revealed that while PLA prices remained stagnant or decreased from 2016 to 2020, text ads prices steadily climbed over that same period. Id.
Sensitivity to Price Changes. Over the years, Google has tested whether it can profitably raise its text ads prices by 5% or more without losing substantial advertisers, and the results have been largely consistent—it can. FOF ¶¶ 238–267; FTC v. Penn State Hershey Med. Ctr., 838 F.3d 327, 338 n.1 (3d Cir. 2016) (“The SSNIP is typically about 5%.”); Sysco, 113 F. Supp. 3d at 33– 34 (same). The court will delve further into the details of Google’s numerous ad experiments and feature launches, infra Section VI.B, but at present it is sufficient to say that the evidence firmly establishes modest advertiser sensitivity to small but significant text ads price increases. This reality is particularly acute for sellers of services or non-tangible goods, who cannot buy PLAs.
***
Accordingly, applying the Brown Shoe factors, Plaintiffs have proven that general search text ads is a relevant product market.
- 2. Google Has Monopoly Power in the General Search Text Ads Market.
Plaintiffs offer both direct and indirect evidence of Google’s monopoly power in the market for general search text advertising. The court starts with the indirect evidence.
Indirect Evidence. Google possesses a large and durable share in the text ads market, which is protected by significant entry barriers. In 2020, its market share in the text ads market was 88%, having grown steadily from 80% in 2016. FOF ¶ 192. Advertisers confirmed Google’s market dominance. They testified that their text ads spending allocation mirrors Google’s and Bing’s relative query volumes (i.e., 90% of spend on Google vs. 10% on Bing). FOF ¶ 232. They also emphasized that under no circumstances would they spend more than 10% of their text ads dollars on Bing, and that no other platforms were viable substitutes. FOF ¶ 233. As one advertising
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