Competetion Law GOOGLE INVESTIGATION -GOOD OR EVIL?

8/22/2019 Competetion Law GOOGLE INVESTIGATION -GOOD OR EVIL?

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GOOSLE INVESTIGATION- IS GOOD EVIL?

TABLE OF CONTENTS

INTRODUCTION.. 3

EU INVESTIGATIONS: THE ALLEGATIONS. 3

1st Allegation Search Results Manipulation. 4

2nd Allegation Targeting Specific Rivals. 4

3rd Allegation Exclusive Advertising Agreements. 5

FACTS. 5

Unknown Algorithm.. 5

Market Share. 6

Law Applicable. 7

Indian Law Position. 8

Deciding upon the Liability of Google: The Arguments. 9

Reasons why Google should be held liable for Anti Competitive Practices. 9

Reasons why Google should NOT be held liable for Anti Competitive Practices. 11

Conclusion. 13

Bibliography. 14

INTRODUCTION

The subject of the paper deals with the current investigations going on against Google initiated

for its controversial behaviour in realm of internet search engines and advertising. The aim of this

paper is to bring out the reasons for the ongoing investigations against Google. The paper will

examine the facts which are present regarding Google and analyse it in relation to the allegations

against it. The paper will be presented in form of arguments making out a case against Google

and for it. For the purpose of this paper, the researchers will be looking at the issue from the EU

law position; moreover the researchers will also be comparing the issue from an Indian


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perspective. The paper will not focus on or predict the conclusion of the investigations. In order

to arrive at its arguments, the researchers will look at certain statistics which are indicative of

Googles position in the world market and specifically EU markets.

The investigations started when the services like ejuris.fr from France complained to the French

authorities that Google was actively hampering the competition in order to abuse its position in

the market.[1] The Complaint taken up by French authorities being investigated when other

countries such as United States, Germany, etc also received similar complaints. Subsequently, the

European Union decided to take up the investigations on behalf of all the member nations. The

paper will examine only the case investigation in European Union and as per the Indian law.

The researchers start the paper on the hypothesis that Google has abused its dominant position as

a service provider in the European and Indian markets, therefore they are liable under EU

Antitrust and Indian Competition Law Regime.

EU INVESTIGATIONS: THE ALLEGATIONS

The allegations against Google are in the nature that Google has been indulging in antitrust and

anti competitive practices. The allegations were being levelled against Google from rival search

engines since September of 2010[2], however to gather momentum, the allegations took a while.

Upon receiving several complaints on behalf of EU member nations and the fact that non member

nations were also receiving such complaints[3] showed that this phenomenon was not particular

to a region, but was happening worldwide. Such a massive move demanded a through probe and

on a larger scale.

On 30th November 2010, the EU Commission served a notice upon Google and initiated antitrust

proceedings. The EU notice also clearly stated that mere service of notice does not indicate thatthe EU Commission has proof of such infringements, it only means that allegations of such

magnitude deserve a unbiased and thorough investigation.[4]

The probable reason for saying this in a notice is the fact that a company as huge as Google being

under investigations would not reflect well on the company, this in turn could have a negative

impact on the companys market share and on the economy of the EU and US which are just

coming out of a recession. Keeping in mind the public interest, in the opinion of the researchers it

was only cautious of the EU Commission to state a caveat in the notice.

1st Allegation Search Results Manipulation

The alleged infringements against Google can be put in three points, firstly, that Google has

ranked certain websites lower in their search engine, especially when it has its own competing

products in the same market. For instances, in case of Air tickets it has been alleged that Google

ranks certain providers lower than others, and also promotes websites which advertise with

Google. Furthermore, the ITA acquisition by Google is supposed to give it further control over

the travel search market, and enhance its ability to further push down the search rankings of

websites owned by competing companies. Google quite obviously denies this.[5]


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The notice for investigation issued by the EU states that Google has been meting out

unfavourable treatment to the vertical search service providers in Googles unpaid and sponsored

search results in addition to giving preferential treatment to its own services.[6]

2nd Allegation Targeting Specific Rivals

Secondly, it has been alleged that Google unfairly targets websites owned and controlled by its

major rivals especially Microsoft, and websites acquired by Microsoft see a marked drop in their

rankings.[7] The effect of this is that when a person or customer searches something using the

Google search engine, the results which are displayed will be such that the Microsoft owned

websites or products would rank lower in the search, despite the fact that they might be more

relevant.

