UNITED STATES OF AMERICA et al v. GOOGLE LLC

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
_________________________________________
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UNITED STATES OF AMERICA et al., )
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Plaintiffs, )
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v. ) Case No. 20-cv-3010 (APM)
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GOOGLE LLC, )
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Defendant. )
_________________________________________ )
_________________________________________
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STATE OF COLORADO et al., )
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Plaintiffs, )
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v. ) Case No. 20-cv-3715 (APM)
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GOOGLE LLC, )
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Defendant. )
_________________________________________ )
MEMORANDUM OPINION
I. INTRODUCTION
The age-old saying “the devil is in the details” may not have been devised with the drafting
of an antitrust remedies judgment in mind, but it sure does fit.
On September 2, 2025, the court issued a Memorandum Opinion (“Remedies Opinion”),
ECF No. 1435 [hereinafter Rem. Op.], following its determination that Defendant Google LLC
had maintained monopolies in the general search services and general search text advertising
markets through exclusive distribution agreements in violation of Section 2 of the Sherman Act.
See United States v. Google LLC, 747 F. Supp. 3d 1 (D.D.C. 2024). The Remedies Opinion
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recounted the case’s procedural history; made new findings of fact, particularly with respect to
emerging generative AI (“GenAI”) products; discussed the legal principles animating the court’s
decision; and determined the scope of remedies sufficient to “pry open” the markets closed by
Google’s antitrust violations. The court agreed that Google’s proposed prohibitory injunctions
were a start. Rem. Op. at 107. But it also held that, to be effective, the remedies should include
some of Plaintiffs’ proposed behavioral remedies, including disclosure of information about
Google’s search index, compelled sharing of certain user data, and forced syndication of search
results and search text ads, as well as a Technical Committee to assist Plaintiffs with their
enforcement efforts. The court rejected more severe proposals, such as the divestiture of Chrome,
mandated choice screens, and a complete payment ban, among others. Id. at 3–6.
The court then directed the parties to meet and confer and present a joint proposed final
judgment consistent with the Remedies Opinion’s findings and conclusions. See id. at 222–23.
That is when the devil reared its head. As has been true during much of this five-year-long
litigation, the parties continued to see eye-to-eye on little, even with the benefit of the Remedies
Opinion. They submitted two competing final proposed final judgments reflecting their respective
interpretations of the Remedies Opinion with accompanying briefs explaining their positions.
See Pls.’ Br. in Supp. of Pls.’ Final Proposed Final J., ECF No. 1442 [hereinafter Pls.’ Br.];
Pls.’ Br., Pls.’ Final Proposed Final J., ECF No. 1442-1 [hereinafter Pls.’ FPFJ]; Def. Google
LLC’s Br. in Supp. of Entry of its Proposed Final J., ECF No. 1441 [hereinafter Google’s Br.];
Google’s Br., App. to Google’s Br., ECF No. 1441-1 [hereinafter Google’s App’x]; Google’s Br.,
Def. Google LLC’s Proposed Final J., ECF No. 1441-2 [hereinafter Google’s FPFJ].
The parties convened before the court on October 8, 2025, for a hearing on those proposed
final judgments (“October 8th hearing”). See Tr. of Hr’g on Final J. Proceedings, ECF No. 1447
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[hereinafter Hr’g Tr.]. A week later, Plaintiffs filed a Notice of Substitute Provisions offering
modified versions of certain provisions in their proposed prohibitory injunctions that purported to
reflect an updated understanding of the court’s Remedies Opinion. See Pls.’ Notice of Substitute
Provisions, ECF No. 1449 [hereinafter Pls.’ Suppl.]. Google responded a few days later.
See Def. Google LLC’s Resp. to Pls.’ Suppl., ECF No. 1451 [hereinafter Google’s Suppl.].
Having now heard hundreds of hours of testimony, reviewed thousands of pages of exhibits
and briefing, and considered all the relevant law and authorities across both the liability and
remedies phases, the court at long last enters the Final Judgment against Google. While the
Remedies Opinion broadly established the court’s remedy-specific conclusions of law, the court
now explains with more granularity the reasons for adopting, rejecting, or modifying the specific
provisions of the parties’ most recent proposed final judgments. See United States v. Microsoft
Corp. (Microsoft III), 253 F.3d 34, 103 (D.C. Cir. 2001) (en banc) (holding that the district court
must “provide an adequate explanation for the relief . . . ordered” and “explain[] how its remedies
decree would accomplish [the] objectives” of antitrust remedies established by the Supreme
Court); cf. Verizon Commc’ns Inc. v. Law Offs. of Curtis V. Trinko, LLP, 540 U.S. 398, 415 (2004)
(“No court should impose a duty to deal that it cannot explain or adequately and reasonably
supervise.” (citation omitted)).
Rather than regurgitate the whole of the Remedies Opinion or scrutinize every word of the
parties’ proposals, this opinion highlights the parties’ major disagreements and explains how the
court resolves them in the Final Judgment. For completeness, the court also includes an Appendix
identifying the finer differences between the parties’ proposals and the language the court
ultimately adopts.
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II. GENERAL PRINCIPLES
The court starts with three preliminary points. First, in their briefs and at the October 8th
hearing, the parties repeatedly offered as a basis for advancing their positions that, by deciding in
the Remedies Opinion to impose or modify a certain remedy, the court had “adopted” text from
the party’s proposed final judgment, or that their proposed provisions “track” the Remedies
Opinion while the other’s depart. See, e.g., Hr’g Tr. at 21:13-17; id. at 41:18–42:10; Pls.’ Br. at
11–12, 28–29; Google’s Br. at 10, 13, 15. Such arguments rest on an incorrect assumption. As
emphasized at the hearing, to the extent the court “adopted” anything offered by a party, it was a
proposed remedy as a general concept, not the text offered to define it. Hr’g Tr. at 21:18–22:3.
“It is a federal court’s judgment, not its opinion, that remedies an injury.” Haaland v. Brackeen,
599 U.S. 255, 294 (2023). The court exercises its remedial authority in this case through the Final
Judgment; the Remedies Opinion and the one at hand merely explain the exercise of this authority.
See Franklin v. Massachusetts, 505 U.S. 788, 825 (1992) (Scalia, J., concurring); cf. Trump v.
CASA, Inc., 606 U.S. 831, 930 n.3 (2025) (Jackson, J., dissenting).
Second, the court reiterates the scope of its remedial authority. “The remedy in a Section 2
enforcement action ‘must seek’ to ‘unfetter a market from anticompetitive conduct,’ ‘deny to the
defendant the fruits of its statutory violation, and ensure that there remain no practices likely to
result in monopolization in the future.’” Rem. Op. at 58 & n.3 (quoting Microsoft III, 253 F.3d at
103). Supreme Court precedent “uphold[s] equity’s authority to use drastic measures to achieve
freedom from the influence of the unlawful restraint of trade,” as long as such measures
“reasonably tend[] to dissipate the restraint and prevent evasions.” United States v. Bausch &
Lomb Optical Co., 321 U.S. 707, 726 (1944). But the “[m]ere existence of an exclusionary act
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does not itself justify full feasible relief against the monopolist to create maximum competition.”
Microsoft III, 253 F.3d at 106 (citation omitted); see also Rem. Op. at 62–63.
Though these broad principles framed the court’s task, the evidence (or lack of it) was the
key to deciding whether to adopt or reject a proposed remedy. After all, “[t]here can be no remedy
absent a factual basis to support it.” Rem. Op. at 119. The court considered and rejected proposed
remedies that could not be sufficiently justified by evidence. See, e.g., id. at 119–28 (rejecting a
payment ban because of anticipated harms to third parties); id. at 164–68 (declining to require
Ads Data–sharing because Plaintiffs did not offer sufficient evidence as to how it would increase
competition in the general search text ads market); see also id. at 128 n.14 (declining to consider
a partial payment ban because of a lack of evidence). The court continues to be guided by the
evidence in fashioning the specific terms of the Final Judgment.
Finally, “it is well settled that once the Government has successfully borne the considerable
burden of establishing a violation of [antitrust] law, all doubts as to the remedy are to be resolved
in its favor.” United States v. E. I. du Pont de Nemours & Co., 366 U.S. 316, 334 & n.18 (1961)
(first citing Bausch & Lomb, 321 U.S. at 726; then citing Loc. 167 of Int’l Bhd. of Teamsters v.
United States, 291 U.S. 293, 299 (1934)). Plaintiffs in this case have successfully borne this
burden. See Google, 747 F. Supp. 3d at 32. Where any doubts remained after considering the
evidence and the parties’ positions, the court has deferred to Plaintiffs as to the appropriate
remedial terms. See also Rem. Op. at 60 (citing 3 PHILLIP E. AREEDA & HERBERT HOVENKAMP,
ANTITRUST LAW ¶ 653f (5th ed. & Supp. 2025) [hereinafter AREEDA & HOVENKAMP] (“[A]ny
plausible doubts should be resolved against the monopolist.”)); id. at 66 n.4 (citing 3 AREEDA &
HOVENKAMP ¶ 650a(2)(B) (“[I]t is always appropriate to deprive the defendant of the continuing
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benefits of past misbehavior. In devising the ‘tailored’ remedies for this purpose, reasonable
doubts will ordinarily be resolved against the defendant.”)).
With this understanding, the court now turns to those terms. The court begins by
addressing several definitions that are fundamental to the reach and effect of the Final Judgment.
It then turns to the prohibitory injunctions and required data-sharing and syndication remedies.
The court concludes by explaining how the Final Judgment will be enforced, in particular the
Technical Committee’s operations and the court’s retention of jurisdiction. The provisions not
addressed in this opinion can be found in the Appendix.
III. DEFINITIONS
A. GenAI-Related Terms
GenAI plays a significant role in these remedies. As a refresher, between the liability and
remedies phases, GenAI burst on to the scene as a formidable nascent threat to general search
engines (GSEs). Rem. Op. at 2; see also id. at 99 (“[T]here is ample evidence that GenAI chatbots
grounded in general search perform an information-retrieval function that is similar to GSEs.”).
The remedies phase thus became “as much about promoting competition among GSEs as ensuring
that Google’s dominance in search does not carry over into the GenAI space.” Id. at 2; see also
id. at 106–07 (“GenAI products have emerged as a competitive threat to the traditional GSE, and
Google cannot be permitted to leverage its dominance in general search to the GenAI product
space.”).
The court determined that GenAI products and companies should be included in the
remedies insofar as GenAI products and GSEs share the capacity to “fulfill a broad array of
informational needs.” Id. at 99–101; see also id. at 45–46 ¶ 66. The court rejected Google’s
insistence that GenAI products should be excluded because they were outside the relevant markets
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or untethered to Plaintiffs’ theory of liability. See id. at 101. Expanding the scope of the remedies
to include GenAI, the court held, was both within the court’s authority and appropriate to ensure
that Google’s illegal conduct could not reverberate into that emerging market. Id. at 101–02 (citing
New York v. Microsoft Corp. (New York I), 244 F. Supp. 2d 76, 128–29, 193 (D.D.C. 2002)).
Despite this, the parties maintain drastically different understandings of how a GenAI
product should be defined for purposes of the Final Judgment. Plaintiffs would have “GenAI
Product” mean “any application, software, service, feature, tool, functionality, or product that
involves or makes use of Generative AI capabilities or models.” Pls.’ FPFJ § IX.J. Google offers
no similar umbrella definition. Rather, in an effort to narrow the universe of GenAI products swept
into the Final Judgment, it offers several different terms referring to discrete GenAI products or
categories of products that have among their “principal functions answering information-seeking
prompts across a wide variety of topics using a broad range of publicly available information.”
See Google’s FPFJ § IX.K, L, Y, Z.
The court adopts Plaintiffs’ definition of “GenAI Product” with Google’s specification that
a GenAI Product, for purposes of this decree, have “among its principal functions answering
information-seeking prompts across a wide variety of topics using a broad range of publicly
available information.” See Final J., ECF No. 1462 [hereinafter FJ], § IX.J.
Google’s discrete terms are too narrow. Taken together, they have the potential to exclude
Google GenAI products beyond Google Gemini and Google Assistant or any product that is not
strictly “a user-facing mobile software application . . . that makes use of generative AI capabilities
or models.” See Google’s FPFJ § IX.K, L; see also Pls.’ Br. at 28–29.
But Plaintiffs’ proposed definition is exceedingly broad. The parties’ shared definition of
“GenAI” (as opposed to “GenAI Product”) is “a type of artificial intelligence that creates new
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content including but not limited to text, images, code, classifications, and other media using
machine learning models.” See Pls.’ FPFJ § IX.I; Google’s FPFJ § IX.H; see also Rem. Op. at 17
¶ 2. Products that “involve[] or make[] use of [such] capabilities or models” encompass a near
infinite swath of industries and products having nothing to do with GSEs or the illegal conduct at
issue. See Google’s Br. at 2–5.
