United States of America v. Google LLC., Court Filing, retrieved on April 30, 2024, is part of HackerNoon’s Legal PDF Series. You can jump to any part of this filing here. This part is 5 of 37.

II. INTRODUCTION TO THIRD PARTIES

A. Amazon

4. Amazon is a technology company with a focus on e-commerce and headquartered in Seattle, Washington. DX1035 at -512–13. Amazon purchases both Text Ads and shopping ads from Google and Bing. Des. Tr. 21:18-22:1, 41:23-42:10 (James (Amazon) Dep.). Amazon is one of the largest purchasers of Search Ads from Google, spending more than $ billion on Google Search Ads in 2021. Des. Tr. 27:4-10 (James (Amazon) Dep.). Search Ads are an important source of revenue and customer acquisition for Amazon. Des. Tr. 24:4-10 (James (Amazon) Dep.).

5. Although primarily a retailer, Amazon also offers advertising products. Amazon- sponsored product ads appear in response to consumers' real-time queries on amazon.com. Tr. 5379:21-5380:5, 5380:9-14, 5437:17-5438:4 (Jerath (Pls. Expert)) (“When you think of Amazon, shopping ads are sponsored product ads,” and discussing UPXD103 at 4–5); Des. Tr. 141:4-7 (Jain (Google) Dep.) (Searches that give rise to PLAs are comparable to Amazon ads.).

The vast majority, if not all, of Amazon's product ads link only Amazon's internal sites (i.e., product or merchant Amazon pages) and can be purchased only by businesses selling products on Amazon. Des. Tr. 105:4–105:8, 105:15–23 (James (Amazon) Dep.); Tr. 3857:24–3858:10 (Lowcock (IPG)).

Thus, Amazon, like many other specialized search engines, seeks to keep users on the search engine's platform or website. Tr. 1492:11–25 (Dischler (Google)); Tr. 3852:25-3853:11, 3857:18-3558:18 ((Lowcock (IPG)) (search results on retailer websites (e.g., Amazon, Walmart) keep the user on retailer's site); Des. Tr. 27:25–28:1, 28:3–28:10 (Ramalingam (Yahoo) Dep.) (A “general search engine would provide answers without any specific restriction to a domain" and a "vertical one is going to be either focused on a particular domain or particular aspect of vertical”).

B. Apple

6. Apple Inc. is a technology company headquartered in Cupertino, California. UPX8105 at -172. Apple manufactures iPhone smartphones that run on Apple's iOS operating system, iPad tablets that run on Apple's iPadOS operating system, and personal computers, called Macs, that run on Apple's MacOS operating system.[1] UPX8105 at -175; UPX5141 at -552 (defining smartphone as "any mobile wireless device running the Android or iOS operating system"). In 2022, Apple reported $394 billion in total net sales and $119 billion in operating income. UPX8105 at -203.

7. Apple offers a web browser known as Safari. Apple preinstalls Safari on Apple's mobile devices and personal computers. Tr. 2454:11–16 (Cue (Apple)). Since 2002, Apple has only offered one web browser: Safari. Des. Tr. 20:14–16 (Apple-EC 30(b)(6) Dep.).

8. On its devices, Apple also offers a “universal search” feature, known as Spotlight. Spotlight is primarily used to search for on-device content but it can also be used to search for information on the web. Tr. 2204:4–2205:21 (Giannandrea (Apple)) (referring to UPXD006 at 1–2); Tr. 2496:17–22 (Cue (Apple)); Des. Tr. 39:21–40:19 (Edwards (Google) Dep.) (In addition to searching on-device content and apps, Spotlight has “query suggestions that you could click on that would then open a web browser with a search query in it.”).

Spotlight does not provide a general search service. Tr. 2205:16–21 (Giannandrea (Apple)). Apple does not show ads in Spotlight. Tr. 2496:23–24 (Cue (Apple)).

9. Siri is Apple’s voice assistant. Siri is primarily focused on (1) helping users perform actions and (2) providing answers to questions. Tr. 2236:13–2237:10 (Giannandrea (Apple)); Tr. 2496:11–14 (Cue (Apple)) (“It’s an . . . audio assistant . . . . It tries to help you get things done.”). If a user asks Siri to “search the web,” Siri can provide results using web search. Tr. 2236:13–2237:10 (Giannandrea (Apple)) (“[I]f you . . . say ‘Siri’ or you press the button on the side of the phone and ask a question or do an action like send a text message, [] we try to do that for you.”); id. 2237:12–2238:1 (“The Siri voice assistant has a feature which is: Search the web for this.

