DOJ v Google Witness Tracker

	A	B	C	D	E	F	G	H	I	J	K	L
1	DOJ v Google Witness Tracker \| Maintained by Vidushi Dyall - Legal Analyst, Chamber of Progress
2	Witness				Key Arguments					Key Points that Each Side Gleaned from Witness Testimony
3	Called By	Name	Affiliation	Testimony Date	Market Power: General Search	Market Power: Adver- tising	Monopoly Maint: Browser Defaults	Monopoly Maint: Android Defaults	SA360	DOJ Key Points	States Key Points	Google Key Points

4	Plaintiffs	Hal Varian	Google	9/13/2023	x		x			Defaults and data are both valuable; debate within Google about role of scale, data, and engineering in Google's success; profits can be indicative of monopoly power		Google's profit is due to its high perforrmance; general search isn't a market b/c it's free for users; best "switching cost" is a high-quality product
5	Plaintiffs	Antonio Rangel	Caltech	9/14/2023			x	x		Search engine defaults generate "sizeable and robust bias towards the default”; search engine choice driven by habit; defaults are more powerful on mobile than desktop		Bing's mobile default deals had little impact on market position; Microsoft devices have “severe choice friction”
6	Plaintiffs	Chris Barton	Google	9/14/2023				x		Google prioritized Android search distribution deals guaranteed default placement; MSFT would secure defaults if Google didn't		Google invested in Android in early mobile days, when future was unclear; Android ecosytem adds value to users & competive restraint on Apple; Google's pitch to Android partners- superior product and monetization; Google lost T-Mobile deal to Yahoo! because G refused to give PII on users and lost deals on AT&T and Verizon to MSFT
7	Plaintiffs	Jim Kolotourous	Google	9/15/2023				x		Google insisted on default search reqs & widget placement in Samsung deal; Samsung pushed back on deal reqs; dispute over chat history settings		RSA partners have options and flexibility; choose Google citing superior quality; Google competes intensely other GSEs to secure deals with OEMs/carriers;
8	Plaintiffs	Jerry Dischler	Google	9/18/2023		x				Ad revenue is a large portion of Google's overall revenue, suggesting an incentive to raise the prices in its auctions; Google increased revenue through 5% increase in auction prices	Advertiser confusion from Google’s “auction time bidding” feature originally being available only on native search ad platform and not SA360	Google faces ads competition from other tech giants like Meta, Amazon, and TikTok; search ads aren't more valuable than other digital ads; "purchase funnel" is obsolete; MSFT Auction Time Bidding feature in SA360 is currently in beta testing
9	Plaintiffs	Brian Higgins	Verizon	9/18/2023	x			x		Not valuable to have specialized vertical search platform as default on an Android phone; unclear if Verizon soliticited competing bids from MSFT/DDG when it renewed its deal with Google		Bing recieved negative user feedback when default on Verizon Android devices; Google did not recieve negative user feedback when it was Verizon default
10	Plaintiffs	Michael Roszak	Google	9/19/2023		x				Document describing search advertising as “one of the world’s greatest business models ever created”; "Google can ignore demand and focus on supply"		Google agreement with Apple reflected Apple substantial bargaining power and value of Apple devices; Document was part of public speaking expertise on hyperbole/ exaggeration. Meta data showed that never opened after being made
11	Plaintiffs	Eric Lehman	Google	9/20/2023	x		x	x		Google's AI investments will help it ensure/extend its lead in search; Google’s access to large amounts of text and user data “would be a useful asset.”		Google has been at forefront/developed large language models (LLM)- BERT, T5, and MUM and shared innovations widely; MUM not trained on click and query data (user interaction)
12	Plaintiffs	Gabriel Weinberg	DuckDuckGo	9/21/2023			x	x		Changing default to DDG is too hard; Google's search defaults are hard for DDG to overcome; EU choice screens were designed poorly but still hold promise		Even with EU choice screen, DDG's share in Europe is lower than in US; DDG had 2022 privacy scandal re MSFT data-sharing; unclear how many DDG users have strong privacy knowledge