GenAI products and companies were expressly included in the Final Judgment because of
the growing integration of GenAI into search products. See Rem. Op. at 19 ¶ 6. But search and
GenAI are not completely interchangeable. See Remedies Hr’g Tr., ECF Nos. 1393–1420
[hereinafter Rem. Tr.], at 21:2-5 (Opening Arg.) (Plaintiffs’ counsel acknowledging that search
and GenAI “are different but overlapping products” and that GenAI “is not a replacement for
[s]earch today”); Rem. Op. at 43 ¶ 63. At least for now, GSEs and GenAI products have use cases
not shared by the other. See Rem. Op. at 44 ¶ 65. Narrowing Plaintiffs’ definition to products that
have “among [their] principal functions answering information-seeking prompts across a wide
variety of topics using a broad range of publicly available information” better fits the purpose of
including GenAI products within the remedial scheme.
Plaintiffs themselves acknowledge that the court “was clear that the final judgment shall
extend to any GenAI Product with the ‘capacity to fulfill a broad array of informational needs.’”
Pls.’ Br. at 28–29 (quoting Rem. Op. at 100). Yet in the same breath, they argue that “Google’s
attempt to restrict what GenAI Products are covered by the final judgment based on their form or
‘principal function’ . . . excludes relevant Google GenAI Products from the final judgment [and]
ignores any possibility that nascent GenAI competitors may disrupt Google’s market dominance
through future innovations.” Id. at 29. Although Plaintiffs stated later that it was “not [their]
intention” to sweep in GenAI technologies such as those powering non-information-retrieval
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functions in Google products like Photos, Gmail, or Drive, Hr’g Tr. at 114:5–115:9; see Google’s
Br. at 2–3, their proposal unequivocally does so.
For these reasons, the court has adopted the definition of “GenAI Product” described
above.1 See FJ § IX.J. The modification makes adopting Plaintiffs’ definition of “Third-Party
GenAI Product” appropriate. See FJ § IX.CC; Pls.’ FPFJ § IX.FF. The court also adopts
Plaintiffs’ definition of “Google GenAI Product.” See FJ § IX.N; Pls.’ § IX.N. Finally, the court
adopts Google’s definition of “Google Assistant Application,” as Plaintiffs’ addition of “and . . .
any Google GenAI Product” would have swallowed the rest of the definition into a nullity.
See FJ § IX.M; Pls.’ FPFJ § IX.M; Google’s FPFJ § IX.K.
B. “Qualified Competitor” and “Competitor”
Because the data-sharing and syndication remedies are designed to directly benefit
potential competitors in the relevant markets, it is necessary to define which emerging or extant
competitors are eligible to enjoy them—that is, to determine who is a “Qualified Competitor.”
To start, the court has adopted Plaintiffs’ version of “Competitor.” See FJ § IX.E. The
parties’ proposed definitions are not so far off, but Google’s includes several qualifications.
Compare Pls.’ FPFJ § IX.E, with Google’s FPFJ § IX.D. Plaintiffs’ version is simpler and reflects
the court’s directive to include GenAI; the court did not intend to broaden the definition of a
Competitor to then narrow it again in unnecessary ways. See Rem. Op. at 103–04 & n.8.
The parties agree that a Qualified Competitor should meet certain data security standards,
agree to regular data security and privacy audits, not pose a risk to the national security of the
United States, and make a sufficient showing of a plan to invest and compete in or with the GSE
1 The court sees no material distinction between the definition of “GenAI Product” it has adopted and Plaintiffs’
suggestion that their definition of “GenAI” should be left intact with their definitions of “Google GenAI Product” and
“Third-Party GenAI Product” limited only to those products that can “fulfill a broad array of informational needs.”
Hr’g Tr. at 115:5-20.
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and/or Search Text Ads markets.2 See Pls.’ FPFJ § IX.W; Google’s FPFJ § IX.T. These criteria
will ensure that the data-sharing and syndication remedies fulfill their intended purpose of
increasing competition in the relevant markets. See Rem. Op. at 129–36, 170–71.
The biggest disagreement among the parties concerns Google’s proposal that a Qualified
Competitor not only be initially certified as one but also annually recertified on those same criteria.
See Google’s FPFJ § IX.T. Google points out that, because Qualified Competitors will be given
an enormous quantity of valuable rights and data, “the incentives for mischief . . . will be
enormous.” Hr’g Tr. at 26:13-18. Google reasons that bad actors that are initially certified as
Qualified Competitors could easily abandon a previously demonstrated “plan to invest and
compete in or with” the relevant markets and potentially pose privacy and security risks or simply
become a white label of Google. Id. at 26:13–28:4. In the absence of a recertification requirement,
Google contends, the remedies could incentivize harmful or even anti-competitive behavior or
allow it to escape detection.
Plaintiffs object to the recertification requirement as “unnecessary red tape.” Id. at 22:5-
7. Although they agree that a Competitor that abandons its plans to compete should be decertified,
Plaintiffs argue that obvious, established contenders like Microsoft’s Bing should not be subject
to a yearly burden to continue to benefit from the remedy. Id. at 22:5-8. Putting up annual
roadblocks burdening all Qualified Competitors rather than calling out Qualified Competitors on
an individual basis “when there’s suspicion” is, to Plaintiffs, an example of a “red-tape hoop” that
Qualified Competitors must jump through that will delay getting “to a world where there’s
competition.” Id. at 25:4-11, 37:6-23.
2 The court expressly revised the language “plan to invest and compete in” to “plan to invest and compete in or with”
the relevant markets. See Rem. Op. at 103–04 (emphasis added). Google’s FPFJ does not reflect this revision.
See Google’s FPFJ § IX.T (“plan to invest and compete with”). The court assumes this was error.
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The court agrees with Google that an annual recertification requirement is prudent. The
court shares Google’s concern about companies initially certified as Qualified Competitors who
might abandon their professed intent to compete and improperly take advantage of data releases
or other remedies. See id. at 23:2–24:12. Some companies that already compete or have
maintained their intent to compete in the relevant markets, such as Microsoft, DuckDuckGo, and
OpenAI, will face no “red tape” in getting recertified. For new market participants, requiring them
to make an annual showing of their continued intent to compete with Google should not prove to
be overly burdensome.
Plaintiffs advance an audit procedure as an alternative to a recertification requirement. Id.
at 25:4-11. But audits are conducted in hindsight, not with foresight. By the time a reason to
initiate an audit arises, the mischief has likely already occurred, potentially with enormous
consequences not only for Google but for its users whose data may be shared with a Qualified
Competitor gone rogue. And Plaintiffs’ suggestion that Qualified Competitors warranting
decertification will be readily noticeable from their market activities (or lack thereof) suffers from
the same infirmity. See id. at 24:16-25. By the time mischief’s effects are felt in the market, it
may be too late. To arrive at a “world where there’s competition,” the remedies must ensure that
their purpose is effected through the entirety of the judgment period. An annual recertification
requirement is a relatively simple prophylactic measure to keep bad actors from escaping
detection. The court trusts that the Technical Committee and Plaintiffs will establish a
recertification process that is neither difficult nor burdensome. See id. at 27:10-14.
Finally, Google would put the burden on the court to determine, sometimes in consultation
with the Technical Committee, whether a Competitor meets the required data security standards,
poses a national security risk to the United States, and has made a sufficient showing of a plan to
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compete in or with the relevant markets. See Google’s FPFJ § IX.T. Though Plaintiffs have
hedged on this point, see infra Section VIII, the Final Judgment is enforced by Plaintiffs.
See Massachusetts v. Microsoft Corp., 373 F.3d 1199, 1243 (D.C. Cir. 2004) (“[U]ltimately the
power to enforce the terms of the decree rests with the government.” (quoting United States v.
Microsoft Corp. (Microsoft IV), 231 F. Supp. 2d 144, 198 (D.D.C. 2002))); see also Pls.’ Br. at
21–24. And the Technical Committee exists to serve Plaintiffs in that effort. See Massachusetts,
373 F.3d at 1244; see also In re Google Play Store Antitrust Litig., 147 F.4th 917, 954 (9th Cir.
2025) (establishing a Technical Committee to “provide[] a process to review and resolve inevitable
disputes between the parties—ideally without further need for judicial intervention”).
As Google often emphasized in its remedies-phase briefs, “courts should never aspire to
the role of central planners and must be sensitive to the possibility that the continuing supervision
of a highly detailed decree could wind up impairing rather than enhancing competition.” Def.’s
Proposed Conclusions of L., ECF No. 1347, at 10 (internal quotation marks omitted) (quoting
Nat’l Collegiate Athletic Ass’n v. Alston, 594 U.S. 69, 102–03 (2021)). The court therefore adopts
Plaintiffs’ version, whereby those determinations are made by Plaintiffs, in consultation with the
Technical Committee. See FJ § IX.V; see also infra Section VIII.
C. “Device”
Google proposes that a “Device” covered by the Final Judgment exclude devices running
on the ChromeOS operating system.3 Google’s FPFJ § IX.F. It points out that “Plaintiffs never
challenged agreements with companies that manufacture Chromebooks, let alone established that
those agreements harm competition” and that the court rejected Plaintiffs’ proposed self-
preferencing ban. Google’s Br. at 7–8 (citing Rem. Op. at 216–17). Google also contends that
3 Google adopted the term “Covered Device” while Plaintiffs use “Device.” Compare Pls.’ FPFJ § IX.H, with Google’s
FPFJ § IX.F. The court opts to use “Device.” See FJ § IX.H.
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placing conditions on the distribution of Chrome could not be achieved with respect to devices
running on ChromeOS because “the Chrome browser is the UI [user interface] for . . . a ChromeOS
device or Chromebook.” Id. at 8 (quoting Rem. Tr. at 3892:17-20 (Samat) (alteration in original)).
In fact, Chrome and ChromeOS are so integrated that Google has not yet been able to separate
them. Id. (citing Rem. Tr. at 2611:6-23 (Nieh)).
The court finds this reasonable. Plaintiffs insist that allowing Google to exclude
ChromeOS-based devices would permit it to enter “nakedly exclusive” agreements with
manufacturers of ChromeOS devices. See Pls.’ Br. at 26–27; Hr’g Tr. at 117:24–118:8. The court
does not share Plaintiffs’ concern. Exclusive distribution of Chrome by a manufacturer of a
ChromeOS device is not the kind of anticompetitive agreement that has been at issue in this case.
Unlike distribution on Android or Apple devices or on a third-party browser, Chrome is a necessary
component of a ChromeOS device. And although Google Search is the default search engine on
Chrome, the court previously rejected a self-preferencing ban in part because Plaintiffs never
pursued a theory of liability based on this fact. Rem. Op. at 216–17. Without a factual basis to
support restricting exclusive distribution of Chrome on ChromeOS devices, the court cannot order
Google be enjoined from entering into such agreements. Cf. Google, 747 F. Supp. 3d at 152
(“[E]xclusive agreements are not condemned per se by the antitrust laws, even if they involve a
dominant firm.”). The court also finds it reasonable to exclude ChromeOS-based devices from the
remedies altogether, rather than, as Plaintiffs suggest, identifying individual provisions from which
they are carved out. Hr’g Tr. at 117:19–118:8.
“Device” will thus expressly exclude “any device on which the ChromeOS operating
system or a successor to the ChromeOS operating system is installed.” See FJ § IX.H. Plaintiffs’
definition is otherwise consistent with the court’s interpretation of the part of Google’s remedies
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that proposed optionality as to the default GSE on a given access point on a device-by-device basis.
See Pls.’ FPFJ § IX.H (“‘Device’ or ‘device’ means any single smartphone, tablet, laptop, or
desktop. For clarity, any two devices are different devices, even if they are the same make and
model (e.g., two Samsung Galaxy S25s are two devices; two Apple iPhone 16 Pros are two
devices).”); Rem. Op. at 105. This definition ensures that optionality will exist at the level of the
individual device. See Pls.’ Br. at 27.
D. “Google”
Finally, a few words on the definition of “Google.” The parties have addressed the court’s
previous concern about the breadth of Plaintiffs’ originally proposed definition, see Rem. Op. at
221–22, by cabining it to those people or entities “controlling or overseeing Google Search
(including syndicated products), Search Text Ads (including syndicated products), the Chrome
Browser Application, the Google Search Application, the Google Assistant Application, and any
related Google GenAI Product.” See Pls’ FPFJ § IX.L; Google’s FPFJ § IX.J.
The court adopts Plaintiffs’ final proposed definition, which includes Google’s “affiliates,
partnerships, and joint ventures” and is written with an eye towards preventing Google from simply
moving its anticompetitive conduct to a sister company. See Pls’ FPFJ § IX.L. To this, the court
also adds: “For clarity, the term ‘affiliates’ includes any Alphabet, Inc.–related entity that controls
or oversees the aforementioned products.” See FJ § IX.L. This definition will capture Alphabet
subsidiaries like DeepMind that are separate from Google but work with it to develop Google
products relevant for purposes of these remedies. See Hr’g Tr. at 123:5-23; see also Rem. Tr. at
625:1–626:3 (Hsiao); id. at 3341:8-21, 3348:7-22 (Collins). Google should not be able to avoid
the terms of the Final Judgment by how Alphabet chooses to organize itself.
