Distinguishing Them from Cluster Markets, 20 Antitrust Source 1, 3 (2021). As already discussed, GSEs are not a “one-stop shop” in the same sense as, say, an office-supply superstore (Staples) or a broadline distributor (Sysco). But they are a distinct product because only a GSE can answer any query—including, importantly, noncommercial and navigational queries. See Grinnell, 384 U.S. at 572–74 (stating that there is “no barrier to combining in a single market a number of different products or services where that combination reflects commercial realities” and the market concerns “a single basic service” that is “unique,” notwithstanding the existence of more specialized competitors). No SVP can match the breadth and comprehensiveness of a GSE. Thus, even if viewed as a “bundle” of search offerings, GSEs comprise a relevant product market.
Finally, the record shows that GSEs and SVPs are complementary goods, undermining Google’s contention that users view the two as true substitutes. Sysco, 113 F. Supp. 3d at 31 (observing that it “would be improper to group complementary goods into the same relevant market just because they occasionally substitute for one another”) (quoting Areeda & Hovenkamp, Fundamentals of Antitrust Law ¶ 565b (4th ed. 2017)). Dr. Baker demonstrated that SVPs receive between 33% to 88% of their traffic, depending on the subject matter area, through a click on a GSE’s SERP, whether through an organic link or an advertisement. FOF ¶ 155. Not surprisingly then, SVPs are Google’s top advertisers. FOF ¶ 156. This data shows that users are not uniformly bypassing Google and going directly to SVPs, thus confirming that SVPs do not cannibalize searches on Google.
As evidence that SVPs pose a competitive constraint, Dr. Israel analyzed queries on Google, Amazon, and Bing, and found that for Google’s top non-navigational shopping queries, Amazon had a significant query volume (3.7 million, as compared to Google’s 5.1 million). FOF ¶ 154. But Dr. Israel’s query volume analysis only reveals that users enter a large number of
150
