as relevant that “[t]he advertising industry and its customers . . . markedly differentiate between advertising in newspapers and in other mass media”). Advertisers have separate teams for search ads and other types of advertising, like display and social media. FOF ¶ 224. They also have separate budgets for those ad channels. Id.
Advertisers uniformly testified that they view search ads as unique because they respond to expressed user intent in real time. FOF ¶¶ 169–171, 218. Or, to put it in marketing terms, paid search is a “bottom funnel” ad channel or a “push” ad. FOF ¶¶ 213, 215, 218. Recall, the “marketing funnel” is a construct used in the advertising industry to generally depict a consumer’s journey from ignorance about a product (at the top of the funnel) to its purchase (at the bottom of the funnel). FOF ¶¶ 213–224. Advertisers attempt to correlate ad types with each stage of that journey based on the advertiser’s goal: promoting product awareness (upper funnel), addressing a consumer’s consideration of a purchase (mid-funnel), or driving sales (lower funnel). Id. Advertisers use the funnel as a framework when determining how to allocate their spending. FOF ¶¶ 221–222. They typically consider search as an ad channel better suited for “lower funnel” objectives than social media or display advertising. FOF ¶¶ 218–220.
Google asserts that the “industry and public recognition” factor weighs against a market for search advertising for two reasons. First, it vigorously contests the relevance of the marketing funnel. Google protests that the funnel is a dated tool with limited application in today’s digital ad market, especially given the explosion of social media advertising. GTB at 18–20; GRCL ¶ 7. It points to industry records that show greater fluidity among different stages of the funnel, and marketers conceiving of non-search ads as bottom-funnel media. GTB at 19–20. Google’s point is that advertisers shift spend to the ad type that they believe will return the greatest ROI, which
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