Case 3:21-cv-00077 Document 1 Filed 01/29/21 Page 1 of 42 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
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`HD MEDIA COMPANY, LLC
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`Plaintiff,
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`vs.
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`GOOGLE, LLC and
`FACEBOOK, INC.
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`Defendants.
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`3:21-cv-00077
`CIVIL ACTION NO. _________________
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`COMPLAINT AND JURY DEMAND
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`INTRODUCTION
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`1.
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`“The basis of our governments being the opinion of the people, the very first
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`object should be to keep that right; and were it left to me to decide whether we should have a
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`government without newspapers, or newspapers without a government, I should not hesitate a
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`moment to prefer the latter.” Thomas Jefferson, Letter to Edward Carrington, Paris, Jan. 16,
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`1787, PrC (DLC), Published in PTJ, 11:48–50.
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`2.
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`The U.S. House Judiciary Committee, Subcommittee on Antitrust, Commercial,
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`and Administrative Law, recently concluded its antitrust investigation into the digital
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`advertising market with a 470-page report entitled “Investigation of Competition in Digital
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`Markets: Majority Staff Report and Recommendations” (“House Judiciary Report”) on October
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`6, 2020. See also Hearing, “Stacking the Tech: Has Google Harmed Competition in Online
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`Advertising?,” U.S. Senate Judiciary Committee, Antitrust, Competition Policy, and Consumer
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`Rights Subcommittee (September 15, 2020).
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`3.
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`As set forth in the House Judiciary Report, Defendants’ anticompetitive and
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`monopolistic practices have had a profound effect upon our country’s free and diverse press,
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`particularly the newspaper industry. Since 2006, newspaper advertising revenue, which is critical
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`for funding high-quality journalism, fell by over 50%. Newspaper advertising has declined from
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`$49 billion in 2006 to $16.5 billion in 2017. As a result of these falling revenues, the existence of
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`the newspaper industry is threatened. Nearly 30,000 newspaper jobs disappeared—a 60%
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`industrywide decline — from 1990 to 2016, according to the Bureau of Labor Statistics. Almost
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`20% of all newspapers have closed in the past 15 years, and “countless others have become
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`shells — or ‘ghosts’ — of themselves,” according to the recent report by the University of North
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`Carolina. The reduction in revenues to newspapers across the country, including Plaintiff, were
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`directly caused by Defendants’ conduct as set forth herein and went directly into Google’s
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`coffers:
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`
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`See David Chavern, Written Statement, Online Platforms and Market Power, Part 1: The Free
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`and Diverse Press, Committee on the Judiciary Subcommittee on Antitrust, Commercial, and
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`Administrative Law, United States House of Representatives (June 11, 2019).
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`4.
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`These hearings launched antitrust complaints filed by the Federal Trade
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`Commission, the Department of Justice, and more than forty State Attorneys General against
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`Google, LLC and Facebook, Inc. See U.S. et al. v. Google LLC, U.S. District Court for the
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`District of Columbia (Case 1:20-cv-03010) (Filed 10/20/20) (“DOJ v. Google case”); State of
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`Texas et al. v. Google LLC, U.S. District Court for the Eastern District of Texas, Sherman
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`Division (Case 4:20-cv-00957) (Doc. 1) (Filed 12/16/20) (“AGs v. Google case”); State of New
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`York et al. v. Facebook, Inc., U.S. District Court for the District of Columbia (Case 1:20-cv-
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`03589-JEB) (Filed 12/09/20) (“AGs v. Facebook case”); FTC v. Facebook, Inc, U.S. District
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`Court for the District of Columbia (Case 1:20-cv-03590-JEB) (Filed 12/09/20) (“FTC v.
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`Facebook case”).
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`5.
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`The allegations set forth herein are taken from the public record in the
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`proceedings referenced above. If proven to be true, Google and Facebook have monopolized the
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`digital advertising market thereby strangling a primary source of revenue for newspapers across
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`the country. This antitrust action is brought to seek all remedies afforded under law.
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`PARTIES
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`6.
