. Google Has Unlawfully Maintained a Monopoly in the Android In-App Payment
`Processing Market ............................................................................................................. 53
`A. Google Has Unlawfully Tied Google Play Billing to the Google Play Store .............. 53
`B. Google Uses Its Unlawful Tie to Maintain its Monopoly in the IAP Processing
`Market ........................................................................................................................ 55
`1. The IAP Processing Market is a Relevant Antitrust Market ................................... 55
`2. The Relevant Geographic Market for IAP Processing is the United States ............ 58
`3. Google Has Monopoly Power in the IAP Processing Market ................................. 58
`4. Google’s IAP Processing Tie is Not Necessary to Incentivize its Investment in the
`Play Store or Android ........................................................................................... 59
`C. The Origin and Rates of Google’s Supracompetitive Commission Illustrate that
`Google Sets Prices at Will ......................................................................................... 60
`D. Google’s IAP Processing Monopoly Harms Competing Streaming and Other
`Subscription Services ................................................................................................. 61
`E. Google’s Unlawful Tie Has Led to Anticompetitive Effects in the IAP Processing
`Market ........................................................................................................................ 64
`III. Google is Engaging in Unfair and Deceptive Conduct that Harms Consumers ............... 68
`A. Google’s False or Misleading Statements About Sideloading Apps Constitute
`Unfair and Deceptive Conduct .................................................................................. 69
`B. Google’s False or Misleading Statements About “Openness” Constitute Unfair
`and Deceptive Conduct .............................................................................................. 71
`C. Google’s Statements and Conduct Regarding Google Play Billing Constitute
`Unfair and Deceptive Conduct .................................................................................. 73
`VIOLATIONS ALLEGED ........................................................................................................... 76
`First Cause of Action: Sherman Act § 2 Monopoly Maintenance in the Android App
`Distribution Market ................................................................................................... 76
`Second Cause of Action: Sherman Act § 1 Unreasonable Restraints of Trade
`Concerning the Android App Distribution Market: OEMs ....................................... 77
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 8 of 144
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`Third Cause of Action: Sherman Act § 1 Unreasonable Restraints of Trade
`Concerning the Android App Distribution Market: App Developers ....................... 79
`Fourth Cause of Action: Sherman Act § 1 Unlawful Tying of Google Play Billing to
`Use of Google Play Store .......................................................................................... 81
`Fifth Cause of Action: Sherman Act § 2 Monopoly Maintenance in the In-App
`Payment Processing Market ...................................................................................... 83
`Sixth Cause of Action: Sherman Act § 1 Unreasonable Restraints of Trade in the In-
`App Payment Processing Market............................................................................... 84
`Seventh Cause of Action: Sherman Act § 1 Unlawful Exclusive Dealing in the In-
`App Payment Processing Market............................................................................... 86
`Eighth Cause of Action: State-Specific Claims ................................................................ 89
`PRAYER FOR RELIEF ............................................................................................................. 128
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 9 of 144
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`COMPLAINT
`The States, Commonwealths, and Districts of Utah, New York, North Carolina,
`1.
`Tennessee, Arizona, Colorado, Iowa, Nebraska, Alaska, Arkansas, California, Connecticut,
`Delaware, District of Columbia, Florida, Idaho, Indiana, Kentucky, Maryland, Massachusetts,
`Minnesota, Mississippi, Missouri, Montana, Nevada, New Hampshire, New Jersey, New
`Mexico, North Dakota, Oklahoma, Oregon, Rhode Island, South Dakota, Virginia, Vermont,
`Washington, and West Virginia, by and through their respective Attorneys General, bring this
`civil enforcement action against Defendants Google LLC, Google Ireland Limited, Google
`Commerce Limited, Google Asia Pacific Pte. Limited, Google Payment Corp., and Alphabet Inc.
`(collectively, “Google”) under federal and state antitrust and consumer protection statutes, to
`enjoin Google from unlawfully restraining trade and maintaining monopolies in the markets for
`Android software application (“app”) distribution and for payment processing of digital content
`purchased within Android apps in the United States, and to obtain redress for consumers.
`NATURE OF THIS ACTION
`Google acquired the Android mobile operating system (“Android”) in 2005.
`2.
`Google promised repeatedly that Android would be the basis for an “open” ecosystem in which
`industry participants could freely compete, and, in Google’s words, have
` Google has not kept its word.
`Instead, Google has taken steps to close the ecosystem from competition and
`3.
