Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 1 of 38
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`Brian C. Rocca, S.B. #221576
`brian.rocca@morganlewis.com
`Sujal J. Shah, S.B. #215230
`sujal.shah@morganlewis.com
`Michelle Park Chiu, S.B. #248421
`michelle.chiu@morganlewis.com
`Minna Lo Naranjo, S.B. #259005
`minna.naranjo@morganlewis.com
`Rishi P. Satia, S.B. #301958
`rishi.satia@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`One Market, Spear Street Tower
`San Francisco, CA 94105
`Telephone: (415) 442-1000
`
`Richard S. Taffet, pro hac vice
`richard.taffet@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`101 Park Avenue
`New York, NY 10178
`Telephone: (212) 309-6000
`
`Ian Simmons, pro hac vice
`isimmons@omm.com
`Benjamin G. Bradshaw, S.B. #189925
`bbradshaw@omm.com
`O’MELVENY & MYERS LLP
`1625 Eye Street, NW
`Washington, DC 20006
`Telephone: (202) 383-5300
`Attorneys for Defendants
`
`Glenn D. Pomerantz, S.B. #112503
`glenn.pomerantz@mto.com
`Kuruvilla Olasa, S.B. #281509
`kuruvilla.olasa@mto.com
`MUNGER, TOLLES & OLSON LLP
`350 South Grand Avenue, Fiftieth Floor
`Los Angeles, California 90071
`Telephone: (213) 683-9100
`
`Kyle W. Mach, S.B. #282090
`kyle.mach@mto.com
`Justin P. Raphael, S.B. #292380
`justin.raphael@mto.com
`Emily C. Curran-Huberty, S.B. #293065
`emily.curran-huberty@mto.com
`Marianna Y. Mao, S.B. #318070
`marianna.mao@mto.com
`MUNGER, TOLLES & OLSON LLP
`560 Mission Street, Twenty Seventh Floor
`San Francisco, California 94105
`Telephone: (415) 512-4000
`
`Jonathan I. Kravis, pro hac vice
`jonathan.kravis@mto.com
`MUNGER, TOLLES & OLSON LLP
`601 Massachusetts Avenue NW, Suite 500E
`Washington, D.C. 20001
`Telephone: (202) 220-1100
`
`Daniel M. Petrocelli, S.B. #97802
`dpetrocelli@omm.com
`Stephen J. McIntyre, S.B. #274481
`smcintyre@omm.com
`O’MELVENY & MYERS LLP
`1999 Avenue of the Stars
`Los Angeles, California 90067
`Telephone: (310) 553-6700
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`
`
`
`
`IN RE GOOGLE PLAY STORE
`ANTITRUST LITIGATION
`
`THIS DOCUMENT RELATES TO:
`
`State of Utah et al. v. Google LLC et al., Case
`No. 3:21-cv-05227-JD
`
`
`
`
`Case No. 3:21-md-02981-JD
`DEFENDANTS’ ANSWERS AND
`DEFENSES TO STATE OF UTAH ET
`AL. COMPLAINT
`DEMAND FOR JURY TRIAL
`
`
`
`
`
`Case No. 3:21-cv-05227-JD
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`ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 2 of 38
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`
`INTRODUCTION
`Defendants Google LLC, Google Ireland Limited, Google Commerce Ltd., Google Asia
`Pacific Pte Ltd., Alphabet Inc., and Google Payment Corp. (collectively “Google”) answer
`Consumer Plaintiffs’ Consolidated First Amended Class Action Complaint, through its
`undersigned counsel, as set forth below.
`Android, Google’s open-source mobile operating system (“OS”), is a critical source of
`competition against other operating systems. This competition has brought tremendous benefits to
`developers and users. By providing Android to smartphone manufacturers for free, Google LLC
`has expanded access to smartphones and the marketplace for mobile apps, creating enormous
`incentives for developers to invest in apps that make virtually every sector of the economy more
`efficient, affordable and accessible for users. These benefits have typically come at little or no
`cost to smartphone manufacturers, developers or users. Google’s app store, Google Play, which
`works on Android, created an innovative channel for the distribution and use of software apps, and
`a leading source of critical competition to Apple’s iOS ecosystem and App Store. Android and
`Google Play have been widely embraced not because of anticompetitive conduct, but because
`users and developers prefer Google Play when given a choice among Android app stores and
`distribution channels. Android device manufacturers can choose to pre-install their own or third-
`party app stores on Android devices, right alongside Google Play, and over 60% of Android
`devices come with more than one app store pre-installed. And Android users are free to download
`apps and app stores directly from the Internet; millions do so every day.
