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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 24 of 286

44. Paid advertisements are typically generated in response to a commercial query and usually appear at the top of a SERP. See UPX1 at 533. Multiple types of advertisements can appear on a SERP, but the two primary ones are general search text ads (which resemble organic results but are labeled “sponsored” on Google) and shopping ads (which typically consist of a product photograph, vendor identity, and price information). See infra Section V.A.1.

45. A vertical offering is a category of specialized information that is accessible to users without leaving the SERP. Tr. at 2336:14-16 (Giannandrea); id. at 6509:7-21 (Nayak). Examples of verticals include information about flights, hotels, and restaurants. Such information is usually acquired from third parties and is referred to as “structured data.” Id. at 8224:18–8225:6 (Reid). Structured data can come from several sources: specialized vertical providers (like online travel sites), users, merchants, or GSE employees in the field. Id. Much of “th[is] information is not even on the web.” Id. at 8224:24-25 (Reid). Another example of structured data is a “knowledge graph,” which is a database containing useful information about people, places, and things, as well as the connections among them. See Moxley 30(b)(1) Dep. Tr. at 17:17-20; UPX1 at 533.

46. GSEs enter into data-sharing agreements with partners (usually specialized vertical providers) to obtain structured data for use in verticals. Tr. at 9148:2-5 (Holden) (“[W]e started to gather what we would call structured data, where you need to enter into relationships with partners to gather this data that’s not generally available on the web. It can’t be crawled.”). These agreements can take various forms. The GSE might offer traffic to the provider in exchange for information (i.e., data-for-traffic agreements), pay the provider revenue share, or simply compensate the provider for the information. Id. at 6181:7-18 (Barrett-Bowen).

47. As of 2020, Microsoft has partnered with more than 100 providers to obtain structured data, and those partners include information sources like Fandango, Glassdoor, IMDb,

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