This is coupled with the allegation that certain websites are blacklisted by Google and of which

the customer is not aware. Hence while searching a particular item, Google will not display

certain websites, irrespective of the fact that they might be relevant to the search query put in by

the user.[8] The reason for blacklisting or listing only specific websites, also termed as white

listing is not known, hence the decision of listing websites solely depends on Google. However,

this is possibly a speculation as there is no conclusive proof of the same.

3rd Allegation Exclusive Advertising Agreements

The third allegation against Google is that it imposes exclusivity obligations on its advertising

and distributing partners. This is accompanied by supposed restriction on advertisers as to the

portability of campaign data to competing online advertising platforms.[9]

The results of its exclusive advertising agreements is to shut out other competitors and this

behavior of the company leads to anti competitive practices. This is especially because Google is

by far the biggest player with regards to online advertising, and the success of several products,especially web services depends on a successful Google online advertising campaign.

FACTS

As on this date, there are few facts which have come into light with respect to the allegations.

However, there are certain facts which have been in the public domain for a while now. This

segment, we shall discuss these facts which have a great bearing on the outcome of the Google

Investigations.

Unknown Algorithm

The Google search engine is based on an unknown algorithm which is responsible for the search

results being displayed. The allegation is of the search results being manipulated is a function of

the algorithm. However, this algorithm is unknown in the public domain[10]. Googles defence

regarding manipulation is heavily reliant upon the unknown algorithm.[11] This defence shall be

dealt with later in the paper.

Market Share


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The market share of Google in the world market and in the affected area is large in number. The

following chart will show the extent of Googles market share.

Figure 1

The above numbers represent statistics of Googles market share in online search engines, and

we see that as a single entity, Google has the largest share in the global market. While in

Germany, France and UK Google is clearly a majority with more than 90% share in global

market. [12]However, in India, the market share of Google is relatively less but nevertheless little

above 80%.[13] As a single entity, it can be arguably said that Google has Indias largest market

share.

With regard to statistics on advertising, we see that while examining a consolidated market as

opposed to fragmented markets of each product, Google has the majority share when compared to

its esteemed competition Microsoft and Yahoo. We see in Figure 2 that Google owns maximum

amount and has about 77% share in the online advertising sector.[14]

This is closely followed by Yahoo, which has been one of the oldest service providers, not only in

field of advertising but also in terms of search engines. Yahoo owns about 20% of the market

share and is rapidly losing its share to Google.[15]

The comparatively recent entrant Bing, from the Microsoft family, is a minority player with a tiny

market share of 3%, however, what is seen is that Bing is coming up very slowly and has

tremendous potential for growth.[16]

Figure 2

Law Applicable

The EU law has issued the notice as per Art. 102 in Treaty on the Functioning of EU, Art. 11 (6)

of Council Regulation no. 1/2003 and Art. 2 (1) of Commission Regulation No. 773/2004, both of

which provide for the initiation of proceedings; however, for the purpose of this paper, the

researchers will not deal with these laws as they are mere procedures.

The aforesaid Art 102 states that dominant position must not be abused, this shows that prima

facie being in dominant position is not a problem, nevertheless abusing it could get one in

trouble. Article also defines abuse.

The researchers will focus on Art. 54 of European Economic Area Agreement, which states:

Any abuse by one or more undertakings of a dominant position within the territory covered by


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this Agreement or in a substantial part of it shall be prohibited as incompatible with the

functioning of this Agreement in so far as it may affect trade between Contracting Parties.

1. Such abuse may, in particular, consist in:

a) directly or indirectly imposing unfair purchase or selling prices or other unfair trading

conditions;

b) limiting production, markets or technical development to the prejudice of consumers;

c) applying dissimilar conditions to equivalent transactions with other trading parties,

thereby

placing them at a competitive disadvantage;

d) making the conclusion of contracts subject to acceptance by the other parties of

supplementary

obligations which, by their nature or according to commercial usage, have no connection with the

subject of such contracts.

Art. 52 would apply when an entity is in dominant position and is abusing such dominant

position, the nature of abuse must be such that it extends over different geographical territories

because if it is specific only to one or two nation then domestic laws would apply. Undertakings

by the entity when are incompatible with the EEA, then EU Commission would have the power

to investigate such dealings. The Article further enumerates the scope of the term abuse.