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IV. PROHIBITORY INJUNCTIONS
The court previously acknowledged that Google’s proposed prohibitory injunctions were
a good starting place to remedy its illegal conduct. Rem. Op. at 104. But they did not alone go
far enough, either as a class of remedies or as injunctive relief itself.
As injunctive relief, Google’s proposals addressed the core of its anticompetitive
conduct—its exclusive distribution agreements. See Google, 747 F. Supp. 3d at 32–33. The
proposed provisions broadly would have offered Google’s distribution partners more flexibility to
contract with companies other than Google for search and search-related products. Rem. Op. at
105–06. The court agreed that Google should indeed be barred from entering into those exclusive
agreements, but also added that (1) like Browser Developers, original equipment manufacturers
(OEMs) and wireless carriers should be given the opportunity to set a different GSE at various
search access points across different devices on an annual basis; (2) Browser Developers should
expressly be permitted to promote any Third-Party General Search Service or Third-Party GenAI
Product; and (3) Google should not be permitted to contract with Apple to exclusively distribute
any Google GenAI product either in any Safari mode or on any Apple mobile or desktop device.
Id. at 110–11.
In their final proposed final judgments, the parties presented slightly different versions of
Google’s originally proposed provisions reflecting different understandings of the court’s
instructions and holdings. The major disagreements here are whether (1) Google GenAI Products
should be subject to lesser restrictions; (2) prohibited conditioning of one Google product on a
partner’s acceptance of another product is limited to actual agreements; (3) distribution contracts
must terminate after one year; and (4) provisions applicable to Browser Developers and Apple
should be different from those applicable to Android devices.
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A. Effect of Inclusion of GenAI
Google appears for the most part to have heeded the court’s ruling that GenAI be
incorporated into the remedies generally, see id. at 99–104, and that it be written into certain
provisions specifically, see, e.g., id. at 111. See generally Google’s FPFJ § III. But its proposed
text includes a semantic head fake to afford greater flexibility for distributing its GenAI products.
For example, Google broadly proposes being barred from conditioning the licensing of “Google
Play or any other Google software application” on the distributing, preloading, placing,
displaying, using, or licensing of the Google Search or Chrome applications. Id. § III.A–B
(emphasis added). This prohibition would prevent Google from, say, tying distribution of Google
Maps to a partner’s acceptance of Search or Chrome. But Google proposes dropping the “any
other Google software application” language when it comes to distributing its GenAI products.
Google would bar itself from conditioning the licensing of only “the Google Search Application,
the Chrome Browser Application, or Google Play” on the distributing, preloading, placing,
displaying, using, or licensing of its GenAI products, including Gemini and Google Assistant. Id.
§ III.C–D. In other words, under Google’s proposal, it could say to a partner, “We’ll license
Google Maps but only if you also distribute Gemini.” Google employs similar methods of relaxing
restrictions that would otherwise prevent it from entering exclusive agreements in other provisions
about GenAI. Compare, e.g., Google’s FPFJ § III.H–I, with id. § III.J; id. § III.L–M, with id.
§ III.N.
Google defends this subtle yet material distinction by arguing that GenAI was “not part of
Plaintiffs’ theory of liability or the Court’s liability determination” either with respect to Google’s
conduct or its products. See Google’s Br. at 11. Provisions that regulate the licensing of Google
GenAI products or revenue-share agreements (RSAs) pertaining to such products should be
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narrower than parallel provisions for Search or Chrome, Google insists, because the former are
“forward-looking provisions” where the court’s “discretion is necessarily less broad,” and a
broader remedy creates the “danger of imposing restrictions that prevent the defendant from
forging new routes to serve consumers.” Id. at 10–12. Accordingly, Google believes it should be
able “to retain the right to condition, for example, the Google Maps and YouTube apps on the
exclusive distribution of Google GenAI and Google Assistant,” because none of these products
are “monopoly products.” Hr’g Tr. at 59:4–62:18; see also Pls.’ Br. at 5.
Adopting Google’s proposal would be self-defeating. See Rem. Op. at 62 (“Antitrust
actions would be ‘futile exercise[s]’ indeed ‘if the Government prove[d] a violation but fail[ed] to
secure a remedy adequate to redress it.” (alterations in original) (quoting E. I. du Pont, 366 U.S.
at 323)). To repeat once more, Google cannot be permitted to replay its illegal conduct with its
GenAI products. Google’s arguments have for the most part already been considered and rejected
by the court. See id. at 99–104.
It is simply not true that the injunctive relief must be so tightly shrink-wrapped around the
exact contours of liability. See Nat’l Soc’y of Pro. Eng’rs v. United States (NSPE), 435 U.S. 679,
698 (1978) (affirming injunctive relief that went “beyond a simple proscription against the precise
conduct previously pursued”); accord 3 AREEDA & HOVENKAMP ¶ 653f (“[I]njunctive relief must
be tailored with sufficient breadth to ensure that a certain ‘class’ of acts, or acts of a certain type
or having a certain effect, not be repeated.”). As Google recognizes, see Google’s Br. at 11, the
court can also enjoin “‘practices connected with acts actually found to be illegal,’ including
practices ‘which are of the same type or class as unlawful acts,’” Rem. Op. at 60 (first citing United
States v. U.S. Gypsum Co., 340 U.S. 76, 89 (1950); then citing Zenith Radio Corp. v. Hazeltine
Rsch., Inc., 395 U.S. 100, 132 (1969)). Employing “the same anticompetitive playbook for its
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GenAI products that it used for Search,” id. at 99, would surely be within the same type or class
as Google’s unlawful exclusionary acts with respect to Search.
At the October 8th hearing, Google contended that it should be permitted to condition its
GenAI products in the same way that, for example, Microsoft has been conditioning distribution
of its GenAI product, Copilot, on other applications “given the nascent nature of the market and
given the level and the degree of competition” and because “Google doesn’t have market power
in Gemini.” Hr’g Tr. at 61:5–64:5; see also Google’s Br. at 13. The court is unpersuaded.
Besides the representation made by counsel at the hearing, no evidence has been presented
that Microsoft in fact conditions distribution of Copilot on other applications, or that any other
company does so with their respective GenAI products. See Rem. Op. at 217 (finding that
Microsoft has integrated Copilot into Edge and Bing, but not that Microsoft bundles Copilot with
other applications). Even if they did, the point of these remedies is not to ensure that Google
maintains parity with competitors—it is to ensure that others can effectively compete in these
markets. Cf. Massachusetts, 373 F.3d at 1231 (Section 2 remedies must “restor[e] conditions in
which the competitive process is revived.”); 3 AREEDA & HOVENKAMP ¶ 650a(2)(D).
Moreover, Google’s argument that it should not be prevented from pursuing creative
licensing regimes with its GenAI products because of its relative lack of power in that market is
unconvincing. Remedies need not be strictly limited to “monopoly products” or even products for
which the monopolist has any leverage in the market. The New York I court recognized this when
it approved the inclusion of new technologies that “ha[d] the capacity to function in a manner
similar to that of” the middleware that was the focus of liability in the remedies decree.
224 F. Supp. 2d at 129. And the D.C. Circuit affirmed that decision. See Massachusetts, 373 F.3d
at 1204. Even Google’s own proposed provisions, by their own terms and by Google’s
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characterization, include products not at issue in liability or for which findings of fact about market
power were never established. See Google’s FPFJ § III.A–B (referring to “Google Play or any
other Google software application” (emphasis added)); Google’s Br. at 11. Google acknowledges
that even those products would fall within the court’s authority to enjoin other conduct “of the
‘same type or class’ as the violations.” Google’s Br. at 11 (citation omitted).
To be certain, the D.C. Circuit has cautioned that when “adopting a forward-looking
provision,” the court’s “discretion is necessarily less broad because . . . it is in danger of imposing
restrictions that prevent the defendant from forging new routes to serve consumers.”
Massachusetts, 373 F.3d at 1224. But that discretion is not so constricted that it prohibits the court
from imposing remedies to prevent the same unlawful conduct from occurring again in a
meaningfully overlapping context. See id. at 1233 (“The district court certainly did not abuse its
discretion by adopting a remedy that denies Microsoft the ability to take the same or similar actions
to limit competition in the future rather than a remedy aimed narrowly at redressing the harm
suffered by specific competitors in the past.”).
In sum, the court declines to accept the relaxed injunctive relief Google proposes with
respect to GenAI products. Those provisions related to such products shall be parallel to the
provisions related to non-GenAI Google products in the way that Plaintiffs propose.4 See FJ
§ III.A–D, H–J, M.
4 Google also characterizes the court’s description of its recent Gemini Commercial Agreement with Samsung as
“recogniz[ing] this distinction” between GenAI and non-GenAI products with respect to access-point optionality.
See Google’s Br. at 12–13 (discussing Rem. Op. at 50–56). The court simply described these agreements to
demonstrate that the liability decision was already influencing the way Google was contracting with its partners,
see Rem. Op. at 107, not to define the scope of the Final Judgment when it comes to the distribution of GenAI products.
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B. Scope of Prohibited Conditioning
The parties appeared to agree throughout the remedies phase about the constraints on
Google’s ability to condition the distribution of one piece of software on another. See Rem. Op.
at 106. Apparently, not so.
Google’s proposed injunctive relief prevents it from entering or maintaining agreements
that contain an express conditioning term. But Plaintiffs’ proposals ban conditioning altogether,
regardless of whether it has been memorialized in an agreement. Compare Google’s FPFJ § III.A–
J (“Google shall not enter or maintain any agreement . . . that conditions . . . .”), with Pls.’ FPFJ
§ III.A–J (“Google shall not condition . . . .”).
Plaintiffs urge acceptance of their version to prevent Google from not only entering into
agreements that contain an express conditioning term, but also declining to enter agreements that
would not. Pls.’ Br. at 3. They allege that “[i]n a meeting, Google confirmed that . . . Google
intends to reserve the right to conditionally refuse to license the Play Store based on whether the
device manufacturers opt to distribute Google Search–related products.” Id. Google emphatically
denies having made this representation, Hr’g Tr. at 54:1–56:10, but still defends its proposed
language on the basis that “Plaintiffs did not establish, and the Court did not find, that Google
engaged in any ‘conditioning’ that did not involve an agreement,” see Google’s Br. at 9–10, and
that Plaintiffs’ proposed language invites potential misinterpretation by partners, see Hr’g Tr. at
56:11-16.
The court has already explained that injunctive relief need not be surgically drawn around
the exact contours of liability. See supra Section IV.A. But more to the point, conditional refusals
to deal are as pernicious as conditional deals committed to writing. Cf. OJ Com., LLC v. KidKraft,
Inc., 34 F.4th 1232, 1247 (11th Cir. 2022) (“Conditional refusals to deal—i.e., one firm unilaterally
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refusing to deal with another firm unless some condition is met—and exclusive dealing [are]
synonymous.” (cleaned up)); BRFHH Shreveport, LLC v. Willis-Knighton Med. Ctr., 49 F.4th 520
(5th Cir. 2022) (“[C]onditional refusals to deal are functionally equivalent to exclusive-dealing
arrangements.” (citing OJ Com., 34 F.4th at 1247)); United States v. Dentsply Int’l, Inc., 399 F.3d
181, 193 (3d Cir. 2005) (analyzing exclusionary business practices as if they were exclusive
agreements because such practices were “as effective as those in written contracts”). A prohibition
on Google’s anticompetitive conduct would be fundamentally flawed if, for example, Google were
prohibited from entering into an agreement that expressly conditions the licensing of the Play Store
on the distribution of Search but were permitted to decline a request to license Google Play because
the partner would not preinstall Search on its devices. See Pls.’ Br. at 3. After all, this court must
“end the illegal conduct and . . . make every effort to protect against conduct of the same type or
class.” New York I, 224 F. Supp. 2d at 189.
Plaintiffs’ language is not impermissibly vague, as Google suggests. Google’s Br. at 10.
It is straightforward: Google shall not condition. Google protests that “Plaintiffs have not
explained whether the act of ‘condition[ing]’ purportedly could reach even a trivial statement by
a single Google employee that does not result in an actual agreement,” Google’s Br. at 10, and that
it is at risk of being brought into a contempt proceeding over a potential misunderstanding during
negotiations, Hr’g Tr. at 56:9-16. These concerns are overstated. The court is confident that
“trivial” statements will not result in contempt proceedings and that if there is a non-trivial
allegation of breach, the Final Judgment’s enforcement procedures will provide an adequate path
to resolution. See generally FJ § VII.
Google swears that “there’s not going to be any conditioning of the type” and that it is
“100 percent certain that [the court] would find that to be a violation of the decree, and that [it]
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will not take place.” Hr’g Tr. at 57:1-4. Then it should have no problem with a decree that
expressly prohibits “any conditioning of the type.” The court therefore adopts Plaintiffs’ language
that “Google shall not condition.” See generally FJ § III.
