queries on both Google and Amazon. Unlike most goods, queries are free, so users face no cost constraint when using more than one site. Thus, the fact that large numbers of consumers use both Google and Amazon tells the court little about whether Amazon is “reasonably interchangeable” with Google. (The same is true for Dr. Israel’s analysis of queries on Yelp and the Auto, Flights, and Shopping verticals.)
Google’s own studies confirm that GSEs and SVPs are complementary goods, not substitutes. Google’s 2019 analysis, entitled “Project Charlotte,” showed that users who engaged with SVPs were more likely to enter queries on Google. FOF ¶ 157. The same is true on mobile applications: A 2020 Google study found a positive correlation between users’ activity on SVP applications and query volume on Google, such that a user’s adoption of Amazon, eBay, Walmart, Pinterest, Spotify, or Twitter was associated with increased revenues and queries on Google mobile. Id. Therefore, although SVPs can and do compete with GSEs for certain types of queries, the evidence does not show that such competition has led to less frequent use of GSEs. Consumers use GSEs and SVPs in a complementary manner to meet their online needs. See Microsoft, 253 F.3d at 52 (products that function “only as a supplement to” the proposed product market are not within the market).
With respect to social media platforms, there is little evidence that they actually compete with GSEs for search queries. Google presented an internal study suggesting that 63% of daily TikTok users aged 18–24 reported using the platform to perform searches within the last week, FOF ¶¶ 140, 163–164 (citing DX241), but that percentage alone tells the court little about actual substitution between GSEs and TikTok. Importantly, the study offers no detail on the types of searches performed or the quality of the results. There also is some evidence—albeit dated—that Facebook use correlates to more searching on Google. FOF ¶ 165. Thus, although it may be that
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