Case 1:23-cv-00108 Document 1 Filed 01/24/23 Page 1 of 153 PageID# 1
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`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Alexandria Division
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`UNITED STATES OF AMERICA
`U.S. Department of Justice
`950 Pennsylvania Avenue NW
`Washington, DC 20530
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`COMMONWEALTH OF VIRGINIA
`202 North Ninth Street
`Richmond, VA 23219
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`STATE OF CALIFORNIA
`455 Golden Gate Avenue, Suite 11000
`San Francisco, CA 94102
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`STATE OF COLORADO
`1300 Broadway, 7th Floor
`Denver, CO 80203
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`STATE OF CONNECTICUT
`165 Capitol Avenue
`Hartford, CT 06106
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`STATE OF NEW JERSEY
`124 Halsey Street, 5th Floor
`Newark, NJ 07102
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`STATE OF NEW YORK
`28 Liberty Street, 20th Floor
`New York, NY 10005
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` JURY TRIAL DEMANDED
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`Case 1:23-cv-00108 Document 1 Filed 01/24/23 Page 2 of 153 PageID# 2
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`STATE OF RHODE ISLAND
`150 South Main Street
`Providence, RI 02903
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`and
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`STATE OF TENNESSEE
`P.O. Box 20207
`Nashville, TN 37202
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`Plaintiffs,
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`v.
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`GOOGLE LLC
`1600 Amphitheatre Parkway
`Mountain View, CA 94043
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`Defendant.
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`COMPLAINT
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`I.
`II.
`III.
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`IV.
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`Case 1:23-cv-00108 Document 1 Filed 01/24/23 Page 3 of 153 PageID# 3
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`Table of Contents
`Introduction ......................................................................................................................... 1
`Nature of this Action ........................................................................................................... 4
`Display Advertising Transactions ..................................................................................... 16
`A.
`How Ad Tech Tools Work .................................................................................... 16
`B.
`How Ad Tech Intermediaries Get Paid ................................................................. 22
`C.
`How Publishers and Advertisers Select Ad Tech Tools ....................................... 24
`D. Why Scale and the Resulting Network Effects are Necessary to Compete in
`Ad Tech ................................................................................................................. 26
`How Multi-Homing Enables Competition in the Ad Tech Stack ......................... 28
`E.
`Google’s Scheme to Dominate the Ad Tech Stack ........................................................... 30
`A.
`Google Buys Control of the Key Tools that Link Publishers and Advertisers ..... 31
`B.
`Google Uses Its Acquisitions and Position Across the Ad Tech Stack to Lock
`Out Rivals and Control Each Key Ad Tech Tool ................................................. 35
`1.
`Google Thwarts Fair Competition by Making Its Google Ads’
`Advertiser Demand Exclusive to Its Own Ad Exchange, AdX ................ 37
`In Turn, Google Makes Its Ad Exchange’s Real-Time Bids Exclusive
`to Its Publisher Ad Server ......................................................................... 43
`Finally, Google Uses Its Control of Publisher Inventory to Force More
`Valuable Transactions Through Its Ad Exchange .................................... 46
`Google’s Dominance Across the Ad Tech Stack Gives It the Unique
`Ability to Manipulate Auctions to Protect Its Position, Hinder Rivals,
`and Work Against Its Own Customers’ Interests ..................................... 55
`a)
`Google Works Against the Interests of Its Google Ads’
`Customers By Submitting Two Bids Into AdX Auctions ............. 57
`Google Manipulates Its Fees to Keep More High-Value
`Impressions Out of the Hands of Rivals ....................................... 60
`Google Buys and Kills a Burgeoning Competitor and Then Tightens the
`Screws ................................................................................................................... 65
`1.
`Google Extinguishes AdMeld’s Potential Threat ..................................... 65
`2.
