at 3701:1-7 (Ramaswamy). The reason “why Neeva failed . . . was simply because [it] could not get enough users to be in that state where they regularly used Neeva.” Id. at 3712:10-12 (Ramaswamy); id. at 3677:2-3, 3700:25–3701:7 (Ramaswamy) (testifying that more users on Neeva would result in greater revenues through subscription fees); id. at 3724:18-21 (Ramaswamy) (“[I]f a well-funded and exceptionally talented team like Neeva could not even be a provider on most of the browsers, I don’t see that as the market working.”).
- 2. Other Search Access Points
77. There are access points other than the default that can be used to distribute a GSE, but those channels are far less effective at reaching users. That is due in part to users’ lack of awareness of these options and the “choice friction” required to reach these alternatives. FOF ¶¶ 65–73.
78. Users can download search applications on Apple devices from the App Store or on Android devices from the Google Play Store. Tr. at 1538:1-4 (Roszak); id. at 617:15-22 (Rangel). But to reach such applications, a user would have to (1) know the application exists and (2) download it. Those points of choice friction reduce the effectiveness of a search app as a channel of distribution. To illustrate the point: Google receives only about 10% of its searches on Apple devices through the Google Search App (GSA). Id. at 9758:16–9760:1 (Murphy) (discussing DXD37 at 52); id. at 2494:22-24 (Cue) (“[M]ost people are sitting on a browser, they don’t really want to go search on an app or a different app from that standpoint.”). (Google does not suffer from this problem on Android devices. GSA is preloaded on all Android devices sold in the United States.) See id. at 791:25–792:2 (Kolotouros); see also infra Section VI.B.1.
79. Google recognizes that the user-downloaded GSA is an ineffective way to reach users. A 2018 internal study revealed that over 35% of iOS users did not know they could
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