# United States v. Google/Findings of Fact/Section 5B

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    B. Display Ads
197. A display advertisement is an image or video that appears on a website. Id. at 4848:17-22, 4857:3-5 (Lim). One type of display ad is a banner ad, which is depicted below at ​the top and side of the image. Id. at 1195:19-25 (Dischler); UPX274 at 841. If a user clicks on a display ad, they will be directed to the advertiser’s website. See UPX8089 at 398.
UPX274 at 841.
198. Display ads only run on a website if the site is supported by software that enables the ad’s placement. For Google Ads that software is the Google Display Network. UPX8056 at .002. Many websites do not have display advertising on them. Tr. at 1193:13-18 (Dischler). Display ads do not appear on a SERP. Id. at 1193:19-21 (Dischler).
199. Display ads are priced based on the impressions that the advertisement receives. “An impression is the delivery of an ad,” which indicates “a high probability that the user has seen the ad.” Id. at 3821:13, 19-20 (Lowcock). The advertiser pays for a display ad whenever it shows up on a user’s screen. Id. at 1177:15-17 (Dischler); UPX1 at 538 (“An impression is counted each time your ad is shown.”). The metric used to price display ads is known as cost-per-mille (or CPM), which is a fixed price per thousand impressions. UPX26 at 770; Tr. at 1194:16–1195:13 (Dischler). Display ads sold through Google are priced through auctions that are distinct from those used for text ads or PLAs. See Tr. at 4006:23-25 (Juda). Display auctions are first-price auctions, where the top bidder wins the ad placement and pays its bid price. UPX6032 at 655–56.
200. Display ads are well-suited for creating brand awareness. UPX26 at 764 (“Display ads . . . aim to build brand recognition[.]”). For instance, if an individual “see[s] a display ad for ​a new fuel-efficient Toyota, [they] might think, ‘Gee, maybe it’s time to buy a new car.’” Tr. at 454:13-20 (Varian) (quoting UPX411 at 638).
201. Because a display ad is not served to a user in response to a query, advertisers rely on various other signals, both from the ad publisher and the user, in determining where to place a display ad. Advertisers can elect to place display ads to appear on content-relevant websites (e.g., an ad for a mixer next to an article on baking) or on specific websites. UPX26 at 769. As for user signals, see id. at 764, advertisers look to place display ads on content-relevant or industry-related websites that the user has visited or whose ads on which the user has clicked, UPX428 at .011; Tr. at 1418:4-8 (Dischler) (“The users’ interest can be signaled in any number of ways, whether it’s visiting a website, whether it’s subscribing to a TikTok channel of a golf influencer or in any number of ways.”).
202. A particularly valuable form of display advertising is “retargeted” display ads. An advertiser uses a consumer’s activity on the advertiser’s website to tailor a later-appearing display ad on another website. To illustrate, “[a] retargeted ad would occur, for example, when you bought a product and there was a complimentary product that was associated with that. So, you could buy a product like ski boots and it would suggest ski equipment or ski mittens.” Tr. at 455:6-9 (Varian). A retargeted display ad can be delivered only after the consumer has visited the advertiser’s website. Id. at 455:25–456:5 (Varian).
203. The placement of a retargeted display ad is most valuable within the first hour after the user visits the advertiser’s website. UPX26 at 764–65. The value of a retargeted ad diminishes as the time increases from the user’s visit to the website, because the user is less likely to possess the intent that they had when visiting the site. Tr. at 456:6-17 (Varian). Take, for instance, a user who visits Best Buy’s website and looks at flat-screen TVs but does not make a purchase. A ​retargeted display ad featuring a brand of flat-screen TV will be less effective as time goes on from when the user visited the Best Buy website.
204. Privacy initiatives can also limit the effectiveness of such targeting techniques. Retargeting data is collected using “cookies” or data about an individual’s prior web activity: “The way this works is that an advertiser or agency presents an ad and a list of cookies to an ad server network and the network displays the ad to the cookies on the list, if and when these cookies show up on particular website.” UPX413 at 735. Cookies can be limited by third parties. For instance, after Apple made privacy changes to a new version of iOS, Meta’s ability to serve retargeting ads was made “much harder or potentially even not possible in some circumstances.” Levy Dep. Tr. at 172:18-24.
205. Retargeted display ads cannot replace search ads. See Tr. at 5220:11-22 (Booth).