Case 1:20-cv-03715-APM Document 3 Filed 12/17/20 Page 1 of 115
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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` Case No. ________________
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`STATE OF COLORADO
`1300 Broadway, 7th Floor
`Denver, CO 80203
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`STATE OF NEBRASKA
`2115 Nebraska State Capitol
`Lincoln, NE 68509-8920
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`STATE OF ARIZONA
`2005 North Central Avenue
`Phoenix, Arizona 85004
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`STATE OF IOWA
`1305 E. Walnut St., 2nd Floor
`Des Moines, IA 50319
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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, North Carolina 27602
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`STATE OF TENNESSEE
`P.O. Box 20207
`Nashville, TN 37202
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`STATE OF UTAH
`160 E 300 S, 5th Floor
`PO Box 140872
`Salt Lake City, UT 84114-0872
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`STATE OF ALASKA
`1031 W. Fourth Avenue, Suite 200
`Anchorage, Alaska 99501
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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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`TERRITORY OF GUAM
`590 S. Marine Corps Drive, Suite 901
`Tamuning, Guam 96913
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`STATE OF HAWAII
`425 Queen Street
`Honolulu, Hawaii 96813
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`STATE OF IDAHO
`954 W. Jefferson Street, 2nd Floor
`P.O. Box 83720
`Boise, Idaho 83720-0010
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`STATE OF ILLINOIS
`100 W. Randolph St.
`Chicago, IL 60601
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`STATE OF KANSAS
`120 S.W. 10th Avenue, 2nd Floor
`Topeka, KS 66612-1597
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`STATE OF MAINE
`6 State House Station
`Augusta, Maine 04333-0006
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`STATE OF MARYLAND
`200 St. Paul Place, 19th Floor
`Baltimore, Maryland 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, Minnesota 55101-2130
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`STATE OF NEVADA
`100 N. Carson St.
`Carson City, Nevada 89701
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`STATE OF NEW HAMPSHIRE
`33 Capitol Street
`Concord, N.H. 03301
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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 OHIO
`150 East Gay Street, 22nd Floor
`Columbus, Ohio 43215
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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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`COMMONWEALTH OF
`PENNSYLVANIA
`14th Floor Strawberry Square
`Harrisburg, PA 17120
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`COMMONWEALTH OF PUERTO
`RICO
`P.O. Box 9020192
`San Juan, Puerto Rico 00902-0192
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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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`STATE OF VERMONT
`109 State St.
`Montpelier, VT 05602
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`COMMONWEALTH OF VIRGINIA
`202 North 9th Street
`Richmond, VA 23219
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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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`STATE OF WYOMING
`2320 Capitol Ave.
`Cheyenne, WY 82002
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`Plaintiffs,
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`v.
`
`GOOGLE LLC
`1600 Amphitheatre Parkway
`Mountain View, CA 94043
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`
`
`Defendant.
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`
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`COMPLAINT
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`1.
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`The States of Colorado, Nebraska, Arizona, Iowa, New York, North Carolina,
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`Tennessee, Utah, Alaska, Connecticut, Delaware, Hawaii, Idaho, Illinois, Kansas, Maine,
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`Maryland, Minnesota, Nevada, New Hampshire, New Jersey, New Mexico, North Dakota, Ohio,
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`4
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`Oklahoma, Oregon, Rhode Island, South Dakota, Vermont, Washington, West Virginia, and
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`Wyoming; the Commonwealths of Massachusetts, Pennsylvania, Puerto Rico, and Virginia; the
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`Territory of Guam; and the District of Columbia, by and through their respective Attorneys
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`General, bring this civil antitrust law enforcement action against Defendant Google LLC
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`(Google) under Section 2 of the Sherman Act, 15 U.S.C. § 2, to restrain Google from unlawfully
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`restraining trade and maintaining monopolies in markets that include general search services,
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`general search text advertising, and general search advertising in the United States, and to
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`remedy the effects of this conduct.
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`NATURE OF THIS ACTION
`Google, one of the largest companies in the world, has methodically undertaken
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`2.
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`actions to entrench and reinforce its general search services and search-related advertising
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`monopolies by stifling competition. As the gateway to the internet, Google has systematically
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`degraded the ability of other companies to access consumers. In doing so, just as Microsoft
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`improperly maintained its monopoly through conduct directed at Netscape, Google has
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`improperly maintained and extended its search-related monopolies through exclusionary conduct
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`that has harmed consumers, advertisers, and the competitive process itself. Google, moreover,
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`cannot establish business justifications or procompetitive benefits sufficient to justify its
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`exclusionary conduct in any relevant market.
