Case 5:22-cv-02314-NC Document 1 Filed 04/13/22 Page 1 of 57
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`Justin S. Nematzadeh*
`NEMATZADEH PLLC
`101 Avenue of the Americas, Suite 909
`New York, New York 10013
`Telephone:
`(646) 799-6729
`jsn@nematlawyers.com
`Attorney for Plaintiffs and the Class
`*Pro hac vice application forthcoming
`
`John G. Balestriere*
`Matthew W. Schmidt (State Bar No. 302776)**
`BALESTRIERE FARIELLO
`225 Broadway, 29th Floor
`New York, New York 10007
`Telephone:
`(212) 374-5401
`Facsimile:
`(212) 208-2613
`john.balestriere@balestrierefariello.com
`matthew.schmidt@balestrierefariello.com
`Attorneys for Plaintiffs and the Class
`*Pro hac vice application forthcoming
`** Admission application forthcoming
`
`Mario Simonyan (State Bar No. 320226)
`ESQGo, PC
`303 North Glenoaks Boulevard, Suite 200
`Burbank, California 91502
`Telephone: (424) 363-6233
`mario@esqgo.com
`Attorney for Plaintiffs and the Class
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`DREAM BIG MEDIA, INC., GETIFY
`SOLUTIONS, INC., and SPRINTER
`SUPPLIER LLC, Individually and on Behalf
`of all Others Similarly Situated,
`
`Plaintiffs,
`
`vs.
`
`Case No.: 3:22-cv-2314
`
`CLASS ACTION
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`COMPLAINT FOR VIOLATIONS
`OF THE SHERMAN ANTITRUST
`ACT, CLAYTON ACT, AND
`UNFAIR COMPETITION LAW
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`ALPHABET INC. and GOOGLE LLC,
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`DEMAND FOR JURY TRIAL
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`Defendants.
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`4/13/2022
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`CLASS ACTION COMPLAINT
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`Case 5:22-cv-02314-NC Document 1 Filed 04/13/22 Page 2 of 57
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`TABLE OF CONTENTS
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`I. NATURE OF THE ACTION ...................................................................................................... 1
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`II. PARTIES .................................................................................................................................... 7
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`IX. CLASS ACTION ALLEGATIONS ....................................................................................... 11
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`III. JURISDICTION AND VENUE ............................................................................................. 13
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`IV. FACTUAL BACKGROUND ................................................................................................. 14
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`V. INTERSTATE TRADE AND COMMERCE .......................................................................... 38
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`VI. ANTITRUST HARM ............................................................................................................. 38
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`VII. PLAINTIFFS AND CLASS MEMBERS WERE INJURED AS A RESULT OF THE
`ALLEGED ANTICOMPETITIVE ACTIONS............................................................................. 42
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`X. CALIFORNIA LAW APPLIES TO THE ENTIRE CLASS ................................................... 44
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`XI. TOLLING OF THE STATUTE OF LIMITATIONS ............................................................ 45
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`XII. CAUSES OF ACTION ......................................................................................................... 47
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`XIII. PRAYER FOR RELIEF....................................................................................................... 53
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`Plaintiffs Dream Big Media Inc., Getify Solutions, Inc., and Sprinter Supplier LLC
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`(“Plaintiffs”), individually and on behalf of all others similarly situated, by Plaintiffs’ undersigned
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`attorneys, for Plaintiffs’ Class Action Complaint for Violations the U.S. Sherman Antitrust Act
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`(“Sherman Act”) and the Unfair Competition Law, against Defendants Alphabet Inc. and Google
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`LLC (“Defendants”), allege the following:
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`I. NATURE OF THE ACTION
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`1.