`insert itself as the middleman between app developers and consumers. Unbeknownst to most
`consumers who own a mobile device running Android, every time they purchase an app from the
`Google Play Store, or purchase digital content or subscriptions within an app, up to 30% of the
`money they pay goes to Google.
`To collect and maintain this extravagant commission, Google has employed
`4.
`anticompetitive tactics to diminish and disincentivize competition in Android app distribution.
`Google has not only targeted potentially competing app stores, but also has ensured that app
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 10 of 144
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`developers themselves have no reasonable choice but to distribute their apps through the Google
`Play Store.
`Google did not stop at excluding potential threats to its app distribution monopoly
`5.
`and extracting monopoly rents for app distribution. Google also ensured it could continue to reap
`windfall commissions from apps after the Google Play Store distributed them to consumers—
`often months or even years later. Namely, Google imposed the same extravagant commission of
`up to 30% of any future digital purchase a consumer might make within an app. For all apps that
`consumers obtain from the Google Play Store, Google requires that consumers purchase any in-
`app digital content through Google Play Billing. By imposing this unduly restrictive and
`anticompetitive tie, Google can indefinitely collect supracompetitive commissions from
`consumers who purchase in-app digital content.
`Mobile devices, including smartphones and tablets, are essential tools in
`6.
`contemporary American life.1 They are indispensable to consumers for personal communication,
`as well as for access to and participation in the modern economy. What makes a mobile device
`“smart” are the myriad apps that can run on the device and are compatible with its mobile
`operating system. U.S. consumers now spend more time using mobile devices than they do
`desktop computers, laptop computers, or televisions. Mobile internet usage is rising while
`desktop internet usage continues to fall, and U.S. consumers spend nearly 90% of their mobile
`internet time within apps instead of mobile browsers. They also spend over $32 billion a year
`purchasing apps and digital content within apps. App developers likewise invest hundreds of
`millions of dollars to build and distribute apps for mobile devices.
`Android is the only viable operating system available to license by mobile device
`7.
`manufacturers that market and sell their devices to U.S. consumers. The barriers to entry in the
`licensable mobile operating system market are high, and even highly resourced entrants, such as
`
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`1 As used herein, “mobile device” means a “smart” mobile device that has multi-purpose
`computing functionality; can connect wirelessly to the internet; has a large graphical user
`interface (as compared to “feature phones” common in past decades) which is often accessed
`through a touch-capacitive screen; and is optimized to run third-party mobile apps.
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 11 of 144
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`Microsoft and Amazon, have failed. Google, which controls approximately 99% of this market,
`has durable monopoly power in the market and considerable leverage over mobile device
`manufacturers and Android app developers.
`In the absence of Google’s anticompetitive conduct, there would be two main
`8.
`channels for U.S. consumers to obtain apps on an open Android operating system: (i) direct
`downloading and installation of apps or app stores; and (ii) apps or app stores pre-installed on
`devices by device manufacturers and/or mobile network operators.
`But Google has closed off its purportedly “open” Android operating system from
`9.
`competition in app distribution. To accomplish this, Google degraded direct distribution
`channels, and then cut deals to discourage and disincentivize any remaining potential
`competition.
`Through its Google Play Store, Google maintains a monopoly in the market for
`10.
`distributing Android apps. Google Play Store distributes over 90% of all Android apps in the
`United States. No competing Android app store has more than 5% of the market.
`Google also requires all app developers that sell content through the Google Play
`11.
`Store to sell any digital in-app content through Google Play Billing. Though it has been
`inconsistent in the past, Google now stringently enforces this tie by preventing apps distributed
`through the Google Play Store from using, directing consumers to, or even informing consumers
`about alternative payment processing options that may provide lower prices. Consumers who
`want to purchase any such content must, therefore, do so through Google Play Billing. This
`illegal tie gives Google an additional monopoly in the market for Android in-app payment
`processing for digital products.2 Google has not yet extended its tie to in-app purchases of
`physical goods and services and requires the use of an alternative payment provider.
`
`2 Consumers who purchase apps or in-app digital content from the Google Play Store pay Google
`directly. From that purchase price, Google takes up to 30%, and transfers the remaining revenue
`to the app developer. See Google Pay Help, GOOGLE,
`https://support.google.com/paymentscenter/answer/7159343?hl=en (“The transaction fee for all
`purchases in Google Play (apps and in-app purchases) is 30% of the price the customer pays. In
`other words, developers get 70% of the payment and the remaining 30% goes to the distribution
`partner and operating fees.”).
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 12 of 144
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`Accordingly, “in-app purchases” as used herein refers to purchases of digital content, not those
`of physical goods and services.