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`3.
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`Today, Google enjoys virtually untrammeled power over internet search traffic
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`that extends to every state, district, and territory in the United States, and, indeed, into nearly
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`every home and onto nearly every smartphone used in the United States.
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`4.
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`Google’s monopoly position derives principally from its overwhelming and
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`durable monopoly in general internet searches. Close to 90 percent of all internet searches done
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`5
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`in the United States use Google. No competing search engine has more than 7 percent of the
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`market, and, over the past decade, no new entrant in the general search market in the United
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`States has accounted for more than 1 percent of internet searches in a given year.
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`5.
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`A central foundation of Google’s business and its resulting monopolies is its
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`collection of vast amounts of data about the people who use Google’s search engine. General
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`search results are not paid for with cash, but in exchange for users’ attention and extremely
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`valuable data. Google closely tracks and analyzes virtually every internet search and click
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`performed by users. In 2010, Google’s then-CEO Eric Schmidt boasted: “We know where you
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`are. We know where you’ve been. We can more or less know what you have been thinking
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`about.”
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`6.
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`This “attention economy” differs from Industrial Age markets of the 19th and
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`20th centuries. Cash is no longer the only form of currency, and rather than mining and
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`monetizing a scarce resource such as oil, the attention economy is based on mining and
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`monetizing knowledge about what is inside the minds of individual users. Google uses its
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`gargantuan collection of data to strengthen barriers of expansion and entry, which blunts and
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`burdens firms that threaten its search-related monopolies (including general search services,
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`general search text advertising, and general search advertising).
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`7.
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`Google converts its general search services monopoly into monopoly positions in
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`extremely lucrative markets for general search-based advertising. As a Google executive recently
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`put it,
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`8.
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`The revenue Google generates from its dominance of general search advertising is
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`astounding. Within the last decade, Google’s revenue from search advertising has grown 300
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`percent and accounts for 61 percent of Google’s total revenue. In 2019, Google made more
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`revenue in what it characterizes as search advertising—$98 billion—than the GDP of 129
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`countries and the budgets of 46 States.
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`9.
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`Steadily and over the years, Google has expanded and refined the tactics it uses to
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`harm competition. Instead of simply producing a better service that keeps consumers and
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`advertisers loyal, Google focuses on building an impenetrable moat to protect its kingdom.
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`10.
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`As Google perceives potential threats to its hegemony, it blunts and burdens those
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`competitive threats. Google recognizes, for example, that voice-based internet searching could
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`easily emerge as the future of search. If freed from Google’s monopolistic grasp, companies
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`could offer new and innovative ways to navigate the internet. But such innovation—such as
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`voice-based home speakers and internet-connected cars—would bring to life the threat that
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` After all, if consumers began relying on home-based
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`smart speakers and internet-connected car platforms not controlled by Google, those devices
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`could support and enable competition in the search-related markets by mixing and matching
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`different search engines for different purposes.
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`11.
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`12.
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`This Complaint focuses on three forms of such anticompetitive conduct.
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`First, Google uses its massive financial resources to limit the number of
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`consumers who use a Google competitor. For example, according to public estimates Google
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`pays Apple between $8 and $12 billion per year to ensure that Google is enthroned as the default
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`search engine on Apple devices, and it limits general search competition on Android devices
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`with a web of restrictive contracts. Google pursues similar strategies with other devices, such as
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`voice assistants and internet-connected cars.
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`13.
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`Second, Google’s Search Ads 360 (“SA360”) service, a search advertising
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`marketing tool used by many of the world’s most sophisticated advertisers, has long pledged to
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`offer advertisers a “neutral” means for purchasing and comparing the performance of not only
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`Google’s search advertising, but also that of its closest competitors. But, in reality, Google
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`operates SA360—the single largest such tool used by advertisers—to severely limit the tool's
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`interoperability with a competitor, thereby disadvantaging SA360 advertisers.
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`14.
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`Third, Google throttles consumers from bypassing its general search engine and
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`going directly to their chosen destination, especially when those destinations threaten Google’s
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`monopoly power. Google acknowledges its
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` because of the proliferation of services offered by specialized vertical providers.