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`Alphabet Inc. and its subsidiaries and affiliated entities, including, without
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`limitation, Google LLC (together, “Defendants” or “Google”), have for years engaged in
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`anticompetitive conduct and other actions in violation of Sections 1 and 2 of the Sherman Act
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`15 U.S.C. §§ 1, 2, et seq. (“Section 1” and “Section 2,” respectively), and the Unfair Competition
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`Law. Leveraging its enormous market power, and at times monopoly power, across a range of
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`internet products, Google has forced users of its digital-mapping products—services that have
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`become ubiquitous through rapid and competitively close acquisitions—into a bundle of
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`services. Then, once locked in, Google ratchets up the cost on its maps products.
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`2.
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`Plaintiffs and Class Members are those who have been harmed by Google
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`improperly tying its mapping products together to restrain competition. Plaintiffs and Class
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`Members also seek injunctive and declaratory relief to stop the alleged anticompetitive conduct.
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`3.
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`Central to Google’s anticompetitive scheme alleged here are Google Maps’
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`application programming interfaces, known as “APIs.” An API is a method for one computer
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`program to make use of, or “call,” the resources of another program or service.
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`4.
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`For instance, a programmer developing a food-delivery application or website that
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`needs to guide drivers to customers through its application (“app”) or website may call on a
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`Google Maps Embed API (“Maps APIs”) for creating a digital dynamic map, call on a Google
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`Routes Directions API (“Routes APIs”) for adding directions on that dynamic map and provide
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`navigation information to the driver, and then call on a Google Places Place Details API (“Places
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`APIs”) for adding information about the restaurant. These are different products in different
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`markets that can be used to create a digital map on an application or website. Indeed, Google
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`itself recognizes that these are different products, as its pricing menu lists out APIs in different
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`product offering groups, including, without limitation, Maps APIs, Routes APIs, and Places
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`APIs.
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`5.
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`Google’s impermissible use of its market power harms not only computer
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`programmers. Websites also use digital-mapping API calls in order to display location
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`information on their websites, something especially important to small businesses looking to
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`attract customers. Embedding digital-mapping APIs into a website allows customers to both
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`locate the business without opening a separate app or web page, and to be sure that they are
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`seeing the correct business. These are all crucial details when a customer is considering whether
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`to patronize a small business, where even small friction can mean loss of a sale.
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`6.
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`Not anyone can call a Google digital-mapping API. Access to a Google mapping
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`API requires an API “key”, which is a unique identifier that Google provides. API keys are
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`tracked to a user’s account, and Google charges for the account holder for API calls made using
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`their key.
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`7.
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`Google’s pricing varies, but, for example, it currently charges $2 for 1,000 calls
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`to its Maps Static API (used to display a single map image on a web page); $2 for 1,000 calls to
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`its Maps JavaScript API (used to display an interactive map that a user can move around and
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`manipulate); $5 for 1,000 calls on its Routes Directions API (used to receive directions for
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`different transportation modes); and $17 for 1,000 calls for Places Place Details API (used to
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`request details about an establishment or point of interest).
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`8. While these costs are small on their own, they add up quickly and are often beyond
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`the control of the purchaser of the API keys. The costs depend on how often a user access or
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`reloads a website. As such, an anxious user who compulsively checks map information may
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`quickly rack up many calls over a short period of time.
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`9.
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`Google has monopoly power—or at the least overwhelming market power—in
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`the relevant product markets for digital-mapping APIs. According to a recent report by the U.S.
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`House Committee on the Judiciary, Subcommittee on Antitrust, Commercial and Administrative
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`Law (“House Antitrust Subcommittee”) that was released around October 6, 2020, entitled
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`“Investigation of Competition in Digital Markets-Majority Staff Report and Recommendations”
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`(“House Antitrust Proposals”), Google’s market share exceeds 80% in these markets.
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`10. Moreover, Google exercises direct market power over the relevant product
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`markets through the anticompetitive practices alleged herein. In essence, Google uses its market
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`dominance to improperly tie together its products and lock users into what is sometimes called
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`the Google ecosystem. There are competitors, but they have nowhere near the direct market
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`power that Google exerts, nor nowhere near the monopoly power that Google has. Those
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`competitors offer Maps APIs, Routes APIs, or Places APIs, mostly at significantly reduced
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`prices to Google—and some even for free—and with comparable data and quality, if not better.