So you might say show me pictures of puppies or search the web for . . . USBs. And so for that feature inside of Siri, it can fall back to web search.”). Siri’s goal is to answer as much as possible of what customers ask with a “fallback” to web search if Apple does not know the answer. Tr. 2535:6–2537:6 (Cue (Apple)). Siri does not provide a general search service. Tr. 2237:20–23 (Giannandrea (Apple)). Apple does not show ads in Siri. Tr. 2496:15–16 (Cue (Apple)).

10. Apple offers users information and recommendations, known as Suggestions, as the users enter text into Safari’s URL bar. Tr. 2208:22–2209:4 (Giannandrea (Apple)). With this feature, Apple infers what the user is looking for and provides a path to the right answer. Id. 2216:25–2218:5 (explaining UPXD007, which depicts a Suggestion in Safari). In some Suggestions, Apple provides its own answers directly to the user, and in others, Apple provides links to third-party websites. Id. 2234:1–2235:4.

11. Apple is Google’s largest distribution partner. Google has had a search distribution agreement with Apple since 2002; since 2005, this agreement has required Apple to pre-set Google as Safari’s exclusive default general search service. Infra ¶¶ 209–230 (§ III.F.1). In search, Google and Apple seek to “work as if [they] are one company.” UPX0617 at -059; id. at -058 (Dec. 20, 2018 email from Donald Harrison (Google) recounting that Tim Cook’s “overall message to Google was ‘I imagine us as being able to be deep deep partners; deeply connected where [Apple’s] services end and [Google’s] begin’”).

12. Under the Apple distribution agreement, Google has made enormous payments to Apple. In 2022, Google’s overall, worldwide payment to Apple under the distribution agreement exceeded $20 billion. Infra ¶ 935. Google’s payments to Apple for Safari address-bar queries alone exceeded $9.6 billion in fiscal year 2020 and surpassed a billion dollars every month by May 2021.[2] Infra ¶ 935.

13. Also, Apple is Android’s largest competitor in the sale of mobile devices in the United States. Tr. 7653:12–14 (Pichai (Google)); id. 7711:3–16 (“We continued to have moments of tension between the two companies. So it’s tough for me -- we build Android, they build iPhones. We compete every day in the marketplace on that and many, many other products.”); id. 7804:19–21.

C. AT&T

14. AT&T Mobility LLC, headquartered in Atlanta, Georgia, has sold Android devices since 2011. JX0091 at -742. Approximately [redacted]% of AT&T’s smartphone sales are Android devices, Des. Tr. 29:11–25 (Ezell (AT&T) Dep.), and with only brief exceptions in 2013 and 2014, each of those devices come preloaded with Google apps and services, id. 73:17– 74:24, 87:11–20, 87:23–90:1, 293:18–294:10.

15. Google and AT&T have been party to an RSA continuously since 2011 and have periodically updated and extended the agreement over the last two decades. Infra ¶¶ 272–275 (§ III.F.2.b.i.a).

D. Booking.com

16. Booking.com is an online travel agency headquartered in Amsterdam, Netherlands. DX3114 at .003–05, .035. Booking is an e-commerce platform where consumers can go to book hotels, flights, cars, and attractions. Tr. 5230:20–5231:7 (Dijk (Booking)). Booking is thus a specialized vertical provider and not a general search engine. Id. 5230:20–23. Booking buys Search Ads primarily on Google and to a much smaller extent on Bing. Id. 5231:8–20. Booking purchases Search Ads to get to “high-intent customers” who “have expressed a very clear interest in booking a hotel.” Id. 5236:18–5237:1. Booking does not sell text ads but does sell other ads on its website. Id. 5244:10–5245:1.

17. OpenTable is one Booking brand. Des. Tr. 17:22–18:4 (Soo (OpenTable) Dep.). OpenTable is a site for booking online restaurant reservations, providing services to both consumers and restaurants. Id. 40:19–41:5. OpenTable purchases Search Ads on Google and Bing. Id. 220:21–221:6.