`Google has steadily expanded its illegal tie: effective September 2021,
`12.
`subscription streaming services for music and video—which Google previously exempted—must
`either submit to Google’s tie or deny consumers the ability to purchase subscriptions from their
`Android apps. Google’s comparable streaming services will gain an enormous competitive
`advantage. Moreover, the non-Google payment processors that these services currently use will
`be forced out of the in-app payment (“IAP”) market as to these services. Google has also
`recently expanded the enforcement of its illegal tie to subscription services including those on
`job search, dating, fitness, and other apps.
`Google’s anticompetitive conduct harms consumers and app developers, both at
`13.
`the point of app distribution and when a consumer later purchases in-app digital products.
`Consumers are direct purchasers of apps in the Google Play Store. Consumers are harmed
`because Google forces them to pay a supracompetitive commission of up to 30% to purchase any
`non-“free-to-download” app. Google’s anticompetitive conduct further harms consumers by
`depriving them of the potential benefits of true competition in app distribution, including better
`features or improved data security. App developers also suffer from Google’s anticompetitive
`conduct. Developers lose profits because potential customers may forgo purchases of existing
`apps in response to the higher prices caused by Google’s conduct. Moreover, Google’s
`supracompetitive commission impedes developers from researching, developing, and bringing to
`market innovative new apps, resulting in further lost profits for them and less innovation and
`choice for consumers.
`Consumers are likewise direct purchasers of in-app digital products using Google
`14.
`Play Billing. Because Google’s tie prevents their use of other payment processors for in-app
`purchases, consumers are harmed by paying Google’s supracompetitive commission of up to
`30%. Consumers are further harmed by the loss of competition among payment processors,
`which may offer substantially lower commissions, as well as enhanced payment features,
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 13 of 144
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`customer service, and data security. App developers are also harmed by Google’s tying conduct,
`which may cause some potential consumers to forgo in-app purchases, resulting in lost profits.
`Further, Google Play Billing disintermediates developers from their customers and prevents them
`from providing tailored customer service on critical customer interactions such as payment
`history and refund requests. And competition in payment processing—which is vibrant in other
`forms of online transactions and would be here but for Google’s tie—is completely foreclosed.
`As set forth below, Google’s durable monopoly power in the markets for Android
`15.
`app distribution and in-app purchases is not based on competition on the merits. These
`monopolies are maintained through artificial technological and contractual conditions that
`Google imposes on the Android ecosystem.
`Today, Google enjoys virtually unchallenged power over Android app distribution
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`and Android in-app purchases of digital content that extends to every state, district, and territory
`in the United States. Because of Google’s anticompetitive conduct, Google Play Store’s market
`share—which is well over 90%—faces no credible threats, and market forces cannot exert
`pressure on its supracompetitive commissions for app and in-app purchases. Google’s conduct
`has deterred new entry and/or prevented would-be competitors from achieving the scale that
`might constrain Google’s power.
`Over the years, Google has steadily expanded and refined the tactics it uses to
`17.
`impede competition in Android app distribution and in-app purchases. Instead of simply
`producing a better app distribution experience, Google uses anticompetitive barriers and
`mandates to protect its monopoly power and grow its supracompetitive revenue from the Google
`Play Store and Google Play Billing.
`This Complaint focuses on five categories of anticompetitive conduct through
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`which Google has obstructed competition in Android app distribution and in-app purchases.
`Google has no legitimate justification for any of this conduct.
`First, Google creates and imposes broad practical, technological, and contractual
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`impediments to effectively close the Android app distribution ecosystem. Google deters
`
`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 14 of 144
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`consumers from directly downloading and installing apps or app stores that might compete with
`the Google Play Store by, among other things, (a) imposing needlessly broad restrictions on
`direct downloading of apps and app stores, which Google calls “sideloading”; (b) using contracts
`with Android device manufacturers to prevent the manufacturers from modifying the operating
`system to circumvent the sideloading or code restrictions imposed by Google; (c) blocking
`competing app stores from distribution on the Play Store; and (d) preventing non-Play app stores
`and apps from purchasing advertising on key Google properties including YouTube and the
`Google search engine results page.
`Second, Google disincentivizes and discourages competition from the only market
`20.
`participants that could otherwise avoid the technological restrictions and be well-positioned to
`compete in app distribution—Android device manufacturers and mobile network operators.