Indian Law Position

Sec 4 of the Indian Competition Act 2002 if for prohibition of abuse of dominant position, the

section carves out the requirements of this section. The section reiterates the earlier position that

being in dominant position, itself, is not a prohibited or anti competitive. However, abuse of such

dominant position is prohibited[17] under the law for the simple reason that it is anti competitive.

Sec 4(2) in detail lists out when an enterprise is said to abuse the dominant position, but for

ascertaining whether an entity is in dominant position, one has to refer to second explanation of

Sec 4 (2) which says that

(a) dominant position means a position of strength, enjoyed by an enterprise, in the relevant

market, in India, which enables it to

i. operate independently of competitive forces prevailing in the relevant market; or

ii. affect its competitors or consumers or the relevant market in its favour

The Competition Commission is empowered to inquire into any alleged contravention of


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dominant position in three ways, first, it can suo moto take up the investigation, second on

receiving complaint from an any person, consumer or their association or trade association and

thirdly by a reference made to it by Central Government or a State Government or Statutory

authority. The power to investigate such complaints or reference finds a place in the statute itself

under Sec. 19 (1)

Sec 19 (4) gives detailed list which is to be considered while determining whether an enterprise is

in dominant position. The list is not an exhaustive list and is an indicative of what all can be

considered while determining the dominant position. Market share, size and resources of the

enterprise are one of the few indicative, yet, prominent indicators of whether an enterprise enjoys

dominant position.

Market being an abstract term is given meaning by the statute as it is called relevant market and

the Commission has to consider geographical market and product market as well. This is

provided under Sec. 19 (5) of the Competition Act. Even while determining geographical market

or product market the statute lays down conditions to be considered, this is laid down under Sec.

19 (6) and Sec. 19 (7).

Deciding upon the Liability of Google: The Arguments

The liability of Google is not finally agreed upon by the researchers, however, for the purpose of

this paper, the researchers will present both the sides of the argument, without going into the

conclusion of the same.

Reasons why Google should be held liable for Anti Competitive Practices

It is agreed that Google dominates the 90% share of the world market[18] in different arenas. It is

also an argument that since Googles algorithm is unknown, it is difficult to ascertain the reasons

for the arrangement of the search results in a particular manner.

Allegation against Google has been that it places its rival companies on a lower search result

scale. For instance, Microsoft related websites are often listed lowest in the Googles search

results.[19]

Google also possess a direct competition to the vertical search engines, especially its acquisition

of ITA, which will give it enough control over the air ticket market because it will be able to

tweak the air ticketing software being used by several major airlines.[20]

Once upon a time, the Microsoft tried to kill the competition in the browser market by bundling

in Internet Explorer for free with Windows Operating System. However after a case against

Microsoft for maintaining this exclusivity, the company changed its policy and gave users the

option to use any browser.[21] However, despite the provision of an option of browser, the user

still retained considerable control over the services it chose to use using it. On the other hand, in

case of Google, the Googles Chrome, Android Smart phones and Chrome OS all encourage use


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of Googles Search, which makes a thorough investigation even more essential.[22]

Google has been alleged to have Exclusive agreements[23] with advertisers which has given

the company too much control over the advertisers as several restrictions are placed to maintain

exclusivity. This behavior of Google may be termed as anti competitive.[24]

By the fact that the rival companies have hardly any market share, it can be deduced that Google

is in the dominant position and by its behavior it cannot be ruled out that Google might not be

indulging in anti competitive practices. Hence the allegations against Google mandate a serious

enquiry. Of course there is no presumption of guilt due to such dominant position, as per the

Indian or the EU competition law regime.

Google Inc is a vertically integrated empire, this means that search of one product leads to

discovery of another product, which is also connected to Google. Right from searching the

product, advertising or buying it, Google enters the field in all areas. Thus, it has a lot of control

over the consumer, the seller of the product and the manufacturers and gets a benefit from each

part of the transaction.

We must remember that there are several factors which might cast a huge doubt on Googles

practices. Thus, apart from its dominant Position resultant of its market share, is its ability to

affect the market, in ways that might be detrimental to other companies and even anti competitive

and might just lead to the abuse of its dominant position. It must be remembered that

advertisement cost indirectly is transferred to Consumers and anti competitive practices involving

the same raise prices for them as well.