`Google Doubles Down on Preventing Rival Publisher Ad Servers from
`Accessing AdX and Google Ads’ Demand .............................................. 68
`Google Manipulates Google Ads’ Bidding Strategy to Block Publisher
`Partnerships with Rivals ........................................................................... 71
`Google Responds to the Threat of Header Bidding by Further Excluding
`Rivals and Reinforcing Its Dominance ................................................................. 72
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`2.
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`3.
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`4.
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`b)
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`C.
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`D.
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`3.
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`i
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`

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`1.
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`2.
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`b)
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`c)
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`The Industry Attempts to Rebel Against Google’s Exclusionary
`Practices .................................................................................................... 72
`Google Blunts Header Bidding By “Drying Out” the Competition ......... 78
`a)
`Google Develops So-Called Open Bidding, Its Own Google-
`Friendly Version of Header Bidding To Preserve Its Control
`Over the Sale of Publisher Inventory ............................................ 78
`Google Further Stunts Header Bidding by Working to Bring
`Facebook and Amazon into Its Open Bidding Fold...................... 82
`Google Manipulates Its Publisher Fees Using Dynamic
`Revenue Sharing in Order to Route More Transactions
`Through Its Ad Exchange and Deny Scale to Rival Ad
`Exchanges Using Header Bidding ................................................ 86
`Google Launches Project Poirot to Manipulate Its Advertisers’
`Spend to “Dry Out” and Deny Scale to Rival Ad Exchanges
`That Use Header Bidding.............................................................. 90
`Google Imposes So-Called Unified Pricing Rules to Deprive
`Publishers of Control and Force More Transactions Through
`Google’s Ad Exchange ............................................................... 101
`Google Outright Blocks the Use of Standard Header Bidding
`on Accelerated Mobile Pages...................................................... 110
`Google Replaces Its Last Look Preference from Dynamic
`Allocation with an Algorithmic Advantage and Degrades Data
`Available to Publishers ............................................................... 113
`Anticompetitive Effects .................................................................................................. 116
`Relevant Markets ............................................................................................................ 123
`A.
`Geographic Markets ............................................................................................ 124
`B.
`Product Markets .................................................................................................. 124
`1.
`Publisher Ad Servers............................................................................... 124
`2.
`Ad Exchanges ......................................................................................... 126
`3.
`Advertiser Ad Networks ......................................................................... 129
`Jurisdiction, Venue, and Commerce ............................................................................... 131
`VII.
`VIII. Violations Alleged .......................................................................................................... 132
`IX.
`Request for Relief ........................................................................................................... 139
`X.
`Demand for a Jury Trial .................................................................................................. 140
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`d)
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`e)
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`f)
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`g)
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`V.
`VI.
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`ii
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`I.
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`INTRODUCTION
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`1.
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`An open, vibrant internet is indispensable to American life. But today’s internet
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`would not exist without the digital advertising revenue that, as a practical matter, funds its
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`creation and expansion. The internet provides the public with unprecedented access to ideas,
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`artistic expression, news, commerce, and services. Content creators span every conceivable
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`industry; they publish diverse material on countless websites that inform, entertain, and connect
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`society in vital ways. Yet the viability of many of these websites depends on their ability to sell
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`digital advertising space. Just as newspaper, radio, and television organizations historically relied
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`on advertising to fund their operations, today’s online publishers likewise rely on advertising
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`revenue to support their activities and reach. But unlike historical media advertising, today’s
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`online ads are bought and sold in enormous volumes in mere fractions of a second, using highly
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`sophisticated tools and automated exchanges that more closely resemble a modern stock
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`exchange than an old-fashioned, bilateral contract negotiation for newspaper ad space.
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`2.
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`Website publishers in the United States sell more than 5 trillion digital display
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`advertisements on the open web each year—or more than 13 billion advertisements every day.
