What Are Search Access Points? Explaining How Google Works

D. Search Access Points

1. A Search Access Point Is Where A Desktop Or Mobile-Device User Can Enter A Query

146. A search access point is any place on a device where a user enters a search query. Tr. 323:11-19 (Barton (Google)); Des. Tr. 44:5-8 (Google-NF 30(b)(6) Dep.); Tr. 1027:23-25 (Higgins (Verizon)) (search entry points are “different mechanisms for you to access search on the device").

2. Search Access Points On Desktop

147. Desktop browsers allow users to view websites, including GSEs. Tr. 7642:13–17 (Pichai (Google)) (in 2004, browser users could “navigate to Yahoo.com or Google.com or whatever your choice was"). Desktop browsers direct queries entered into the address bar to a GSE. Des. Tr. 211:16–212:5 (Google-RG2 30(b)(6) Dep.) (queries entered into a browser's address bar are conducting “default search”); Tr. 700:12–701:2 (Rangel (Pls. Expert)) (discussing DXD-01 at .001–04 and showing general search being conducted from an address bar in Safari on desktop). In the past, toolbars, or plug-ins for different browsers, were another method by which consumers could access GSEs (and by which Google could track general search market share). Tr. 7642:2–12 (Pichai (Google)) (“Google Toolbar was a way by which, in those days in browsers, you could add an extension . . . a search box . . . it provided users a convenient way to search Google”); Tr. 201:2–6 (Varian (Google)). The advent of built-in search boxes on browsers rendered downloadable tool bars obsolete. Tr. 7676:16–7677:19 (Pichai (Google)) (toolbar was developed when there was no built-in browser search box); Tr. 201:4–8 (Varian (Google)) (toolbars are “no longer popular”).

3. Search Access Points On Mobile

148. The number of search access points on mobile has grown over time. Des. Tr. 71:8–19, 72:4–20 (Ezell (AT&T) Dep.) (search access points include search widgets, browser search, and voice search); Tr. 3714:3–11 (Nadella (Microsoft)) (“search access point[s]” are “the places where people get to a search engine” and have “changed over time and have multiplied”); UPX0581 at -625.

149. Market participants have developed a lexicon to describe the geography of mobile devices and places where app icons and widgets, including ones containing search access points, can be placed. Des. Tr. 65:19–68:15 (Ezell (AT&T) Dep.) (describing terms such as the hot seat, minus one screen, plus one and plus two screens, and application tray). The default home screen is the screen users sees after unlocking a mobile device or pressing the home button. Tr. 790:22– 791:2, 805:25–806:2 (Kolotouros (Google)).

The plus one screen refers to the screen to the right of the default home screen, i.e., the screen a user navigates to by swiping from right to left from the default home screen. Id. 947:23–948:8. The minus one screen refers to the screen to the left of the default home screen, i.e., the screen a user navigates to by swiping from left to right from the default home screen. Tr. 3123:1–12 (Tinter (Microsoft)); Des. Tr. 42:2–17 (Giard (T-Mobile) Dep.).

150. The hot seat or application dock on a mobile device refers to the bottom row of apps that a user can access quickly and that persist when swiping to the right or left. Tr. 923:8– 23 (Kolotorous (Google)).

a) Mobile Browsers

151. Mobile browsers are preinstalled on virtually all mobile devices distributed in the United States. Tr. 1518:17–19 (Yoo (Google)) (MADA requires Chrome to be pre-loaded on the device); Tr. 2454:11–16 (Cue) (Apple)) (Safari browser is preloaded onto Apple devices).

152. Mobile browsers contain preinstalled search access points (e.g., address bar, default homepage) set to default GSEs. Tr. 1518:17–21 (Yoo (Google)) (MADA requires Chrome with Google set as the default search engine); Tr. 795:15–17 (Kolotouros (Google)) (address bar on Chrome is a search access point); Tr. 1028:1–3 (Higgins (Verizon)) (a search bar in a browser is a search entry point).

b) Search Apps

153. Search apps are applications that allow users to conduct searches and direct queries to a preset GSE. Tr.797:25–798:11 (Kolotouros (Google)) (the Google Search app directs a search query to Google through the same process as searching through Chrome.); Des. Tr. 55:16–19 (Ribas (Microsoft) Dep.) (Bing search app links to searches on Bing); Des. Tr. 142:20–25 (van der Kooi (Microsoft) Dep.) (a search app is an entry point that “can either be downloaded or that is the default on a third-party platform”).