`Far from generating anticompetitive harm, Android and Google Play bring enormous
`benefits to developers and users—and they do so at zero cost to users and minimal cost to
`developers, including the States, in the vast majority of cases. Plaintiff States’ suit threatens to
`undermine, rather than enhance, the very competition that has brought these benefits, and harm the
`same consumers the States purport to represent.
`RESPONSE TO NUMBERED PARAGRAPHS
`The section headings in the Complaint do not require a response. To the extent that the
`section headings contain allegations requiring a response, Google denies all such allegations.
`
`-2-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 3 of 38
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`Google denies the allegations in Paragraph 1, except admits that Plaintiffs purport
`1.
`to bring claims under Sections 1 and 2 of the Sherman Act and under state law.
`Google denies the allegations in Paragraph 2, except Google admits that Google
`2.
`LLC acquired the Android mobile operating system in 2005 and that Android is an open
`ecosystem that, at its core, has always been about openness, and respectfully refers the Court to
`the quoted documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 3, except admits that one or more
`3.
`defendants receive a payment for in-app purchases with respect to apps distributed through Google
`Play, and charges up to 30% as a service fee. Google avers that Google provides benefits to
`developers, including discoverability made possible by distribution, e-learning opportunities, free
`tools for developers to effectively build apps for Android devices, testing and monitoring tools,
`and a global digital payment infrastructure to enable developers to transact with users using the
`most effective payment methods regardless of where the developers or users are located. Google
`further avers that Google has enabled developers to create revenue streams for themselves.
`Google further avers that beginning on January 1, 2018, the service fee on subscriptions with
`respect to apps distributed through Google Play was reduced from 30% to 15% in the second year.
`Google further avers that beginning on July 1, 2021, the service fee was reduced to 15% for the
`first $1 million of revenue on digital goods or services every developer earns each year.
`Google denies the allegations in Paragraph 4.
`4.
`5.
`Google denies the allegations in Paragraph 5, except admits that Google users use
`Google Play Billing for in-app purchases with respect to apps distributed through Google Play
`with some exceptions, including purchasing physical goods and purchasing digital content
`elsewhere that is consumed within the app.
`Google admits the allegations in Paragraph 6, except that it lacks knowledge or
`6.
`information sufficient to form a belief as to the truth of the allegations in the last three sentences.
`Google denies the allegations in Paragraph 7.
`7.
`8.
`Google denies the allegations in Paragraph 8.
`9.
`Google denies the allegations in Paragraph 9.
`-3-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 4 of 38
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`Google denies the allegations in Paragraph 10.
`10.
`Google denies the allegations in Paragraph 11, except admits that Google Play
`11.
`Billing is required for in-app purchases of digital content on apps distributed through the Google
`Play Store, and admits that in-app purchases of physical products do not require Google Play
`Billing.
`Google denies the allegations in Paragraph 12.
`12.
`Google denies the allegations in Paragraph 13.
`13.
`Google denies the allegations in Paragraph 14.
`14.
`Google denies the allegations in Paragraph 15.
`15.
`Google denies the allegations in Paragraph 16.
`16.
`Google denies the allegations in Paragraph 17.
`17.
`Google denies the allegations in Paragraph 18.
`18.
`Google denies the allegations in Paragraph 19, except admits that the “direct
`19.
`downloading of apps and app stores” is sometimes called “sideloading,” and avers that multiple
`app stores and access points to apps exist, as users can and do multi-home in accessing apps.
`Google denies the allegations in Paragraph 20.
`20.
`21.
`Google denies the allegations in Paragraph 21.
`22.
`Google denies the allegations in Paragraph 22.
`23.
`Google denies the allegations in Paragraph 23, except admits that Google users use
`Google Play Billing for purchases through Google Play with some exceptions, including
`purchasing physical goods and purchasing digital content elsewhere that is consumed within the
`app.
`
`Google denies the allegations in Paragraph 24.
`24.
`Google denies the allegations in Paragraph 25.
`25.
`Google denies the allegations in Paragraph 26.
`26.
`The allegations in Paragraph 27 are legal conclusions not subject to admission or
`27.
`denial. To the extent a response is required, Google denies the allegations in Paragraph 27.
`
`
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`-4-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 5 of 38
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`The allegations in Paragraph 28 are legal conclusions not subject to admission or
`28.
`denial. To the extent a response is required, Google denies the allegations in Paragraph 28.