13	Plaintiffs	John Giannandrea	Apple	9/21/2023	x		x			Amazon, TikTok, Expedia and Facebook are not competitors against Google in search; Apple crawls web to support products(spotlight; safari search; keyboard dev)		Other search engines pay Apple in rev share agreements; Apple compared Google and Bing’s search quality, Google “wins big” almost everywhere adding to user exp.; DuckDuckGo is “veneer on Bing/Yahoo!; Bing’s quality is lacking; iOS17 lets private browsing users set a secondary default search engine
14	Plaintiffs	Eddy Cue	Apple	9/26/2023			x			Apple hasn't looked into developing its own search engine; sought to increase revenue share in ISA with Google; Apple has obligation to defend ISA in goverment investigations		Apple chooses G because it sees it as the best; choice screens take away from user's out-of-box experience; Microsoft and Yahoo abused API mechanisms that prompted users to switch defaults
15	Plaintiffs	Mikhail Parakhin	Microsoft	9/27/2023	x	x	x			Feedback loop: more users-> more clicks-> better search quality; people don't usually switch defaults; securing Apple default would be "transformational" for Bing	Advertisors seek out Google; SMBs only stay with Google	Bing's reverse feedback loop: less development & investment-> worse search & less relevant ads-> fewer users & advertisers-> less data; MSFT's search team is a fraction of the size of G's
16	Plaintiffs	Anna Kartasheva	Google	9/27/2023				x		Google assessed whether Samsung integration of Branch was violation of Google/Samsung revenue sharing agreement		Google never instructed OEMs to refrain from using Branch's technology; Branch search would produce irrelevant, low-quality results
17	Plaintiffs	Jonathan Tinter	Microsoft	9/28/2023	x		x	x		Scale drives both search quality & advertiser interest; Bing "just big enough to play but not big enough to win"; MFST has failed to secure default deals	Google's "dominance" in search advertising means there is inherently less advertiser demand for Bing's services	75% of MSFT Edge users switch their default from Bing to Google, due to quality preferences; search default in Windows are 2x harder to change vs. iOS/Android; Windows doesn't offer secondary option search engines
18	Plaintiffs	Alex Austin	Branch Metrics	9/28/2023				x		Samsung limited Branch app search integration due to implicit pressure from Google		Contributing factors to Branch's failures: Samsung priviacy concerns; Branch pitting OEMs vs. carriers; critical reviews of Branch's product; acknowledge that Branch produced web results; Branch never saw itself as a Google competitor
19	Plaintiffs	Satya Nadella	Microsoft	10/2/2023	x	x	x	x		Consumers don't really switch due to deeply ingrained habit; Internet is "Google's Internet"		Bing gains user data by powering Yahoo search results; Users repeatedly switched Bing defaults to Google (Blackberry, Verizon, Nokia, Edge, MSFT Duo device)
20	Plaintiffs	Sridhar Ramaswamy	Neeva	10/3/2023	x		x	x		Neeva exited search competition due to growth struggles; defaults are most effective way to distribute search engine; access point deals w/Google prevented Neeva being offered as an option		Only 2.5% of market is needed to compete with Google; consumers reluctant to pay $5/month for Neeva; Neeva's results relied on Bing; Neeva not a victim - sold for 2x seed investment
21	Plaintiffs	Adam Juda	Google	10/4/2023		x				Google's ad auction mechanics are a bit of a black box; Google can impact ad prices through ad system knobs/settings		G ad auctions can't systematically change prices; goal of G ad product launches is to increase ad relevance/quality, which benefited users and advertisers; ad auction changes have resulted in both increases and decreases in CPCs
22	Plaintiffs	Joshua Lowcock	Universal McCann (IPG)	10/4/2023		x				Search ads don't compete with display/awareness ads (different parts of marketing funnel); recommends Google search ads as must-buy to clients despite rising CPCs, due to Google's scale		Agency's own memos/decks say rigid "marketing funnel" is outdated; consumer journey is no longer linear; Internal docs advise on shifting spend across ad channels to maximize ROI
