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

Layout 2
    G. SA360
279. A search engine management tool, or SEM tool, enables advertisers to manage advertising campaigns across different online platforms, including GSEs, SVPs, and social media platforms. Id. at 1232:13–1233:18 (Dischler). “Native tools” refer to proprietary software products that allow advertisers to make ad purchases directly on the owner’s platform. Google’s native tool is Google Ads, and Microsoft’s is Microsoft Ads. (Since both Yahoo and DDG use Microsoft’s search results, they also rely upon Microsoft Ads as their underlying ad technology.) Id. at 1229:16-19, 1232:19–1233:6 (Dischler).
​280. SEM tools are helpful because they take the application programming interface from native tools and apply them in ways that facilitate management of multi-platform advertising campaigns all in one place. Id. at 1234:11-24 (Dischler).
281. Google owns an SEM tool called Search Ads 360, or SA360. Id. at 1234:2-4 (Dischler). It was initially developed by a company called DoubleClick, which Google acquired in 2007. Id. at 1235:5-12 (Dischler); id. at 3668:23-24 (Ramaswamy). Google advertised the SEM tool as “a neutral third party, helping [advertisers] achieve the highest return on investment, regardless of the online channel.” PSX1109 at 093. Google continues to maintain that the “aim of the product” is “to be a neutral third party.” Tr. at 1236:21-23 (Dischler).
282. Other SEM tool companies include Skai, Marin, and Adobe. Id. at 1423:9-10 (Dischler). About one third (31%) of all search ads revenue on Google and Bing flows through SEM tools. See id. at 7095:1-24 (J. Baker) (discussing PSXD11 at 73). SA360 is the market leader, with 76% of all SEM tool ad dollars spent on SA360. Id.
283. Auction-time bidding (ATB) is a feature available in both the Google Ads and Microsoft Ads native tools. Id. at 1230:4-6, 1240:4-7 (Dischler). ATB affords advertisers the ability to adjust bidding strategies in real time during ad auctions. The alternative to ATB—intraday bidding—allows bidding strategies to be updated a few times a day. Because ATB permits advertisers to adjust their bids in real time, it is more efficient than intraday bidding at allocating ad dollars to achieve their highest return. Id. at 1230:7–1231:9 (Dischler) (“It’s beneficial to advertisers, because it’s better than the other alternatives.”).
284. ATB has been available on the Google Ads native tool since about 2016. Id. at 1231:10-14 (Dischler). It has a high adoption rate, meaning that it is popular among advertisers, in part because it yields an improved ROI. Id. at 1231:15-17 (Dischler).
​285. By September 2019, ATB was fully integrated into the Google Ads interface on SA360. Id. at 4308:9-11 (R. Krueger); PSX386 at 607. It was immensely popular, with an 80% adoption rate and a 15–30% increase in ROI. PSX386 at 607. Google viewed the implementation of ATB into Google Ads on SA360 as a “high-complexity” feature that took between two to three years to accomplish. Tr. at 1425:18-24 (Dischler). When ATB was introduced in SA360 for Google Ads, Microsoft had ATB available only on its native tool. Id. at 1240:4-7 (Dischler).
286. In the summer of 2019, Microsoft asked Google to integrate ATB and other features into the Microsoft Ads interface on SA360. See id. at 4309:5–4334:13, 4341:6–4345:2 (R. Krueger). Google slow-rolled the request. It instead prioritized continued work on Project Amalgam, which was an effort to overhaul SA360 to introduce it as “a completely new product,” including “immediate support for most new Google Ads features and improved support for other channels and search engines, like Microsoft Advertising[.]” DX282 at .001; Tr. at 4468:4-15 (R. Krueger); see id. at 4745:4–4746:5-11 (Varia) (discussing DX132 at .005). It also completed the years-long Project Myx, which integrated ATB for Google Ads into SA360. Tr. at 4691:9-15, 4728:7–4729:7 (Varia). Microsoft grew increasingly frustrated by Google’s inaction, and it eventually requested a CEO-to-CEO level resolution of the matter. PSX360 at 750. Notwithstanding these efforts, at the time of trial, ATB still was not integrated into the Microsoft Ads interface on SA360. Tr. at 5158:9-24 (Booth).
287. Unlike SA360, other SEM tools offer ATB for Microsoft Ads on their platform. See id. at 6643:7-12 (Vallez) (Skai); Heath Dep. Tr. at 47:3–48:8 (Adobe), 83:7–84:16 (Marin).
288. With ATB unavailable for Microsoft Ads on SA360, some advertisers have used other SEM tools or Microsoft’s native tool to avail themselves of that feature for their Bing ad ​spend. This includes one of SA360’s largest advertisers, Home Depot. See PSX441 at 903–04; PSX1203 at 992; Tr. at 5161:22–5162:14 (Booth).