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`But over the past several years, these competitors have been strangled out of competing
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`effectively in the relevant product markets because of Google’s anticompetitive conduct alleged
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`herein.
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`11. Direct victims of these alleged anticompetitive schemes are the class members
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`identified herein: those who have purchased Maps APIs, Routes APIs, or Places APIs, or had
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`their free credits provided by Google (the “free-tier credits”) used up more rapidly because of
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`Maps APIs, Routes APIs, or Places APIs.
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`12. Google’s terms of service prohibit users from using any Google Maps API or
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`component with any API or component of any other digital-mapping provider or service, which
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`constitute separate and distinct products. Google goes so far as to prohibit display of non-Google
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`digital maps near their own maps on an application or web page.
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`13. Further, the type of data tied together are not simply maps themselves, but what
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`Google considers to be related data, including, without limitation, business and other location
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`listings, which Google calls “Places.” Google Places functions like a modern phone book,
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`review website, and more, pulling together not just the address of a business, but also its
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`operating hours, menus, user reviews, and other information. In addition to the terms in Google’s
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`terms of service, Google has been aggressively enforcing these provisions and effectively
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`forcing users to choose whether they will use all of Google’s digital-mapping APIs or none of
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`them, all to the inclusion of competitors digital-mapping APIs.
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`14. A particular example (without limitation) of the anti-competitive nature of the
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`tying alleged herein is that even if a Class Member requests a specific JavaScript-related Google
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`Maps API, Google unilaterally will add on unnecessary, non-responsive other digital-mapping
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`APIs, such as Places APIs, to that request and charge the Class Member for those additional
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`APIs.
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`15. Another particular example (without limitation) is that prior to anticompetitive
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`changes to Google’s terms of services related to its digital-mapping APIs, certain JavaScript or
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`Software Development Kits (“SDK tools”)—not technically APIs—were provided as
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`complimentary with other API calls because those JavaScript or SDK tools were necessary to
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`make the actual APIs accurately overlay information as an image on a digital map. Those tools
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`were not technically APIs. But after changes, Google recategorized those JavaScript or SDK
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`tools as APIs, made them compulsory to other purchased APIs, and charged Class Members for
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`them.
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`Case 5:22-cv-02314-NC Document 1 Filed 04/13/22 Page 7 of 57
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`16. Another example (without limitation) is that even if a Class Member wanted to
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`overlay data that it has acquired through its own app or website—for example, Places API data
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`concerning information learned from its own users, such as comments on a particular restaurant
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`dish—on top of a digital-map that has used any Google APIs, Maps APIs, Routes APIs, or
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`Places APIs, the Class Member cannot because even the Class Member’s own data would be
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`considered to violate the terms of service if it is overlayed on top of a digital map that used any
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`Google digital-mapping APIs.
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`17. The graphic below displays the Google Places API in practice—while this
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`restaurant review has little relation to traditional mapping, Google ties this Places API service
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`together with basic mapping functions.
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`18.
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`This unlawful tying and monopolistic behavior has resulted in concrete damages
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`to app and website developers and all other direct users (or those who used them through a pass-
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`through entity or website that passed all of the costs to them) of Google’s digital-mapping APIs,
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`in part through anticompetitive price hikes, forcing users to purchase separate Google products.
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`19.
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`For years, Google offered a free tier of the digital-mapping APIs, incentivizing
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`developers or users to build their apps or websites with Google Maps. And during these years,
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`Google has been acquiring potential competitors, such as Waze, to get to its monopoly power—
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`or, at the least, market power.
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`20.
