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United States v. Google/Findings of Fact/Section 2C

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C. Types of Queries

33. A GSE can supply information from a broad variety of sources, covering nearly any topic. Tr. at 8708:16-20 (Israel) (agreeing that GSEs “can handle virtually any type of query”). Thus, it is “the first place that you can turn to,” and “a place that you go to for the vast majority of your information needs.” Id. at 3670:6-18 (Ramaswamy); see also id. at 6511:11-23 (Whinston) (same); id. at 7027:23-25 (J. Baker) (“[A] general search user can get satisfactory responses to multiple queries from multiple sources, all without switching sites.”); id. at 10471:17-25 (Oard) (“[M]ental process is costly[] and . . . people may just not know about where things are.”); cf. id. at 8717:17-18 (Israel) (“If I don’t know the best source, I may have to try various ones.”).

34. Google classifies its queries by subject matter, and it has developed more than two dozen “level-one” classifications. Id. at 7029:2-16 (J. Baker) (discussing PSDX11 at 17). Users tend to use a GSE for a short period of time to search for a particular topic and then allow time to pass before using a GSE to search for a different topic. Put differently, users do not typically search multiple different subject matters during an unbroken time period. Id. at 8419:9-15 (Israel) (discussing DXD29 at 25) (78% of users searched within only one vertical in a short period). Yet, if viewed over a longer period, users frequently turn to GSEs to search for a broad variety of topics. See id. at 7029:17–7031:11 (J. Baker) (discussing PSXD11 at 19) (showing based on Google sessions data from 2019 and 2021 that nearly 65% of “sessions,” defined in the study as a 24-hour period, involved users searching in more than one classified segment).

35. Many users begin their online information gathering journeys on GSEs. An analysis by U.S. Plaintiffs’ expert Dr. Michael Whinston found that 77% of search sessions on Windows desktop devices began on GSEs. Id. at 4614:12-24 (Whinston). That 77% figure is arguably lower on mobile devices, on which users are more likely to start searches directly within an application instead of a GSE. See id. at 5875:19–5876:9 (Whinston).

36. There are two general types of queries on GSEs: noncommercial and commercial.

37. A noncommercial query is one in which the user seeks to retrieve information that the GSE does not attempt to monetize by delivering a search advertisement. 80% of Google’s queries are noncommercial in nature. Id. at 8396:16–8398:17 (Israel); UPX10 at 053 n.6.

38. Commercial queries, as the name implies, are queries that the GSE perceives are an expression of commercial intent by the user and constitute the remaining 20% of Google’s queries. Tr. at 8396:16–8398:17 (Israel); UPX10 at 053 n.6. Typically, such a query seeks information on a product or a service. GSEs often serve advertisements on a search engine results page in response to a commercial query. See infra Section V.A.1. Like Google, only about 20–30% of Bing’s queries are commercial and show ads. Tr. at 3645:13–3646:2 (Nadella).

39. Navigational queries, which can be either commercial or non-commercial, are a type of query that reflects a user’s intent to navigate directly to a particular website. Id. at 185:1119 (Varian). GSEs may or may not serve ads on a navigational query. An example of a navigational query is “Amazon,” which may express the user’s intent to go to Amazon.com. See id. at 8721:12-13 (Israel) (“[O]ne use of a general search engine[] is as this vehicle to take me to other sites.”). Users often enter navigational queries. In fact, at a given time, Google’s top five queries by query volume are navigational queries, UPX342 at 859, and nearly 12% of all Google queries are navigational queries, Tr. at 8748:22–8749:1 (Israel) (calculation reflected in Whinston Expert Report at 64); id. at 8748:25–8749:1 (Israel) (the volume of navigational queries is “significant”). Navigational queries are unique to GSEs, because only a GSE’s results page supplies a user with organic links used to navigate to another website. See id. at 4616:23-25 (Whinston) (specialized vertical providers are “not sending you off to other sites” because “they don’t have a broad index of the web”); see infra Section IV.A.

40. The number of general search queries has grown dramatically over the last decade, especially on mobile devices. See Tr. at 8442:17–8443:2 (Israel) (discussing DXD29 at 45) (“[O]utput is more than double over this 10-year time period.”); id. at 7248:4-10 (J. Baker) (discussing PSXD12).