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`The sheer volume of these online ads make the offline advertisements of yesteryear pale in
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`comparison. To put these numbers in perspective, the daily volume of digital display
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`advertisements grossly outnumbers (by several multiples) the average number of stocks traded
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`each day on the New York Stock Exchange. The digital display advertising business is also
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`lucrative. Collectively, these advertisements generate more than $20 billion in revenue per year,
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`just for publishers based in the United States.
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`3.
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`To meet this demand, sophisticated technological tools, informally known as “ad
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`tech,” have developed to automate advertising matchmaking between two key groups: website
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`1
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`publishers and advertisers.1 These tools have evolved such that today, every time an internet user
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`opens a webpage with ad space to sell, ad tech tools almost instantly match that website
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`publisher with an advertiser looking to promote its products or services to the website’s
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`individual user. This process typically involves the use of an automated advertising exchange
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`that runs a high-speed auction designed to identify the best match between a publisher selling
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`internet ad space and the advertisers looking to buy it.
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`4.
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`But competition in the ad tech space is broken, for reasons that were neither
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`accidental nor inevitable. One industry behemoth, Google, has corrupted legitimate competition
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`in the ad tech industry by engaging in a systematic campaign to seize control of the wide swath
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`of high-tech tools used by publishers, advertisers, and brokers, to facilitate digital advertising.
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`Having inserted itself into all aspects of the digital advertising marketplace, Google has used
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`anticompetitive, exclusionary, and unlawful means to eliminate or severely diminish any threat
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`to its dominance over digital advertising technologies.
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`5.
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`Google’s plan has been simple but effective: (1) neutralize or eliminate ad tech
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`competitors, actual or potential, through a series of acquisitions; and (2) wield its dominance
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`across digital advertising markets to force more publishers and advertisers to use its products
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`while disrupting their ability to use competing products effectively. Whenever Google’s
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`customers and competitors responded with innovation that threatened Google’s stranglehold over
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`any one of these ad tech tools, Google’s anticompetitive response has been swift and effective.
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`Each time a threat has emerged, Google has used its market power in one or more of these ad
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`1 Internet advertisers include businesses, agencies of federal and state governments, charitable
`organizations, political candidates, public interest groups, and more. The money these advertisers
`spend on digital advertising creates an important stream of revenue for websites to use in
`creating, developing, and publishing website content.
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`2
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`tech tools to quash the threat. The result: Google’s plan for durable, industry-wide dominance
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`has succeeded.
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`6.
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`Google, a single company with pervasive conflicts of interest, now controls:
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`(1) the technology used by nearly every major website publisher to offer advertising space for
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`sale; (2) the leading tools used by advertisers to buy that advertising space; and (3) the largest ad
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`exchange that matches publishers with advertisers each time that ad space is sold. Google’s
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`pervasive power over the entire ad tech industry has been questioned by its own digital
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`advertising executives, at least one of whom aptly begged the question: “[I]s there a deeper issue
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`with us owning the platform, the exchange, and a huge network? The analogy would be if
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`Goldman or Citibank owned the NYSE.”
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`7.
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`By deploying opaque rules that benefit itself and harm rivals, Google has wielded
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`its power across the ad tech industry to dictate how digital advertising is sold, and the very terms
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`on which its rivals can compete. Google abuses its monopoly power to disadvantage website
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`publishers and advertisers who dare to use competing ad tech products in a search for higher
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`quality, or lower cost, matches. Google uses its dominion over digital advertising technology to
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`funnel more transactions to its own ad tech products where it extracts inflated fees to line its own
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`pockets at the expense of the advertisers and publishers it purportedly serves.
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`8.
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`Google’s anticompetitive behavior has raised barriers to entry to artificially high
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`levels, forced key competitors to abandon the market for ad tech tools, dissuaded potential
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`competitors from joining the market, and left Google’s few remaining competitors marginalized
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`and unfairly disadvantaged. Google has thwarted meaningful competition and deterred
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`innovation in the digital advertising industry, taken supra-competitive profits for itself, and
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`3
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`prevented the free market from functioning fairly to support the interests of the advertisers and
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`publishers who make today’s powerful internet possible.