Reasons why Google should NOT be held liable for Anti Competitive Practices

On the other side of the spectrum are arguments which are coming from several quarters as to

how and why Google cannot and should not be held liable for anti competitive practices. The first

and foremost amongst them all is that unlike other industries, even in the technology sector, the

internet is closest to a free market where only the best and most useful products and services

survive. Thus, a product from a non descript country might do as well as any other company. Also

financial soundness is not a determinant of success on the virtual world, unlike the real world

industries, and the barriers to entry are a lot lower. The internet is such that even established

companies often have to face defeat in their endeavours of creating successful products. An

example of which is Googles drubbing in the social network website business wherein its Orkut

and Buzz service failed to match up to the popularity and utility of Facebook. It is indeed true that

the internet, unlike other businesses, is product quality driven with usually a very low cost ofmoving to other products and services. For example in case of social networks, Myspace which

was owned by Microsoft gave way to Orkut which was owned by Google, which has now given

way to Facebook. Other similar examples would be of Email services, wherein Hotmail, which

completely revolutionised the market initially with the products it offered, and then it gave way to

Yahoo/AOLs email services, which gave way to Gmail, and now it is a possibility that Facebook

Mail might become major player in this very market.


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The second and a very promising argument is that as Google earns a lot more through search

advertising than it does through its own services, modifying organic search results to favour some

and against some would not be the best of strategies to use, especially because it will strike at the

root of its biggest business success: the Google search engine.[25] In fact Googles dominance in

search and rather the internet is solely the result of it giving better and more relevant results to its

users, which cannot be delivered by tampering with organic search results, as used to be done inthe 90s by several search engine service providers.

The third argument is the one which is advanced by Google itself, wherein it states that the

popularity of websites in its search rankings are more about proper search engine optimization

(SEO) than anything else, and in fact they cheekily suggest that possibly many of the companies

complaining against them should possibly try working on better SEO![26]

The fourth argument is the nature of the internet itself wherein different players have succeeded at

different points in time, only to be overtaken by other companies providing better goods and

services. As a matter of fact, even the search engine industry used to be dominated by AltaVista in

the 90s, but Google overtook it with its cutting edge search engine.[27] The future is still veryuncertain and it is very possible for another competitor, including Bing and possibly even

Facebook to over shadow Googles search engine in the coming years, though presently it seems

to be a distant possibility.[28]

The fifth argument that is being used to support Googles point of view is that allegedly the action

has been pushed through by rivals like Microsoft which is trying to gain a foothold in the search

business as well with its Bing! search engine, and are using the anti-trust action to gain traction

for their own search engine. Furthermore, all major players like Yahoo and Bing are trying to get

a better share of the search advertising market and that can be seen from their recent acquisitions

of web advertisement firms, just when Google bought DoubleClick.[29] Thus, given the large

amount of revenue involved in online search and advertising business, many big players, such asMicrosoft, Apple and Facebook, who have relatively deep pockets, would like to see themselves

playing a bigger role in this market, but unsettling Googles dominance.[30]

Conclusion

In this paper the researchers have tried to flesh out some of the possible arguments that could bemade for or against Google, in view of investigation into its alleged anti competitive activities.

These conclusions cannot prove or disprove the factum of Googles anti competitive behaviour

but they do try to look at the factors which the EU competition watch dog might be looking at.

The researchers believe that Googles revolutionary products, especially Google Search have

changed the face of the internet (and possibly the world). However, Google should never be

allowed to abuse its dominant position, but using it legitimately should not be looked down upon.


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There is no presumption of abuse made in case of anti-competition laws being examined in this

paper, and hence there is no reason to believe that Google is guilty of anti competitive practices.

On the other hand, we are also of the opinion that given the clear indicators as to Googles

dominance in world search and internet advertising markets, it is prudent in public interest to

investigate its processes in a much better manner. However, this must not become an opportunity

for rival companies to tarnish Googles image in the garb of their so called public spirited actions.

Therefore, we believe that Google should be asked to disclose its unknown algorithm to a group

of experts who will examine to see whether it is being used for any anti competitive purposes and

furthermore, it might be prudent to make provisions for regular review of the same, as was done

in the Microsoft case, to avoid any further suspicion or possibility of anti competitive behaviour.

Bibliography

Articles

Greg Sterling , Admitting Role In Google Anti-Trust Complaints Microsoft Complains Of Google

Lock In. Available at searchengineland.com/admitting-role-in-google-anti-trust-complaints-

microsoft-complains-of-google-lock-in-37009

Google and Anti Trust: Engine Trouble, Available at www.economist.com/node/17629823

Microsoft says Googles Acts Raise Anti trust Issues, Available at

www.reuters.com/article/idUSTRE61Q02H20100227

Google Defends itself against Anti trust Regulation, available at

www.informationweek.com/news/internet/google/showArticle.jhtml?

articleID=217800685&pgno=3&queryText=&isPrev=

Facts about Googles acquisition of ITA Software, available at

www.google.com/press/ita/saying.html.