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`Plaintiff, HD MEDIA COMPANY LLC (“HD Media” or “Plaintiff”), is a West
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`Virginia limited liability company with its principal office address at 946 Fifth Avenue,
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`Huntington, Cabell County, WV 25701. HD Media owns and operates several newspapers in
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`West Virginia, including The Herald-Dispatch in Huntington and Cabell County, the Charleston
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`Gazette-Mail, The Wayne County News, The Putnam Herald, the Williamson Daily News, The
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`Logan Banner, the Coal Valley News in Boone County, and The Independent Herald in
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`Pineville.
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`7.
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`These newspapers have roots dating back to the 1870s and serve as the primary
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`source of news journalism throughout West Virginia covering such events as the Monongah coal
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`mine disaster (1909) (the deadliest in America), Mother Jones and the coal wars including the
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`Matewan Massacre and Battle of Blair Mountain, the Great Flood of the Ohio River (1937), the
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`Marshall University plane crash (1970), the Buffalo Creek Disaster (1971), and the Sago Mine
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`disaster (2006), as well as the statewide opioid epidemic which won The Pulitzer Prize for
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`Investigative Journalism (2017).
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`8.
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`Plaintiff has the largest newspaper circulation in the State of West Virginia under
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`one ownership. Plaintiff’s newspapers provide an important and integral function of reporting
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`and publishing news to the citizens of West Virginia. In many instances, Plaintiff’s papers are
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`the major source of news for the West Virginia citizens they serve and are a primary source of
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`community news and commentary. As a direct result of the Defendants’ antitrust violations
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`described herein, and as set forth in more detail below, the newspapers in West Virginia are
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`currently under a very real existential threat to their existence. Without redress, these
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`newspapers, and hence the citizens of West Virginia, may well end up in the “news desert”
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`described below.
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`9.
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`Defendant, GOOGLE LLC (“Google”), is a limited liability company organized
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`and existing under the laws of the State of Delaware, and is headquartered in Mountain View,
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`California. Google is an online advertising technology company providing internet-related
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`products, including various online advertising technologies, directly and through subsidiaries and
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`business units it owns and controls. Google is owned by Alphabet Inc., a publicly traded
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`company incorporated and existing under the laws of the State of Delaware and headquartered in
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`Mountain View, California.1
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`10.
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`Defendant, FACEBOOK, INC. (“Facebook”), is a Delaware corporation with its
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`principal office or place of business situated in Menlo Park, California. At all times relevant to
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`1 See DOJ v. Google case at ¶18; AGs v. Google case at ¶21.
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`this Complaint, Facebook has operated its social-networking service through its website,
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`www.facebook.com, and mobile applications that connect users with Friends on Facebook.2
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`NATURE OF THIS ACTION
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`11.
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`H.D. Media, and other newspapers across the country, compete for revenue in the
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`digital advertising market. Google monopolizes the market to such extent that it threatens the
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`extinction of local newspapers across the country. There is no longer a competitive market in
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`which newspapers can fairly compete for online advertising revenue. Google has vertically
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`integrated itself, through hundreds of mergers and acquisitions, to enable dominion over all
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`sellers, buyers, and middlemen in the marketplace. It has absorbed the market internally and
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`consumed most of the revenue. Google’s unlawful anticompetitive conduct is directly stripping
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`newspapers across the country, including Plaintiff, of their primary revenue source.
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`12.
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`The freedom of the press is not at stake; the press itself is at stake. Plaintiff has
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`suffered an “antitrust injury” under Sections 1 and 2 of the Sherman Act. 15 U.S.C. § 2.
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`13.
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`Google and Facebook, archrivals in the digital advertising market, conspired to
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`further their worldwide dominance of the digital advertising market in a secret agreement
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`codenamed “Jedi Blue.” The two archrivals, who are sometimes referenced as operating a
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`duopoly in the market, unlawfully conspired to manipulate online auctions which generate digital
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`advertising revenue. Facebook and Google agreed to avoid competing with another in September
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`2018. The quid-pro-quo was as follows—Facebook would largely forego its foray into header
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`bidding and would instead bid through Google’s ad server. In exchange, Google agreed to give
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`Facebook preferential treatment in its auctions.