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`Specialized vertical providers, like an online travel agency who offer consumers the ability to
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`complete a transaction then and there, do not compete in Google’s search-related markets.
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`Nevertheless, they pose a threat to Google’s monopoly power in those markets because their
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`success would both strengthen general search rivals with whom they partner and lower the
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`artificially high barriers to expansion and entry that protect Google’s monopolies.
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`15.
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`In this fashion, Google undermines competitive threats, limiting the ability of
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`consumers and advertisers to obtain information and make their own choices.
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`16.
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`In a more competitive market, Google’s search-related monopolies could be
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`challenged or even replaced by new forms of information discovery. Rival general search
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`engines would be able to create better services for consumers, including improved privacy,
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`advertising-free search, and stronger partnerships with specialized vertical providers that can
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`offer the ability to sell a service directly (like an airline ticket) or better ways to find, compare,
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`and buy services (like those provided by plumbers or electricians). More competitive general
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`search engines also could offer better advertising and lower prices to advertisers (and lower
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`8
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`prices would be expected to flow through to consumers). But Google’s actions have blocked and
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`burdened the current and emerging general search technology.
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`17.
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`The broad group of States that seek to hold Google accountable for its illegal
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`conduct, as alleged in this Complaint, also support the allegations in the complaint recently filed
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`by a number of sister States and the United States Department of Justice. The additional claims
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`in this case are brought to combat a broader range of Google’s illegal conduct.
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`18.
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`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
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`economies, and their citizens that has flowed, and continues to flow, from that conduct. Plaintiff
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`States seek to restore lost competition and prevent Google from engaging in similar conduct in
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`the future.
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`19.
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`It is now time to put a stop to those anticompetitive actions and to remedy past
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`competitive harms, not simply by ceasing the wrongful conduct, but also by reversing the
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`adverse impacts and restoring competition.
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`JURISDICTION, PARTIES, AND VENUE
`This Court has subject matter jurisdiction over this matter pursuant to 15 U.S.C.
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`20.
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`§§ 4 and 26, and 28 U.S.C. §§ 1331 and 1337.
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`21.
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`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 competition laws authorize
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`States to bring actions to protect the economic well-being of their States and obtain injunctive
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`and other relief to redress harm caused by violations of those laws.
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`22.
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`The Attorneys General appear in their respective sovereign or quasi-sovereign
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`capacities as well as their respective statutory, common law, and equitable powers, and as parens
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`patriae on behalf of the citizens, general welfare, and economy of their respective States.
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`23.
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`The Attorneys General assert these claims based on their independent authority to
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`bring this action pursuant to Section 16 of the Clayton Act, 15 U.S.C. § 26, to obtain injunctive
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`and accompanying equitable relief based upon Defendant’s anticompetitive practices in violation
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`of Section 2 of the Sherman Act, 15 U.S.C. § 2.
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`24.
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`Defendant Google LLC is a Delaware limited liability company with its principal
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`place of business in Mountain View, California. Google LLC is the primary operating subsidiary
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`of the publicly traded holding company Alphabet Inc. The sole member of Google LLC is XXVI
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`Holdings, Inc., a Delaware corporation with its principal place of business in Mountain View,
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`California, and a wholly owned subsidiary of Alphabet Inc. Google LLC owns and operates
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`consumer services such as Android, Chrome, Gmail, Google Drive, Google Maps, Google Play,
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`Google Search, YouTube, Google Cloud, SA360, and a wide range of digital advertising
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`products for advertisers, advertising agencies, and publishers.
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`25.
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`This Court has personal jurisdiction over Google, and venue is proper in this
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`Court under 15 U.S.C. § 22 and 28 U.S.C. § 1391 because Google transacts business and is
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`found within this District.
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`FACTUAL ALLEGATIONS
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`I.
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`Google Maintains Its Market Power through a Range of Exclusionary,
`Anticompetitive Conduct.
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`26.
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`Twenty years ago, Google already claimed to be the world’s largest general
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`search engine. Its market share in general search services has only grown since, from 70 percent
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`in 2007, to over 85 percent in 2019. Bing, its closest competitor in the general search services
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`market, runs a distant second and receives about 7 percent of general search queries in the United
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`States. The ubiquity of Google’s general search engine has made the term “google” a verb
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`synonymous with conducting a query on a general search engine.