`Google denies the allegations in Paragraph 29.
`29.
`30.
`Google denies the allegations in Paragraph 30.
`31.
`Google denies the allegations in Paragraph 31 except admits that mobile device
`manufacturers, wireless carriers, and app developers utilize Android and distribute apps and that
`tens of millions of consumers choose Android-based smartphones in the United States.
`Google denies the allegations in Paragraph 32.
`32.
`33.
`Google denies the allegations in Paragraph 33.
`34.
`The allegations in Paragraph 34 consist of Plaintiffs’ characterizations of their
`purported claims and legal conclusions not subject to admission or denial and to which no
`response is required. To the extent any response is required, Google denies the allegations in
`Paragraph 34.
`Google denies the allegations in Paragraph 35, except admits that Google LLC is a
`35.
`limited liability company organized and existing under the laws of the State of Delaware with its
`principal place of business in Mountain View, California, and that Google LLC is a party to the
`Google Play Developer Distribution Agreement (“DDA”). Google further admits that Google
`LLC is a subsidiary of XXVI Holdings Inc., which is a Delaware corporation and a subsidiary of
`Alphabet Inc. Google further admits that Alphabet Inc. is a publicly traded company that is
`incorporated and existing under the laws of the State of Delaware and that maintains its principal
`executive offices in Mountain View, California. Google further admits that its products and
`services include Android OS, Chrome, Gmail, Drive, Maps, Google Play, Search YouTube,
`Google Cloud, and Search Ads 360.
`Google denies the allegations in Paragraph 36, except admits that Google Ireland
`36.
`Limited is organized under the laws of Ireland with its principal place of business in Dublin,
`Ireland, is a subsidiary of Google LLC, and is a party to the DDA.
`
`
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`-5-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 6 of 38
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`Google denies the allegations in Paragraph 37, except admits that Google
`37.
`Commerce Ltd. is organized under the laws of Ireland with its principal place of business in
`Dublin, Ireland and is a party to the DDA.
`Google denies the allegations in Paragraph 38, except admits that Google Asia
`38.
`Pacific Pte. Ltd. is organized under the laws of Singapore with its principal place of business in
`Mapletree Business City, Singapore, and is a party to the DDA.
`Google denies the allegations in Paragraph 39, except admits that Google Payment
`39.
`Corp. is a Delaware corporation with its principal place of business in Mountain View, California
`and is a subsidiary of Google LLC.
`Google denies the allegations of Paragraph 40, except admits that Alphabet Inc. is a
`40.
`Delaware corporation with its principal place of business in Mountain View, California.
`The allegations in the first sentence in Paragraph 41 are legal conclusions not
`41.
`subject to admission or denial. To the extent a response is required, Google does not dispute
`subject matter jurisdiction. Google admits the allegations in the second sentence in Paragraph 41.
`The allegations in Paragraph 42 are legal conclusions not subject to admission or
`42.
`denial. To the extent a response is required, Google does not dispute—for purposes of this action
`only—personal jurisdiction of this Court or the venue of this action.
`The allegations in Paragraph 43 are legal conclusions not subject to admission or
`43.
`denial. To the extent a response is required, Google does not dispute—for purposes of this action
`only—the venue of this action.
`Google admits the allegations in Paragraph 44.
`44.
`45.
`Google admits the allegations in Paragraph 45.
`46.
`Google denies the allegations in Paragraph 46, except admits the allegations in the
`first and last sentences.
`Google admits the allegations in Paragraph 47.
`47.
`48.
`Google denies the allegations in Paragraph 48, except admits that original
`equipment manufacturers (“OEMs”) frequently pre-install an OS on each mobile device.
`
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`-6-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 7 of 38
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`Google denies the allegations in Paragraph 49, except admits that most mobile
`49.
`device manufacturers do not develop their own OSs. Google is without knowledge or information
`sufficient to form a belief as to the truth of the allegations in Paragraph 49 about Apple.
`Google denies the allegations in Paragraph 50, except that Google is without
`50.
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`50 about Apple.
`Google denies the allegations in Paragraph 51.
`51.
`52.
`Google admits the allegations in Paragraph 52.
`53.
`Google denies the allegations in Paragraph 53, except admits that Google LLC
`acquired the Android mobile operating system in 2005.
`Google denies the allegations in Paragraph 54.
`54.
`55.
`Google denies the allegations in Paragraph 55, and avers that evidence shows that
`users can and do switch and multi-home among and between mobile and nonmobile ecosystems,
`including between Android and iOS.
