has surpassed its revenue in retail advertising and is growing at a faster rate). Other SVPs are more recent market entrants and are looking to grow their search ads business. See Tr. at 8438:12-20 (Israel) (“[W]hat the lesson of commercial verticals has told us is that where there’s money to be made, SVPs pop up and they compete for advertising.”). These are not small firms likely to compete only at the margins. They include mega-retailers looking to aggressively expand their search ads business. Walmart and Target are two examples. Id. at 8549:9–8550:17 (Israel) (describing Walmart’s emergence as a search advertiser); Alberts Dep. Tr. at 40:5-10 (same as to Target). Online travel sites are another. Tr. at 5244:12-17 (Dijk) (describing Booking.com’s emerging search ads offerings). It is not surprising then that Google’s share of the search ads market has steadily eroded since 2017. Id. at 4779:7-15 (Whinston) (discussing UPXD102 at 63) (declining from near 80% in 2017 to 74% in 2020). U.S. Plaintiffs thus have not shown that the barriers to entering the search advertising market are comparable to those that protect Google’s monopoly in general search.
Meta’s experience in search ads does not counsel a different outcome. U.S. Plaintiffs argue that if a massive digital media company like Meta could not enter search ads successfully, no new entrant can be expected to survive. UPFOF ¶ 584 (describing Facebook’s “multiple unsuccessful attempts to enter the Search Ads market”). But U.S. Plaintiffs acknowledge that the reason for this failure had nothing to do with barriers to entry and instead was due to the difficulty of serving search ads on social media platforms. See id. ¶ 585 (“Google recognizes that, due to the nature of Facebook’s product, the social network is ill-suited to offer Search Ads.”) (citing Tr. at 1491:21–1492:2 (Dischler) (“The search feature is just not very important on Facebook for searching for products or services or other commercial things.”)). That social media is a poor fit for search ads
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