FOF ¶ 166. There is no evidence that the massive growth of social media ads, for example, has come at the expense of search ads.
The record also shows that to the extent advertisers shift spending, they do so as part of a “full-funnel strategy.” Campaign goals may require a different blend of complementary advertising types to further a firm’s objectives. FOF ¶ 221. For instance, companies may shift ad spend to more upper-funnel strategies when introducing new products to create awareness but move ad spend to lower-funnel strategies if trying to increase seasonal sales of well-known products. FOF ¶¶ 226–227. The fact that advertisers may move money between search and social ads to achieve varying goals does not make them substitutes. See Klein v. Facebook, Inc., 580 F. Supp. 3d 743, 782–83 (N.D. Cal. 2022) (concluding that social ads are a distinct market from other online ads due to industry recognition, in part because, in contrast to search ads, “social advertisements help a company find customers who are not already looking for the company’s products”); FTC v. IQVIA Holdings Inc., No. 23-cv-06188 (ER), 2024 WL 81232, at *17 (S.D.N.Y. Jan. 8, 2024) (“An agency running an advertising campaign will not have an unlimited budget, so it must make decisions about how to allocate the advertising funds it has. But the fact that [search] competes with these channels for advertising dollars in a broader market does not necessarily mean those channels are reasonably interchangeable substitutes that must be included in the relevant product market.”).
The Nike-Meta episode does not help Google, either. In 2020, Nike boycotted advertising on Facebook, cutting all of its social spending on the platform for several months. According to Dr. Israel, Nike reallocated that spend to search and display ads and, when the boycott ended, Nike reverted the money to its social budget. Tr. at 8517:1–8518:13 (Israel) (discussing DXD29 at 83, 86–87). Per Google, this demonstrates reasonable interchangeability. But Dr. Whinston’s
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