Jump to content

Page:United States v Google 20240805.pdf/34

From Wikisource
This page has been proofread, but needs to be validated.
Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 34 of 286

Safari default, and 80% of Android queries were through defaults secured by the distribution deals). Far fewer users search directly on Google’s website.

75. Google recognizes that securing the default placement is extremely valuable for monetizing search queries. In 2017, Google estimated that its default placements drove over half (then 54%) of its overall search revenue, a percentage that had grown since 2014. UPX83 at 968. For devices manufactured by Samsung—the largest Android OEM—80% of search revenue earned on those devices in 2016 flowed through default placements secured by the MADAs (Chrome and the Google Search Widget). See UPX639 at 266; UPX660 at 369. In 2019, about 50% of all search revenue on Android devices flowed through the Google Search Widget. UPX0316 at 906. In 2020, Google’s internal modeling projected that it would lose between 60–80% of its iOS query volume should it be replaced as the default GSE on Apple devices, UPX148 at 826, which would translate into net revenue losses between $28.2 and $32.7 billion (and over double that in gross revenue losses), UPX1050 at 887. And in a 2015 presentation, Google expressed confidence in its standing among Apple users, but warned that its position “is still very vulnerable if defaults were to change.” UPX171 at 186.

76. Neeva exemplifies the importance of search distribution through a readily accessible channel. Neeva secured the capital and human resources needed to build a search engine. Tr. at 3671:4–3672:13 (Ramaswamy). Although it initially syndicated search results from Bing, it eventually crawled the web, built an index, and developed a ranking model, which relied heavily on artificial intelligence technology, to generate its own search results for about 60% of its queries. Id. at 3775:9–3776:21, 3739:14-16 (Ramaswamy). But Neeva was unable “to be even a default provider on things like the major browsers or operating systems,” which “was what made [its founders] conclude that it was hard to have Neeva consumer search as a viable business.” Id.

30