53. Adding features to the SERP also dramatically increases costs. UPX266 at 985 (explaining that “[f]eatures are even more incrementally expensive,” such as including web search and video search on a single SERP, which costs about five times more per query than web search alone). There are many other contributing costs.
54. Apple itself has estimated that it would cost $6 billion annually (on top of what it already spends developing search capabilities) to run a GSE. Tr. at 2295:9-16 (Giannandrea); UPX460 at 177.
55. But building and maintaining a GSE is only half of the cost equation. Monetizing a GSE is also an expensive proposition. In 2020, Google spent $11.1 billion to operate its search ads business. By comparison, it spent $8.4 billion on search (excluding revenue share payments). Tr. at 4764:12-20 (Whinston) (discussing UPXD102 at 52). In 2020, Bing earned only $7.7 billion total in search ads revenue. Id. at 4765:4-6 (Whinston) (discussing UPXD102 at 52).
56. As result of the extraordinary resources required to build, operate, and monetize a GSE, venture capitalists and other investors have stayed away from funding new search ventures. Id. at 2261:11-19, 2268:6-7 (Giannandrea) (stating that “a startup could not raise enough money . . . to build a very good, large-scale search engine” because “to build a competitive project is very expensive”); UPX240 at 507 (internal Apple document written by Giannandrea stating that “the reason a better search engine has not appeared is that it’s not a [venture capital] fundable proposition even though it’s a lucrative business”); Tr. at 3510:24–3512:7 (Nadella) (describing Silicon Valley’s view of venture funding of search as the “biggest no fly zone”).
57. New investment has not poured in despite the promise of high profit margins in general search. See UPX635 at 352 (Apple executive noting that “there aren’t so many businesses
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