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`2 See AGs v. Facebook case at ¶21; Complaint, U.S. et al. v. Facebook Inc., United States District Court for the
`District of Columbia (Case 1:19-cv-02184-TJK) (Doc. 1) (Filed 07/24/19).
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`14.
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`This agreement closed a growing threat to Google’s primacy and has since further
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`cemented its stranglehold on the marketplace. These actions are illegal and directly caused
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`newspapers across the country, including the Plaintiff, enormous financial harm in the form of
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`loss of revenue sources. This is a per se violation of Section 1 of the Sherman Act which
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`declares “[e]very . . . conspiracy, in restraint of trade or commerce among the several States” to
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`be illegal. 15 U.S.C. § 1.
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`15.
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`The Clayton Act, 15 U.S.C § 12, et seq., operates in conjunction with the
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`Sherman Act to create private causes of action for violations of federal antitrust laws. See Blue
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`Shield of Va. v. McCready, 457 U.S. 465, 471, 102 S. Ct. 2540, 2544 (1982); Pfizer, Inc. v.
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`Gov’t of India, 434 U.S. 308, 311-13, 98 S. Ct. 584, 586-88 (1978).
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`16.
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`There is a direct causal connection between these antitrust violations and the harm
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`to the Plaintiff. The harm was intentional and intended. The harm is of a type that Congress
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`sought to redress in providing a private remedy for violations of the antitrust laws. The loss of
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`revenue streams can be directly tied to the antitrust conduct of the Defendants. Plaintiff is a
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`direct victim of the alleged antitrust injury as a competitor in the digital advertising market.
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`Damages can be quantified and apportioned among those directly and indirectly harmed.
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`17.
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`In its Complaint, Plaintiff does not allege a breach of any contract, nor a dispute
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`regarding the performance of a contractual term, with Defendants. Plaintiff alleges two distinct
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`antitrust causes of action: (1) Google unlawfully exercised monopoly power of the digital
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`advertising market (both search advertising and display advertising) which is a Sherman Act §2
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`violation and a violation of W.Va. Code § 47-18-4; and (2) Google and Facebook unlawfully
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`conspired to engage in anticompetitive conduct which is a per se Sherman Act §1 violation
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`(including the sealed Jedi Blue agreement) and a violation of W.Va. Code § 47-18-3. Nothing
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`herein should be construed to allege a breach of, nor arise out of, any terms of use governing any
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`contractual agreement between Plaintiff and Defendants.
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`JURISDICTION AND VENUE
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`18.
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. §§
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`1331 and 1337; Section 2 of the Sherman Act, 15 U.S.C. § 2, et seq.; and Sections 3, 4 and 16 of
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`the Clayton Act, 15 U.S.C. §§ 14, 15 and 26 because plaintiff alleges violations of federal law.
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`This Court has supplemental jurisdiction over Plaintiff’s state law claims under 28 U.S.C. § 1367
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`because those claims are so related to Plaintiff’s claims under federal law that they form part of
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`the same case or controversy.
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`19.
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`This Court also has jurisdiction over this action under statutory authority of 28
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`U.S.C. § 1332 in that Plaintiff is a citizen of West Virginia and all Defendants are citizens of
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`states other than West Virginia and the amount in controversy well exceeds $75,000.00 exclusive
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`of interest and costs.
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`20.
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`Venue and jurisdiction are proper in this District pursuant to 15 U.S.C. § 22
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`because Defendants transact business in this District.
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`a)
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`At all times material herein, Google engaged in regular, practical, everyday
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`business of a substantial character in this District, including Cabell County. Upon
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`information and belief, Google is the largest provider of digital advertising in this
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`District, including Cabell County, and Google regularly directs commercial
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`activity to this District by targeting and supplying consumers within this District
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`with directed advertisements. Google operates its products within this District on
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`a regular and everyday basis, which are used by thousands and thousands of
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`consumers within this District each day. These products include Google Search,
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`Chrome, YouTube, Gmail, Android, Google Maps, Good Drive, and Google Play
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`Store. Google is ubiquitous across the digital economy in this District. Its contacts
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`with this district are regular and continuous; they are not isolated and sporadic.