E. Branch

18. Branch Metrics (Branch) is a software company that develops tools for navigating and discovering mobile applications. Over 100,000 apps use Branch’s deep linking technology to route users to specific content pages within the apps. Tr. 2906:3–2907:3 (Austin (Branch)) (describing how Branch has developed and marketed tools, other than an app-search tool, that help users interact with their apps).

19. Branch’s primary mission since 2014 has been building a service that allows consumers to search for mobile app pages as easily as they search for webpages. Branch’s appsearch tool (1) allows users to enter a query, (2) displays search results that list mobile app content responding to that query, and (3) sends users directly to that content when they click on search results. Id. 2893:18–2895:6 (describing the company’s mission and explaining design of Branch’s app-search tool).

F. Brave

20. Brave Software, Inc. (Brave) is headquartered in San Francisco, California. Brave develops the Brave browser and the Brave search engine. UPX0829 at -187, -190; Tr. 9693:8– 9695:3 (Murphy (Def. Expert)). Brave’s browser distributes the Brave search engine. Tr. 9693:8–9695:3 (Murphy (Def. Expert)).

G. Dentsu

21. Dentsu is an advertising company headquartered in Tokyo, Japan. UPX0772 at -783; Des. Tr. 22:14–25:8 (Alberts (Dentsu) Dep.). Dentsu has separate teams for ads appearing on general search engines and ads not placed with general search engines. Id. 40:23–42:15. Dentsu purchases Text Ads on behalf of its clients; most of these are placed on Google. Id. 24:9– 16.

H. DuckDuckGo

22. DuckDuckGo is a general search services provider based in Paoli, Pennsylvania. Founded in 2008, DuckDuckGo offers a number of privacy-focused web services, including a browser and email service, but is best known for its private search engine. Tr. 1937:8–20 (Weinberg (DuckDuckGo)). DuckDuckGo licenses search results from Microsoft, including ads, but also indexes the parts of the web for proprietary modules displayed alongside “the traditional links.” Id. 1938:16–1939:23. DuckDuckGo responds to approximately 100 million searches a day. Id. 1938:11–15.

23. DuckDuckGo has a general search services market share of 0.88% in the United States as of 2020. PSX00338 at -828.

I. Expedia

24. Expedia Group (Expedia) is an online travel agency headquartered in Seattle, Washington. DX0308 at .001, .004. Expedia sells flights, hotel rentals, vacation rentals, car rentals, and other parts of a trip experience. Tr. 6500:15–18 (Hurst (Expedia)). Expedia is thus a SVP and not a general search engine. Id. 6580:4–15. Expedia includes three primary brands: expedia.com, hotels.com, and Vrbo. Id. 6500:15–25. The largest source of spend at Expedia is paid Search Ads. Id. 6506:18–21. Expedia’s advertising spend on Google is ten times bigger than Expedia’s spend on Bing. Id. 6506:3–14. Expedia also sells Search Ads on its websites. Tr. 5380:9–14 (Jerath (Pls. Expert)) (discussing UPXD103 at 5).

J. Facebook

25. Facebook is a social media service owned by Meta and headquartered in Menlo Park, California. DX0589 at .001, .011. Facebook generates most of its revenue from advertising. Id. at .026. Many of the companies that purchase ads from Facebook “spend only a relatively small portion of their advertising budget” on Facebook ads. Id. Nearly all the ads shown on Facebook are social ads; [redacted]% are Search Ads. UPX1019 at -524; UPX2113 at -789.

Apple’s recent privacy initiatives have substantially undermined Facebook’s ability to sell targeted or retargeted ads. UPX0923 at -695 (“For Safari users: . . . Targeting crippled, retargeting impossible“); Des. Tr. 164:13-165:6, 172:15-24 (Lecy (Meta) Dep.) (as a result of Apple’s privacy initiatives, Meta’s ability to help advertisers target their ads has been impacted negatively;” Apple’s iOS 14 privacy changes made “it much harder or potentially not even possible“ for Meta to effectively retarget ads)). Infra¶ 422.

K. IPG

26. IPG is a holding company for mobile advertising and media agencies. that Tr. 3801:19-3802:4 (Lowcock (IPG)). IPG entity Universal McCann is a media agency purchases and places advertisements on behalf of its clients. Id. Reprise, an IPG agency, specializes in advising clients on purchasing search and social ads. Id. 3878:19–3879:1. IPG recommends that clients purchase Google Search Ads, even in the face of price increases. Id. 3826:4-15, 3827:20-23.

