# United States v. Google/Findings of Fact/Section 4A

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​IV. OTHER PLATFORMS
    A. Special Vertical Providers
141. Specialized vertical providers, or SVPs, are platforms that respond to queries centered on a particular subject matter. Tr. at 8626:5-12 (Israel). Examples of SVPs include Amazon, Expedia, and Yelp. See id. at 1031:14-18 (Higgins); id. at 2169:3-8 (Giannandrea).
​142. Most SVPs do not respond to noncommercial queries, although there are exceptions, e.g., Wikipedia. Id. at 8396:23–8397:3 (Israel).
143. SVPs are not GSEs. E.g., id. at 8098:4-6 (Gomes).
144. Once a user is on an SVP’s site, the SVP facilitates navigation “only to sites in their segment where [the user] can make a transaction,” with some exceptions. Id. at 7032:18-23 (J. Baker). This is known as a “walled garden” model, where the platform has proprietary, structured data that is not available on the open web. Id. at 8100:11-14 (Gomes). Thus, an SVP like “Amazon is not a competitor for nav[igational] queries.” Id. at 8749:3 (Israel); see also id. at 1492:18-22 (Dischler) (“Google offers the full web, to the extent that Google has access to it. Amazon offers the products that are available at Amazon. It’s possible that some products available at Amazon are not available via Google’s access on the web, and Amazon may have their own unique inventory.”).
145. Home Depot, for instance, maintains a product catalog of goods that it sells both online and in stores. Id. at 5115:4-11 (Booth); see also id. at 8395:14-24 (Israel) (discussing DXD29 at 17) (Home Depot is an SVP in the shopping vertical). Users of Home Depot’s digital platforms can use them to purchase those goods but not navigate to a product-maker’s website to make a direct purchase there instead. See id. at 5115:12-14, 5128:22–5129:4 (Booth); van der Kooi Dep. Tr. at 79:11-12 (“It is a search on what is available in the catalog.”).
146. Fact witnesses with industry experience agree that SVPs are different from GSEs. See, e.g., Tr. at 1031:20–1032:2 (Higgins) (stating GSEs involve “anything that’s available on the web,” while SVPs are “specifically focused on a domain”); id. at 2168:5–2169:11 (Giannandrea) (does not consider SVPs to be GSEs); id. at 3670:12-13 (Ramaswamy) (GSEs are “best defined in contrast to a specialized search engine”); id. at 5230:21-23 (Dijk) (Booking.com is not a GSE).
​147. Fact witnesses with industry experience also agree that an SVP could not substitute for a GSE as a default search engine. Id. at 2171:10-13 (Giannandrea) (agreeing that “users, when they put something in the URL bar of Safari, they have an expectation that it’s going to go to a general search engine”); id. at 1032:7-20 (Higgins) (stating that he would not recommend that an SVP be set as a default search engine on a Verizon device, because “consumers would like to have some search capability on their devices, and the preference would be for a general as opposed to a specific vertical”); id. at 7425:25–7426:14 (Raghavan); M. Baker Dep. Tr. at 217:3-15, 218:8-9 (“The user experience trying to use general search with only Amazon would not be good.”).
148. Plaintiff States’ expert, Dr. Jonathan Baker, provided an example. If a user enters a query for “UFOs” on Google, they will be presented with nearly 2 billion search results. But that same query on Amazon yields only around 10,000 results, all of which are products for purchase. And if a user searches on Expedia or HomeAdvisor for “UFOs,” they will receive no results. Tr. at 7031:21–7032:6 (J. Baker) (discussing PSXD11 at 21).
149. Google’s own employees recognize that SVPs are not GSEs. See id. at 8098:4-6 (Gomes); UPX911 at 875 (“Amazon is not considered a search site.”); Tr. at 183:13-18 (Varian) (agreeing that “Amazon, Apple, and Facebook don’t provide general-purpose search engines”); id. at 484:20–485:4 (Varian) (Amazon’s search results are narrower than Google’s “[b]ecause they use different algorithms, different datasets, different history, different understanding of users”).
150. Nevertheless, both Google and other GSEs compete against SVPs for certain commercial queries in vertical offerings, such as travel and shopping. See Tr. at 3646:3-11 (Nadella); id. at 5883:16-22 (Whinston); id. at 8202:1-6 (Reid) (listing Amazon, DoorDash, OpenTable, Yelp, and TripAdvisor as competitors for shopping and food queries); id. at 7310:5–7312:4 (Raghavan); see UPX8085 at 854 (“We face formidable competition in every aspect of our ​business, including, among others, from . . . vertical search engines and e-commerce providers for queries related to travel, jobs, and health, which users may navigate directly to rather than go through Google[.]”). Google’s internal documents reflect differentiated analysis for “traditional Search engines such as Bing, Yandex, DuckDuckGo and alike” versus “[v]ertical search and apps analysis (including Amazon, Booking, etc.)[.]” UPX483 at 295.
