See supra Section III.A.1. Thus, the mere fact that advertisers move some spending between text ads and PLAs does not, without more, make them substitutes.
Unique Production Facilities. Text ads are generated and sold through different means than PLAs. The appearance and content of text ads is controlled by the advertiser, who has substantial design input. FOF ¶¶ 182, 184. In contrast, Google designs PLAs; the advertiser merely supplies the inventory. FOF ¶ 183. While both text ads and PLAs are sold through auctions, the auctions are separate. FOF ¶ 185. And Google has rejected proposals to integrate the auctions because “user intent and advertiser value is different across the units, and as a result advertisers are not bidding on the same thing on Shopping and Text ads.” UPX1013 at .003; FOF ¶ 185. Finally, while PLAs appear on SVPs and other platforms, text ads are unique to GSE SERPs. Cf. FOF ¶ 193 (SVP search ads are almost exclusively PLAs).
Distinct Customers. As already discussed, text ads are open to nearly all advertisers, whereas PLAs can feature only tangible goods.
Google counters that “[t]he observation that some advertisers purchase only text ads (and not product listing ads), or do not advertise with certain major SVPs, does not show that general search text advertising is a relevant market because not all potential substitutes need to be equally compelling to all customers.” GCL ¶ 34; see also GRCL ¶ 9. But that argument largely misses the point. Over 92.0% of Google’s advertisers purchase only text ads. For that large cohort PLAs apparently will not do. A product that serves less than 10% of advertisers cannot be a substitute for one that serves all of them.
Distinct Prices. Text ads and PLAs are both priced on a cost-per-click, or CPC, basis. The prices of text ads, however, are higher than those of PLAs. FOF ¶ 186. Dr. Whinston’s analysis
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