387. That contract did not limit partners’ ability to preload “vertical and customizable search functionality such as restaurant search, local business search, application search, and video search” onto covered devices and states that those functions are “not General Web Search” within the meaning of the contract. Id.
388. The 2021 Google-Verizon RSA defines “Alternative Search Service” as “(a) any web or (b) any on-device search service that in response to queries incorporates multiple vertical search functionalities, and that, in each case of (a) and (b), offers functionality that is substantially similar to Google Search (as determined by Google in its reasonable discretion)[.]” JX93 at 489. This definition expressly carves out “search within a single mobile application that is limited to content within a particular, single or multiple vertical . . . that provides search results that [are] not substantially similar to Google Search (in its reasonable discretion)[.]” Id. The 2021 Google-Verizon RSA restricts the installation or promotion of Alternative Search Services, with a limited carve-out for Yahoo verticals, which was never implemented. FOF ¶¶ 371–375.
389. The 2021 Google-AT&T RSA defines “Alternative Search Service” as “any application, product, or service, other than Google Search, which, in response to queries, delivers search results consisting of (a) internet content or (b) content from multiple applications on a Device that [is] owned by entities that are not Affiliates of one another, in each case of (a) and (b), in a manner that is substantially similar to Google Search (as determined by mutual agreement of the Parties in accordance with section 7.2).” JX91 at 743. The AT&T agreement carves out similar functionality to the Verizon agreement, including any vertical content “that provides search results without searching the internet, other mobile applications, or web pages,” providing Spotify and Waze as examples. Id. The AT&T agreement prohibits AT&T from preloading or otherwise
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