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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 50 of 286

III. GOOGLE SEARCH

A. Product Development

126. Google is widely recognized as the best GSE available in the United States. See, e.g., id. at 2586:1-2 (Cue) (Apple) (“Google still has the best search engine by far[.]”); DX547 at .002 (Mozilla) (“Google is the clear winner when it comes to product experience and what users want.”) (internal quotation marks omitted); Christensen Dep. Tr. at 146:19-23 (Motorola) (“We have a positive opinion about Google Search, as do most consumers I think. It’s—it’s fast. It’s reliable. It performs well for consumers’ intended purchase in our opinion.”); Giard Dep. Tr. at 33:2-3 (T-Mobile) (Google “provides customers with the best overall device experience[.]”); DX385 at 239 (AT&T) (“Google generates more query volume and monetizes search at higher rates than Bing and Yahoo[.]”); accord Tr. at 9429:3 (Rosenberg) (Google) (“[W]e think Search is best in class.”).

127. Although Google significantly outperforms all rivals on mobile devices, Bing’s search quality on desktop measures up to Google’s. See Tr. at 6048:12-15 (Whinston) (Bing’s quality “is very close on desktop” to Google); UPX238 at 667 (“Bing is comparable on desktop . . . and leads in several desktop verticals[.]”); UPX260 at 681 (Bing is comparable to Google for desktop result relevance and outperforms Google on desktop for overall preference).

128. Google’s superior product quality rests in part on its numerous innovations over the years, as depicted below. See Tr. at 9899:21–9900:6 (Murphy) (discussing DXD37 at 140).

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