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`Google also derives substantial revenue from the operation and use of its products
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`within this District.
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`b)
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`Facebook is the largest social networking platform in this District. Each day,
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`thousands and thousands of consumers within this District access Facebook and
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`its family of products, including Facebook Blue, Instagram, Messenger, and
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`WhatsApp. Facebook also regularly directs commercial activity to this District by
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`serving directed and targeted advertisements to consumers within this District.
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`Facebook derives substantial revenue from its commercial activities in this
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`District. Its contacts in this District are regular, constant, and of a substantial
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`character. Facebook’s activities are not isolated or sporadic.
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`21.
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`Venue is also proper in this District pursuant to 28 U.S.C. § 1391(b) in that a
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`substantial part of the events or omissions giving rise to this action occurred in this judicial
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`district.
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`22.
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`This Court also has personal jurisdiction over each of these Defendants in that, at
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`all times material herein, they transacted business in West Virginia; contracted to supply services
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`or things in West Virginia; and/or committed acts and/or omissions in or outside West Virginia
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`which caused tortious injury to Plaintiff.
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`23.
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`Defendants’ conduct as alleged herein has had a substantial effect on interstate
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`and intrastate commerce. At all material times, Google and Facebook participated in the conduct
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`set forth herein in a continuous and uninterrupted flow of commerce across state and national
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`lines and throughout the United States.
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`FACTUAL ALLEGATIONS
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`A.
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`24.
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`The Importance of a Free and Diverse Press and the Decline of Local
`Newspapers.
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`A free and diverse press is essential to a vibrant democracy. Whether exposing
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`corruption in government, informing citizens, or holding power to account, independent
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`journalism sustains our democracy by facilitating public discourse.
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`25.
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`Newspapers have played a key role in our democracy since its founding.
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`“Journalism is said to be the first rough draft of history. . . . The Federalist Papers were first
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`published in newspapers in New York in 1787-88 to promote the ratification of the United States
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`Constitution. The fact that policy debates today are informed by the public forum offered by
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`newspapers in the past is a reminder that the media have been intertwined with and integral to
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`democracy since the founding.”3
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`26.
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`“The liberty of the press ought not to be restrained.” Alexander Hamilton, THE
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`FEDERALIST PAPERS: NO. 84 (1791).
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`27.
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`Congress has declared: “In the public interest of maintaining a newspaper press
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`editorially and reportorially independent and competitive in all parts of the United States, it is
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`hereby declared to be the public policy of the United States to preserve the publication of
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`newspapers in any city, community, or metropolitan area where a joint operating arrangement
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`has been heretofore entered into because of economic distress or is hereafter effected in
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`accordance with the provisions of this chapter.” 15 U.S.C. §§ 1801, et seq.
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`28.
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`In 1995, Microsoft CEO Bill Gates circulated an internal memorandum to
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`executive staff which concluded: “The Internet is a tidal wave. It changes the rules. It is an
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`incredible opportunity as well as incredible challenge[.]”4 As a result, newspapers have seen a
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`steady decline in circulation.5 According to the Pew Research Center, U.S. newspaper circulation
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`fell in 2018 to its lowest level since 1940, the first year with available data. 6
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`29.
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`Since 2006, newspaper advertising revenue, which is critical for funding high-
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`quality journalism, fell by over 50%. Despite significant growth in online traffic among the
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`nation’s leading newspapers, print and digital newsrooms across the country are laying off
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`reporters or folding altogether. As a result, communities throughout the United States are
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`increasingly going without sources for local news. The emergence of platform gatekeepers—and
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`the market power wielded by Google and Facebook—has contributed to the decline of
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`trustworthy sources of news.
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`30.