C. Annual Termination
At the liability phase, the court determined that “[t]he lack of flexibility for partners to exit
the distribution agreements reinforces their foreclosure effect.” Google, 747 F. Supp. 3d at 158.
This lack of flexibility came from both the agreements’ durations and the fact that they were not
easily terminable. Id. The court thus approved of provisions giving Browser Developers, OEMs,
and wireless carriers an annual opportunity to reset the search product at different access points
across different devices. Rem. Op. at 110–11.
Google believes that multi-year agreements with a right to opt out annually without
termination fees offer sufficient flexibility. In fact, it argues, a multi-year agreement with annual
opt-outs would increase the contracting options for partners, including opting out of their
agreements after one year, if they wish. Google’s Br. at 14; Hr’g Tr. at 74:19–75:5. Google insists
that partners want these choices and that providing them will foster greater competition. Hr’g Tr.
at 75:6-13.
Plaintiffs see it differently. They urge that an applicable agreement must “terminate[] no
more than one year after the date it is entered.” Pls.’ FPFJ § III.K. Stressing that Google’s prior
agreements were hard to terminate, Plaintiffs argue that Google’s proposal would still permit it to
find creative ways to make termination difficult or to discourage opting out, such as by annually
increasing RSA payments or imposing other burdens. Pls.’ Br. at 7 & n.2.
The court holds that a hard-and-fast termination requirement after one year would best
carry out the purpose of the injunctive relief.
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Recall, the liability phase “record reflects no meaningful competitive rebidding of the
agreements. The more common story is Google’s partners renewing the agreements without
genuine consideration of an alternative.” Google, 747 F. Supp. 3d at 158. Requiring contracting
parties to reevaluate their positions and renegotiate their agreements each year would create regular
opportunities for competitive rebidding. Competitors in the industry would be on regular notice
as to when an agreement between a Browser Developer, OEM, or wireless carrier and Google is
coming to an end and be able to prepare accordingly to enter a competitive bid when that time
comes. See Hr’g Tr. at 73:19–74:8. A bright-line, one-year term also will simplify enforcement.
See Pls.’ Br. at 7; Hr’g Tr. at 73:11-18 (Plaintiffs’ counsel suggesting that adopting Google’s
language would in fact be less efficient than Google represents because it may require “mini
economic trial[s]” on potential multi-year contracts “to see whether or not the incentives
overwhelm what should be the right of termination”); see also id. at 67:24–69:6 (Plaintiffs’ counsel
approving of an omnibus agreement for the required separate agreements for different Operating
System versions and privacy modes across different devices as long as each agreement must be
renegotiated each year). But see Google’s Br. at 14 & n.2 (describing Plaintiffs’ proposal as
increasing administrative burden because the optionality Plaintiffs seek could be achieved in a
single agreement).
The court is skeptical of Google’s contention that its proposal would give partners more
flexibility. In theory, partners have always had a choice. But in practice, Google has held all the
cards. Google, 747 F. Supp. 3d at 158; Hr’g Tr. at 80:1-5. Knowing that contracts will come to
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an end annually gives them a bit of the leverage they previously lacked and, importantly, will
create frequent opportunities for genuine competition.5
Courts have presumed under related antitrust provisions that exclusive contracts ending
within a year are reasonable. Google, 747 F. Supp. 3d at 157. Given the aggregation of factors
contributing to the exclusive agreements’ substantial foreclosure of the market, the hard-and-fast
yearly termination requirement will help to “pry open” that market. See FJ § III.K–M.
D. Browser Developers and Apple
The parties’ proposals with respect to Browser Developers and Apple differed from the
start, and they have only diverged further. Plaintiffs originally proposed that Google could “enter
or maintain any agreement requiring” either a Browser Developer or Apple to set Google Search
(and for Apple, also any Google GenAI Product) as the default search engine or product only if
that agreement applies to just one Operating System Version and one Privacy Mode at a time.
Pls.’ FPFJ § III.L–M. They also clarified that “this provision does not prohibit Google from
negotiating multiple such agreements with” a Browser Developer or Apple “as long as no
agreement is conditioned on another.” Id. Google, on the other hand, proposed that it could enter
such an agreement as long as the Browser Developer or Apple is permitted “on an annual basis to
set a different Default Search Engine in the United States for any Operating System Version and/or
Privacy Mode offered by the Browser Developer [or Apple] without foregoing any payments
attributable to an Operating System Version or Privacy Mode where Google Search remains set as
5 Google takes issue with a yearly termination requirement as “impermissibly regulat[ing] third parties.” Google’s Br.
at 13. But antitrust remedies directed at agreements that unlawfully foreclose markets will necessarily affect relevant
third parties to some degree. That is unavoidable. See, e.g., New York I, 224 F. Supp. 2d at 152–56 (approving
restrictions on Microsoft’s ability to enter certain agreements with third party OEMs); cf. E. I. du Pont, 366 U.S. at
326 (“[C]ourts are authorized, indeed required, to decree relief effective to redress the violations, whatever the adverse
effect of such a decree on private interests.”).
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the Default Search Engine.”6 Google’s FPFJ § III.L; id. § III.M–N. Plaintiffs maintain that
Google’s provision would allow it to require Apple to set Google as the default search engine on
every instance of Safari on every Apple device at every access point as long as it did so one year
at a time. Pls.’ Br. at 8–9; Hr’g Tr. at 72:3-15. But Google is adamant that its provision would
allow a Browser Developer or Apple on an annual basis to “mix and match” across Operating
Systems or Privacy Modes without any impact on their revenue share. Hr’g Tr. at 77:14–78:10.
It insists that the only difference between its provisions and Plaintiffs’ is the issue of yearly
termination and administration. Id. at 78:11–79:8.
At the October 8th hearing, Plaintiffs justified their proposal in part by stating that they
understood the court “to permit some more exclusive dealing on browsers and Apple.” Id. at 70:4–
16. More specifically, they said, “We read Your Honor’s opinion to suggest that you would be
okay with more all-or-nothing type agreements, where Google would buy, for example, all iPhones
in the United States, the standard Safari mode default, where Apple can’t change a single device
to a different default. We find that troubling, but if they were going to do that, we want it to be
limited to the mode and the operating system.” Id. at 69:7-13. In response, the court clarified it
did not intend for there to be daylight between restrictions on Google’s ability to contract with
respect to Android devices and those with respect to Browser Developers and Apple. Id. at 70:25–
71:15. Plaintiffs told the court that this was “welcome news,” id. at 71:16, and that they would
“love to rewrite” those provisions, id. at 87:23–88:22.7
6 Because the court has already found that applicable restrictions should not be relaxed with respect to GenAI products
and that agreements permitted under the prohibitory injunctions must terminate after one year, see supra Sections
IV.A, C, the court discusses these provisions without addressing those differing elements of the parties’ proposals.
The court also does not discuss the one element of these provisions that is undisputed—that Browser Developers and
Apple are expressly permitted to promote any Third-Party General Search Service and Third-Party GenAI Product.
See Pls.’ FPFJ § III.L–M; Google’s FPFJ § III.L–N.
7 As far as the court can tell, Plaintiffs appear to have understood the court to “permit some more exclusive dealing”
with respect to Browser Developers and Apple because it read the court’s description of Google’s original revised
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Following this exchange, Plaintiffs submitted new proposals for its provisions regarding
Browser Developers and Apple. See Pls.’ Suppl. These revised provisions tightened the
restrictions to mirror those imposed on Android partners. They would prevent Google from
conditioning consideration for (1) setting Google Search or any Google GenAI Product as the
Default Search Engine or default GenAI Product on any browser access point (including
alternative modes) or any proprietary Apple feature or functionality (such as Safari, Siri, Spotlight,
and any Privacy Mode) on a device on (2) setting the same product on any other browser access
point or proprietary Apple feature or functionality on that same device or any other device in the
United States. See Pls.’ Suppl. § III.L–M. In other words, Plaintiffs propose that the same access-
point-by-access-point and device-by-device optionality it proposes for Android devices apply also
to browsers and Apple devices.
The Final Judgment will include, over Google’s objection, Plaintiffs’ revised provisions
regarding Browser Developers and Apple. See FJ § III.L–M.
As a threshold matter, the court rejects Google’s contention that it cannot consider
Plaintiffs’ updated provisions because they were presented “after the evidentiary record is closed
and after briefing and argument on the parties’ [proposed final judgments].” See Google’s Suppl.
at 5. Plaintiffs have not relied on new evidence. And Google has had a fulsome opportunity to
respond at both the October 8th hearing and in writing. Furthermore, in crafting the Final
Judgment, the court is not beholden to the exact language the parties have proposed at any stage.
proposed final judgment and its acknowledgment that “[a]ll of this is a good start” as adopting that description for
purposes of the Final Judgment. See Rem. Op. at 105–07 (“Under its proposal . . . Google also would be permitted to
pay Browser Developers, including Apple, to set Search as the default GSE, so long as the Browser Developer (1) can
promote other GSEs and (2) is permitted to set a different GSE on different operating system versions or in a privacy
mode and make[] changes, if desired, on an annual basis. . . . And Apple could preload GSEs on a device-by-device
basis (i.e., Safari for Mac versus Safari for Windows), and install different GSEs for different search modes, like
private browsing.”). As previously explained, see supra Section II, any “approvals” of a proposed remedy did not
signal the court’s embrace of the proposal’s specific text.
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The court makes this determination with the evidentiary record already before it, as well as the
benefit of the parties’ arguments and submissions.
Google’s merits objections to Plaintiffs’ updated proposals are largely a reprise of its
position that the prohibitory injunctions must be limited to the narrowest reading of the court’s
liability findings. For example, Google stresses multiple times that Plaintiffs only established that
the “purported ‘exclusivity’ arose from Apple having agreed for the term of the contract not to
‘pre-select a different default search engine in Safari’s private browsing mode’ or ‘offer a different
default search engine on different Apple devices (e.g., different defaults on mobile versus desktop
devices).’” Id. at 1 (quoting Pls.’ Post-Trial Br., ECF No. 896, at 36); see also id. at 2–3 (referring
to the court’s representation at the October 8th hearing that it had understood Plaintiffs’ reference
to device-level optionality as being relevant to the device type). Maybe so, but the court can
fashion a remedy that goes “beyond a simple proscription against the precise conduct previously
pursued.” NSPE, 435 U.S. at 698; see supra Section IV.A.
Google also argues that device-by-device and access-point-by-access-point optionality is
unnecessary to include in the provision applicable to Apple. Because Apple, too, is an OEM,
Google states, all the other provisions in the prohibitory injunction will also apply to Apple.
Google’s Suppl. at 3. This is only partly true.
The court held at the liability phase that “(1) agreements between Google and browser
developers, such as Apple and Mozilla, were exclusive insofar as they established Google as the
out-of-the box default search engine; (2) mobile application distribution agreements (“MADAs”)
between Google and Android [OEMs] were exclusive in practice; and (3) [RSAs] between Google
and Android device distributors—both OEMs and wireless carriers—formalized the practical
exclusivity of the MADAs.” Rem. Op. at 9–10 (citing Google, 747 F. Supp. 3d at 146–52).
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In doing so, it evaluated separately the Apple Internet Services Agreement (ISA) and Browser
Developer agreements on one hand and the Android agreements on the other, because the way
Google Search was distributed across those agreements differed. For Apple and Browser
Developers, Search is integrated into specific search access points, such as Safari, Siri, and
Spotlight on Apple devices, and the search box, navigation or location bar, and search box
displayed on the Startpage on Mozilla’s Firefox browser. See Google, 747 F. Supp. 3d at 44 ¶ 59;
id. 96 ¶ 334. For Android devices, on the other hand, Search is primarily distributed through
individual applications, such as the Google Search Widget and Chrome, and bundled with others
like YouTube and Google Maps as part of the MADAs. Id. at 97–100 ¶¶ 348–361. Apple does
not contract for Google services through applications the way Android partners do. So, while
Apple is indeed an OEM, those provisions that prevent Google from conditioning payment or
licensing of applications on the distribution of one another do not apply to Apple. This objection
therefore falls flat.
Finally, Google maintains that “[t]he additional provision applicable to agreements setting
Google Search as the Default Search Engine in a Third-Party Browser has always differed in some
respects from the provisions directed to certain devices because a browser default is only one
search access point on a device. There is no logical basis for distinguishing between individual
devices or access points in the context of a browser default, which is why no one even suggested
such a concept until Plaintiffs raised it this month.” Google’s Suppl. at 4 (emphasis omitted).
