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Page:United States v Google 20240805.pdf/36

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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 36 of 286

download GSA, and most of those who were aware of GSA did not want to install it. See UPX139 at 149. Over half of Safari users had not installed GSA, and of those that had installed it, over 80% still preferred using Safari. Id. at 150.

80. Another non-default search access point is the bookmarks page on a browser. See Tr. at 10195:21–10196:3 (Murphy) (discussing DXD37 at 47). The Safari “Favorites” page, for instance, contains preloaded icons to access Google, Bing, and Yahoo. Id. A user also can add a new search engine on that page. But few consumers use this channel, as it first requires finding the Favorites page in a new Safari tab, which requires an “extra click[.]” Id. at 10101:19–10102:21 (Murphy). Google itself receives only 10% of its searches on Safari through the bookmark. Id. at 9758:16–9760:1 (Murphy) (discussing DXD37 at 52).

81. Users also can reach GSEs by downloading an alternative browser from an applications store or the web. For example, a user can download Chrome, Edge, or DDG onto an Apple device. This, too, is not an easily accessible search point, as it involves similar choice friction as acquiring a search application. Google receives only 7.6% of all queries on Apple devices through user-downloaded Chrome. Id.

82. To be sure, downloads of an alternative browser occur with greater frequency on Windows desktop computers. On such devices, Edge is the default browser and Bing is the default search engine. Id. at 3096:14-20 (Tinter). Yet, Google’s search share on Windows devices is 80%, with most of the queries flowing through the Chrome default, which means Chrome was downloaded onto the device. See id. at 9737:9-21 (Murphy) (discussing DXD37 at 36, 38). Google’s dominance on Windows cannot, however, be attributed simply to the popularity of Chrome. Google had an 80% search share on Windows when Chrome first launched, and that share has remained steady ever since (see below).

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