23	Plaintiffs	Michael Whinston	MIT	10/5/2023	x	x	x			Expert in industrial organization, opined: General search services, general search text advertising, and search advertising in the United States are relevant markets; Google possesses substantial market power protected by barriers to entry in each of the relevant markets; Google search distribution contracts give it exclusive defaults, which are a larger driver of search traffic; Google search distribution contracts foreclose rivals from a substantial share of each relevant market; Google search distribution contracts have harmed competition to the likely detriment of consumers and advertisers		Traits of general search engines (habit formation, less time/energy used, depth and breadth of results) also apply to specialized vertical vertical providers; G faces strongest competition outside of general search for monetizable queries; advertisers more likely to turn to Amazon/FB as alternative to G; G built strong brand recognition due its novel and "revolutionary" technology; G continues to innovate ad platform and increase advertiser ROAS/ROI; default agreements don't foreclose preloading rival apps and incentivize OEMs on security/operating system upgrades; EU choice screen resulted in 1-2% shift in market share
24	Plaintiffs	Patrick Chang	Samsung Next Ventures	10/5/2023				x		Carriers had concerns regarding Branch due to potential conflicts with their agreements with Google.		Samsung had internal concerns about impact of Branch on other partnerships, user experience, and low user engagement w/ Branch results; Samsung felt Branch was not a trustworthy partner
25	Plaintiffs	Ryan Krueger	Google	10/5/2023					x		MSFT requested integration of its Auction Time Bidding feature into SA360; SA360 team wasn't able to proritize; MSFT escalated matter with senior G execs in spring 2020	SA360 feature development is prioritized based on advertiser feedback; MSFT lacked "fractual conversion capability" needed to achieve compatibility with SA360; ATB is a complex feature that demands sizeable engineering power; SA360 was undergoing an entire redesign and did not have enough resources to support an immediate integration of MSFT tools
26	Plaintiffs	Amit Varia	Google	10/6/2023					x		Microsoft was ready to recruit advertisers in early 2020 to begin testing but SA360 placed this on hold; chat logs has history off setting; SA360 is #1 SEM tool	SA360 feature development driven by advertiser requests, not MSFT; SA360 team made herculean effort & added 15 add'l engineers to integrate 12 MSFT ad features; SA360 faces strong competition from SEM rivals Kenshoo, Marin, Adobe
27	Plaintiffs	Joan Braddi	Google	10/9/2023			x		x	Didn't consider Amazon a competitor in general search; Google opposed a ballot screen on iOS	MSFT elevated SA360 complaints to senior G execs	G deals with Apple involved give and take, like any biz negotiation; G didn't have obligation to act on MSFT SA360 complaints because product is for advertisers
28	Plaintiffs	Arjan Dijk	Booking	10/11/2023		x				Booking has one-sided relationship with Google; Booking tries to decrease spending on paid search but feels that Google intentionally forces sites to advertise by decreasing quality of organic search results		Booking CEO and CFO attested to very positive relationship with Google; Google ads optimization have helped increase Booking's ROI; Google has given Booking notice and collaborated on changes to ad platform
29	Plaintiffs	Ryan Booth	Home Depot	10/11/2023		x			x	Google removed data from Search Query Report for advertisers, leading to loss of critical data for advertisers	Search ads distinct; Google search ads are must-buy; switching SEM tools is a cumbersome process, suggesting that advertisers are forced to stay with SA360	Home Depot chose SA360 because of superior usability; SA360 didn't even integrate all of Google's own ad features; Marin and Adobe also don't support MSFT's auction-time bidding feature; SQR data change was to protect privacy; Return on ad spend (ROAS) trumps all, even if CPCs increase
30	Plaintiffs	Tracy-Ann Lim	JP Morgan Chase	10/11/2023		x				Text ads distinct from shopping ads (JPMC only uses first); search ad budgets are rigid and not interchangable with other ad formats; JPMC spends 3x on search ads vs. social media		Marketing funnel concept is somewhat outdated; JPMC improved its overall cost of acquiring new customers through advertising; JPMC relationship with Google is strong