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`9.
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`The harm is clear: website creators earn less, and advertisers pay more, than they
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`would in a market where unfettered competitive pressure could discipline prices and lead to more
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`innovative ad tech tools that would ultimately result in higher quality and lower cost transactions
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`for market participants. And this conduct hurts all of us because, as publishers make less money
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`from advertisements, fewer publishers are able to offer internet content without subscriptions,
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`paywalls, or alternative forms of monetization. One troubling, but revealing, statistic
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`demonstrates the point: on average, Google keeps at least thirty cents—and sometimes far
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`more—of each advertising dollar flowing from advertisers to website publishers through
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`Google’s ad tech tools. Google’s own internal documents concede that Google would earn far
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`less in a competitive market.
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`10.
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`The United States and Plaintiff States bring this action for violations of the
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`Sherman Act to halt Google’s anticompetitive scheme, unwind Google’s monopolistic grip on
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`the market, and restore competition to digital advertising.
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`II.
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`NATURE OF THIS ACTION
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`11.
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`The seeds for Google’s eventual march toward a monopoly in ad tech were sown
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`in the early 2000s, when it capitalized on its well-known search engine to start a profitable
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`search advertising business. In 2000, Google launched Google Ads (then called AdWords2), a
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`tool that allowed businesses to buy advertisements that could be seen by Google search users
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`right alongside Google’s popular search engine results. Businesses quickly learned the power of
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`2 Over the period addressed by the Complaint, Google has renamed its ad tech products a number
`of times and has either shifted certain functions between products or combined its products in
`ways intended to obscure Google’s dominance across the ad tech stack.
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`4
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`this instantaneous, highly-targeted advertising technique, and they flocked to Google Ads as a
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`result.
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`12.
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`By the early 2000s, Google realized that these same advertisers would buy digital
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`advertisements on third-party websites as well. So Google stepped in to profit (as a middleman)
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`on digital advertising transactions having nothing to do with Google or its search engine by
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`creating an advertiser ad tech tool for Google Ads’ customers that wanted to buy ad space on
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`third-party websites.
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`13.
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`But Google was not satisfied with its dominance on the advertising side of the
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`industry alone; Google devised a plan to build a moat around the emerging ad tech industry by
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`developing a tool that would be used by website publishers as well.
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`14.
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`Google sought to develop an ad tech tool called a publisher ad server that
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`publishers would use to manage their online advertising sales. Google recognized that because
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`publisher ad servers set the rules for how and to whom publisher advertising opportunities are
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`sold, owning a publisher ad server was key to having visibility into, and control over, the
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`publisher side of digital advertising. By controlling the publisher ad server on the other end of
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`the transaction, Google could further entrench its advertiser customer base by giving advertisers
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`access to more advertising opportunities and pushing more transactions their way.
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`15.
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`Of course, by becoming the dominant player on both sides of the digital
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`advertising industry, Google could also play both sides against the middle. It could control both
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`the publishers with digital ad space to sell, as well as the advertisers who want to buy that space.
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`With influence over advertising transactions end-to-end, Google realized it could become “the
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`be-all, and end-all location for all ad serving.” The outsized influence it could obtain by having a
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`dominant position on both sides of the industry would give Google the ability to charge supra-
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`5
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`competitive fees and also enjoy an abiding dominance sufficient to exclude rivals from
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`competition. Google would no longer have to compete on the merits; it could simply set the rules
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`of the game to exclude rivals.
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`16.
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`The only problem with Google’s plan was that Google’s publisher ad server failed
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`to gain traction in the industry. So, Google pivoted to acquiring the market-leading publisher ad
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`server from an ad tech firm called DoubleClick. In early 2008, Google closed its acquisition of
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`DoubleClick for over $3 billion. Through the transaction, Google acquired a publisher ad server
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`(“DoubleClick for Publishers” or “DFP”), which had a 60% market share at the time. It also
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`acquired a nascent ad exchange (“AdX”) through which digital advertising space could be
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`auctioned. The DoubleClick acquisition vaulted Google into a commanding position over the
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`tools publishers use to sell advertising opportunities, complementing Google’s existing tool for
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`advertisers, Google Ads, and set the stage for Google’s later exclusionary conduct across the ad
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`tech industry.