`Google denies the allegations in Paragraph 56.
`56.
`57.
`Google denies the allegations in Paragraph 57.
`58.
`Google denies the allegations in Paragraph 58.
`59.
`Google denies the allegations in Paragraph 59.
`60.
`Google admits the allegations in Paragraph 60, except that Google is without
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`84 about why consumers typically obtain additional applications.
`Google denies the allegations in Paragraph 61, except admits the allegations in the
`61.
`second sentence.
`Google denies the allegations in Paragraph 62.
`62.
`63.
`Google denies the allegations in Paragraph 63.
`64.
`Google denies the allegations in Paragraph 64, except admits that the “direct
`downloading of apps by consumers without using an app store” is sometimes called “sideloading,”
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`-7-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 8 of 38
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`and avers that multiple app stores and access points to apps exist, as users can and do multi-home
`in accessing apps.
`Google denies the allegations in Paragraph 65.
`65.
`66.
`Google denies the allegations in Paragraph 66, and avers that evidence shows that
`users can and do switch and multi-home among and between mobile and nonmobile ecosystems,
`including between Android and iOS.
`Google denies the allegations in Paragraph 67.
`67.
`68.
`Google denies the allegations in Paragraph 68.
`69.
`Google denies the allegations in Paragraph 69, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`Google denies the allegations in Paragraph 70.
`70.
`71.
`Google denies the allegations in Paragraph 71.
`72.
`Google denies the allegations in Paragraph 72.
`73.
`Google denies the allegations in Paragraph 73.
`74.
`Google denies the allegations in Paragraph 74.
`75.
`Google denies the allegations in Paragraph 75.
`76.
`Google denies the allegations in Paragraph 76, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 77, except admits that consumers can
`77.
`download apps on Android devices from competing app stores or through sideloading.
`Google denies the allegations in Paragraph 78.
`78.
`79.
`Google denies the allegations in Paragraph 79, except that Google admits that
`Google LLC owns Android OS.
`Google denies the allegations in Paragraph 80, and respectfully refers the Court to
`80.
`the cited document for a complete and accurate statement of its contents.
`Google denies the allegations in Paragraph 81, and respectfully refers the Court to
`81.
`the cited documents for a complete and accurate statement of their contents.
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`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 9 of 38
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`Google denies the allegations in Paragraph 82, and respectfully refers the Court to
`82.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 83, and respectfully refers the Court to
`83.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 84, except that Google is without
`84.
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`84 about what Amazon has said.
`Google denies the allegations in Paragraph 85, and respectfully refers the Court to
`85.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 86, and respectfully refers the Court to
`86.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 87, and respectfully refers the Court to
`87.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 88, and respectfully refers the Court to
`88.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 89, and respectfully refers the Court to
`89.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 90.
`90.
`91.
`Google denies the allegations in Paragraph 91, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 92, except admits that Android 12
`92.
`includes modifications related to third-party app stores and that in certain instances sideloaded
`apps do not automatically update in the background on the Android OS. Google is without
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`92 about what Amazon has said.
`Google denies the allegations in Paragraph 93.
`93.
`94.
`Google denies the allegations in Paragraph 94, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
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`-9-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 10 of 38
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`Google denies the allegations in Paragraph 95, and respectfully refers the Court to
`95.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 96, except admits that Aptoide was
`96.
`flagged as “harmful.”
`Google denies the allegations in Paragraph 97, except that Google admits the
`97.
`existence of Portuguese litigation involving Aptoide, and that Google is without knowledge or
`information sufficient to form a belief as to the truth of the allegations in the first sentence about
`the findings of the purported “independent study.”
`Google denies the allegations in Paragraph 98, and respectfully refers the Court to
`98.
`the cited documents for a complete and accurate statement of their contents.
`Google denies the allegations in Paragraph 99.
`99.
`100. Google denies the allegations in Paragraph 100.
`101. Google denies the allegations in Paragraph 101, except admits that one or more
`defendants have entered into agreements with OEMs and respectfully refers the Court to the cited
`documents for a complete and accurate statement of their contents.
`102. Google denies the allegations in Paragraph 102, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`103. Google denies the allegations in Paragraph 103, except admits that developers are
`generally required to enter into the DDA to distribute apps through Google Play. Google further
`admits that DDA, Section 4.5 states, “You may not use Google Play to distribute or make
`available any Product that has a purpose that facilitates the distribution of software applications
`and games for use on Android devices outside of Google Play.” Google respectfully refers the
`Court to the cited documents for a complete and accurate statement of their contents.
