products and services for which social media advertising is far less compelling (e.g., financial services). FOF ¶¶ 219–220.
To further underscore the distinction between search and social media ads, consider a new ad product recently introduced by Google: Demand Gen (or Discovery Ads). It is a feed-based ad platform for YouTube and Gmail, developed to better compete for advertising dollars going to Meta properties and TikTok, among others. Before its launch, Google recognized that it did not have an advertising channel that competed effectively for that highly lucrative ad spend. FOF ¶ 211; UPX29 at 541 (“Google has no direct competitor to Facebook’s ad offering[.]”). And, when describing the audience targeted for Discovery Ads, Google did so with terminology by now familiar to the reader. UPX33 at 145 (describing the social ads buyer as seeking to “create intent” and “find new customers,” as compared to the search ads buyer, who aims to “capture a person’s declared intent”) (2020). Thus, while Google as a firm may fiercely compete with Meta’s feed-based ads offerings, Google search ads do not.
Second, Google claims that U.S. Plaintiffs’ proposed market fails to account for the public’s consideration of different ad channels. Google argues that the market should be defined based on the degree of audience overlap. See GTB at 17–18 (citing Tr. at 4634:24–4635:11 (Whinston) (“The overlap between the audiences is really important for the amount of substitution there will be between ad products.”)). In other words, ads that target the same audiences should be treated as part of the same ad market. Google contends that “Plaintiffs’ ads markets exclude forms of digital advertising that feature a high degree of audience overlap while including those with less overlap.” Id. at 18. For instance, Google users typically do not also use Bing, FOF ¶ 21, but they do frequently use Amazon, FOF ¶ 157; see, e.g., GTB at 17–18, GFOF ¶¶ 1018–1024. So, Google argues, U.S. Plaintiffs are mistaken when they consider search ads on Bing in the same
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