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`17.
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`After the DoubleClick acquisition, Google enhanced and entrenched DFP’s
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`already-dominant market position. Google internally recognized that publisher ad servers are
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`“sticky” products, meaning that publishers rarely switch because of the high costs and risks
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`involved. As DoubleClick’s former CEO observed, “Nothing has such high switching costs. . . .
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`Takes an act of God to do it.” Thus, in order to lock more publishers into DFP and to reinforce
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`its stickiness, Google forged an exclusive link between Google Ads and DFP through the AdX
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`ad exchange. If publishers wanted access to exclusive Google Ads’ advertising demand, they had
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`to use Google’s publisher ad server (DFP) and ad exchange (AdX), rather than equivalent tools
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`offered by Google’s rivals. In effect, Google positioned itself to function simultaneously as
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`buyer, seller, and auctioneer of digital display advertising.
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`6
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`18.
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`Google’s strategy paid off. This arrangement has had a profound effect on the
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`evolution of digital advertising. First, it tilted the industry in Google’s favor, driving publishers
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`to adopt and stay on Google’s DFP publisher ad server in order to have access to Google Ads’
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`advertiser demand. Second, it cut off the possibility that Google Ads’ advertiser spending could
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`sustain, or encourage the entry of, a rival ad exchange or publisher ad server by providing critical
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`advertising demand. For the vast majority of webpage publishers, this arrangement made DFP
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`the only realistic publisher ad server option. Indeed, by 2015, Google estimated that DFP’s
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`publisher ad server market share had grown to a remarkable 90%. Google’s durable monopoly
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`over the publisher ad server market has allowed it to avoid innovation and competition by
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`controlling the very rules by which the game is played. As a result, other publisher ad servers
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`have left the market altogether, refocused on related markets, or faded into insignificance; no
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`new publisher ad servers have entered the market.
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`19.
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`Around the same time that Google tied its exclusive Google Ads’ advertiser
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`demand to its publisher ad server (DFP) through AdX, Google took two additional steps to make
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`it more difficult for rivals to compete.
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`20.
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`First, Google configured Google Ads to bid on Google’s AdX ad exchange in a
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`way that actually increased the price of advertising, to the benefit of publishers and the detriment
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`of Google’s own advertiser customers. As one Google employee observed, Google Ads was
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`effectively sending a “$3bn yearly check [to publishers] by overcharging our advertisers to
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`ensure we’re strong on the pub[lisher] side.” In the short-term, this conduct locked publishers
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`into Google’s publisher ad server by providing them a steady stream of intentionally-inflated
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`prices for certain inventory, at the cost of Google’s own advertiser customers. But in the long
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`run, Google’s actions harmed publishers as well by driving out rival publisher ad servers and
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`7
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`limiting competition in the publisher ad server market. In effect, Google was robbing from Peter
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`(the advertisers) to pay Paul (the publishers), all the while collecting a hefty transaction fee for
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`its own privileged position in the middle. This conduct turned the entire purpose of the digital
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`advertising industry on its head. Rather than helping to fund website publishing, Google was
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`siphoning off advertising dollars for itself through the imposition of supra-competitive fees on its
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`platforms. A rival publisher ad server could not compete with Google’s inflated ad prices,
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`especially without access to Google’s captive advertiser demand from Google Ads.
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`21.