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`27.
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`Google monetizes its search results by selling to advertisers the ability to reach
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`consumers who have entered general search terms. As a result of its significant power in the
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`general search services market, Google also has built durable monopolies in general search text
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`advertising and in the larger market for general search advertising, which consists of all paid
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`placements available in connection with a general search results page (including both general
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`search text advertisements and specialized advertisements sold by general search engines).
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`28.
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` Google’s search results originally contained no advertising and consisted only of
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`results produced by its search engine. These links are called “general” or “organic” results, and
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`they allow a consumer to travel directly to a third-party website associated with the link (the way
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`a search for United States District Court District of Columbia results in an organic link that
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`brings a consumer to this Court’s website). When conducting search queries, consumers are also
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`accustomed to seeing the familiar text-based advertisements that typically appear on the Google
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`search results page above and below the organic search results (“general search text
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`advertisements”).
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`29.
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`Today, as Google has buried many of the general, or organic, results beneath
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`general search advertisements or Google features that occupy the majority of the space “above
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`the fold”—that is, those results viewable on a search results page that produces results of
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`commercial interest without scrolling or clicking through to another search results page. As a
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`result of the prevalence and prominence of advertising and Google’s own search features on its
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`search results page, organic results now often appear “below the fold.”
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`30.
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`Figure 1 displays the results of the query “plumbers in Denver” and labels each
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`unit on the page. At the top of the page are general search specialized advertisements contained
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`in a unit referred to as a “carousel;” these advertisements include features like ratings and
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`provide access to reviews. Here, the “carousel” depicts three similarly formatted tiles
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`highlighting different service providers. Following the carousel, general search text
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`advertisement units appear; the word “Ad” prominently appears, in this case, as part of an
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`advertisement purchased by Mr. Rooter. Next comes Google’s “OneBox;” a Google feature that
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`appears prominently on the search results page to steer consumers to Google’s own properties
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`(the content of a typical OneBox is shown below in screenshots 2 and 3 of Figure 2, and also
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`below the text advertisements in Figure 9). Below these sections, and well below the fold, appear
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`the organic search results that consumers can use to travel directly to third-party websites.
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`Figure 1
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`31.
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`This presentation increases the importance of paid placements, particularly on
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`mobile devices that have much smaller screens. Figure 2 shows sequential pages as the user
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`scrolls down the search results page for the same “plumbers in Denver” query on an Apple
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`device. Note that no organic results appear on this first screen. To uncover the unpaid organic
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`links, the consumer would need to scroll multiple times before reaching organic links that
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`directly take the user to the relevant third-party websites.
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`Figure 2
`Advertising is not present on all Google general search results pages. Indeed,
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`32.
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`more than
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` of Google’s general search queries produce organic results without any
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`kind of general search advertising.
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`33.
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`Google’s general search services monopoly feeds and reinforces its general search
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`text advertising and general search advertising monopolies in two ways.
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`34.
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`First, Google’s maintenance of its monopoly in general search services provides it
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`with an artificially enlarged audience whose attention and data it can monetize through the sale
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`of advertisements. Google’s continued ability to sell general search advertising depends on its
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`continued ability to attract the attention of the consumers globally that use Google to make
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`trillions of general searches each year—consumers that advertisers will pay to reach.
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`35.
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`Second, Google’s general search monopoly generates massive amounts of data
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`that Google monetizes through its search advertising monopolies. Put simply, Google may have
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`more data about more people than any other entity in the history of the world.
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`36.
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`Despite its seemingly impregnable position, Google recognizes that its continued
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`market dominance would be vulnerable in a more competitive market. For example, new general
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`search challengers could emerge to offer differentiated services, such as greater privacy
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`protection, search without advertising, or simply better search results. As Google appreciates,
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`general search has limited functionality and could be supplanted by innovative new ways of
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`finding information, such as voice assistants that reach general search engines through new
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`channels like home speakers and connected cars. (Those channels, which also include desktop
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`and mobile browsers, are referred to as “search access points”).
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`37.