Google overlooks the fact that Browser Developers can also be OEMs—notably, for instance,
Samsung. Google, 747 F. Supp. 3d at 35–37 ¶¶ 9, 16. Others may emerge in the future. Plaintiffs’
proposal ensures that a device manufacturer that also has a proprietary browser could contract for
browser placement with different competitors. The court acknowledges that at present firms that
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are only Browser Developers (e.g., Mozilla) may not have the ability to select a default search
engine on a device-by-device basis. But because express recognition of such optionality would
deny Google “the ability to take the same or similar actions to limit competition in the future,”
Massachusetts, 373 F.3d at 1233, the court thinks deference to Plaintiffs is warranted here.
See E. I. du Pont, 366 U.S. at 334; supra Section II.
E. Other Provisions
The court addresses two final provisions of the proposed prohibitory injunctive relief, each
proposed by Plaintiffs or Google alone. The court adopts neither.
First, Plaintiffs propose a provision that reads: “Google shall not enter or maintain any
exclusive contract relating to the distribution of Google Search, the Google Search Application,
the Chrome Browser Application, the Google Assistant Application, and any Google GenAI
Product in the United States.” Pls.’ FPFJ § III.N. This is far too broad and vague a term.
Federal Rule of Civil Procedure 65(d) requires that every order granting an injunction
“describe in reasonable detail . . . the act or acts restrained or required.” Fed. R. Civ. P.
65(d)(1)(C). Plaintiffs defend the provision essentially as being designed to catch what is “not
allowed.” Hr’g Tr. at 87:12–88:3; see also Pls.’ Br. at 12 (“Section III.N prevents any inadvertent
gap between the remedies opinion and the final judgment regarding the treatment of exclusive
contracts relating to the distribution of Google Search, Chrome, Google Assistant, and the Gemini
app.”). But that is exactly the kind of ban on unspecified conduct that Rule 65(d) is designed to
prevent. Schmidt v. Lessard, 414 U.S. 473, 476 (1974) (“[Rule 65(d)] requires that those enjoined
receive explicit notice of precisely what conduct is outlawed.”); cf. Gulf Oil Corp. v. Brock,
778 F.2d 834, 843 (D.C. Cir. 1985) (rejecting order that enjoined “substantially similar” conduct
without explaining what would be similar). The provision tracks what Plaintiffs describe as “the
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Court’s directive that . . . the final judgment bar ‘any exclusive contract,’” Pls.’ Br. at 12 (quoting
Rem. Op. at 3), but again, the Final Judgment is what restrains Google, not an opinion. Rule 65(d)
requires specificity, not vague language that might fill undefined “gaps.” See United States v.
Philip Morris USA Inc., 566 F.3d 1095, 1137 (D.C. Cir. 2009) (“[W]e have held injunctions to be
too vague when they enjoin all violations of a statute in the abstract without any further
specification . . . .” (citing SEC v. Wash. Inv. Network, 475 F.3d 392, 407 (D.C. Cir. 2007))).
The court can understand Plaintiffs’ desire to include a provision that “helps prevent a
recurrence of the unlawful conduct by ensuring that Google cannot adopt novel forms of the
exclusive distribution the Court condemned.” Pls.’ Br. at 12 (citing Microsoft II, 253 F.3d at 103).
But the court cannot enjoin “all future violations of the antitrust laws.” Zenith Radio, 395 U.S. at
133. The Final Judgment’s enforcement provisions, including the court’s retention of jurisdiction,
should provide an avenue for addressing any allegation of noncompliance or circumvention.8
Second, Google proposes a provision that reads: “Nothing in this Final Judgment shall
otherwise prohibit Google from providing Consideration to a manufacturer or wireless carrier with
respect to any Google product or service in exchange for such entity’s distribution, placement on
any access point, promotion, or licensing of that Google product or service.” Google’s FPFJ
§ III.O. Apparently, Google drafted this provision in response to Plaintiffs’ previously proposed
payment ban. Pls.’ Br. at 13. The court has rejected for now that proposed remedy. Rem. Op. at
119–28. Because this provision otherwise adds nothing of value to the Final Judgment, the court
declines to adopt it.
8 Plaintiffs’ counsel also stated that “[i]f those provisions [enjoining Google from locking up device or access-point
flexibility] were also changed to where everyone, including Apple and browsers, had device-by-device and access-
point-by-access-point flexibility, I don’t know if I could name a type of exclusive agreement right now that would be
captured by III.N.” Hr’g Tr. at 88:4-12. Because the court adopts Plaintiffs’ modified §§ III.L and III.M, see supra
Section IV.D, Plaintiffs’ concern should be placated.
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V. DATA-SHARING
The chief conflict regarding the data-sharing remedy has to do with Google’s proposal that
the data be shared subject to a license governing use. See Google’s FPFJ § IV.C.4.
Required sharing of certain data is justified to “narrow the scale gap created by Google’s
exclusive distribution agreements and, in turn, the quality gap that followed.” Rem. Op. at 130.
Google has acquired a massive scale advantage in part because its exclusive distribution
agreements have enabled Google to see far more queries than any of its rivals. Google,
747 F. Supp. 3d at 49–50 ¶¶ 86–90. Those queries gave Google data that helped improve the
quality of Search, which in turn attracted more users and improved monetization, reinforcing the
flywheel of network effects that entrenched Google’s monopoly. Id. at 161–62. Because antitrust
remedies must “deny to the defendant the fruits of its statutory violation,” Microsoft III, 253 F.3d
at 103 (citations omitted), and because scale is a significant fruit of Google’s exclusive distribution
agreements, see Rem. Op. at 89, the court held that sharing data—specifically, of Web Search
Index9 Data and User-side Data—“represents a reasonable method of eliminating the
consequences of [Google’s] illegal conduct,” Rem Op. at 130 (quoting NSPE, 435 U.S. at 698).
The data would give competitors the opportunity to boost quality while they continue to innovate
to set themselves apart competitively from Google. See id. at 145–46; see also id. at 130 (citing
In re Google Play Store, 147 F.4th at 947 (affirming an information-sharing remedy that would
“overcome [Google’s] illegally amplified network effects by giving rival stores a fair opportunity
to establish themselves” (cleaned up))).
9 The Final Judgment adopts Google’s “Web Search Index” rather than Plaintiffs’ “Search Index.” See FJ § IX.FF;
Appendix; Google’s App’x at 1. Google’s term and definition more closely aligns with the court’s prior directive that
this definition should exclude data from Google’s various other indexes not crawled from the web. See Rem. Op. at
141.
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Google proposes that any data required to be shared under the Final Judgment be subject
to a license governing use. That license would “include a requirement that the Qualified
Competitor commit not to share or sell the datasets, and shall use the datasets for the exclusive
purpose of serving users located in the United States through a General Search Engine, Search
Text Ads, and/or a Third-Party GenAI Product.” Google’s FPFJ § IV.C.4. The Final Judgment
should forbid Qualified Competitors from selling the data they receive to unknown third parties,
Google argues, because the data-sharing remedy is meant to furnish Qualified Competitors tools
to compete in the relevant markets, not to give them an easy way to “turn a quick profit in a manner
that violates user privacy (including Google’s own terms of service).” Google’s Br. at 20.
In general, the court agrees that data should be shared subject to a license, but with
modifications that incorporate some of Plaintiffs’ objections.
A. Restriction on Sharing or Selling Data
Plaintiffs’ main concern raised at the October 8th hearing about the licensing proposal was
that restricting Qualified Competitors from selling or sharing data from the jump would
“artificially constrain them right now before we even know who they are, what their new product
might be, [or] how they might innovate on that.” Hr’g Tr. at 47:3–48:1.
As to the restriction on selling data, Plaintiffs argue that any Competitor whose intention
is only to sell data rather than earnestly use it to compete would be screened out from the start, as
such a firm would not be certified as a Qualified Competitor. Id. at 47:3-11. When pressed to
offer a scenario in which it would be appropriate for a Qualified Competitor to simply sell the data
to a third party, regardless of whether that third party has an interest in developing a GSE, counsel
for Plaintiffs could only relay that those specific scenarios are as of now unknown. They noted
only that it is possible, for example, that a Qualified Competitor would want to sell a product that
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includes the data, and the Final Judgment should not preemptively preclude them from doing so
without letting that scenario unfold. See id. at 49:5-17.
As to the restriction on sharing data, Plaintiffs worry that such a license would prevent
Qualified Competitors from sharing data with a partner in a joint venture, for example “with an AI
company to improve search results or innovate new search-oriented products.” Pls.’ Br. at 15;
see also Hr’g Tr. at 48:18–49:19. Google does not flatly oppose the possibility of such a joint
venture, but it points out that it “would need to understand whether the joint venture partner is
actually doing something that is related to the purposes of this remedy.” Hr’g Tr. at 53:10-24.
With all this in mind, the court agrees that it is appropriate to subject Qualified Competitors
to a license that prohibits them from sharing or selling the data received under the Final Judgment.
But those Qualified Competitors will be able to petition the Technical Committee (or the court, if
necessary) for relief from that constraint.
The court has serious concerns about allowing Qualified Competitors unbridled use of this
valuable data. Even with appropriate privacy safeguards in place, User-side Data is still likely to
contain highly sensitive information about individual users. See Rem. Op. at 163. And allowing
a Qualified Competitor simply to sell the data to make a profit would be inconsistent with the
purpose of this remedy. But at the same time, the court also agrees that Qualified Competitors
should not be prevented from entering joint ventures or otherwise innovating with this data. After
all, data-sharing is meant to give competitors a hand in setting themselves apart from Google.
See id. at 145–46. Because the real-world effects of the data-sharing remedy have not yet been
borne out, there is value in leaving slightly ajar the door to the possibility that some form of sharing
or selling the data would be reasonable. See also Hr’g Tr. at 52:22–53:3 (Plaintiffs’ counsel stating
that they are more concerned about the hurdles put up for sharing and would be willing to write
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out the sale provision); id. at 53:21-24 (Google’s counsel stating that a Qualified Competitor and
its potential partner getting approval and providing Google with notice and some transparency
would be “something that makes sense”).
B. “Exclusive Purpose”
Next, Plaintiffs take issue with Google’s proposed limitation that Qualified Competitors
use the data “for the exclusive purpose of serving users . . . through a General Search Engine,
Search Text Ads, and/or a Third-Party GenAI Product.” See Google’s FPFJ § IV.C.4. They read
this language as permitting Qualified Competitors to use the data “only for ‘serving’ users results,”
but not to improve algorithms or products. Pls.’ Br. at 15.
The court does not read the proposed text so narrowly. That provision does not require a
Qualified Competitor to only serve users “results.” It does not limit how the data is used, whether
directly to serve query results or to improve algorithms or products, as long as the end purpose of
such use is to develop a product in the relevant markets that is competitive in quality.
Google itself maintains that “these terms are intended to require Qualified Competitors to
use the disclosed data solely to compete in the appropriate markets rather than turn a quick profit.”
Google’s Br. at 20; see also Hr’g Tr. at 42:25–43:20 (Google’s counsel agreeing with the court
that the intention behind this phrase is not how Plaintiffs characterized it). If it becomes evident
during the judgment period that Google does in fact intend to use this language to essentially
neutralize the remedy, the court will reconsider it. But for now, the court finds this limitation
reasonable.
C. Burden on Qualified Competitors
Plaintiffs worry that “Qualified Competitors who currently sell data or search results (for
example to GenAI companies) would also be forced, at significant expense, to make the choice of
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either maintaining a second copy of their data or systems untouched by the data at issue or shut
down that business.” Pls.’ Br. at 15.
The court is unsure of Plaintiff’s concern. Nothing in the Final Judgment would prevent a
Qualified Competitor from selling its own search results and its own search results data, even if
such products used Google’s proprietary data as an input in some way. And companies like the
GenAI companies Plaintiffs refer to that could benefit from the data in a way that is consistent
with the purpose of the remedy can themselves seek to be certified as Qualified Competitors.
Lastly, if there is some compelling reason a Qualified Competitor must sell the data that is
consistent with the purpose of this remedy, it may petition the Technical Committee (or the court)
to do so. See supra Section V.A.
D. Location of Users Served
Google would specify that the consumers served by use of the data be “located in the United
States.” Google’s FPFJ § IV.C.4. Plaintiffs argue that, under Google’s provision, a Qualified
Competitor that currently serves search results worldwide using one system would be forced to
exert considerable effort into building anew or maintaining separate infrastructure to use Google’s
data for the purpose of only serving users “located in the United States.” Pls.’ Br. at 15. At the
hearing, the court asked counsel for Google how this would be feasible as a practical matter. Hr’g
Tr. at 44:3-45:21. Counsel for Google responded that “that may be a [T]echnical [C]ommittee
issue that . . . depending on how these competitors operate . . . [the Technical Committee] can
resolve,” id. at 45:14-17, but that ultimately what that phrase attempts to prevent is data getting
into the hands of competitors who would use the data to develop products, whether search or
unrelated to search, outside of the United States or that do not include the United States because
“[t]hat’s outside the scope of what this case was about,” id. 45:2-8. Though the court understands
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Google’s concern, given the practical difficulties the language may produce, the court believes
that excising the phrase would avoid confusion. The court is willing to revisit this issue if
necessary, with input from the Technical Committee.