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`Overwhelmingly however, around May 2018 and continuing thereafter, Google
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`Maps introduced a single “pay-as-you-go” pricing plan for the core mapping APIs. This shift
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`reduced the number of free maps API calls that a firm could make from 25,000 per day to around
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`930 per day. Developers told the House Antitrust Subcommittee that the change amounted to a
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`price increase of 1,400%. One market participant told the House Antitrust Subcommittee that
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`Google instituted this price hike after “gaining dominance.” Since becoming a Google Maps
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`customer, the market participant’s costs “have increased over 20x” and “there are no viable
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`alternatives.” To present, the staggering price increases to the APIs and also lowering of the
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`free-tier credits continues to damage the class members.
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`21.
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`Even other large companies are beholden to the Google Defendants. For example,
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`the House Antitrust Subcommittee reported that the ride-sharing company Lyft has cited its use
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`of Google Maps as a potential risk to its business model. Lyft stated in a securities filing that
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`“[s]ome of our competitors or technology partners may take actions which disrupt the
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`interoperability of our platform with their own products or services.”
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`22.
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`Under per se liability, whether the purported pro-competitive effects outweigh the
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`anti-competitive effects is irrelevant. The allegations herein present per se liability.
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`Case 5:22-cv-02314-NC Document 1 Filed 04/13/22 Page 9 of 57
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`23.
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`In the alternative, Defendants’ potential defenses of pro-competitive explanation
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`of avoiding “quality issues and/or brand confusion” are not justified. Even with an ever-
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`increasing stranglehold over Maps APIs, Routes APIs, and Places APIs, Google with its strict
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`control has recklessly or intentionally done a poor job of maintaining quality and accurate
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`business-mapping features.
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`24.
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`Defendants’ pricing for Google Maps APIs, Routes APIs, and Places APIs are
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`notoriously known to be materially more expensive than competitors’ pricing. Many
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`competitors, indeed, offer such APIs for free.
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`25.
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`Further Google does not offer a full suite of APIs in all of its Maps APIs, Routes
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`APIs, and Places APIs. There are bodies of API information within these relevant product
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`groups that Google does not offer, that competitors may have, but that Class Members cannot
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`access because of Google’s anticompetitive conduct alleged herein.
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`26.
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`This class action is not about punishing an innovative company that is reaping the
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`rewards of its well-deserved success through large size and power. Instead, this class action is
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`about seeking redress from and stopping a massive company which had the means to acquire
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`several other companies to gain size and create entry barriers, and then used its tying and
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`monopolistic maintenance and exclusionary actions in certain relevant products and services to
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`stifle competition. The result foreclosed users from using sought-after products and services
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`offered by competitors in other relevant products and services.
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`II. PARTIES
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`Dream Big Media, Inc.
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`27.
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`Plaintiff Dream Big Media, Inc. (“Dream Big Media”) is a California corporation
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`with a principal place of business in California.
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`28.
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`Dream Big Media is a digital-advertising business that has used and paid for
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`Case 5:22-cv-02314-NC Document 1 Filed 04/13/22 Page 10 of 57
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`Google’s digital-mapping APIs.
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`29.
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`For example, it used Google Maps Route APIs to determine the distance between
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`two zip codes. These fees also quickly added up. For example, in November 2019 and December
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`2019 alone, Dream Big Media incurred $1,371.44 on Google Maps’ “Distance Matrix API”
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`alone. Distance Matrix API is a Routes product that provides the travel distance between two
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`points.
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`30.
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`Due to the anticompetitive conduct alleged herein, Dream Big Media could not
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`use competing providers’ digital-mapping APIs nor mix and combine Google’s digital-mapping
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`APIs with competitors’ digital-mapping APIs.
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`31.
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`Dream Big Media was forced to use the other products or services that Google
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`had made subject to the tying and other anti-competitive conduct alleged herein.
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`Getify Solutions, Inc.
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`32. Plaintiff Getify Solutions, Inc. (“Getify Solutions”) is a Texas corporation with a
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`principal place of business in Texas.
