33 (citing DX430 at 2). The internet of today is a far different animal. Hundreds of millions of dollars is just the opening ante to enter the search market in part because of the internet’s dramatic growth; billions are needed to acquire meaningful market share. See infra Section IV.A. The next great search engine (if there is to be one) will not be built in a rented garage like Google. See Microsoft, 253 F.3d at 56 (stating that this case is not about Microsoft’s “initial acquisition of monopoly power,” but about its “efforts to maintain this position through means other than competition on the merits”).
Finally, Google argues that regardless of its market share and any barriers to entry, its lack of monopoly power is confirmed by the dramatic growth in search output and its numerous innovations that have increased search quality. Cf. Qualcomm, 501 F.3d at 307 (“The existence of monopoly power may be proven through direct evidence of supracompetitive prices and restricted output.”).
Dr. Israel opined: “A firm has monopoly power if it can act like a monopol[ist], which means reduce market-wide output. So to establish market power directly, you would need to show that the firm has reduced output relative to some but-for world[.]” Tr. at 8439:8-11 (Israel). But restricted output is simply a form of direct proof. Its absence is not fatal, as indirect evidence suffices to establish monopoly power. See Mylan Pharms. Inc. v. Warner Chilcott Pub. Ltd. Co., 838 F.3d 421, 435–36 (3d Cir. 2016) (treating as direct evidence the absence of “markedly restricted output” but then evaluating indirect evidence of monopoly power). Also, reduced output is an ill-fitting indicia of monopoly power in a market like search. Google’s marginal cost of responding to one additional query is near zero. In such a market, a dominant firm has no incentive to restrict output to earn monopoly profits. See H. Øverby & Jan Arlid Audestad, Introduction to Digital Economics § 6.2 (2d ed. 2021) (For a digital good like search, “because the marginal cost is zero and [] there is no limit to the number of units that
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