* * *
The provision imposing a license for shared data will thus be as follows: “The data
specified in Sections IV.A and B will be shared pursuant to a license governing use. The terms of
the license shall include a requirement that the Qualified Competitor commit not to share or sell
the datasets unless authorized by the Technical Committee or the Court and shall use the datasets
for the exclusive purpose of serving users through a General Search Engine, Search Text Ads,
and/or a Third-Party GenAI Product.” FJ § IV.C.3. To be clear, the license requirement is not
meant to allow Google to impose further burdens on Qualified Competitors. Nor is it meant to be
an “artificial hurdle[]” to Qualified Competitors’ ability to innovate. See Hr’g Tr. at 52:20-21. As
drafted by the court, this provision will simply ensure that execution of this remedy remains
moored to its purpose. To facilitate execution of this remedy, the court has also included in the
Final Judgment a provision requiring that Plaintiffs and the Technical Committee, with input from
Google, create a template for such a license within six months of the effective date of the Final
Judgment. See FJ § IV.C.3.
VI. SEARCH SYNDICATION
Because it will take time for Qualified Competitors to develop high-quality competitive
GSEs even with the data-sharing remedy, the court found that requiring Google to syndicate its
search results would provide a much-needed “bridge” for Qualified Competitors to deliver quality
search results that will foster short-term competition with Google. Rem. Op. at 170–71 (quoting
Rem. Tr. at 3023:16–3024:14 (J. Adkins) (agreeing that “search syndication can provide a bridge
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until a new search engine can become a fully independent search engine”)). But it also determined
that the information syndicated would be narrower than what Plaintiffs proposed and that
syndication would be subject to a license restricting use, as “the purpose of this remedy is to
provide a short-term measure for Qualified Competitors to compete as they improve their own
search capabilities, not an additional means to facilitate that development. Other remedies serve
that latter purpose.” Id. at 178.
Consistent with the Remedies Opinion, the parties’ proposals include some version of a
search syndication license. See Pls.’ FPFJ § V.A–B; Google’s FPFJ § V.A–B. They differ in
substantial ways, however. Mainly, the parties disagree on whether the terms of the search
syndication license should (1) be restricted to those “no less favorable” than those in existing
licenses or to “ordinary commercial” terms; (2) permit Google to restrict display of search results;
(3) permit sub-syndication; and (4) last for a term of five years regardless of whether such term
might extend beyond the six-year judgment period.
A. “No Less Favorable” versus “Ordinary Commercial” Terms
1. License Terms Generally
Originally, Plaintiffs had proposed an exceedingly broad search syndication remedy. They
proposed, among other things, that Google would be required to provide search syndication
services only at marginal cost and could not place any conditions or restrictions on how a Qualified
Competitor could use or display the syndicated content. Rem. Op. at 168–70. The court narrowed
many of these provisions largely because they strayed too far from terms found in licensing
agreements in the existing search syndication market. Id. at 173–74 (quoting Bausch & Lomb,
321 U.S. at 728 (“Congress has been liberal in enacting remedies to enforce the antimonopoly
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statues. But in no instance has it indicated an intention to interfere with ordinary commercial
practices.”)).
In making this determination, the court used phrases like the following: that a “Qualified
Competitor who opts into the syndication remedies shall receive organic results and features on
terms no less favorable than a current licensee”; “when it comes to a remedy like syndication for
which there is an established market and which requires Google to deal with a Qualified
Competitor, it is best to hew closely to ordinary commercial terms”; and “[p]ricing shall be based
on ‘financial terms no worse than those offered to any other users of Google’s search syndication
products.’” Id. at 173–74 (emphases added) (citation omitted). The court’s overarching point was
that the terms of a syndication license should not be unmoored from commercial realities already
in place.
The parties have picked from this section of the Remedies Opinion the phrases that, they
believe, best fit their purposes. Phrases like “no less favorable than,” “no worse than,” and “least
restrictive” appear throughout Plaintiffs’ proposal. See Pls.’ FPFJ § V.A–B. Google’s, on the
other hand, consistently refers to “ordinary commercial” terms. See Google’s FPFJ § V.B.
The parties have sparred over what these terms mean and whether they track the court’s opinion.
See Pls.’ Br. at 18–20; Google’s Br. at 25–29.
For the most part, the court is wary of Google’s blanket reliance on “ordinary commercial”
terms. First, Google’s use of “ordinary commercial” terms is ambiguous. As Plaintiffs point out,
it is unclear what an “ordinary commercial” term with respect to any limitation currently is or how
it may change over time. Pls.’ Br. at 19. To be fair, the court used “ordinary commercial terms”
in the Remedies Opinion, so Google cannot be faulted for grasping onto that language. But it did
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not intend for that phrase to convey an effective veto to Google over the search syndication terms
merely because a term or some combination of terms is not deemed “ordinary.”
But that is precisely how Google would have the court apply it. If a Qualified Competitor
proposes a term that is not “ordinary” or typical to Google’s existing syndication agreements,
Google wants to be able to reject it. Such an ability would inhibit the innovation this remedy
attempts to encourage. For example, potential Qualified Competitor DuckDuckGo operates a GSE
that seeks to set itself apart by focusing on user privacy. Br. of Amicus Curiae Duck Duck Go,
Inc. in Supp. of Pls.’ FPFJ, ECF No. 1446-1 [hereinafter DuckDuckGo Br.], at 4; Google,
747 F. Supp. 3d at 36 ¶ 12. In an amicus brief, DuckDuckGo worries that, under Google’s
proposed provisions, Google would be able to refuse to syndicate search results to privacy-focused
GSEs like DuckDuckGo’s by saying that a provision ensuring a certain degree of user-data
protections is not “ordinary” to Google’s existing syndication agreements. DuckDuckGo Br. at 5.
Qualified Competitors hoping to compete by offering unique services or features may therefore be
forced to either forego the syndication remedy or abandon developing what sets them apart. Id. at
5–6.
Save one exception, the court will adopt Plaintiffs’ language over Google’s use of
“ordinary commercial” terms. Because these provisions are many, the court will discuss two areas
where these differences were particularly contentious: pricing and display restrictions.
2. Pricing
The court held that Google would not be required to provide syndication services at “no
more than . . . marginal cost.” Rem. Op. at 174. Because the availability of marginal-cost
syndication from Google would disincentivize new syndication market entrants and potentially
harm current providers of search syndication services, the court wrote that “[p]ricing shall be based
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on ‘financial terms no worse than those offered to any other user of Google’s search syndication
products.’” Id. at 173–74 (citation omitted).
And yet Google took a different tack. It now proposes that “Google will offer these
syndication services on a non-discriminatory basis to Qualified Competitors at market rates
consistent with ordinary commercial terms agreed to by other users of Google’s search syndication
products.” Google’s FPFJ § V.B.3.
Its main objection to the court’s language, which Plaintiffs have adopted, is that it would
create the same problems the court contemplated would arise from a “marginal cost” provision.
A most-favored-nation pricing term, Google protests, would result in syndication licenses with
pricing terms cherry-picked from, for instance, discounted organic search syndication pricing
offered to partners who also syndicate search text ads, sometimes at prices below marginal cost.
Google’s Br. at 26. Ordinarily, Google says, such discounted pricing is offered because the
discount is offset by the revenue Google expects from the ad syndication. Id. Google argues that
being required to offer the discounted rate to a Qualified Competitor where Google cannot expect
the same revenue to offset it would “‘interfere with’ and ‘reduce, if not eliminate, competition in
the market for syndicated search results’” for the same reasons the court determined marginal-cost
pricing would. Id. (quoting Rem. Op. at 175).
Google’s concern is overstated. The court thinks it is unlikely that a Qualified Competitor
will syndicate search results from Google but not search text ads. After all, it is through search
text ads (and other forms of advertising) that GSEs generate revenue. While it may be possible
that a Qualified Competitor will syndicate search results from Google but search text ads from
elsewhere or not at all, until such arrangements come to fruition, the court is disinclined to alter
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the Final Judgment in a way that permits Google to dictate pricing with Qualified Competitors
based on existing commercial terms reached with Google’s profit motive in mind.
Similarly, that most-favored-nation pricing would “substantially impact[] Google’s
monetization expectation,” Google’s Br. at 26, is of no moment. Google’s “monetization
expectation” is a fruit of its illegal conduct. See Rem. Op. at 95–97. “Those who violate the
[Sherman] Act may not reap the benefits of their violations and avoid an undoing of their unlawful
project on the plea of hardship or inconvenience.” E. I. du Pont, 366 U.S. at 326–27. The Final
Judgment’s pricing provisions may result in syndication agreements that depart from the way
Google has historically contracted or made its revenue. See Google’s Br. at 26–27. But that is an
acceptable consequence of remedying Google’s illegal conduct. Microsoft III, 253 F.3d at 103
(holding that Section 2 remedies must “deny to the defendant the fruits of its statutory violation”
(internal citation and quotation marks omitted)).
3. Restriction on Display of Search Results
Originally, it was Plaintiffs who sought to enable Qualified Competitors to “effectively
replicate how Google delivers its [search engine results pages (“SERPs”)].” Rem. Op. at 172
(“How else to explain Plaintiffs’ insistence that Google must provide information that is ‘the same
as if the Qualified Competitor’s query had been submitted through Google.com’?” (citation
omitted)). Now, Plaintiffs accuse Google of attempting such a result. Hr’g Tr. at 98:15–99:1.
And they are right. Google now proposes that it be “permitted to place its ordinary commercial
restrictions on the use and display of its syndicated results and content.” Google’s FPFJ § V.B.8.
At the October 8th hearing, Google’s counsel explained that its typical syndication-display
restrictions include requiring a “Powered by Google” branding insignia, preventing the licensee
from changing the order of the syndicated search results, or simply preventing the licensee from
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“using the syndicated results in manners other than the way Google . . . presents them.” Hr’g Tr.
at 106:19–107:10. Google believes it should be able to continue to impose these restrictions under
the Final Judgment.
Plaintiffs aver that if Google can limit Qualified Competitors’ display of the syndicated
search results to, for example, the “10 blue links” in the way they are displayed on Google’s own
SERPs, a GenAI company like OpenAI would not be able to “repackag[e] it” as they or their
consumers would see fit. Id. at 98:15–99:1; see also Rem. Tr. at 389:17–390:2 (Turley) (OpenAI
is “not trying to recreate the type of experience that [a consumer] would find on Google.com where
you see ten blue links.”); Hr’g Tr. at 98:18-21 (“[Google’s] provision says they can put ordinary
commercial restrictions on the use and display of syndicated Search results. That is what we worry
about would create a world of Google clones.”). Because of these concerns, Plaintiffs propose that
Google may not impose such restrictions “beyond the least restrictive terms Google provides under
any current search syndication agreements.” Pls.’ FPFJ § V.B.6.
The court agrees with Plaintiffs. Google frames its proposal in part by arguing that
oftentimes a Qualified Competitor wants to be able to adopt Google’s branding “as part of the
reason why they’re syndicating from Google.” Hr’g Tr. at 109:9-18. That may be true for some
current licensees. But for a Qualified Competitor—who, to reiterate, can only be certified if it can
demonstrate a plan to invest and compete in or with the GSE and/or Search Text Ads markets—
becoming a Google clone or marketing itself as one seems an unlikely desire. The syndication
remedy is meant to give Qualified Competitors a boost in quality while they develop competitive
products, not to pose as Google in the meantime. And at least one potential Qualified Competitor
in the GenAI space has explicitly expressed a desire to depart from Google’s familiar ten blue
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links format. At bottom, allowing Google to require licensees to display results to replicate
Google’s SERPs would be at odds with what this remedy is designed to achieve.10
* * *
In sum, both pricing and non-pricing restrictions or limitations in a search syndication
license pursuant to the Final Judgment shall be, for the most part, defined by Plaintiffs’ language,
on “least restrictive,” “no less favorable,” or “no worse” terms. The Final Judgment will retain
the use of “ordinary commercial” terms to protect against Qualified Competitors using the
syndication agreement in a manner than exceeds its intended purpose. See Rem. Op. at 184 (citing
Rem. Tr. at 2988:9–2989:3, 2990:22–2992:10 (J. Adkins) (discussing Google’s ordinary
restrictions on scraping, indexing, and crawling in its current syndication agreements)).
A final word on Google’s objections: Google contends that Plaintiffs’ proposed license
restrictions contradict the court’s previous assurance that “Qualified Competitors generally will
have to follow ordinary commercial terms and therefore will not need to be customized.” Google’s
Br. at 28–29 (quoting Rem. Op. at 180). Google takes this quote out of context. The court made
this assurance in response to Google’s concern that the syndication remedy would put the court in
the role of a “central planner.” Rem. Op. at 180 (citation omitted). Google should take the court
at its word that it has no intention of becoming a “central planner.” Indeed, adopting Plaintiffs’
terms will avoid this. Google appears to believe that, unless it alone gets to say what terms are
ordinary, each license will be a custom-made patchwork of terms causing Google insurmountable
challenges.11 But there is more certainty in the universe of terms that are the “least restrictive” or
10 As to use, Google explains Qualified Competitors should not be permitted to use syndicated data to feed into their
LLMs for training. Hr’g Tr. at 107:11–108:1. The court agrees the Final Judgment should not permit this. See id. at
108:19–109:2. But the court does not believe that is what Plaintiffs seek or that the Final Judgment in fact permits it.
