Google’s Conduct Forecloses A Substantial Share Of Text Ads And Search Ads in the U.S.

B. Google’s Conduct Forecloses A Substantial Share Of Text Ads And Search Ads In The United States

965. The exclusive defaults secured by Google’s exclusionary contracts cover 45% of all Text Ads revenue in the United States. Tr. 5772:20–5773:2 (Whinston (Pls. Expert)) (referencing UPXD104 at 39). This does not include Text Ads revenue earned through the Google bookmark in Safari, the Google Search App on iOS, or Chrome on Windows or Apple devices. Id. 5772:20–5773:2 (referencing UPXD104 at 39 and explaining that the coverage figure for Text Ads is “doing exactly the same thing” as the general search service coverage figure “but for search text ad revenue”).

966. The exclusive defaults secured by Google’s exclusionary contracts cover 36% of all Search Ads revenue in the United States. Tr. 5773:3–7 (Whinston (Pls. Expert)) (referencing UPXD104 at 40). Similarly, this does not include Search Ads revenue earned through the Google bookmark in Safari, the Google Search App on iOS, or Chrome on Windows or Apple devices. Id. 5773:3–7 (referencing UPXD104 at 40 (see note below chart)).

967. A conservative estimate of the percentage of users who are not conceivably available to even a much stronger rival for each ads market would be two-thirds of the coverage estimate. Tr. 5773:8–17 (Whinston (Pls. Expert)). This estimate is conservative because evidence suggests that changing a default shifts a higher percentage of ad revenue than queries. Id. 5773:18–5774:1 (discussing UPX0066 at -071, which estimates that Google lost 30% of its default traffic and 45% of its default revenue after Mozilla switched the Firefox default to Yahoo). These high numbers confirm the substantiality of the 45% and 36% foreclosures for Text Ads and Search Ads, respectively.