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Page:United States v Google 20240805.pdf/51

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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 51 of 286

Google Has Made Continual Investments That Expand the Use of Search

DXD37 at 140.

129. “In analyzing potential changes to its Search product, Google considers the needs of users. Google recognizes that it exists in a competitive landscape and if it does not satisfy users’ information needs, users will access information from other search providers (general or otherwise). Google does not, however, consider whether users will go to other specific search providers (general or otherwise) if it introduces a change to its Search product.” UPX6019 at 365–66.

B. Branding

130. The fact that “Google is used extremely highly across the world . . . contribute[s] to brand formation.” Tr. at 672:20-21 (Rangel); id. at 7780:23-24 (Pichai) (“Our brand gets validated by being present as a default in iPhones.”). Google also built brand loyalty and recognition by offering a high quality product. Id. at 5921:22–5922:5 (Whinston); id. at 8397:2122 (Israel) (“Google is building a brand reputation by how well it provides searches.”).

131. Google has long recognized that “the affinity of the Google brand was something that was valued by users[.]” Id. at 361:17-18 (Barton); see UPX93 at 904 (“Several factors are believed to affect the choice [of a GSE], including . . . brand strength[.]”) (2007); UPX171 at 186

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