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`In a more competitive market, Google could also face more competition for
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`general search advertising revenue, which comes disproportionately from a small category of
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`inquiries about “vertical” commercial segments, such as travel and local services, like restaurants
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`and electricians. Consumer queries in these vertical commercial segments are also the focus of
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`“specialized vertical providers,” which offer different, more immersive experiences than a
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`general search results page. Specialized vertical providers are typically companies that offer
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`consumers ways to find and connect with merchants or service providers, such as airline ticket
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`sellers or local electricians, and often to complete or book transactions with those merchants.1
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`Because of Google’s dependence on general search revenue, it needs consumers to use general
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`search to reach specialized vertical providers, rather than bypassing general search to travel
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`directly to them. Although they are not competitors to Google in its search-related markets,
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`specialized vertical providers pose a unique threat to Google’s incumbent search advertising
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`revenue (much as Netscape’s browser posed a threat to Microsoft’s operating-system monopoly)
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`because consumers could reach them without the use of a general search engine. But, as Google
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`well knows, under current market conditions, the ability of consumers to use general search
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`engines to reach more specialized service providers is very important as a means of customer
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`acquisition.
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`38.
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`Specialized vertical providers, in a more competitive marketplace, could become
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`more valuable partners for general search engines, which could strengthen such Google
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`competitors and weaken barriers to expansion or entry in search-related markets.
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`39.
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`To prevent that, Google has constructed a series of artificial barriers to protect
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`against the expansion and entry it fears. In addition to any barriers that would exist in a more
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`competitive market, these artificially-erected barriers afford Google considerable protection from
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`its vulnerabilities and support Google’s anticompetitive efforts to construct a
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`
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` This action seeks to enjoin and redress three forms of anticompetitive conduct
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`Google uses to artificially widen its moat.
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`1 The DOJ calls these companies “specialized search engines,” which is also accurate but it is
`important to note that such companies are not simply providing a subset of general search
`responses. Rather, they are offering distinct, additional features that often involve the ability to
`complete a transaction. Thus, a typical company offers both a specialized service and sales of
`products and services.
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`40.
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`Contractual exclusion of rival general search engines: Google has entered a
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`series of contracts to artificially limit competition from general search competitors and cement
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`its monopoly position.
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`41.
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`Not long after its inception, Google recognized that it could easily control
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`consumers’ use of a general search engine by making Google the default search engine on
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`browsers. As it said,
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`42.
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`To maintain its search-related monopolies, Google has used its monopoly power
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`to make Google’s general search engine the default on as many browsers as possible. For
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`example, a browser that “ships” to consumers with a setting that makes Google’s general search
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`engine the default general search engine gives Google de facto exclusivity, because consumers
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`seldom bother to change the default. Google’s exploitation of consumers’ so-called “default
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`bias” explains the vast sums Google pays independent browsers to secure the default status.
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`43.
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`Google has entered search advertising revenue share agreements with numerous
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`firms, including Android device manufacturers, companies that offer browsers (like Apple and
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`Mozilla, the creator of the web browser Firefox), and U.S. mobile carriers like T-Mobile,
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`Verizon, and AT&T. As a result of these agreements, Google has secured default placement of
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`Google Search on 80 percent of web browsers, the primary gateway to the internet in the United
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`States (including Google’s own Chrome, which is the most used web browser, and Apple’s
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`Safari), and has thus erected artificial barriers to prevent general search competitors from
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`reaching consumers. And now, Google is demanding even more—
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`44.
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`Starting around 2011, consumers began migrating from personal desktop
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`computers to mobile devices. By 2017, most general search queries in the United States were
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`made on mobile devices, not desktop browsers. Google recognized that mobile devices offered
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`new and existing competitors an avenue to gain a foothold against Google by answering
`
`consumer queries on the go.
`
`45.
`
`In anticipation of the threat that the transition to mobile devices posed to its
`
`monopoly power, Google purchased Android, a mobile operating system, and then used Android
`
`to limit the reach of competing general search engines. It did this by restricting the ability of
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`Android mobile device manufacturers to provide consumers access to competing general search
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`engines on an equivalent basis as Google’s. For example, in exchange for the right to use
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`Android, Google required
`
` to make Google the default home screen and general search
`
`engine on its mobile devices. In addition, Google pays Android device manufacturers and U.S.
`
`mobile carriers
`
` dollars annually to ensure that Google remains the default general
`
`search engine and, in most cases, the exclusive general search services option distributed with
`
`the device. These revenue share agreements reinforce Google’s search advertising monopoly
`
`profits, which aids Google’s maintenance of existing search-related monopolies while generating
`
`future monopoly profits that can be used to buy more monopoly maintenance.
