purpose of getting to another site on the web (e.g., “amazon,” “home depot,” “baltimore sun”)—are exclusive to GSEs. FOF ¶ 39. Nearly 12% of Google’s queries are navigational queries, and according to a 2018 Google weekly query report, its top five queries by query volume were all navigational queries. Id.
By contrast, SVPs are “walled gardens,” meaning their query responses are derived from structured data available only on that particular platform. FOF ¶ 144. Such data cannot typically be crawled by a GSE. FOF ¶¶ 45, 144. Because a user’s search is confined to the SVP’s structured data, users cannot use an SVP to navigate beyond the platform. FOF ¶ 144. For instance, Home Depot maintains a vast product catalog of goods that it sells both online and in stores. FOF ¶ 145. Users of Home Depot’s digital platforms can purchase those products from Home Depot but cannot navigate to a product-maker’s website to make a direct purchase. Id. In addition, as the name implies, SVPs are typically “specialized” to a particular subject matter (e.g., Amazon for shopping, Expedia for travel, Yelp for local businesses). FOF ¶¶ 141, 146. Although some SVPs do answer noncommercial queries, most notably Wikipedia, the vast majority do not. FOF ¶ 142. Thus, a user who wishes to acquire different categories of information could not do so from a single SVP and instead would have to take trips to multiple sites. FOF ¶¶ 33, 147. Even then, there are some types of queries—like long-tail queries—for which there may not be an SVP to deliver an answer. FOF ¶ 148.
The product delivered to consumers on a GSE differs significantly from what is produced by an SVP. When a user enters a query into Google or Bing, the result is a search engine results page, or SERP, which contains organic links that enable the user to navigate to other websites. FOF ¶¶ 41, 43. For commercial queries, the Google SERP will include advertisements, which similarly link to other webpages. FOF ¶ 172. And, in some cases, the SERP will contain vertical
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