L. JPMorgan Chase

27. JPMorgan Chase & Co. (JPMorgan) is a financial services company headquartered in New York, New York. JPMorgan buys Text Ads from Google and Bing, splitting its spend between the two roughly 90% and 10% respectively. Tr. 4869:7–23 (Lim (JPMorgan)); DX0663 at -491. All JPMorgan's business lines purchase Search Ads, whereas only some of its business lines purchase other ad types. Tr. 4842:15-4843:2 (Lim (JPMorgan)). JPMorgan spends three times more on Search Ads than it spends on social ads. Id. 4861:23–25.

M. LG Electronics

28. LG Electronics (LG), based in Seoul, South Korea, was a leading manufacturer of Android devices sold in the United States. UPX0558 at -051–52; UPX5358 at -001; Tr. 1516:4– 21 (Yoo (Google)). In 2021, LG stopped selling smartphones in the United States. Tr. 820:3–5 (Kolotouros (Google)).

29. Google and LG have been party to Mobile Application Distribution Agreements (MADAs) and Revenue Sharing Agreements (RSAs) continuously since 2007 and 2009, respectively, and have periodically updated and extended the agreements over the last two decades. Infra ¶¶ 237, 254.

N. Microsoft

30. Microsoft Corp. is a technology company headquartered in Redmond, Washington. UPX8094 at -517, -519. Microsoft sells Search Ads and display ads globally. Id. at -531.

31. Microsoft licensed a third-party general search engine (MSN Search) in 1998, began offering its own general search engine in 2005, and launched the Bing branding in 2009. Tr. 3546:13–3548:5 (Nadella (Microsoft)). In 2009, Yahoo began syndicating its organic search results from Microsoft. Id. 3641:2–3642:24; DX0271 at .002. Today, Microsoft is Google’s only general search engine competitor in the United States that crawls the internet to create its own web index. Infra ¶ 75. Microsoft has invested approximately $100 billion in Bing over the past 20 years and has a current market share of 5.5% in the United States as of 2020. Infra ¶¶ 522, 538.

32. Microsoft owns and operates the Windows Operating System for desktop computers. Microsoft has preloaded the Internet Explorer or Edge browser on computers with Windows for many years. Tr. 3580:2–12 (Nadella (Microsoft)). Bing and its predecessors have been the default engine on Microsoft’s browsers since 2005. Tr. 76775:5-23 (Pichai (Google)); UPX0172 at-730-31.

O. Motorola

33. Motorola Mobility LLM, headquartered in Chicago, Illinois, is a leading manufacturer of Android devices sold in the United States. JX0039 at -794 (Motorola RSA (2017)); Tr. 1103:13–23 (Higgins (Verizon)). Motorola has manufactured Android smartphones since 2009, and exclusively used Android as the mobile operating system for its smartphones since 2012. Des. Tr. 21:17-23:1 (Christensen (Motorola) Dep.).

34. Google acquired Motorola in 2012. Id. 142:11–19. Google later sold Motorola to Lenovo Group Ltd., and Motorola is now a subsidiary of Lenovo. Id. 15:12-17. Google and Motorola have been party to a MADA and RSA continuously since 2009 and 2005, respectively, and have periodically updated and extended the agreements over the last two decades. Infra ¶¶237, 254. Since Lenovo's purchase of Motorola, Motorola-branded devices have been subject to Lenovo's MADA and RSA. Id. 63:23-64:23.

P. Mozilla

35. Maker of the Firefox browser, Mozilla is a software company headquartered in Mountain View, California. JX0031 at -612 (Mozilla SA (2016)). Firefox has around 10% share of the browser market on desktop and a “[v]ery, very small” share among browsers on mobile. Des. Tr. 127:12–128:8, 134:9–23 (Baker (Mozilla) Dep.). The mission of the Mozilla Foundation is to create an internet that is “open and accessible to all" by advocating for user choice, privacy, security, open source, and interoperability. Des. Tr. 20:16–21:14 (Baker (Mozilla) Dep.); Des. Tr. 274:1-7 (Baker (Mozilla) Dep.) (Privacy has “always been a part of Mozilla" and that Mozilla has a "strong emphasis" on it.).

