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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 33 of 286

72. Google understands that switching on mobile is more challenging than on desktop. To illustrate, in 2016 and 2020, Google estimated that if it lost the Safari default placement, it would claw back more search volume on desktop than on mobile. See UPX142 at 886 (2016) (Google would recover only 30% on iOS but 70% on MacOS); UPX148 at 826 (2020) (same, projecting 60–80% query loss on iOS); see also UPX84 at 728 (2016) (“User behavior is more heavily influenced by default settings on mobile and tablet[.]”); UPX139 at 119 (2020) (“People are much less likely to change [the] default search engine on mobile.”).

73. Google appreciates that increased choice friction discourages users from changing the default. See UPX103 at 214 (2021 Google document from Google’s Behavioral Economics Team stating that a “[s]eemingly small friction points in user experiences can have a dramatically disproportionate effect on whether people drop or stick”); UPX848 at 612 (“[Y]ou want to think about each step, as small as it might be, and see if there is a way to eliminate it, delay it, simplify it, default it.”); UPX172 at 731 (“[O]f the tiny fraction of end users who try to change the default, many will become frustrated and simply leave the default as originally set[.]”).

74. A GSE’s placement as the default thus drives search volume through that access point. Tr. at 3689:21-24 (Ramaswamy) (testifying that “the convenience of easy accessibility and tapping into . . . engrained default behaviors are the deciding factors when it comes to whether a search engine gets lots of usage”); id. at 7674:6–7675:21 (Pichai) (“[B]ecause you’re taking existing users, and by giving them more convenient access points, you’re making them search more. . . . Done correctly, and if you’re putting a product out in front of users which users like and want to use, yes, defaults can make a difference.”). In 2017, over 60% of all queries entered on Google flowed through defaults. UPX83 at 967; see id. (60% of iOS queries were through the

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