31	Plaintiffs	Kinshuk Jerath	Columbia Business School	10/12/2023		x				Expert in digital advertising, opined:General Search Text ads are a distinct product category; Effectively providing text ads and other search ads requires significant resources, and advertisers have few alternatives apart from Google; Google harms advertisers through its withholding of information and control of the ad auctions; Marketing funnel is "timeless" framework and widely referenced		Opinions framed by the marketing funnel (circa.1898); Didn't rely on any recent material citing funnel; Downplayed transformations to digital marketing landscape but ack'd rapid recent growth (100x more tools for adv.); Didn't look at internal documents from 9+ companies that list display/social media ads as mid-bottom funnel activity which don't align fully w/opinion; Thinks privacy regulations don't cover ads
32	Plaintiffs	Neil Barrett-Bowen	Microsoft	10/17/2023			x				Scale is a key leveraging point when entering content acquisition partnerships; denies correlation between imrpovement to search quality and added traffic; expensive/cumbersome to crawl web and some data is locked up	Bing failed in invest in mobile and harvest fresh data like SVPs and Google; Bing has good penetration in US and disparity w/ Google hasn't affected Bing's ability to enter into partnerships; Bing competes with SVPs in some cases (travel)
33	Defendant	Pandu Nayak	Google	10/18/2023	x					Running an index requires large amount of resources; dollar constraint on capacity budget; User interaction data is a factor in search quality		Google invests in crawling web infrastructure and creating strong index; Quantity of info =/= quality; Google constantly runs tests on search quality; Google analyzes competitor search quality; Google has make breakthroughs in AI; AI launches have transformed search quality
34	Plaintiffs	Jeff Hurst	Expedia	10/19/2023		x					Advertising on Google is essential; SEO results are less visible due to ads and "meta products"; Vrbo investments on Google increased at a higher rate than corresponding traffic;	Expedia opted out of meta product and has low SEO score on certain queries; Vrbo faces stiff competition from Airbnb and other travel companies; Google and Expedia compete on broad and specific travel queries; Google compete with Trip Advisor and Booking to monetize travel queries
35	Plaintiffs	Paul Vallez	Skai	10/19/2023		x			x		Skai supported MSFT ATB within 2 years; advertisers lose some insights when using Google/Bing native tools; Google spend is higher because of query volumes- advertisers seek this out	Skai recieves funding from MSFT and awards for its support of MSFT tech; Skai built out failed MSFT features; Skai has built out features in piece-meal way and before advertisers express demand- value prop is to be 1st to win the race
36	Plaintiffs	Jason Kreuger	Google	10/24/2023					x		SA360 team postponed MSFT plan in early 2020 to recruit advertisers for testing; looped in legal team when developing roadmap-uncommon practice	100s of adv feedback requesting G ATB feature and handful for Bing ATB; Adv surveys on top 20 requests did not include Bing ATB; G ATB took over 3 years to launch but MSFT raised escalation after few months; MSFT did not have fractual attribution credit or campaign level conversions- needed to achieve parity
37	Plaintiffs	Wilfred Amaldoss	Duke University	10/24/2023		x			x		Expert on digital marketing, opined: General search ads have a distinct purpose b/c they help advertisers reach consumers w/ high probability of purchase; Google has reduced visibility of certain specialized vertical providers (SVP) on the search engine results page (SERP). This conduct has increased the costs of maintaining prominence on the G SERP for those SVPs; Google’s failure to support auto-time bidding and other MSFT ad toll features on SA360 has decreased the efficiency of advertiser’s spend.	Amaldoss conceded that ad channels can be run across funnel; didn’t look at SERPs of other search engines that use travel units/prioritize ad results; did not assess if G's SERP units were useful or harmful to users; couldn’t offer an opinion if SVPs suffered any competitive harm; was incorrect in his claim that “dynamic search ads” for Bing weren’t fully supported by SA360; didn’t analyze if a lack of support for features affected advertiser spend across G and MSFT; couldn’t name SEM tool that offers full support for features on native tools.