36. Mozilla began setting Google as the default search engine on Firefox in 2004. UPX5434 at -126–27 (§ 2.4) (Mozilla SA (2004)). Mozilla switched the default search engine on Firefox to Yahoo in 2014, but switched the default back to Google in 2017. Des. Tr. 62:9–18 (Baker (Mozilla) Dep.); DX1012 at -695–96 (§ 3.3.1(a)–(b)); JX0048 at -775 (§ 1) (Mozilla SA (2017 amend.)) (adding the United States to an ongoing agreement that had previously applied only to other countries).

37. Approximately 80% of Mozilla’s revenue comes from its revenue sharing agreement with Google. Des. Tr. 41:18–24 (Baker (Mozilla) Dep.).

38. Mozilla receives revenue from other general search engines, including DuckDuckGo and Bing, for non-exclusive distribution in the United States. DX1005 at -156–58 (§§ 3.1, 4.1, 5.1) (Mozilla has “the right, but not the obligation,” to distribute Bing Search in exchange for [redacted]% revenue compensation); DX1011 at -309–10, -322 (§§ 2.1, 4.1, D.1(a)) (Mozilla has “the right, but not the obligation,” to distribute DuckDuckGo Search in exchange for [redacted]% revenue compensation); Des. Tr. 41:10–12 (Baker (Mozilla) Dep.).

Q. Neeva

39. Incorporated in 2017, Neeva was a general search engine founded by Sridhar Ramaswamy, a former Senior Vice President for Ads and Commerce at Google. Tr. 3667:10– 3668:15, 3669:15–3670:5 (Ramaswamy (Neeva)). Neeva positioned itself as an ads-free private search engine with a focus on artificial intelligence (AI) and customer personalization. Id. 3669:15–3670:5, 3671:2–2672:5. Neeva operated on a subscription-based model, charging customers roughly $5 a month or $50 a year. Id. 3675:22–3677:10.

40. In May 2023, Neeva shut down its consumer search engine and was acquired by Snowflake, an enterprise data company. Id. 3674:16–2675:6.

R. Samsung Electronics Corp.

41. Samsung Electronics Corporation, headquartered in Suwon, South Korea, is the leading manufacturer of Android devices sold in the United States. Des. Tr. 95:4–96:1, 96:3–16, 96:18–20, 96:22–97:13 (Baxter (Samsung)). Globally, Samsung is responsible for more Android activations than any other company and, across Android partners, Samsung is Google’s top generator of search and Play Store revenue. UPX0639 at -266.

42. Like Google, Samsung develops branded apps and services that come preloaded on its Samsung Android devices. Samsung’s Android devices come with two browsers preinstalled—Chrome and Samsung’s proprietary S Browser. Des. Tr. 158:9–11 (Ezell (AT&T) Dep.); Des. Tr. 60:6–11 (Giard (T-Mobile) Dep.).

Samsung’s Android devices also come with two app stores preinstalled—Google’s Play Store and Samsung’s far less popular Galaxy Store. Des. Tr. 91:2–92:12, 92:24–93:2 (Baxter (Samsung) Dep.). Samsung’s Galaxy Store is not intended as a replacement for the Play Store. Des. Tr. 91:4–92:12 (Baxter (Samsung) Dep.) (The Galaxy Store is “not a real relevant solution” and has no identifiable “benefits . . . to the market.”). Instead, the Galaxy Store (1) offers a smaller, curated set of applications and (2) distributes application programming interfaces (APIs) and other software that support Samsung products and services. Id.. 92:16–23.

43. Samsung’s innovation arm, “Samsung Next,” invests in innovative technology companies that develop tools to improve the user experience on Samsung devices. Tr. 4485:17– 4486:2, 4491:22–4492:16 (Chang (Samsung Next)). One of Samsung Next’s investments was in Branch, which Samsung viewed as “one of the rising leaders in mobile deep linking.” Id. 4492:17–4493:2.

44. Google and Samsung have been party to a MADA and RSA continuously since 2009 and 2011, respectively, and have periodically updated and extended these agreements. Infra ¶ 237, ¶¶ 294–303 (§ III.F.2.b.iii.a–b).

S. The Home Depot

45. The Home Depot is one of that largest home improvement retailers in the United States, selling products in stores, on its website, and through its app. Tr. 5115:2–5, 5115:10–16 (Booth (The Home Depot)). The Home Depot purchases advertising on Google and Bing, allocating roughly 90% of its ad spend to Google and around 8–10% to Bing. Id. 5141:18– 5142:13. The Home Depot purchases Search Ads, display ads, and social ads, but these purchases are managed by two separate teams—one handles Search Ads and the other handles display and social ads. Id. 5117:20–5118:19.

