devices, Google receives less than 5% of its query volume through organic searches. Id. at 9758:16–9760:1 (Murphy) (discussing DXD37 at 52). On Android devices, that number is only 10%. Sept. 19, 2023 (Sealed Session) Tr. at 23:25–27:2 (Yoo).
- G. The Importance of Scale
86. Early on, Google understood that the information gleaned from user queries and click activity were a strong proxy for users’ intent and that such information could be used to deliver superior results. See UPX251 at 870 (“[M]ost of the knowledge that powers Google, that makes it magical, ORIGINATES in the minds of Google users.”); id. at 871 (“As people interact with the search results page, their actions teach us about the world.”); UPX203 at 906 (“If a document gets a positive reaction, we figure it is good. If the reaction is negative, it is probably bad. Grossly simplified, this is the source of Google’s magic.”).
87. Greater query volume means more user data, or “scale.” As the most widely used GSE in the United States, Google receives nine times more queries each day than all of its rivals combined across all devices. The disparity is even more pronounced on mobile. There, Google receives nineteen times more queries than all of its other rivals put together. See Tr. at 4761:6-24, 4762:19–4763:2 (Whinston) (discussing UPXD102 at 47, 49).
88. There are different types of user data. Click data, for example, includes the search results on which a user clicks; whether the user returns to the SERP and how quickly; how long a user hovers over SERP results; and the user’s scrolling patterns on the SERP. See UPX4 at .004. From such data, a GSE learns not only about the user’s interests but also the relevance of the search results and quality of the webpages that the user visits. Tr. at 1767:215–1771:22 (Lehman) (discussing UPX4 at .004).
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