151. Google views competition from SVPs as “intense for commercial clicks.” UPX343 at 845. A 2020 Bank of America study reported that 58% of users search Amazon first when they seek to make an online purchase, as opposed to only 25% who go first to Google, demonstrating Google’s secondary status as a starting point for users with high commercial intent. Tr. at 8425:15–8426:8 (Israel) (discussing DXD29 at 28). Google thus perceives Amazon as posing a risk of siphoning queries away from Google. DX126 at .019.
152. Microsoft recognizes that “if Bing or Google were not doing vertical searches well, or at least not having organic results that people could click to get to vertical search engines,” users might bypass GSEs and instead search directly on Amazon from the outset. Tr. at 3649:23–3650:6 (Nadella). But cf. id. at 1942:18-21 (Weinberg) (DDG does not consider Amazon or other SVPs to be competitors that users are likely to switch to or from).
153. Even for overlapping queries, GSEs and SVPs can serve as complementary search platforms. As Dr. Baker opined, “it wouldn’t be surprising if, for example, a search user entered a query for red shoes on a general search firm, saw a link to a shopping SVP, and then clicked on it and entered a search for red shoes there. That would be a natural thing to expect.” Id. at 7035:913 (J. Baker); accord id. at 7435:5-7 (Raghavan) (“Prime members who in any way intend to shop at Amazon might come to Google and do a lot of research before they do it.”).
​154. For that reason, studies conducted by Google’s expert Dr. Mark Israel regarding query overlap do not show that SVPs like Amazon and Yelp belong in the same product market as Google. See id. at 8406:5–8407:4 (Israel) (discussing DXD29 at 20) (analysis showing that a query sample of Google’s top 25 non-navigational shopping queries attracts more queries weekly on Amazon (3.7 million) than Bing (0.4 million)); id. at 8411:3-13 (discussing DXD29 at 21) (finding that Yelp’s local query volume is higher than Google’s and much higher than Bing’s); see also id. at 8401:4–8404:15 (Israel) (discussing DXD29 at 18) (analyzing the percentage of searches on GSEs as compared to SVPs for particular verticals).
155. SVPs are often reliant upon GSEs for traffic. See id. at 3534:7-23 (Nadella); id. at 2645:13-18 (Parakhin); id. at 7032:7-15, 7033:13-21 (J. Baker). For instance, Dr. Baker’s analysis demonstrated that 33–88% of SVPs’ online traffic (depending on the vertical) flows through GSEs, either via organic links or advertisements. Id. at 7033:18-21 (J. Baker) (discussing PSXD11 at 25). Although this analysis omits traffic through mobile applications, the conclusion is bolstered by Google’s own analysis showing that “Amazon” was Google’s fourth highest query by volume in 2018. See UPX342 at 859.
156. For this reason, SVPs are top advertisers on GSEs. Tr. at 9209:1-10 (Holden) (travel SVPs like Booking.com and Expedia are some of Google’s largest advertisers); id. at 4615:11-16 (Whinston) (“[I]f you go and you look which are the biggest advertisers on Google, which are the biggest advertisers on Bing, the answer is specialized search engines. And what it’s reflecting is that there’s a bunch of traffic they think they can’t get directly, you know, otherwise they wouldn’t be spending the money to try to get referrals.”); id. at 5116:3-8 (Booth) (Home Depot is a “large” purchaser of ads on Google, spending “hundreds of millions of dollars”); see also infra Section V.A.1.
​157. Empirical research—performed by Google—demonstrates that use of SVPs is complementary, rather than cannibalistic. In other words, there is no evidence that increased use of SVPs correlates with a diminished use of Google or other GSEs. See UPX344 at 058; UPX436 at 005. For instance, Google’s 2019 Project Charlotte study showed that users who were members of SVP loyalty clubs (e.g., Amazon Prime) or who otherwise engaged with SVPs were more likely to enter queries on Google. Tr. at 7430:2–7435:20 (Raghavan). Similarly, a 2018 Google analysis concluded that Android users who were active on the Amazon application yielded $2.31 per user in incremental search revenue for Google. UPX335 at 694. More recently, a 2020 Google study found a positive correlation between Amazon application use and query volume on Google, ultimately determining that a user’s adoption of any of six major SVP applications—Amazon, eBay, Walmart, Pinterest, Spotify, or Twitter—was related to increased revenues and queries on Google mobile, with no significant change on desktop behavior. Tr. at 8733:1–8738:19 (Israel); PSX562 at 966, 977.
158. SVPs do not view themselves as competing with general search, although they may compete with GSEs’ vertical offerings. See, e.g., Tr. at 6580:1-15 (Hurst) (Expedia competes with Google’s travel verticals, but not its search product, because users “can’t generally search for most of the things [one] search[es] Google for on Expedia . . . Expedia[’s] product literally does not work for what I assume is the overwhelming majority of Google general search.”).