`104. Google denies the allegations in Paragraph 104, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`105. Google denies the allegations in Paragraph 105, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
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`-10-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`106. Google denies the allegations in Paragraph 106, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`107. Google denies the allegations in Paragraph 107.
`108. Google denies the allegations in Paragraph 108, except admits that one or more
`defendants offer an App Campaigns program, and respectfully refers the Court to the cited
`documents for a complete and accurate statement of their contents.
`109. Google denies the allegations in Paragraph 109.
`110. Google denies the allegations in Paragraph 110, except admits that one or more
`defendants have agreements called Mobile Application and Distribution Agreements (“MADAs”)
`and optional Revenue Share Agreements (“RSAs”) with some OEM and mobile network operator
`(“MNO”) partners, and respectfully refers the Court to the cited documents for a complete and
`accurate statement of their contents.
`111. Google denies the allegations in Paragraph 111, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`112. Google denies the allegations in Paragraph 112, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents. Google admits that
`mobile manufacturers have a choice whether to enter into a MADA to distribute devices with
`proprietary Google apps, including the Google Play Store, and that these agreements contain
`various provisions regarding placement of certain Google apps for the initial out-of-the-box
`settings, though the specific terms have changed over time.
`113. Google denies the allegations in Paragraph 113.
`114. Google denies the allegations in Paragraph 114, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`115. Google denies the allegations in Paragraph 115, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`116. Google denies the allegations in Paragraph 116, except admits that one or more
`defendants offer Google Play Services, and respectfully refers the Court to the cited documents for
`a complete and accurate statement of their contents.
`
`-11-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 12 of 38
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`117. Google denies the allegations in Paragraph 117.
`118. Google denies the allegations in Paragraph 118, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`119. Google denies the allegations in Paragraph 119, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`120. Google denies the allegations in Paragraph 120, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`121. Google denies the allegations in Paragraph 121, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`122. Google denies the allegations in Paragraph 122, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`123. Google denies the allegations in Paragraph 123, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`124. Google denies the allegations in Paragraph 124, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`125. Google denies the allegations in Paragraph 125.
`126. Google denies the allegations in Paragraph 126, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`127. Google denies the allegations in Paragraph 127, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`128. Google denies the allegations in Paragraph 128, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`129. Google denies the allegations in Paragraph 129, except admits that one or more
`defendants have revenue sharing agreements with OEMs and MNOs, and respectfully refers the
`Court to the cited documents for a complete and accurate statement of their contents.
`130. Google denies the allegations in Paragraph 130, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`
`
`
`
`
`-12-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
`
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 13 of 38
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`131. Google denies the allegations in Paragraph 131, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`132. Google denies the allegations in Paragraph 132, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`133. Google denies the allegations in Paragraph 133, except that Google is without
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`133 about Samsung’s products and operations.
`134. Google denies the allegations in Paragraph 134, except that Google is without
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`134 about Samsung’s products and operations.
`135. Google denies the allegations in Paragraph 135, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`136. Google denies the allegations in Paragraph 136, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`137. Google denies the allegations in Paragraph 137, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`138. Google denies the allegations in Paragraph 138, except that Google is without
`knowledge or information sufficient to form a belief as to the truth of the allegations in Paragraph
`138 regarding Samsung’s calculation of its revenue, and respectfully refers the Court to the cited
`documents for a complete and accurate statement of their contents.
`139. Google denies the allegations in Paragraph 139, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`140. Google denies the allegations in Paragraph 140, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`141. Google denies the allegations in Paragraph 141, and respectfully refers the Court to
`the cited documents for a complete and accurate statement of their contents.
`142. Google denies the allegations in Paragraph 142.
`
`
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`
`-13-
`;ANSWERS AND DEFENSES TO STATE OF UTAH ET AL. COMPLAINT
`Case No. 3:21-cv-05227-JD; Case No. 3:21-md-02981-JD
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`Case 3:21-cv-05227-JD Document 175 Filed 10/11/21 Page 14 of 38
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`143. Google denies the allegations in Paragraph 143, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`144. Google denies the allegations in Paragraph 144, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`145. Google denies the allegations in Paragraph 145.
`146. Google denies the allegations in Paragraph 146, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`147. Google denies the allegations in Paragraph 147, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`148. Google denies the allegations in Paragraph 148, and respectfully refers the Court to
`the cited document for a complete and accurate statement of its contents.
`149. Google denies the allegations in Paragraph 149, and respectfully refers the Court to
`the cited document for a complete and accurate statement of