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`Second, Google used its captive advertiser demand to thwart legitimate
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`competition by giving its AdX ad exchange an advantage over other ad exchanges through a
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`mechanism known as dynamic allocation. Dynamic allocation was a means by which Google
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`manipulated its publisher ad server to give the Google-owned AdX (and only AdX) the
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`opportunity to buy publisher inventory before it was offered to any other ad exchange, and often
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`to do so at artificially low prices. Google also programmed DFP, its publisher ad server, to
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`prevent publishers from offering preferential terms to other ad exchanges or allowing those
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`exchanges to operate in the same way with DFP. Google knew that dynamic allocation would
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`inevitably steer advertising transactions away from rivals, denying them critical scale needed to
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`compete, and would advantage AdX, where Google could extract the largest fees. Google’s
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`scheme predictably reinforced publishers’ dependence on both AdX and DFP. Publishers were
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`effectively precluded from using rival ad servers or ad exchanges that might better suit their
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`needs while Google was given a free pass from having to compete on the merits with those
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`rivals.
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`22.
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`By at least 2010, other ad tech companies had recognized that Google’s platforms
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`were not working in the best interest of publishers, and they attempted to develop innovative
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`Case 1:23-cv-00108 Document 1 Filed 01/24/23 Page 13 of 153 PageID# 13
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`technologies to introduce more competition. Some companies began offering “yield
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`management” functionality that helped publishers identify on a real-time basis better prices for
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`their inventory outside of Google’s products. Google recognized that yield managers posed a
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`major threat to the increasingly closed system Google sought to establish, in which only its ad
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`exchange was able to compete based on real-time pricing. So, in response, Google employed a
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`familiar tactic: acquire, then extinguish, any competitive threat.
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`23.
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`In 2011, Google acquired AdMeld, the leading yield manager, folded its
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`functionality into Google’s existing products, and then shut down its operations with non-Google
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`ad exchanges and advertiser tools. Google soon thereafter changed its AdX contract terms to
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`prohibit publishers from using any other platform (such as another yield manager) that would
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`force AdX to compete in real time with other ad exchanges. As a Google product manager wrote:
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`“Our goal should be all or nothing – use AdX as your [exchange] or don’t get access to our
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`[advertising] demand.” Unsurprisingly, this unabashed, anticompetitive conduct had a profound
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`effect on the market, denying rival ad tech competitors the scale necessary to compete and
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`depriving publishers the benefits of free market competition and real choice.
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`24.
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`Not long after, in 2013, Google launched Project Bernanke, a secret scheme to
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`manipulate the bids that Google Ads submitted into Google’s ad exchange, AdX, in order to win
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`more competitive transactions and solidify AdX’s dominance in the industry. Project Bernanke
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`allowed Google to suppress competition by preventing rival ad exchanges from achieving the
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`transaction volume and scale necessary to compete. Unless another ad exchange developed both
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`its own unique source of captive advertiser demand—where it could potentially manipulate
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`advertiser bids—and a widely-adopted publisher ad server—where it could see the same
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`advertising inventory and bid data as Google—competition on the same terms as Google was
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`9
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`Case 1:23-cv-00108 Document 1 Filed 01/24/23 Page 14 of 153 PageID# 14
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`nearly impossible. Once again, by controlling all sides of the ad tech industry, Google has been
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`able to manipulate the system in ways unique to itself so that, in the end, it did not have to
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`compete on the merits for customers and volume.
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`25.
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`Publishers and competing ad tech providers, increasingly wary of Google’s
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`bullying behavior, have continued to look for new ways to circumvent Google’s dominance.
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`Between 2012 and 2013, market participants began using a technique called “header bidding”
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`as a partial workaround to Google’s self-preferential algorithms and ad tech restrictions. As one
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`Google employee explained, “Publishers felt locked-in by dynamic allocation in [Google’s ad
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`server] which only gave [Google’s ad exchange] the ability to compete, so HB [header bidding]
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`was born.”
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`26.