T. T-Mobile

46. T-Mobile, headquartered in Bellevue, Washington, has sold Android devices since 2009. Infra ¶ 284. Approximately 50% of T-Mobile’s smartphone sales are Android devices, and each of those devices comes preloaded with Google apps and services. Des. Tr. 23:16–21, 23:23–24:4, 24:6–7, 24:9–14 (Giard (T-Mobile) Dep.).

47. Google and T-Mobile have been party to an RSA continuously since 2009 and have periodically updated and extended the agreement over the last 15 years. Infra ¶¶ 284–287 (§ III.F.2.b.i.c).

48. Sprint, formerly headquartered in Overland Park, Kansas, began selling Android devices in 2008. Infra ¶ 288. Sprint had an RSA requiring default exclusivity since that time. Infra ¶ 288. Sprint, previously the fourth-largest carrier in the United States, merged with T-Mobile in 2020. Des. Tr. 186:16–20 (Giard (T-Mobile)); Tr. 1515:15–25 (Yoo (Google)). Devices Sprint sold before the merger continue to be covered by the terms of Sprint’s prior RSA. UPX5545 at -482 (§ 3) (Sprint RSA (2020 amend.)).

49. Google and Sprint had been party to an RSA continuously from 2008 to 2020, and periodically updated and extended the agreement over that time. Infra ¶ 288.

U. Verizon

50. Verizon, headquartered in New York, New York, has sold Android devices since 2009. JX0010 at -994 (Verizon RSA (2009)) (effective date Oct. 1, 2009). Approximately [redacted]% of Verizon’s smartphone sales are Android devices, and each of those devices come preloaded with Google apps and services and are subject to the terms of a MADA. Tr. 1102:17–23, 1024:23–1025:6 (Higgins (Verizon)).

51. Verizon acquired Yahoo in June 2017. Id. 1043:14–18. In May 2021, Verizon announced that it was selling Yahoo to Apollo Capital. Id. 1072:2–13.

52. Google and Verizon have been party to an RSA continuously since 2009 and have periodically updated and extended the agreement over the last 15 years. JX0010 at -994 (Verizon RSA (2009)) (effective date Oct. 1, 2009); infra ¶¶ 276–283 (§ III.F.2.b.i.b).

V. Yahoo

53. Founded in 1994 and headquartered in Sunnyvale, California, Yahoo is a general search services provider and pioneer of the early Internet. DX0937 at -968, UPX1053 at -121. Verizon acquired Yahoo in June 2017. Tr. 1043:14–18 (Higgins (Verizon)). In May 2021, Verizon announced that it was selling Yahoo to Apollo Capital. Id. 1072:2–13.

54. Yahoo has operated a general search engine for several decades, as well as a number of web properties, including Yahoo News, Yahoo Finance, and Yahoo Sports. Des. Tr. 24:14–24 (Ramalingam (Yahoo) Dep.). As of 2020, Yahoo held 2.2% market share in the U.S.’s general search services market. Infra ¶ 522.

55. In the early 2000s, Yahoo used its own web crawler to construct a web index. Des. Tr. 35:7–18, 35:24–36:1 (Ramalingam (Yahoo) Dep.). But this ended in 2009 when Yahoo contracted with Microsoft for Bing to provide results for Yahoo in the United States beginning in the fall of 2010; Yahoo stopped serving its own search results. Id.; DX0271 at .001–03. Since then, Yahoo’s search results in the United States have been syndicated from Bing. DX0271 at .001–03; DX1038 at -624.

W. Yandex

56. Yandex is a multinational technology company that operates the largest search engine in Russia. Tr. 2641:20–24 (Parakhin (Microsoft)); Tr. 2296:12–13 (Giannandrea (Apple)) (Yandex is “the number one search engine in Russia”). In 2017, Russian competition authorities required Google to implement a choice screen on Android devices; this resulted in a consistent and continuing loss in Google’s Android query share that was acquired by Yandex. Infra ¶ 910.

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[1] Because iPads previously ran on Apple’s iOS operating system, iPhones and IPads are sometimes referred to collectively as “iOS devices.“

[2] By comparison, Google collectively paid carriers and Android OEMs more than $1.5 billion for U.S. searches in 2020. Infra ¶ 936.