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Page:United States v Google 20240805.pdf/31

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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 31 of 286

67. Individuals often are not aware that they are acting out of habit. Tr. at 542:4-12 (Rangel). Consequently, when users are habituated to a particular option, they are unlikely to deviate from it. As Google’s behavioral economics team wrote in 2021: “Inertia is the path of the least resistance. People tend to stick with the status quo, as it takes more effort to make changes.” UPX103 at 214; see also UPX171 at 190 (2015 Google study based on 26 user interviews; almost half of the users (12) did not notice a surreptitious change from Google to Bing on their iPhone; “People expressed interest (but not huge urgency) to switch back to Google”); Tr. at 7677:5–7682:19 (Pichai) (discussing UPX172, a 2005 letter from Google to Microsoft stating that “most end users do not change defaults”).

68. Many users do not know that there is a default search engine, what it is, or that it can be changed. Tr. at 548:24–549:3 (Rangel); id. at 9942:7-10 (Murphy); see UPX123 at 469, 485 (2007 Google study showing that the default homepage on a browser is “[c]onfigurable by user but very few know/care to change it” and that “[u]sers do not always make an active, deliberate choice of a” search engine); PSX216 at 126 (2016 Google-internal email identifying “one fundamental issue [a]s that users on Edge don’t even realize they aren’t using Google”); UPX66 at 73 (2018 Google study showing substantial user confusion regarding which browser and GSE was in use); UPX2051 at 520 (2020 Google study showing that over half of iPhone users in the United States were “unsure” which GSE powered Safari and concluding that users are “often unaware they’re using Google”).

69. Even users who “are not in this habitual mode and [] try to change the default will get frustrated and stop the process” if there is “choice friction.” Tr. at 547:5-16 (Rangel). “Choice friction” refers to the concept that subtle challenges or barriers make it increasingly more difficult

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