11 In response to the court’s note in the Remedies Opinion that “[i]f there are technical feasibility issues with
syndicating only crawled web results, Google shall so advise the court,” Rem. Op. at 173 n.24, Google now lists a
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that are “no less favorable.” In any event, Google cannot “avoid an undoing of [its] unlawful
project on the plea of hardship or inconvenience.” See E. I. du Pont, 366 U.S. at 326–27.
Lastly, for both the search and search text ads syndication remedies, the court will also
require that Plaintiffs and the Technical Committee, with input from Google, create a template for
such syndication licenses within 60 days of the effective date of the Final Judgment. See FJ
§§ V.B, VI.B.
B. Sub-Syndication
The court agrees with Google that Qualified Competitors should not be able to sub-
syndicate the search results they syndicate from Google under the Final Judgment. See Google’s
FPFJ § V.B.11. Plaintiffs object, arguing that sub-syndication is a standard permission in the
existing syndication market and that, because it is not apparent yet whether a Qualified Competitor
would “need” to sub-syndicate, the Final Judgment should not foreclose them from doing so
upfront. Hr’g Tr. at 93:3-16.
But Google has it right: “Allowing Qualified Competitors to sub-syndicate Google’s
results . . . is entirely divorced from the Court’s reasoning that new general search engine entrants
should receive syndication from Google for the purpose of improving . . . their own SERPs.”
Google’s Br. at 22 (citing Rem. Tr. at 4805:4-6 (Closing Arg.) (Plaintiffs’ counsel stating that it’s
their “view that the syndication remedy should not be available to people who just want to
syndicate”)). Given that search syndication is meant to provide a Qualified Competitor a way to
serve high-quality results while it develops its own products, the court does not see why a Qualified
Competitor would “need” to sub-syndicate to accomplish that purpose. See Rem. Op. at 170–71.
host of “technical feasibility issues.” See Google’s Br. at 29. The court is not at this time convinced that these issues
are so burdensome the features subject to syndication must be limited to those that Google “provides under current
standard search syndication agreements.” See id. As explained above, Google overstates how “bespoke” the
syndication agreements with Qualified Competitors will be. See id.
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And that some syndication agreements today, including Google’s, permit some level of sub-
syndication does not warrant expanding the purpose of the syndication remedy. See Pls.’ Br. at
20; Hr’g Tr. at 93:19–94:8; see also id. at 105:6–106:6 (Google’s counsel stating that sub-
syndication is not a widespread practice and usually limited to the licensee’s affiliate, and that in
those agreements where Google does permit sub-syndication, it retains an absolute right to
reject it).
C. Duration
A syndication license pursuant to the Final Judgment will be for a term of five years,
regardless of when Google’s syndication service is made available to the Qualified Competitor,
for both search and search text ads syndication.
Despite the court’s holding to that effect, see Rem. Op. at 175–76, Google has added that
a syndication license will be for a term of five years, unless there are fewer than five years
remaining before the end of the judgment period. Googe’s FPFJ § V.A. In that case, Google
proposes, the license will be for a term lasting the remainder of the judgment period. Id. In
practice, what that means is that only a Qualified Competitor that comes onto the scene during the
first year of the Final Judgment will enjoy a full five-year syndication term.
The court does not dwell on this long. It held that the syndication license would be for five
years based on testimony from potential Qualified Competitors that five years would be enough
time in which to become independent of Google. Rem. Op. at 175–76 (citing Rem. Tr. at 426:16-
25 (Turley)); id. at 176 n.25 (citing to article detailing that Brave began delivering search results
exclusively from its own search index within about two years). And as DuckDuckGo points out,
allowing these syndication licenses to terminate at the end of the judgment period could permit
Google to simply run out the clock on license negotiations, especially as the judgment period draws
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to a close. DuckDuckGo Br. at 6–7. The syndication remedy as Google would have it would not
fulfill its purpose for a Qualified Competitor that becomes certified in year five of the six-year
judgment period; the Qualified Competitor would simply not have enough time with the syndicated
data to develop a competitive GSE in the meantime. See Rem. Op. at 175–76; Hr’g Tr. at 110:10–
111:8. What’s more, were the court to adopt Google’s proposal, the incentive for Qualified
Competitors to come forward would diminish over the period remaining on the Final Judgment.
Such an outcome would benefit only Google, not competition.
VII. SEARCH TEXT ADS SYNDICATION
“Because Google has more users, it has more advertisers, and with more advertisers, it has
more dollars to improve its GSE and pay for distribution.” Rem. Op. at 183. And because
Qualified Competitors would be attempting to compete “[i]n the face of such formidable
headwinds,” the court held that Qualified Competitors should also be able to syndicate search text
ads from Google as a “short-term measure designed to ‘pry open’ the relevant markets.” Id.
For the same reasons search syndication licenses will be restricted on “no less favorable
terms” and other similar language used by Plaintiffs rather than Google’s “ordinary commercial”
terms, the same will be true, for the most part, for search text ads syndication. See generally FJ
§ VI. The restriction on scraping, indexing, and crawling will remain on ordinary commercial
terms. Id. § VI.B.6. The provision regarding the duration of such licenses will also be the same.12
Id. § VI.B.
12 The restriction on display will be slightly different. See FJ § VI.B.6. The court previously held that “Google may
place ordinary-course restrictions on the use or display of syndicated content.” Rem. Op. at 184. Unlike in search
syndication, Google presented evidence of the specific ways search text ads syndication without ordinary-course
restrictions on display or use could harm advertisers and ad quality. See id. (citing Rem. Tr. at 2972:4–2976:3, 2979:5–
2984:10 (J. Adkins)). That said, the court does not adopt Plaintiffs’ narrow enumeration of permissible justifications
for imposing such restrictions. See Pls.’ FPFJ § VI.B.6.
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The search text ads syndication remedy differs in one important way from the search
syndication remedy. The court previously contemplated the possibility of new entrants into the ad
platform market. See Rem. Op. at 183 (“It is also possible that an independent ad platform could
emerge to compete with Google and Microsoft, which are the only current suppliers of general
search text ads in the United States.”). Becoming an independent ad platform in the search text
ads market takes a near-insurmountable effort in part due to Google’s monopoly. See Rem. Tr. at
1794:12–1797:3 (Epstein) (describing “cold start” problems). To be competitive, a potential new
entrant would need to be able to offer publishers syndication of high-quality ads. See id. at
1798:16–1799:16 (Epstein); see also Pls.’ Br. at 20. So, while sub-syndication of search results
would be inappropriate for Qualified Competitors looking to compete in search for the reasons
explained above, see supra Section VI.B, sub-syndication of search text ads would be a useful
bridge for a Qualified Competitor looking to compete with Google’s ad platform. Sub-syndication
will thus be permitted for search text ads only if “such Qualified Competitor has been certified as
a Competitor to a Google ads platform (e.g., Google Ads).” FJ § VI.B.9.
VIII. ENFORCEMENT
From the beginning, the provisions related to the Technical Committee have been
contentious. The court will not rehash the parties’ arguments or go over their final proposals with
a fine-tooth comb here. Rather, the court will explain at a high level its approach to the relevant
provisions.
The court has been clear that a Technical Committee is an appropriate instrument to assist
Plaintiffs in their enforcement efforts, as it “comports with federal courts’ long history of utilizing
appointed experts and provides a process to review and resolve inevitable disputes between the
parties—ideally without further need for judicial intervention.” Rem. Op. at 211 (quoting In re
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Google Play Store, 147 F.4th at 954). A Technical Committee that is the “enforcement arm of the
government,” Microsoft IV, 231 F. Supp. 2d at 197, embodies the principle that with the
government’s broad authority to enforce the antitrust laws comes discretion with how violations
should be redressed, see F. Hoffman-La Roche Ltd. v. Empagran S.A., 542 U.S. 155, 170–71
(2004) (“A Government plaintiff . . . must seek to obtain the relief necessary to protect the public
from further anticompetitive conduct and to redress anticompetitive harm. And a Government
plaintiff has legal authority broad enough to allow it to carry out this mission. . . . ‘[I]t is well
settled that once the Government has successfully borne the considerable burden of establishing a
violation of law, all doubts as to the remedy are to be resolved in its favor.’” (quoting E. I. DuPont,
366 U.S. at 334)); see also Ford Motor Co. v. United States, 405 U.S. 562, 575 (1972).
Throughout the remedies phase, Plaintiffs have vigorously insisted that the court’s rulings
and the case law make clear that “ultimately the power to enforce the terms of the decree rests with
the government.” Pls.’ Br. at 21 (quoting Massachusetts, 373 F.3d at 1243). In their most recent
brief, they took issue with Google’s attempts at squeezing Plaintiffs out of various enforcement
activities and roping the court into resolving disputes instead. Id. at 20–21. They also accused
Google of attempting to “empower Google to delay or stymie enforcement at every turn simply by
objecting.” Id. at 21. Plaintiffs’ FPFJ reflects these objections. See generally Pls.’ FPFJ § VII.
Yet at the hearing, Plaintiffs appeared to surrender their position. From the jump, they
conceded that Google should have full opportunity to object to any detail of the Final Judgment’s
execution. See Hr’g Tr. at 18:24–19:10. And despite the clear textual differences in the parties’
FPFJs and briefs, Plaintiffs’ counsel effectively agreed that “there is substantively no difference
between the language that [Plaintiffs have] proposed, at least with respect to Google’s ability to
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object and bring things to the Court’s attention, and what [Google has] proposed.” Id. at 20:11–
21:2.
Plaintiffs’ counsel tried to assure the court that it is “free to delegate any of those elements
[of enforcement] entirely to the [T]echnical [C]ommittee, entirely to [P]laintiffs.” Id. at 34:7-14.
But the court is frankly at a loss for how it can square this with their simultaneous position that
“there is no such decision that ends with [Plaintiffs] and the [T]echnical [C]ommittee” and that
“Google can object to everything and almost anything that would then require [the court’s]
resolution.” Id. at 19:20–20:5.
The court is wary of being called in as a referee to the minutiae of the Final Judgment’s
execution and enforcement. Nevertheless, because the parties agree that Google should have a
broad right to object, the court will grant it. See FJ § VII.A.7.k. This should put to rest Google’s
blanket objections to Plaintiffs’ alleged attempts at taking decision-making authority from the
court. Google’s Br. at 30–32. The parties offer the assurance that they will elevate for judicial
consideration only the most important conflicts. See Hr’g Tr. at 19:24–20:5; 26:7-12. The court
is skeptical. Still, it adopts Google’s express right to object with cautious optimism that the parties
will keep their word.
Although Google will have an express right to object, the court affords some deference to
Plaintiffs’ provisions in this section of the Final Judgment. See generally FJ § VII; see also
Appendix. Google appears to protest any function carried out by the Technical Committee that
goes beyond mere “technical competence,” characterizing the broad oversight and investigative
functions Plaintiffs propose as “an end-run around the Court’s rejection of the Plaintiffs’
anticircumvention and anti-retaliation proposals.” See Google’s Br. at 32–33. Yet, the Technical
Committee established in New York I and affirmed by Massachusetts had much of these same
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broad functions. See Second Modified Final J., United States v. Microsoft Corp., No. 98-cv-1232,
ECF No. 889 (D.D.C. Mar. 22, 2009). None of these responsibilities are a “substitute for the
enforcement authority of [Plaintiffs]” or the court. Rem. Op. at 212 (citing Massachusetts,
373 F.3d at 1244).
Finally, to keep the court updated on the progress of executing the Final Judgment,
Plaintiffs, with input from the Technical Committee, shall submit a status report within 90 days of
the effective date of the Final Judgment and then on future dates as set by the Court. FJ § VII.E.1.
IX. RETENTION OF JURISDICTION
Last but not least, the court addresses its retention of jurisdiction. The Supreme Court was
explicit in United States v. United Shoe Machinery Corp. that, where the government is entitled to
relief in a Section 2 case, the “court’s power” to order additional relief to remedy an earlier antitrust
violation “is clear,” even after the judgment period has passed. 391 U.S. 244, 251 (1968);
accord 2A AREEDA & HOVENKAMP ¶ 325a (“[A] court’s involvement is not necessarily ended
once its decree is issued.”); id. ¶ 325c2 (“Antitrust decrees may reserve the court’s jurisdiction to
order additional or modified relief.” (citing United States v. United Shoe Mach. Corp., 110 F. Supp.
