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Page:United States v Google 20240805.pdf/30

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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 30 of 286

64. Thus, only 30% of queries in the United States run through a search access point that does not default to Google. See id. at 5762:22–5763:13 (Whinston) (discussing UPXD104 at 37). (To be clear, those 30% of searches are not all run on GSEs other than Google. A large percentage of those searches still are entered into Google, but through channels other than the default search access points, such as user-downloaded Google Search app or a search on www.google.com.)

65. That users overwhelming use Google through preloaded search access points is explained in part by default bias, or the “power of defaults.” The field of behavioral economics teaches that a consumer’s choice can be heavily influenced by how it is presented. Id. at 526:7-21 (Rangel) (describing the concept of “choice architecture”). The consensus in the field is that “defaults have a powerful impact on consumer decisions.” Id. at 526:22-25 (Rangel).

66. According to U.S. Plaintiffs’ expert, Dr. Antonio Rangel, whose testimony the court credits, “the vast majority of individual searches, or queries, are carried out [by] habit,” because search is a high frequency activity done on a familiar device that provides an instant response. Id. at 543:2-9 (Rangel) (“Habits develop very strongly in those situations of high repetition and immediate feedback.”); see also id. at 543:14-19 (Rangel) (“When a consumer encounters their devices for the first time and they start searching, they start searching with the default search engine, which for many of them is the case. . . . If that search engine that is the default generates adequate experiences, the consumer will get habitized to that.”). A 2020 Google study confirmed this. A group of iOS users were asked what app they would choose to open a link in an email: Chrome, the Google Search app, or Safari? Regardless of the option the user selected, their leading rationale for doing so was “Habit/Regular Usage.” UPX757 at 628.

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