Antitrust Suit Filed Against Google Available at

www.businessweek.com/the_thread/techbeat/archives/2009/02/antitrust_suit.html

googlesystem.blogspot.com/2009/03/googles-market-share-in-your-country.html

As Google Grows so do the Anti Trust Issues, available at blogs.wsj.com/law/2009/05/08/as-

google-grows-so-to-do-the-antitrust-issues

Committed to competing fairly, available at

googlepolicyeurope.blogspot.com/2010/02/committed-to-competing-fairly.html
http://var/www/apps/conversion/tmp/scratch_5/www.economist.com%2Fnode%2F17629823http://var/www/apps/conversion/tmp/scratch_5/www.reuters.com%2Farticle%2FidUSTRE61Q02H20100227http://var/www/apps/conversion/tmp/scratch_5/www.informationweek.com%2Fnews%2Finternet%2Fgoogle%2FshowArticle.jhtml%3FarticleID=217800685&pgno=3&queryText=&isPrev=http://var/www/apps/conversion/tmp/scratch_5/www.informationweek.com%2Fnews%2Finternet%2Fgoogle%2FshowArticle.jhtml%3FarticleID=217800685&pgno=3&queryText=&isPrev=http://var/www/apps/conversion/tmp/scratch_5/www.google.com%2Fpress%2Fita%2Fsaying.htmlhttp://var/www/apps/conversion/tmp/scratch_5/www.businessweek.com%2Fthe_thread%2Ftechbeat%2Farchives%2F2009%2F02%2Fantitrust_suit.htmlhttp://var/www/apps/conversion/tmp/scratch_5/www.reuters.com%2Farticle%2FidUSTRE61Q02H20100227http://var/www/apps/conversion/tmp/scratch_5/www.informationweek.com%2Fnews%2Finternet%2Fgoogle%2FshowArticle.jhtml%3FarticleID=217800685&pgno=3&queryText=&isPrev=http://var/www/apps/conversion/tmp/scratch_5/www.informationweek.com%2Fnews%2Finternet%2Fgoogle%2FshowArticle.jhtml%3FarticleID=217800685&pgno=3&queryText=&isPrev=http://var/www/apps/conversion/tmp/scratch_5/www.google.com%2Fpress%2Fita%2Fsaying.htmlhttp://var/www/apps/conversion/tmp/scratch_5/www.businessweek.com%2Fthe_thread%2Ftechbeat%2Farchives%2F2009%2F02%2Fantitrust_suit.htmlhttp://var/www/apps/conversion/tmp/scratch_5/www.economist.com%2Fnode%2F17629823


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Google-ITA Software deal: Bad timing for Google? Available at

www.tnooz.com/2010/09/20/news/google-ita-software-deal-bad-timing-for-google/

Diller: Google Faces Antitrust Issues On Search Neutrality available at

www.tnooz.com/2010/10/01/news/diller-google-faces-antitrust-issues-on-search-neutrality/.

Acquisitions and Anti Trust, available at googlepublicpolicy.blogspot.com/2010/12/acquisitions-

and-antitrust.html

Local Search: Its all about Best Answers, available at

googlepublicpolicy.blogspot.com/2010/12/local-search-its-all-about-best-answers.html.

Is Google too Big to Shop?, available at dealbook.nytimes.com/2010/12/15/is-google-too-big-to-

shop.

Brussels pushes harder in Google probe, available at

www.theregister.co.uk/2010/12/17/google_eu/

European Antitrust Inquiry Into Google Is Broadened, available at

www.nytimes.com/2010/12/18/technology/18google.html?_r=1

Round Two: Is Google a Monopoly?, available at dealbook.nytimes.com/2010/12/21/round-two-

is-google-a-monopoly

Books

D. A. Vise, The Google Story: Inside the Hottest Business, Media and Technology Success of Our

Time, (Pan Macmillan: London, 2008)

S. Gilbert, The Story of Google, books.google.co.in/books?

id=15FITwV8HlIC&printsec=frontcover#v=onepage&q&f=false

S.Brin and L.Page, Google Speaks: Secrets of the Worlds Greatest Billionaire Entrepreneurs

books.google.co.in/books?

id=NfkonH0VcT0C&printsec=frontcover&source=gbs_atb#v=onepage&q&f=false

Miscellaneous

Global Digital Marketing Performance Search Engine Report, available at

www.efrontier.com/sites/default/files/Digital-Performance-Marketing-Report-Q4-20101.pdf.