Search apps are search access points that can be preinstalled on a smartphone or other device. Tr. 323:11–19 (Barton (Google)) (The Google search app is one access point). The preset GSE in a search app generally cannot be changed by the user. Tr. 6066:17–21 (Whinston (Pls. Expert)) (a search widget is a manifestation of a search engine application with a convenient search entry box); Tr. 833:11–16 (Kolotouros (Google)) (the widget can be removed but the search itself cannot be changed).

154. The Google Search App—with Google set as the default GSE—is preinstalled on virtually all Android devices distributed in the United States. Tr. 1518:12–16 (Yoo (Google)) (MADA requires the Google search app to be preinstalled on the device); UPX0129 at -905 (MADA requires preinstallation of the Google search app).

c) Search Widgets

155. Widgets are self-contained code that display a program, or a piece of a program, that is a shortcut to an application. Tr. 1029:6–12 (Higgins (Verizon)) (a search widget is “a small piece of software that sits on your device that allows access to search capability.”). Search widgets are search access points, directing queries to a preset GSE. Tr. 794:3–5, 795:8–14 (Kolotouros (Google)) (Google search widget is a search access point that must be set to Google search); Des. Tr. 98:1–10 (Christensen (Motorola) Dep.) (a search widget is “a common way to search” and home screen placement enhances accessibility of the widget); Tr. 559:9–13 (Rangel (Pls. Expert)) (the search widget “allows consumers to type a search there without having to open a browser; a search app and, by default, searches with Google”); Des. Tr. 143:2–23 (van der Kooi (Microsoft) Dep.) (the search default/search box is “already on the device and is staring you in the face”).

The Google Search Widget is a visual representation of the Google search app in which users can enter queries. Tr. 791:3–7, 794:3–9 (Kolotouros (Google)) (explaining that the Google Search Widget is part of the GSA and that it is a search box users can enter questions in). The Google Search Widget is sometimes referred to as the QSB or quick search box. Tr. 796:16–19 (Kolotouros (Google)).

156. Google’s search widget is preinstalled across the home screen of all Android devices distributed in the United States. Tr. 18:1–4 (Sept. 19, 2023 sealed PM session) (Yoo (Google)) (the widget is part of the Google search app, which the MADA requires to be on the device); Tr. 815:9–22 (Kolotouros (Google)) (Google had not granted, any waivers, which would allow manufacturers to remove the widget from the home screen); Tr. 815:16–816:1 (Kolotouros (Google)) (not aware of any Samsung or Motorola device without a pre-installed Google Search Widget); Tr. 792:25–793:23 (Kolotouros (Google)) (discussing JX0049 and confirming that all MADAs require Google Search Widget placement on the default home screen). Tr. 3125:10– 3125:22 (Tinter (Microsoft)) (against Microsoft’s preference, Google widget appears on the home screen of the Microsoft Duo, a dual-screen Android smartphone); Des. Tr. 45:6–11 (Christensen (Motorola) Dep.) (all Motorola devices ship with the Google Search Widget on the default home screen).

157. Neither Android users nor Google’s counterparties like the search widget on the device’s home screen. UPX0128 at -546–47 (2016 Lockheimer (Google) email to Google chief business officer informing him that “[w]e’ve done UX research” confirming that “[u]sers generally are tired (visually) of our widget” and “OEMs are VERY tired (visually) of our widget . . . they feel like they don’t get to differentiate”).

4. Other Search Access Points

158. Other search access points, such as voice assistants and smart keyboards, have miniscule search volume. Tr. 3107:3–3108:19 (Tinter (Microsoft)) (Apple hoped to encourage use of the voice assistant and voice entry point but “in practice, that thesis did not play out as…there was not a significant user behavior shift” from searching in the browser to using Siri and Spotlight).