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`33.
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`In 2018, Getify Solutions developed a mobile web app called “RestaurNote” that
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`allowed users to make notations about experiences that related to their physical location, among
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`other uses. For instance, if you had a memorable meal at a restaurant and wanted to order it
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`again—or ordered poorly and wanted to avoid the error next time—you could make a note for
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`the next time you went to that restaurant.
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`34. A mobile web app is intended for use on mobile devices (such as phones or
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`tablets) and is built using web technologies (as opposed to native mobile apps that are built for
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`Android or iOS).
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`35. RestaurNote utilizes Google’s web-based digital-mapping APIs in order to allow
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`users to find their location on a map—a crucial feature of an app tied to physical location—and
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`for other uses.
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`36. RestaurNote is intended to be a free app, and Google Maps’ original pricing
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`structure provided for this—Maps provided sufficient free credits that even moderately sized
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`businesses could expect to rarely exceed the credit allowance.
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`37. However, in the summer of 2018, Google announced a major change in its pricing
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`structure, which significantly impacted the amount that an app like RestaurNote would pay.
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`Given that RestaurNote was intended to be a free app, this made the program unworkable, and
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`Getify Solutions indefinitely paused its development once the app was stable and usable, with
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`limited access given to friends and family to keep fees from Google under control. This was
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`despite the fact that Getify Solutions ran through substantial amounts of the credits offered by
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`Google in order to induce it to use the APIs, and Getify Solutions expended significant time,
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`effort, and costs to have developed the app to launch.
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`38. Due to the anticompetitive conduct alleged herein, Getify Solutions could not use
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`Google’s digital-mapping APIs alongside any other APIs from any other provider besides
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`Google if any of that data would interact with Google’s digital-mapping capabilities. And Getify
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`Solutions was forced to either exclusively use products and services provided by Google,
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`pursuant to the tying and other anti-competitive conduct alleged herein, or use no Google-
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`provided products and services in the RestaurNote app.
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`Sprinter Supplier LLC
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`39. Plaintiff Sprinter Supplier LLC is a Pennsylvania limited liability company with
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`a principal place of business in Pennsylvania.
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`40. Sprinter Supplier is an e-commerce automotive parts shop located in Northeast
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`Philadelphia. During the global Covid pandemic, Sprinter Supplier also began ordering personal
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`protective equipment, such as masks, to distribute to frontline workers. It found that digital-
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`mapping APIs were highly valuable in displaying map information on its website in order to
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`help local customers find its business.
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`41. When Sprinter Supplier initially became aware of Google’s staggering digital-
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`mapping APIs pricing, it searched for providers as an alternative to or in combination with
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`Google’s digital-mapping APIs. Indeed, Sprinter Supplier found competing providers to Google
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`of comparable digital-mapping APIs, especially those that offered such APIs for free or at
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`significantly cheaper prices.
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`42. But due to the anticompetitive conduct alleged herein, Sprinter Supplier could not
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`use those competing providers’ digital-mapping APIs nor mix and combine Google’s digital-
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`mapping APIs with competitors’ digital-mapping APIs. And Sprinter Supplier was forced to use
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`the other products or services that Google had made subject to the tying and other anti-
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`competitive conduct alleged herein. However, the costs of Google’s digital-mapping APIs
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`quickly became concerning. Although Google promised Sprinter Supplier free credits, those
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`credits were quickly eaten up by Google’s digital-mapping API fees.
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`Defendants
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`43.
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`Defendant Alphabet Inc. (“Alphabet”) is a Delaware corporation with its principal
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`place of business at 1600 Amphitheatre Parkway, Mountain View, California 94043. Defendant
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`Alphabet wholly owns and controls Defendant Google and non-party Waze, and Defendant
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`Alphabet is the alter ego of Defendant Google and Waze. Google and Waze direct all profit to
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`and report revenue through Alphabet.