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`Since 2006, the news industry has been in economic freefall, primarily due to a
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`massive decrease in advertising revenue caused by Defendants’ anticompetitive and unlawful
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`conduct. Both print and broadcast news organizations rely heavily on advertising revenue to
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`support their operations, and as the market has shifted to digital platforms, news organizations
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`3 Sandra Feder, Stanford Report, Interview with James Hamilton, Hearst Professor of Communication at Stanford
`University’s
`School
`of
`Humanities
`and
`Sciences,
`February
`27,
`2020:
`https://news.stanford.edu/2020/02/27/journalism-and-democracy/
`4 https://www.justice.gov/sites/default/files/atr/legacy/2006/03/03/20.pdf. Microsoft proceeded
`to monopolize
`internet access resulting in a consent decree with the U.S. Department of Justice to resolve antitrust claims. United
`States v. Microsoft Corp., 231 F. Supp. 2d 144, 149 (D.D.C. 2002).
`5 Penelope Muse Abernathy, News Deserts And Ghost Newspapers: Will Local News Survive?, The Center for
`Innovation and Sustainability in Local Media, Hussman School of Journalism and Media, University of North
`Carolina at Chapel Hill (2020) (2020_News_Deserts_and_Ghost_Newspapers.pdf (usnewsdeserts.com).
`6 Pew Research Center is a nonpartisan fact tank that informs the public about the issues, attitudes, and trends
`shaping the world. It does not take policy positions. The Center conducts public opinion polling, demographic
`research, content analysis, and other data-driven social science research. It studies U.S. politics and policy;
`journalism and media; internet, science, and technology; religion and public life; Hispanic trends; global attitudes
`and trends; and U.S. social demographics and trends.
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`have seen the value of their advertising space plummet steeply. For newspapers, advertising has
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`declined from $49 billion in 2006 to $16.5 billion in 2017. National and local news sources alike
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`have felt this decrease.
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`31.
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`As a result of falling revenues, newspapers are steadily losing the ability to
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`financially support their newsrooms, which are costly to maintain but provide immense value to
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`their communities. A robust local newsroom requires the financial freedom to support in-depth,
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`sometimes years-long reporting, as well as the ability to hire and retain journalists with expertise
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`in fundamentally local issues, such as coverage of state government.
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`32.
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`Budget cuts have also led to a dramatic number of newsroom job losses. This
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`decline has been primarily driven by a reduction in newspaper employees, who have seen
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`employment fall by half over a recent eight-year period, from 71,000 in 2008 to 35,000 in 2019.
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`In 2019 alone, 7,800 media industry employees were laid off. The Bureau of Labor Statistics
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`estimates that the total employment of reporters, correspondents, and broadcast news analysts
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`will continue to decline by about 11% between 2019 and 2029.
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`33.
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`Researchers at the University of North Carolina School of Media and Journalism
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`found that the United States has lost nearly 1,800 newspapers since 2004 either to closure or
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`merger, 70% of which were in metropolitan areas. As a result, the majority of counties in
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`America no longer have more than one publisher of local news, and 200 are without any paper.
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`34.
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`According to a recent article published by the University of North Carolina, many
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`citizens across the country now live in a “news desert” as a result of these closures and layoffs:
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`and demographic trends. All of the Center’s reports are available at www.pewresearch.org. Pew Research Center is
`a subsidiary of The Pew Charitable Trusts, its primary funder.
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`35.
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`In order to survive in the digital marketplace, newspapers were forced to
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`transition revenue sources from traditional print advertisements to digital advertising.
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`Unfortunately, the illegal monopolization of digital advertising by Google, along with private
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`agreements with Facebook, have prevented newspapers from competing on the merits in the
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`digital advertising market.
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`36.
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`Local journalism is essential for healthy communities, competitive marketplaces,
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`and a thriving democracy. Unfortunately, the local news industry is being decimated in the
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`digital age. This is due both to the rapid proliferation of online news content as well as unfair
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`market practices by some of the world’s largest technology companies that reuse local news’
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`content, data, customers, and advertisers. Report, “Local Journalism: America’s Most Trusted
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`News Sources Threatened,” U.S. Senate Committee on Commerce, Science, and Transportation
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`(October 2020).
