building of a search index as a “Herculean problem”). Developing just the technical infrastructure alone requires billions of dollars. Id. at 1651:12-25 (Roszak).
51. A competitive analysis performed by Google illustrates the point. In late 2020, Google estimated how much it would cost Apple to create and maintain a GSE that could compete with Google. Google “estimate[d] that the total capital expenditures required [for Apple] to reproduce [Google’s technical] infrastructure dedicated to search would be in the rough order of $20[ billion].” UPX2 at 392–93; Tr. at 1644:8-20 (Roszak). Google further estimated that, if Apple needed only half of Google’s infrastructure to produce a competitive GSE, it would have to spend $10 billion to get it off the ground, plus $4 billion annually in technical infrastructure. UPX2 at 393. On top of that, if Apple could sustain a business with only one third of Google’s engineering and product management costs, it still would cost Apple $7 billion annually. Seven billion dollars was equal to more than 40% of Apple’s total research and development expenditure in 2019. Id.
52. The cost of maintaining a fully-integrated GSE once built runs into the billions of dollars. In 2020, Google spent $8.4 billion to operate its search engine (excluding revenue share payments). This expense is attributable to a variety of inputs. By way of example, the “petabytes” of user data that Google maintains are “expensive to store[.]” Tr. at 7824:2-3 (Fox); id. at 6337:2021 (Nayak) (“[T]he cost of processing the data goes up if we’re talking about large amounts of data.”). Certain highly effective ranking mechanisms, such as artificial intelligence-driven models, are computationally more expensive than others because they are costly to train and require significant engineering capabilities. See id. at 1931:17-20 (Lehman); id. at 6447:11-16, 6452:1-8, 6452:15-19 (Nayak); id. at 8278:15-18, 8281:13-24 (Reid).
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