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Page:United States v Google 20240805.pdf/94

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Case 1:20-cv-03010-APM
Document 1033
Filed 08/05/24
Page 94 of 286

259. And Google met that objective year after year. As the below chart shows, Google has enjoyed unusually consistent revenue growth from 2010 to 2018 that hovered at or above the 20% expectation.

UPX342 at 824.

260. If Google grew concerned about meeting its revenue targets, it called for a “Code Yellow effort,” where its “top priority” would be to “deliver [] revenue launches” through intentional pricing. UPX738 at 406; see UPX733 at 203–04 (describing the Sugarshack format pricing launch, which was used to meet Google’s revenue targets in response to a Code Yellow); UPX514 at 386 (describing ad launches implemented to meet Code Yellow revenue goals).

261. Google’s pricing decisions also reflected an understanding that increasing its revenue in the ways discussed might occasionally come at a cost (or no improvement) to advertisers. See UPX734 at 509 (“cleverer . . . auction pricing” comes “at a cost to advertisers”); UPX507 at .015 (“Sales struggles to explain these [price increases] in terms of user/advertiser value[.]”); UPX889 at 780 (auction pricing mechanisms are “[n]ot designed to increase clicks”); UPX36 at 065 (“[C]urrent system has issues. We’re acknowledging the current CPM space is giving them different prices at the same value.”).

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