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`Publishers used header bidding to take back some degree of power over their own
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`advertising transactions. They inserted header bidding computer code onto their own websites to
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`allow non-Google advertising exchanges an opportunity to bid for advertising inventory before
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`Google’s hard-coded preferences for its own ad exchange were triggered. Header bidding
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`allowed publishers to ensure that multiple advertising exchanges—not just Google’s AdX—
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`could bid on their inventory, thereby increasing the chances that they could find the best match.
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`27.
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`Google has refused to tolerate this new form of competition, even though it has
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`acknowledged in internal emails that header bidding had grown naturally out of Google’s being
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`“unwilling[] to open our systems to the types of transactions, policies and innovations that
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`buyers and sellers wish to transact.” Indeed, Google privately admitted that “header bidding and
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`header wrappers are BETTER than [Google’s platforms] for buyers and sellers,” and that
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`increased competition between AdX and publishers using header bidding would increase
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`publisher revenues by 30 to 40%, and would provide additional transparency to advertisers. Not
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`10
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`only would header bidding enable rival exchanges to compete more effectively against Google’s
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`ad exchange, it might also allow them or others to enter the publisher ad server market if Google
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`no longer had exclusive access to unique advertiser demand.
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`28.
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`Google executives described header bidding as an “existential threat.” They
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`worried that wider adoption of header bidding practices could lead to Google’s ad exchange
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`having to compete with other ad exchanges on a level playing field, where Google could no
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`longer set the rules in its own favor. If that were to happen, those rival ad exchanges might
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`actually succeed in eroding, or even breaking up, Google’s advertiser juggernaut, and the entire
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`industry could be opened up for competition. Google feared the worst: the entire moat of
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`anticompetitive protections that Google had built around the ad tech industry could be breached.
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`29.
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`Faced with this “existential” threat, Google sought to stem the rising tide toward
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`header bidding by promoting a Google-friendly analog of header bidding that Google
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`deceptively titled “Open Bidding.” Google has promoted Open Bidding as an answer to the
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`industry’s call for wider participation by rival ad exchanges and increased competition. In fact,
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`Open Bidding was a Trojan Horse that Google used to further cement its own monopoly power.
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`30.
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`As a condition to using Google’s Open Bidding, Google has required that
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`publishers and participating ad exchanges give Google visibility into each auction (including
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`how rival exchanges bid), allow Google to extract a sizeable fee on every transaction (even
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`where another exchange won), and limit the pool of advertisers allowed to bid in the auctions. In
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`doing so, Google’s ad exchange has retained a guaranteed seat in every auction, regardless of
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`whether Google’s ad exchange offers the best match between advertisers and publishers.
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`31.
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`Google also sought to co-opt what it perceived to be its two biggest threats
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`(Facebook and Amazon) into Open Bidding. In internal documents, Google concluded that while
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`it “[c]annot avoid competing with FAN [Facebook],” it could, through a deal with Facebook,
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`“build a moat around our demand.” Internal documents recommending a deal with Facebook
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`revealed Google’s primary motive: “[f]or web inventory, we will move [Facebook’s] demand off
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`of header bidding set up and further weaken the header bidding narrative in the marketplace.”
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`Thus, for these reasons, Google ultimately agreed to provide preferential Open Bidding auction
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`terms to Facebook in exchange for spend and pricing commitments designed to push more of
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`Facebook’s captive advertiser spend onto Google’s platforms. Google sought to head off
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`Amazon’s investment in header bidding technology with a similar offer, albeit without the same
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`success.
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`32.
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`Google also adjusted its auction mechanisms across its ad tech products to divert
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`more transactions to itself and away from rivals that might deploy header bidding. On the
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`publisher side, Google allowed AdX—and only AdX—to change its auction bid by altering
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`Google’s own fee after seeing the price to beat from another exchange.
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`33.
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`On the advertiser side, Google first considered outright blocking its advertiser
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`buying tool from buying inventory made available via header bidding. The goal: “dry out HB
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`[header bidding].” When Google decided that strategy would be too costly for Google, it pivoted
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`to a different and more insidious