does not mean that the market is protected by high entry barriers. It just means that the strength of social media advertising lies elsewhere.
In the end, courts “cannot be blinded by market share figures and ignore marketplace realities, such as the relative ease of competitive entry.” Tops Markets, 142 F.3d at 98–99. Here, the court finds that, notwithstanding Google’s leading market share, the recent history of new entrants, the strength of those entrants, and their growth show that barriers to entry are not so high as to compel the conclusion that Google has monopoly power in the market for search advertising. Cf. id. (finding no monopoly power by a retail supermarket in a local area where barriers to entry were low, despite 72% market share). U.S. Plaintiffs therefore have not proven a Section 2 violation in the search ads market.
- B. Google Has Monopoly Power in the General Search Text Ads Market.
- 1. General Search Text Ads Is a Relevant Product Market.
The court moves next to general search text advertising. As before, the court applies the Brown Shoe factors to determine the relevant product market and then addresses Google’s counterarguments. Each of the relevant Brown Shoe criteria warrants recognizing general search text advertising as a relevant product market.
Peculiar Characteristics and Uses. General search text advertisements, or “text ads,” are displayed on a SERP in response to a user’s query. FOF ¶¶ 175–176. Like search ads, they are distinguishable from social media and display ads for the reasons already stated, supra Section III.A.1. Text ads have various unique features that also differentiate them from other types of search ads, most notably shopping ads, or PLAs.
First, text ads have the appearance of organic search results and provide web links to the advertiser’s site. FOF ¶ 176. They can include an image but are largely text-based. Id. PLAs, on
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