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`B.
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`Digital Advertising Market
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`37.
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`There are two principal forms of digital advertising: search advertising and
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`display advertising.
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`38.
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`“Search advertising” refers to digital ads on desktop or mobile search engines,
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`such as the Google.com homepage, displayed via “search ad tech” alongside search engine
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`results. Search advertising is often bought and sold via real-time bidding (RTB) auctions among
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`advertisers, where advertisers set the price they are willing to pay for a specific keyword in a
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`query.
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`39.
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`“Display advertising” refers to the delivery of digital ad content to ad space on
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`websites and mobile apps, which is referred to as “inventory.” Within display advertising, there
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`are two separate “ad tech” market platforms: first-party and third-party.
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`40.
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`“First-party display ad tech platforms” sell ad space on their own platforms
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`directly to advertisers. For example, Facebook sells ad space on its platform to advertisers.
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`Google sells display ads on its own properties such as YouTube.
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`41.
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`“Third-party display ad tech platforms” are run by intermediary vendors and
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`facilitate the transaction between third-party advertisers and third-party publishers. Here,
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`specialized software automates the buying and selling of digital ads through an ad exchange.
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`C.
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`The Third-Party Ad Tech Suite
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`42.
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`Sell-side software includes publisher ad servers. The primary function of a
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`publisher ad server is to fill ad space on a publisher’s website that is personalized to the interests
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`of a specific website viewer. Sell-side software also includes ad networks, which aggregate ad
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`inventory from many different publishers and divide
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`that
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`inventory based on user
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`characteristics—such as age or location. Ad networks sell the pool of inventory through ad
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`exchanges or demand-side platforms (DSPs).
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`43.
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`Buy-side software includes advertiser ad servers, that is, software that stores,
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`maintains, and delivers digital ads to the available inventory. Advertiser ad servers facilitate the
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`programmatic process that makes instantaneous decisions about which advertisements to display
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`on which websites to which users and displays the ad on that site. Ad servers collect and report
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`data, such as ad impressions and clicks, for advertisers to monitor ad performance and track
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`conversion metrics. Buy-side software also includes demand-side platforms, software that allows
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`advertisers to buy advertising inventory from a range of publishers. Demand-side platforms use
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`data to create targeted ad audiences and engage in purchasing and bidding.
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`44.
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`Approximately 86% of online display advertising space in the U.S. is bought and
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`sold in real-time on electronic trading venues, which the industry calls “advertising exchanges.”7
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`Ad exchanges refer to the ad trafficking system that connects advertisers looking to buy
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`inventory with publishers selling inventory. Sales on ad exchanges occur primarily through: (1)
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`open real-time bidding auctions; (2) closed real-time bidding auctions; or (3) programmatic
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`direct deals. The ad tech suite also includes analytics tools that allow advertisers and publishers
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`to measure ad campaign efficiency, including consumers’ interactions with an ad. Similarly, data
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`management platforms aggregate and store consumer data from various sources and process the
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`7 Dina Srinivasan, Why Google Dominates Advertising Markets Competition Policy Should Lean on the Principles
`of Financial Market Regulation, 24 Stan. Tech. L. Rev. P55, 58 (2020).
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`data for analysis. Advertisers and publishers use data management platforms to track, partition,
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`and target consumer audiences across websites.
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`45.
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`The Ad Exchange connects advertisers looking to buy inventory with publishers
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`selling inventory. With intermediaries that route buy and sell orders, the structure of the digital
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`advertising market is similar to the structure of electronically traded financial markets. In digital
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`advertising, a single company, Google, simultaneously operates the leading trading venue, as
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`well as the leading intermediaries that buyers and sellers go through to trade. At the same time,
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`Google itself is one of the largest sellers of ad space globally. Google monopolizes advertising
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`markets by engaging in conduct that lawmakers prohibit in other electronic trading markets:
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`Google’s ad exchange shares superior trading information and speed with the Google-owned
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`intermediaries, Google steers buy and sell orders to its own exchange and websites (for example,
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`Google Search & YouTube), and Google abuses its access to inside information.8
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`46.