`Google recognized these competitive threats and sought to eliminate them through a carrot-and-
`stick approach. The carrot is revenue share agreements that Google provides Android device
`manufacturers and mobile network operators—sharing Google’s monopoly rents and, thereby,
`disincentivizing or restricting them from attempting to create or foster a competing app store.
`The sticks are contracts that require Android device manufacturers to preload Google Play Store
`on the default home screen, render it undeletable from the device, and ensure that no other
`preloaded app store has a more prominent placement than the Google Play Store.
`Third, Google has focused its anticompetitive strategies on Samsung, the largest
`21.
`manufacturer of Android devices sold in the United States. Google has taken the extraordinary
`step of attempting to buy off Samsung to limit competition from the Samsung Galaxy app store
`by, among other things, offering incentives for Samsung to turn the Galaxy store into a mere
`“white label” for the Google Play Store—meaning that Samsung would use the backend services
`of the Google Play Store, including Google Play Billing, while retaining its Samsung Galaxy
`Store branding.
`Fourth, Google launched incentive programs to share monopoly profits with large
`22.
`app developers that might be capable of disrupting Google’s app distribution monopoly. Google
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`COMPLAINT
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 15 of 144
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`did so to prevent these large app developers from fostering their own app store or moving en
`masse to a competing app store like Samsung’s.
`Fifth, Google mandates that consumers who download apps from the Google Play
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`Store also use Google Play Billing for all in-app purchases. This unlawful tie effectively
`precludes an Android app consumer from purchasing additional digital content directly from the
`app developer or via the app developer’s chosen payment processing service; Google forces the
`consumer to continue doing business with it and to indefinitely pay Google’s supracompetitive
`commissions.
`In a more competitive environment, Google’s app distribution monopoly could be
`24.
`disrupted. Instead, because of Google’s exclusionary conduct, even Amazon, one of the biggest
`and most sophisticated content distributors, has tried but failed to create a competitive Android
`app store that could weaken Google’s app distribution monopoly through free and fair
`competition.
`In the absence of Google’s unlawful tying conduct—requiring essentially all
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`Android app customers to use Google Play Billing for in-app purchases of digital content—there
`would be vigorous competition in the Android in-app payment processing market, as exists in
`other payment processing markets. Google uses its durable monopoly power in the Android in-
`app payment processing market to extract a supracompetitive 30% commission from
`consumers—a figure over ten times greater than what other payment processors charge for
`purchases of non-digital goods through Android apps or for digital and non-digital goods on the
`internet.
`For these reasons, the Plaintiff States, by and through their Attorneys General,
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`bring this action to end Google’s anticompetitive conduct and the harm to the States, their
`economies, and their residents that has flowed, and continues to flow, from that conduct. Plaintiff
`States seek to restore competition and prevent Google from engaging in similar conduct in the
`future.
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`Case 3:21-cv-05227-JSC Document 1 Filed 07/07/21 Page 16 of 144
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`JURISDICTION, PARTIES, AND VENUE
`Plaintiff States, by and through their respective Attorneys General, bring this
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`action as the chief legal officers of their respective States. Federal and state competition and
`consumer protection laws authorize States to bring actions to protect the economic well-being of
`their States and obtain injunctive and other relief to redress harm caused by violations of those
`laws.
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`The Attorneys General appear in their respective sovereign or quasi-sovereign
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`capacities and under their respective statutory, common law, and equitable powers, and as parens
`patriae on behalf of natural persons residing in their respective States pursuant to § 4C of the
`Clayton Act, 15 U.S.C. § 15c.
`States have a quasi-sovereign interest in protecting residents from illegal
`29.
`anticompetitive conduct and the resulting ongoing economic harm. By preventing competition in
`the markets for Android app distribution and for payment processing of digital content purchased
`within Android apps in the United States, Google has deprived the Plaintiff States and their
`residents of the benefits of a competitive marketplace and harmed the economic well-being of
`each State’s residents.
`Google’s anticompetitive conduct has caused residents in each State to pay higher
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`prices for apps on Android devices and for Android in-app payments, which has constituted
`ongoing, actual financial losses and has diverted resources that could otherwise be directed
`toward other purposes to the benefit of each State. Consumers are also harmed because Google’s
`anticompetitive conduct deprives them of the potential benefits of true competition, including
`better services and improved data security. But for Google’s actions, other market participants
`could provide innovative alternatives in the relevant markets, to the benefit of each State’s
`economy and general prosperity.
`Due to the pervasiveness and vital importance of mobile devices, mobile
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`ecosystems, and apps, as alleged herein, Google’s anticompetitive conduct and the corresponding
`lack of competition in th

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