38	Plaintiffs	Jonathan Baker	American University	10/25/2023	x	x			x		Expert in economics/industrial organization, opined: - G exercises substantial market power in each of three markets - G’s exclusive defaults/SA360 conduct reduced the incentive/ability G’s rivals to compete	No analysis on extent of price competition between SEM tools;no quantitaive opinion on switching cost; only looked at info beyond 2016, but cherry-picked older info favorable to opinions; “scale matters” but doesn't know how much
39	Defendant	Prabhakar Raghavan	Google	10/26/2023	x	x				TikTok and Amazon aren't default options on browsers; you can use TikTok without entering query; could have created a separate privacy engine/browser but didn't; internal G doc on Amazon found its growth was incremental rather than cannabalizing		G continues to innovate in search- AI, breakthrough search feats, increased R&D budget; G increased latency by 500 milliseconds; G faces strong comp from social media and SVPs, pie is growing and G's share is growing at slower rate;
40	Defendant	Sundar Pichai	Google	10/30/2023	x		x			G believed MSFT IE7 default was anti-competitive and that a choice screen should be implemented; emails/doc on G and Apple relationship described as deeply linked and operating as one company; email stating that defaults have a strong impact; chat logs were turned off for a period of time		G built Chrome in response to stagnation in browser market and to boost search use; Chrome and Android were developed by G and made free/usable (used by MSFT); Apple and G fiercely compete on several product lines; Distrubution deal is "enhanced promotion"; OEMs are further incentived in RSA to carry out security/letter upgrades
41	Defendant	Edward A. Fox	Virginia Tech	10/30/2023	x					Had never conducted a prior data reduction experiment; did not have direct access over G computers when running experiment; did not have access to Bing computers or data sets; didn't conduct live traffic experiment or factor in "freshness" which is a signal for search quality; used less citations in his report than his standard practice		Expert in info retrieval, opined: Vast majority of Google-Bing search quality gap must be explained by factors other than volume of user interaction data; A company as efficient as Google could have search quality similar to Google even at Bing's scale; A company as efficient as Google but with Microsoft's scale would not meaningfully benefit from increase in user interaction data; There are diminishing returns to search quality from an increase in the quantity of user interaction data; Ran data reduction experiment which concluded that <95% of quality diff between G and B was from non-scale factors.
42	Defendant	Ben Gomes	Google	10/31/2023	x					G's relies on user interaction data for features (Spelling, synonym, auto-complete), and improvements can stem from more click and query data. Gomes ack'd that G pays attention to Bing [latency]; Code Yellow- cited low query vol as reason for not meeting rev targets		G key innovations: Page Rank, Spelling, Synonyms, Autocomplete, Universal Search, Knowledge Graph; G successful pivoted to mobile and overcame challenges on input/small screens/slow page load/evolving ecosystem; G:”critical that the whole web evolves, not just us”; users turn to apps [FB/Amazon] on mobile; Did not want to use query vol as a metric of growth
43	Defendant	Elizabeth Reid	Google	11/1/2023	x					Bing and DDG aim to answer any query- social media is not as good at certain classes of queries; AI and Search gets better with more users; Bard was launched soon after ChatGPT- had error in demo which led to $100B loss	User generated content- more users means more content;SVP results are served bc of relevance but pay ads to be at top of SERP	Distinguished b/t query and info need; G views other search engines (Bing, DDG), Apple, apps (DoorDash, Yelp, Trip Advisor), messaging apps, Amazon, Chat GPT, and social media sites (TikTok, Instagram) as competition to serving info to users that meet their needs; 64% Tiktok users use Tiktok as search engine; G invests heavily in new formats[Google Lens] and collecting info for maps/local/geo
44	Defendant	Eric Christensen	Motorola	11/1/2023				x		Agrees to MADA b/c G licenses play store to Motorola; would be interested to in a modification or standalone license for PlayStore b/c it would offer more flexibility		MADA doesn't prevent Motorola from pre-loading Motorola/3rd party apps;carriers never complained about pre-loading G search/Chrome on devices;nobody from Motorola suggested pre-loads other than G Search/Chrome; no other search engines/browser approached Motorola to pre-install their product;RSA is optional and device by device- Motorola enrolled all devices b/c of success of program
45	Defendant	Mitchell Baker	Mozilla	11/1/2023			x			Mozilla makes more money from G today than when its market share was higher; hard for a new search engine to arise/challenge G b/c of data and its history in search; bulk of revenue is from default agreements and G is largest contributor		G took time to understand Mozilla;” there was nothing in the world like G… G changed the game with their page rank”; took a “bet” when switched default to Yahoo which ended up in failure b/c of excessive ads/poor quality, so switched back to G; Mozilla would suffer financial and competitive harm if lost ability to enter into G default; MSFT as only option would mean “death spiral” for Mozilla; MSFT has been trying to kill Firefox