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`The digital advertising market is highly concentrated, with Google and Facebook
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`controlling the majority of the digital advertising market in the United States, capturing nearly all
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`of its growth in recent years.
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`47.
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`Over the last decade, the digital advertising market has experienced double-digit
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`year-over-year growth. The market, however, has become increasingly concentrated since the
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`advent of programmatic trading. In 2017, Business Insider reported that Google and Facebook
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`accounted for 99% of year-over-year growth in U.S. digital advertising revenue. Today,
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`advertisers and publishers alike have few options when deciding how to buy and sell online ad
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`space.
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`8 Id.
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`48.
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`This concentration likely exists in part due to high barriers to entry. Google and
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`Facebook both have a significant lead in the market due to their significant collection of
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`behavioral data online, which can be used in targeted advertising. Additionally, Google and
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`Facebook do not provide access to this unique data in open data exchanges. Advertisers only
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`access to this information is indirect—through engagement with Google and Facebook’s ad tech
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`suite.
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`49.
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`This significant level of concentration in the online advertising market—
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`commonly referred to as the digital ad duopoly—has harmed the quality and availability of
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`journalism. As a result of this dominance, there has been a significant decline in advertising
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`revenue to news publishers, undermining publishers’ ability to deliver valuable reporting and
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`“siphon[ing] revenue away from news organizations.” House Judiciary Report, p. 70.
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`50.
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`There is a clear correlation between layoffs and buyouts in the newspaper industry
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`with the growth in market share for the duopoly—Google and Facebook. The internet
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`distribution systems distort the flow of economic value derived from good reporting. The effects
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`of this revenue decline are most severe at the local level, where the decimation of local news
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`sources is giving rise to local news deserts.
`
`D.
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`51.
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`Google‘s Digital Advertising Market Monopoly.
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`All roads lead through Google. See Fiona Scott Morton & David Dinielli,
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`Roadmap for a Digital Advertising Monopolization Case Against Google (May 2020); Fiona
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`Scott Morton & David Dinielli, Roadmap for a Monopolization Case Against Google Regarding
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`the Search Market (May 2020). These two papers together show how Google monopolized
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`general search and used that dominance as a springboard to build and maintain dominance in the
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`digital display advertising market as well.
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`52.
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`Google was launched in 1998 as a general online search engine. Founded by
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`Larry Page and Sergey Brin, the corporation got its start by serving users web results in response
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`to online queries. Google’s key innovation was its PageRank algorithm, which ranked the
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`relevance of a webpage by assessing how many other webpages linked to it. In contrast with the
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`technology used by rival search engines, PageRank enabled Google to improve the quality of its
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`search results even as the web rapidly grew. While Google had entered a crowded field, by 2000
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`it had become the world’s largest search engine. Later that year Google launched AdWords, an
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`online advertising service that let businesses purchase keywords advertising to appear on
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`Google’s search results page—an offering that would evolve to become the heart of Google’s
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`business model.
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`53.
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`Today, Google is ubiquitous across the digital economy, serving as the
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`infrastructure for core products and services online. It has grown and maintained its search
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`engine dominance, such that “Googling” something is now synonymous with online search itself.
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`The company is now also the largest provider of digital advertising, a leading web browser, a
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`dominant mobile operating system, and a major provider of digital mapping, email, cloud
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`computing, and voice assistant services, alongside dozens of other offerings. Nine of Google’s
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`products—Android, Chrome, Gmail, Google Search, Google Drive, Google Maps, Google
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`Photos, Google Play Store, and YouTube—have more than a billion users each.
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`54.
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`Google established its position through acquisition, buying up successful
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`technologies that other businesses had developed. In a span of twenty years, Google purchased
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`well over 260 companies.
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`55.
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`Google is now one of the world’s largest corporations. For 2019, Google reported
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`total revenues of $160.7 billion—up 45% from 2017—and more than $33 billion in net income.
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`56.
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`Although Google has diversified its offerings,