2. In addition, 38 other States and jurisdictions (the “Plaintiff States”) filed a separate action that incorporates the allegations

Google’s ability to avoid investing in quality improvements at the rate it would in a competitive market is a sign of monopoly power

In 2020, Google’s U.S. Search Ads market share was 74%. For YouTube in 2022, Google forecasted revenue of $[redacted] billion

The challenged contracts foreclose a substantial portion of each relevant market. And Google’s ownership of Chrome (which defaults to Google) magnifies that

Defaults are powerful in virtually all contexts. In fact, Google spends more money securing exclusive defaults than on all other search-related expenses

Google’s search distribution contracts harm competition in the general search services, Search Ads, and Text Ads markets in the United States in at least two wa

Because Google always sets itself as the Chrome search default, rivals cannot achieve distribution by being set as that default.

When deciding whether to invest in improvements in search quality, Google compares the costs of investment to the benefits, such as likely returns in revenue

“Scale” refers to the amount of user-side data a search engine accumulates. Userside data includes: (1) the user query, (2) the ranked results returned

Google permanently deletes all “off the record” communications after 24 hours if both users in a one-on-one chat have their retention history set to “off,”

Absent Google’s exclusionary contracts, consumers likely would have had significantly better and more varied search services.

Google’s payments are not passed through to consumers, and even if they were, the payments do not outweigh harm to competition in the relevant markets.

Those benefits are largely illusory, as Google has failed to substantiate them beyond conjecture from abstract principles of economics.

Google has long trained its employees to include attorneys on “any written communication regarding RevShare and MADA.”

At trial, Google and Plaintiffs reserved generalized objections to embedded hearsay in more than 100 exhibits otherwise admitted into evidence.

Google’s business model for the Android ecosystem (the “Android Model”) would not collapse if MADAs and RSAs did not require search default exclusivity.