[1]www.theregister.co.uk/2010/12/17/google_eu/

[2]www.theregister.co.uk/2010/12/17/google_eu/

[3] dealbook.nytimes.com/2010/12/15/is-google-too-big-to-shop and

www.google.com/press/ita/saying.html
http://var/www/apps/conversion/tmp/scratch_5/www.tnooz.com%2F2010%2F09%2F20%2Fnews%2Fgoogle-ita-software-deal-bad-timing-for-google%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.tnooz.com%2F2010%2F10%2F01%2Fnews%2Fdiller-google-faces-antitrust-issues-on-search-neutrality%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.nytimes.com%2F2010%2F12%2F18%2Ftechnology%2F18google.html%3F_r=1http://var/www/apps/conversion/tmp/scratch_5/www.efrontier.com%2Fsites%2Fdefault%2Ffiles%2FDigital-Performance-Marketing-Report-Q4-20101.pdfhttp://var/www/apps/conversion/tmp/scratch_5/www.efrontier.com%2Fsites%2Fdefault%2Ffiles%2FDigital-Performance-Marketing-Report-Q4-20101.pdfhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.google.com%2Fpress%2Fita%2Fsaying.htmlhttp://var/www/apps/conversion/tmp/scratch_5/www.tnooz.com%2F2010%2F09%2F20%2Fnews%2Fgoogle-ita-software-deal-bad-timing-for-google%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.tnooz.com%2F2010%2F10%2F01%2Fnews%2Fdiller-google-faces-antitrust-issues-on-search-neutrality%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.nytimes.com%2F2010%2F12%2F18%2Ftechnology%2F18google.html%3F_r=1http://var/www/apps/conversion/tmp/scratch_5/www.efrontier.com%2Fsites%2Fdefault%2Ffiles%2FDigital-Performance-Marketing-Report-Q4-20101.pdfhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.theregister.co.uk%2F2010%2F12%2F17%2Fgoogle_eu%2Fhttp://var/www/apps/conversion/tmp/scratch_5/www.google.com%2Fpress%2Fita%2Fsaying.html


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[4]http://europa.eu/rapid/pressReleasesAction.do?

reference=IP/10/1624&format=HTML&aged=0&language=EN&guiLanguage=en

[5]http://www.informationweek.com/news/internet/google/showArticle.jhtml?

articleID=217800685&pgno=3&queryText=&isPrev=

[6] Supra Note 4.

[7] Supra Note 4.

[8] blogs.wsj.com/law/2009/05/08/as-google-grows-so-to-do-the-antitrust-issues/.

[9] Supra Note 4.

[10] dealbook.nytimes.com/2010/12/21/round-two-is-google-a-monopoly.

[11] blogs.wsj.com/law/2009/05/08/as-google-grows-so-to-do-the-antitrust-issues/.

[12] googlesystem.blogspot.com/2009/03/googles-market-share-in-your-country.html.


[14] news.cnet.com/8301-1023_3-9993380-93.html

[15] news.cnet.com/8301-1023_3-9993380-93.html


[17] Sec 4 (1) of the Act

[18] www.tnooz.com/2010/10/01/news/diller-google-faces-antitrust-issues-on-search-neutrality/

[19] www.economist.com/node/17629823 .

[20] www.google.com/press/ita/saying.html

[21] Microsoft v. U.S.

[22] The reliance on Googles search engine is getting even more pronounced with the success of

its open-source mobile platform, Android, which has in no time become the most popular smart

phone operating system.

[23] www.economist.com/node/17629823 .

[24] dealbook.nytimes.com/2010/12/21/round-two-is-google-a-monopoly/?

[25] googlepolicyeurope.blogspot.com/2010/02/committed-to-competing-fairly.html

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[28] www.economist.com/node/17629823

[29] googlepublicpolicy.blogspot.com/2010/12/acquisitions-and-antitrust.html

[30] www.reuters.com/article/idUSTRE61Q02H20100227

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Competetion Law GOOGLE INVESTIGATION -GOOD OR EVIL?

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