46	Defendant	Mark A. Israel	Compass Lexicon	11/2/2023	x	x	x	x	x	Haven't defined boundaries of relevant anti-trust market; haven't done query by query analysis; testimony tossed in prior antitrust case; didn't offer opinion or conclusion on but-for world; some auction tunings have focused on pricing; semantic bidding isn't optional and some adv will need to enter large amount of negative key words to opt out		Expert in economics and industrial organization opined: 1. User search: Plaintiffs improperly combine distinct products that belong in seperate markets and thus define away strong competition 2. User Search: Google does not have monopoly power 3. Search Adverrtising: Plaintiffs define away the strongest competition Google faces 4. Search Advertising: Google does not have monopoly power 5. Search Advertising:: google has not harmed competition or advertisers 6. SA360: Google has not harmed competition or advertisers
47	Defendant	Jennifer Fitzpatrick	Google	11/6/2023	x	x				There have been other privacy features, such as a sliding scale, to reduce # of settings users need to adjust that G opted not to implement; Incognito mode is not truly private	A search may be classified by vertical but responses may fall outside of the vertical/across categories; G ATB available on SA360 for years but no dates given on when Bing ATB wil launch	G continues to invest in privacy and rolls out features; privacy by design approach; creates help pages to inform users on privacy functions; settings/check-ups give users control over privacy- can opt out of personalized ads and delete search history
48	Defendant	Richard Holden	Google	11/7/2023	x						Partners like Expedia have expressed complaints about amount of info needed/spend vs. value from G Hotel ads and text ads; hotel unit occupies space on SERP, sometimes before organic results/blue links	G faces intense competion across travel and shopping verticals, invested and innovated in these areas; G competes with online travel agents, meta search providers, and GSEs; G hotel/flight unit is first in class; flight unit date grid is among largest cache in the world and not monetized
49	Defendant	Adrienne McAllister	Google	11/7/2023				x		Back and forth with Verizon over exclusivity; Verizon considered Yahoo on devices but needed opt for lower rev share % from G; email about relaxing config reqs to ease regulatory risk		RSAs are optional; improves competition between Android and Apple b/c of security/letter update reqs, Chrome pre-load and G widgets;
50	Defendant	Jamie Rosenberg	Google	11/8/2023				x		RSA agreements were renegotiatied with different % structure bc of concerns of Android declining market share;G internal doc about avoiding "trigger" language in communications that regulators would pick up on		G investmentment into Android overcame fragmentation and walled garden issues in smartphones at the time; MADAs don't impose default/exclusivity reqs; RSAs are optional on device by device basis; funds from RSA agreement aid competition with Apple
51	Defendant	Jeff Giard	T-Mobile	11/8/2023				x		G has control over what goes on Android devices; TM had concerns about G collection of user data; RSAs don't include wind down period; Androids wihout the Play Store aren't successful		T-Mobile entered into a deal with G because of the revenue stream to T-Mobile and the ability to provide its users with "the best handset experience."; rev from RSA impacts pricing "offsets downward pressures on ARPU"; believes G products combat fragmentation issues on Android, making them more competive with Apple.
52	Defendant	Dan Levy	Meta	11/9/2023		x				Older Facebook docs refer to business in funnel terms and geared towards "demand generation" (upper funnel); Kenshoo docs- search and social ads are complements; query data is valuable signal and contains user intent		Marketing funnel is imprecise model; advertisers switch budgets betweent G and Meta; ads are multipurpose- marketers target all levels of funnel; Meta competes with G, Amazon, MSFT, Tiktok ect.; prices are set at auction; tuning is a mechanism that accounts for value gaps from improvements made to auction
53	Defendant	Jeff Ezell	AT&T	11/9/2023				x		There were concerns that partnership with Branch metric would place AT&T in breach of agreements with G; no wind down period in RSAs mean AT&T can stop recieving payment but G products are already/stay pre-loaded on devices		AT&T chooses what to pre-load in order to build streamlined out of box experience and avoid "bloatware"; doesn't typically allow 3rd party apps on home screen regardless of payment amount; RSA ensures "timely" security upgrades; 2021 RSA terms with lower rev % is offset by Android initiative agreement- enabling AT&T to earn more if it maintains X amount of active Android devices
54	Defendant	Kevin Murphy	University of Chicago	11/13/20203	x		x	x		Choice screens could free up/distribute search volume;		Expert in economics, opined: 1. Google browser default agreements enhanced, rather than harmed competition 2. Android agreements are pro-competitive 3. The challenged agreements don't hinder rivals' incentives/abilities to compete; Browser defaults reflect partners' design decisions that enhance competition;Pre-installation exclusivity =/= Exclusive search on device
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