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`44.
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`Defendant Google LLC is a Delaware limited liability company with its principal
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`place of business at 1600 Amphitheatre Parkway, Mountain View, California 94043. Defendant
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`Google is a wholly owned and controlled subsidiary of XXVI Holding Inc., which is a subsidiary
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`of Defendant Alphabet. Since 2005, Google has wholly owned and controlled Google Maps.
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`Since 2013, Google has wholly owned and controlled Waze. Google is the alter ego and agent
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`of Defendants Alphabet and Waze, and the companies regularly combine and comingle their
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`operations.
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`45.
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`All Defendants are engaged in substantial interstate commerce. Each Defendant
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`deals with and earns revenue from app and website developers and other users throughout the
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`U.S.
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`IX. CLASS ACTION ALLEGATIONS
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`46.
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`Plaintiffs brings this action on behalf of themselves and as a class action under
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`Federal Rules of Civil Procedure 23(a), (b)(2), and (b)(3) on behalf of the following class
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`(“Class”):
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`From April 13, 2018, through the date that the alleged unlawful anticompetitive
`activity ceases, all direct purchasers, app or website developers, or other types of
`users of Maps APIs, Routes APIs, or Places APIs, or direct purchasers, app or
`website developers, or other types of users of Maps APIs, Routes APIs, or Places
`APIs who spent money or had their free-tier credits consumed more rapidly because
`of the anticompetitive allegations therein, or other types of users who continue to
`experience anticompetitive harm as a result of the allegations herein.
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`47.
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`Specifically excluded from the Class are the following: Defendants; officers,
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`directors, or employees of any Defendant; any entity in which any Defendant has a controlling
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`interest; any affiliate, legal representative, heir, or assign of any Defendant; any person acting
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`on their behalf; any judicial officer presiding over this action and his/her immediate family
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`members; the judicial staff; and any juror assigned to this action.
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`48. Also specifically excluded from this Class are indirect purchasers, app or website
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`developers, or other types of users who have purchased Maps APIs, Routes APIs, or Places APIs
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`from a more-direct purchaser to Defendants that did not pass on all of the purchase price or free-
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`tier credits to the app or website developers or other types of users.
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`49.
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`The Classes are readily ascertainable, and the records for them should exist,
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` CLASS ACTION COMPLAINT
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`including, without limitation, in Defendants’ own records and transaction data.
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`50. Due to the nature of the trade and commerce involved, there are three of
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`geographically dispersed members in the Class, the exact number and their identities being
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`known to Defendants.
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`51.
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`Plaintiff’s claims are typical of the Class members’ claims. Plaintiffs and the Class
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`members sustained damages arising out of Defendants’ common course of conduct in violation
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`of the laws alleged herein. Each Class member’s damages and injuries were directly caused by
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`Defendants’ wrongful conduct.
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`52.
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`There are questions of fact and law common to the Class members, including the
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`following, without limitation:
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`a. Whether Google has monopoly power in the relevant markets, including the
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`markets for Maps APIs, Routes APIs, and Places APIs;
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`b. Whether Defendants have engaged in unlawful tying or bundling;
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`c. Whether Defendants have engaged in unlawful monopoly leveraging;
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`d. Whether Google engaged in unlawful self-preferencing;
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`e. Whether Defendants have blocked rivals from competing in the digital-
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`mapping stack;
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`f. Whether the anticompetitive conduct constitutes monopolization, monopoly
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`maintenance, an attempt to monopolize, or a conspiracy to monopolize;
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`g. Whether Defendants’ anticompetitive conduct has harmed Plaintiffs and the
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`Class members by increasing their costs;
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`h. Whether Defendants’ anticompetitive conduct has harmed Plaintiffs and the
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`Class members by causing them to pay supra-competitive prices for using
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`Defendants’ digital-mapping products and services; and
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` CLASS ACTION COMPLAINT
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`i. The appropriate Class-wide damages measure.
