the other hand, are visually driven and appear at the top of the SERP in what is referred to as a “carousel.” They are not integrated into the SERP results. FOF ¶¶ 177–178.
Second, advertisers write the “copy” for text ads but do not do so for PLAs. FOF ¶ 182. Advertisers value this control because it allows them to highlight discounts, seasonal offerings, new products, or other promotions. Id. PLAs offer little content other than a product image, its pricing, and its source. FOF ¶¶ 178, 183. For instance, Home Depot may purchase a PLA to sell a trash can that is currently on sale in response to the query “trash can.” But a PLA cannot promote its storewide Labor Day sale, during which all trash cans are 50% off. That information can be conveyed only with a text ad. FOF ¶¶ 179, 182.
Third, and perhaps most importantly, text ads are available to a far broader range of advertisers than PLAs. PLAs can feature only tangible goods because they can be depicted visually, whereas text ads may be used to sell all manner of goods and services. FOF ¶ 179. This distinction is crucial. Over 92% of Google’s advertisers only purchase text ads, while a mere 5.5% of Google’s advertisers purchase both. FOF ¶ 181 (only 2% of Google’s advertisers purchase PLAs but not text ads); see also id. (“In terms of revenue, 52.8% of ad dollars spent on Google came from advertisers who purchase only text ads.”). Notably, some of Google’s largest advertisers are travel sites, FOF ¶ 180, who have no use for PLAs. The breadth of advertiser access and usage is a key distinction between text ads and PLAs.
Industry or Public Recognition. Both Google and its advertisers recognize text ads as a distinct product submarket. Google has repeatedly acknowledged that text ads and shopping ads are different products. FOF ¶ 187. It even has different teams for text ads and PLAs. Id.
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