`
`46.
`
`Google’s agreement with Apple spans both personal computing and mobile
`
`devices. The estimated
`
` per year Google pays to Apple through its revenue share
`
`agreement entrenches Google as the default search engine on the Safari browser. Google’s
`
`contract with Apple extends to other search access points on Apple devices, such
`
`
`
`, which are preset with Google’s general search engine as
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`the default or exclusive option. Apple, of course, provides the only significant mobile operating
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`system other than Google’s Android.
`
`47.
`
`As a result of these unlawful contractual restrictions, Google’s general search
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`engine is the de facto search engine on nearly all mobile devices in the United States, and
`
`competition in general search services on mobile devices is stifled.
`
`48.
`
`As technology marches forward, new threats to Google’s dominance continue to
`
`emerge. Just as in mobile, new ways to search (by, for example, giving voice commands to a
`
`home speaker or to a car) present new avenues for competition. These new ways to search, free
`
`from Google control, could enable the use of rival general search engines. In response to these
`
`emerging threats, Google imposes the same contractual exclusivity it applies to mobile devices
`
`by, for example, barring the hardware manufacturers of voice assistant devices from permitting
`
`consumers to move seamlessly between Google Assistant and competing personal voice
`
`assistants, which serve as distribution channels for general search services. Google has even
`
`precluded the inclusion of rival personal assistant devices in any sales—even as a free addition—
`
`by a partner subject to its incentive program.
`
`49.
`
`Exclusion through Google’s general search advertising tool: Advertising tools
`
`that optimize companies’ search advertising purchases have become increasingly important to
`
`advertisers. Google’s own search advertising tool, SA360, serves more advertisers than any other
`
`tool. Such tools can promote competition in search advertising by, for example, allowing easy
`
`comparison of competing offers.
`
`50.
`
`Google has consistently assured advertisers that it would operate SA360 in a
`
`neutral manner. But Google harms competition by refusing interoperability to comparable
`
`advertising features offered by Microsoft’s Bing general search engine. Instead, Google
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`continuously favors advertising on its own platform and steers advertiser spending towards itself
`
`by artificially denying advertisers the opportunity to evaluate the options that would serve those
`
`advertisers best. No technical or operational barrier prevents SA360 from providing advertisers
`
`with direct and interoperable access to relevant data and important functionality from multiple
`
`general search engines.
`
`51.
`
`Suppression of specialized vertical providers: Google derives a substantial
`
`portion of its general search advertising monopoly rents from a handful of vertical commercial
`
`segments that represent a disproportionate share of its general search advertising revenue.
`
`General searches for travel and local services, like restaurants or plumbers, are prime examples.
`
`Google recognizes that
`
`
`
` by attracting consumers to their out-of-
`
`market specialized search tools directly, without using a general search engine to reach them
`
`(just as a new resident in a neighborhood stops using a map once having memorized the location
`
`of the local supermarket, doctor’s office, or dry cleaner).
`
`52.
`
`To artificially foreclose this opportunity and maintain its search-related
`
`monopolies, Google takes advantage of the fact that it has already banished rival general search
`
`engines to the fringes of the search-related markets, which has fostered an artificial dependence
`
`by specialized vertical providers on Google as a way to acquire customers. Doubling down on its
`
`exclusionary conduct, Google takes advantage of certain specialized vertical providers’
`
`dependence on Google, treating them differently than participants in other commercial segments
`
`and further limiting their ability to acquire customers.
`
`53.
`
`Google’s exclusion of general search engines through its mobile contracts makes
`
`specialized vertical providers particularly reliant on Google and vulnerable to Google’s
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`Case 1:20-cv-03715-APM Document 3 Filed 12/17/20 Page 21 of 115
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`exclusionary tactics. For example, Google sells advertisements to some specialized vertical
`
`providers, but, depending on the commercial segment involved, unnecessarily limits their utility.
`
`In some circumstances, Google prohibits specialized vertical providers that advertise from
`
`prominently displaying their own brand name or the links that would bring consumers to the
`
`specialized vertical providers’ own websites, preventing these specialized vertical providers from
`
`establishing or stewarding customer relationships. And by virtue of its monopoly power, Google
`
`extracts from some specialized vertical providers massive amounts of proprietary customer data
`
`that Google can then use to compete against them.
`
`54.
`
`Google’s exclusionary strategies against specialized