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`53.
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`Plaintiffs will fairly and adequately protect the Class members’ interests.
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`Plaintiff’s interests are aligned with and not antagonistic to those of the other Class members.
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`Plaintiffs have retained counsel competent and experienced in prosecuting class actions and
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`antitrust litigation to represent itself and the Class.
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`54.
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`Questions of fact or law are common to the Class members and predominate over
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`any questions affecting only individual Class members.
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`55.
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`A class action is superior to other available methods for the fair and efficient
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`adjudication of this controversy. The prosecution of separate actions by individual class
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`members would impose heavy burdens on the courts and Defendants and would create a risk of
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`inconsistent or varying adjudications of the questions of fact and law common to the Class. On
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`the other hand, a class action would achieve substantial economies of effort and expense and
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`would assure uniformity of decisions as to persons similarly situated without sacrificing
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`procedural fairness or brining about other undesirable results. Absent a class action, it would
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`not be feasible for the vast majority of Class members to seek redress for the violations of law
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`alleged herein.
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`III. JURISDICTION AND VENUE
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`56.
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`This class action arises under Sherman Act Sections 2 and 15, 15 U.S.C. §§ 2, 15,
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`and Clayton Act Sections 4 and 16, 15 U.S.C. §§ 15 & 26.
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`57.
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`This Court has subject matter jurisdiction over Sherman Act claims pursuant to
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`28 U.S.C. §§ 1331 & 1337 and Clayton Act Sections 4 and 16, 15 U.S.C. §§ 15 & 26.
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`58.
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`This Court has personal jurisdiction over Defendants. Alphabet, Google, Google
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`Maps, and Waze each maintain their headquarters in California.
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`59.
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`Venue is proper in this District pursuant to Clayton Act Sections 4, 12, and 16, 15
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`U.S.C. §§ 15, 22, and 26, and 28 U.S.C. § 1391(b), (c), and (d). All Defendants reside, transact
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`business, are found, and have agents in this District.
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`60.
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`Pursuant to the Google Maps Platform Terms of Service, venue and personal
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`jurisdiction is consented to in this District.
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`61.
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`Defendants’ acts were within the flow of, were intended to have, and did in fact
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`have a substantial effect on the interstate commerce of the United States.
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`IV. FACTUAL BACKGROUND
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`62.
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`The digital-mapping “stack” provides users with virtual maps of the physical
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`world.
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`63. With the proliferation of smart devices, digital mapping has become a critical
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`resource for users and businesses alike.
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`64.
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`There are two sets of customers for digital-mapping services: app or website
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`developers (or other types of businesses) who use underlying mapping libraries and design tools
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`to produce customized maps; and consumers (or users), who use map products for navigation.
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`65.
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`Consumer-facing providers of mapping services license map databases and layer
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`technologies atop of the map data. Consumers use these search and traffic tools either through
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`a standalone, turn-by-turn navigation service that licenses the underlying data—such as
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`MapQuest or Bing Maps—or through a vertically integrated provider, such as Google Maps,
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`Waze, or other providers.
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`66.
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`App or website developers or other users have contracted with Defendants to use
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`their Google Maps and related products and services, including, without limitation, application
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`APIs, and other products and services, such as Google’s general search tools and Google Cloud
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`Platform ("GCP").
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`67.
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`The essential input for both types of services is a digital-map database.
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`68. Mapping data can be gathered in a few ways, including through the collection of
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`imagery from satellites and streets, the tracking of global positioning system (“GPS”) traces,
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`and the collation of public domain mapping data.
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`69.
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`Building a digital map database is costly and time-intensive, requiring significant
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`investment in mapping technologies and data collection.
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`70.
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`The more robust the API, the more it costs. Desktop-based pulls and more
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`advanced functions, such as directions, route-mapping search, street view, speed limits, or
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`current location tracking can go a la carte for as much