of Google’s overall queries by type. FOF ¶ 151; FOF ¶ 38 (80% of queries on Google are noncommercial in nature); see also 548 F.3d at 1048 (Tatel, J., concurring) (“That Whole Foods and Wild Oats have attracted many customers away from conventional grocery stores by offering extensive selections of natural and organic products thus tells us nothing about whether [they] should be treated as operating in the same market as conventional grocery stores.”). That Google and Amazon have some overlapping users does not, without more, mean they belong in the same product market.
Third, there is nothing improper about aggregating varied query types into a single relevant market. According to Dr. Israel, the “clustering” of different verticals into a single market is appropriate only when the competitive conditions are similar, that is, when information providers are competing to resolve similar user questions, such as those related to travel. See Tr. at 8400:623 (Israel); ProMedica Health Sys., Inc. v. FTC, 749 F.3d 559, 565 (6th Cir. 2014) (“If the [competitive] conditions are similar for a range of services, then the antitrust analysis should be similar for each of them.”). He acknowledges that there may be submarkets for travel or shopping or local queries, but he rejects an overarching market that collects those submarkets under the umbrella of general search. See Tr. at 8399:7–8400:23 (Israel).
But Dr. Israel’s “cluster” market principle does not apply here, because a GSE is better thought of as a “bundle” of offerings. Cf. Whole Foods, 548 F.3d at 1039 (Brown, J.) (recognizing a “cluster” market based on “a core group of particularly dedicated, distinct customers, paying distinct prices”). “Unlike cluster markets, which aggregate a number of individual relevant markets, a bundle market is the collection of products or services that comprise the relevant market where customers value suppliers offering a package of goods and benefit from the ‘one-stop shopping’ experience.” Kevin Hahm & Loren K. Smith, Clarifying Bundle Markets and
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