295 (D. Mass. 1953), aff’d per curiam, 347 U.S. 521 (1954))). Both parties’ proposals would
preserve this court’s jurisdiction accordingly.
Plaintiffs’ proposal that it be permitted to file suit against Google for a period of four years
after the expiration of the Final Judgment for any violations of the Final Judgment committed
during the judgment period is not, as Google argues, the impermissible creation of a cause of
action. See Google’s Br. at 38–39. It is simply a part of the court’s retention of its jurisdiction to
enable Plaintiffs to enforce the Final Judgment.
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That said, the court will not determine now, as Plaintiffs propose, what Plaintiffs must
show to alter the judgment and to what standard Google will be held in response. Compare FJ
§ XI.A, with Pls.’ FPFJ § XI.A. The court will address those specifics if and when the time comes.
X. CONCLUSION
It bears repeating that “Google is a monopolist, and it has acted as one to maintain its
monopoly.” Google, 747 F. Supp. 3d at 32. In crafting the Final Judgment, the task of this court
was to “unfetter a market from anticompetitive conduct, . . . deny to the defendant the fruits of its
statutory violation, and ensure that there remain no practices likely to result in monopolization in
the future,” Microsoft III, 253 F.3d at 103 (internal quotation marks and citations omitted), even if
the remedies ordered would “entail harsh consequences,” FTC v. Whole Foods Mkt., Inc., 548 F.3d
1028, 1033 (D.C. Cir. 2008) (quoting E. I. du Pont, 366 U.S. at 327). The terms of the Final
Judgment have been designed to do just that consistent with established Section 2 legal principles.
The Final Judgment accompanies this Memorandum Opinion.
Dated: December 5, 2025 Amit P. Mehta
United States District Judge
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APPENDIX
I. JURISDICTION
Plaintiffs’ Proposal Google’s Proposal Final Judgment
The Court has jurisdiction over the
subject matter of this action and over
Google.
This Court has jurisdiction over the
subject matter of this action and over
Google LLC.
This Court has jurisdiction over the
subject matter of this action and over
Google LLC.
II. APPLICABILITY
Plaintiffs’ Proposal Google’s Proposal Final Judgment
This Final Judgment applies to Google
and to each of its officers, directors,
agents, employees, subsidiaries,
successors and assigns; and to all other
persons in active concert or
participation with Google who have
received actual notice of this Final
Judgment by personal service or
otherwise.
This Final Judgment applies to Google
and to each of its officers, directors,
agents, employees, subsidiaries,
successors, and assigns.
This Final Judgment applies to Google
and to each of its officers, directors,
agents, employees, subsidiaries,
successors, and assigns; and to all
other persons in active concert or
participation with Google who have
received actual notice of this Final
Judgment by personal service or
otherwise.
III. PROHIBITORY INJUNCTIONS
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
license of the Google Search
Application on any device sold in the
United States.
A. Google shall not enter or
maintain any agreement with a
manufacturer that conditions the
licensing of Google Play or any other
Google software application on that
manufacturer also distributing,
preloading, placing, displaying, using,
or licensing the Google Search
Application on Covered Devices sold
in the United States.
A. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
license of the Google Search
Application on any device sold in the
United States.
B. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
license of the Chrome Browser
Application on any device sold in the
United States.
B. Google shall not enter or
maintain any agreement with a
manufacturer that conditions the
licensing of Google Play or any other
Google software application on that
manufacturer also distributing,
preloading, placing, displaying, using,
or licensing the Chrome Browser
Application on Covered Devices sold
in the United States.
B. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use or
license of the Chrome Browser
Application on any device sold in the
United States.
C. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
C. Google shall not enter or
maintain any agreement with a
manufacturer that conditions the
licensing of the Google Search
C. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
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license of the Google Assistant
Application on any device sold in the
United States.
Application, the Chrome Browser
Application, or Google Play, on the
manufacturer also distributing,
preloading, placing, displaying, using,
or licensing the Google Assistant
Application on Covered Devices sold
in the United States.
license of the Google Assistant
Application on any device sold in the
United States.
D. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
license of any Google GenAI Product
on any device sold in the United
States.
D. Google shall not enter or
maintain any agreement with a
manufacturer that conditions the
licensing of the Google Search
Application, the Chrome Browser
Application, or Google Play, on the
manufacturer also distributing,
preloading, placing, displaying, using,
or licensing Google GenAI Assistant
Application on Covered Devices sold
in the United States.
D. Google shall not condition the
licensing of Google Play or any other
Google application on the distribution,
preload, placement, display, use, or
license of any Google GenAI Product
on any device sold in the United
States.
E. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
licensing any Third-Party General
Search Service on any device sold in
the United States.
E. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions (i) Consideration or (ii) the
license of Google Play or any Google
software application, on that
manufacturer or wireless carrier
refraining from developing,
distributing, preloading, placing,
displaying, using, selling, or licensing
any Third-Party General Search
Service on Covered Devices sold in
the United States.
E. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
licensing any Third-Party General
Search Service on any device sold in
the United States.
F. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
licensing any Third-Party Browser on
any device sold in the United States.
F. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions (i) Consideration or (ii) the
license of Google Play or any Google
software application, on that
manufacturer or wireless carrier
refraining from developing,
distributing, preloading, placing,
displaying, using, selling, or licensing
any Third-Party Browser on Covered
Devices sold in the United States.
F. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
licensing any Third-Party Browser on
any device sold in the United States.
G. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
G. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions (i) Consideration or (ii) the
license of Google Play or any Google
software application, on that
manufacturer or wireless carrier
G. Google shall not condition
(i) Consideration or (ii) the license of
Google Play or any Google software
application on a device manufacturer
or wireless carrier refraining from
developing, distributing, preloading,
placing, displaying, using, selling, or
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licensing any Third-Party GenAI
Product on any device sold in the
United States.
refraining from developing,
distributing, preloading, placing,
displaying, using, selling, or licensing
any Third-Party GenAI Assistive
Service on Covered Devices sold in
the United States.
licensing any Third-Party GenAI
Product on any device sold in the
United States.
H. Google shall not condition the
payment for preload of, placement of,
or assignment of an access point for
the Google Search Application for one
device on any other preload,
placement, or assignment of an access
point for the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, or any Google GenAI
Product for that device or any other
device sold in the United States.
H. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions the payment for preload,
placement, or assignment of an access
point for the Google Search
Application on the preload, placement,
or assignment of any other access
point to any of Google Search, the
Google Search Application, the
Chrome Browser Application, the
Google Assistant Application, and/or a
Google GenAI Assistant Application
on Covered Devices sold in the United
States. For the avoidance of doubt,
Google shall only contract with such
partners with respect to such access
points on a device by device basis.
H. Google shall not condition the
payment for preload, placement, or
assignment of an access point for the
Google Search Application for one
device on any other preload,
placement, or assignment of an access
point for the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, or any Google GenAI
Product for that device or any other
device sold in the United States.
I. Google shall not condition the
payment for preload of, placement of,
or assignment of an access point for
the Chrome Browser Application for
one device on any other preload of,
placement of, or assignment of an
access point for the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, or any Google GenAI
Product for that device or any other
device sold in the United States.
I. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions the payment for preload,
placement, or assignment of an access
point for the Chrome Browser
Application on the preload, placement,
or assignment of any other access
point to any of the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, and/or a Google GenAI
Assistant Application on Covered
Devices sold in the United States. For
the avoidance of doubt, Google shall
only contract with such partners with
respect to such access points on a
device by device basis.
I. Google shall not condition the
payment for preload, placement, or
assignment of an access point for the
Chrome Browser Application for one
device on any other preload,
placement, or assignment of an access
point for the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, or any Google GenAI
Product for that device or any other
device sold in the United States.
J. Google shall not condition the
payment for preload of, placement of,
or assignment of an access point for
the Google Assistant Application or
any Google GenAI Product for one
device on any other preload,
placement, or assignment of an access
point for the Google Search
Application, the Chrome Browser
J. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier that
conditions the payment for preload,
placement, or assignment of an access
point for the Google Assistant
Application or a Google GenAI
Assistant Application on the preload,
placement, or assignment of any other
J. Google shall not condition the
payment for preload, placement, or
assignment of an access point for the
Google Assistant Application or any
Google GenAI Product for one device
on any other preload, placement, or
assignment of an access point for the
Google Search Application, the
Chrome Browser Application, the
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Application, the Google Assistant
Application, or any Google GenAI
Product for that device or any other
device sold in the United States.
access point to any of the Google
Search Application and/or the Chrome
Browser Application on Covered
Devices sold in the United States. For
the avoidance of doubt, Google shall
only contract with such partners with
respect to such access points on a
device by device basis.
Google Assistant Application, or any
Google GenAI Product for that device
or any other device sold in the United
States.
K. Google shall not enter or
maintain any agreement requiring or
conditioning Consideration on the
distribution of, preload of, placement
of, display of, use of, license of, or
assignment of an access point for the
Google Search Application, the
Chrome Browser Application, the
Google Assistant Application, or any
Google GenAI Product in the United
States unless the agreement terminates
no more than one year after the date it
is entered.
K. Google shall not enter or
maintain any agreement with a
manufacturer or wireless carrier
requiring the preload, placement, or
assignment of an access point on
Covered Devices in the United States
to any of the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, and/or a Google GenAI
Assistant Application for a period of
more than one year, unless the
agreement allows the manufacturer or
wireless carrier to terminate the
agreement on an annual basis and does
not charge a fee for terminating.
K. Google shall not enter or
maintain any agreement requiring or
conditioning Consideration on the
distribution, preload, placement,
display, use, license, or assignment of
an access point for the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, or any Google GenAI
Product in the United States unless the
agreement terminates no more than
one year after the date it is entered.
L. Google shall not condition
(1) Consideration for a Browser
Developer setting Google Search or
any Google GenAI Product as the
Default Search Engine or default
GenAI Product on any browser access
point (including alternative modes
such as Privacy Mode) on any Device
on (2) the Browser Developer setting
Google Search or any Google GenAI
Product as the Default Search Engine
or default GenAI Product on any other
browser access point on that same
Device or any other Device in the
United States. Any agreement
containing a default condition
permitted by this provision must
expire after one year and must
expressly permit the Browser
Developer to promote any Third-Party
General Search Service and Third-
Party GenAI Product.1
L. Google shall not enter or
maintain any agreement requiring a
Browser Developer to set Google
Search as the Browser Default Search
Engine in a Third-Party Browser in the
United States unless the agreement
(i) permits the Browser Developer on
an annual basis to set a different
Default Search Engine in the United
States for any Operating System
Version and/or Privacy Mode offered
by the Browser Developer without
foregoing any payments attributable to
an Operating System Version or
Privacy Mode where Google Search
remains set as the Default Search
Engine; and (ii) expressly permits the
Browser Developer to promote any
Third-Party General Search Service or
Third-Party GenAI Product in the
United States.
L. Google shall not condition
(1) Consideration for a Browser
Developer setting Google Search or
any Google GenAI Product as the
Default Search Engine or default
GenAI Product on any browser access
point (including alternative modes
such as Privacy Mode) on any Device
on (2) the Browser Developer setting
Google Search or any Google GenAI
Product as the Default Search Engine
or default GenAI Product on any other
browser access point on that same
Device or any other Device in the
United States. Any agreement
containing a default condition
permitted by this provision must
expire after one year and must
expressly permit the Browser
Developer to promote any Third-Party
General Search Service and Third-
Party GenAI Product.
1 Originally: “Google shall not enter or maintain any agreement requiring a Browser Developer to set Google Search as the Browser
Default Search Engine in a Third-Party Browser in the United States unless the agreement (i) applies to no more than one Operating
System Version and no more than one Privacy Mode, (ii) terminates no more than one year after the date it is entered, and (iii) expressly
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M. Google shall not condition
(1) Consideration for Apple setting
Google Search or any Google GenAI
Product as the Default Search Engine
or default GenAI Product with respect
to any proprietary Apple feature or
functionality, including Safari, Siri,
Spotlight, and any Privacy Mode
within those products, on one Device
on (2) Apple setting Google Search or
any Google GenAI Product as the
Default Search Engine or default
GenAI Product with respect to any
proprietary Apple feature or
functionality on that same Device or
any other Device in the United States.
Any agreement containing a default
condition permitted by this provision
must expire after one year and must
expressly permit Apple to promote any
Third-Party General Search Service
and Third-Party GenAI Product.2
M. Google shall not enter or
maintain any agreement requiring
Apple, Inc. (“Apple”) to set Google
Search as the Default Search Engine in
the United States with respect to any
proprietary Apple feature or
functionality, including Siri and
Spotlight, unless the agreement
complies with Section III.L above.
M. Google shall not condition
(1) Consideration for Apple setting
Google Search or any Google GenAI
Product as the Default Search Engine
or default GenAI Product with respect
to any proprietary Apple feature or
functionality, including Safari, Siri,
Spotlight, and any Privacy Mode
within those products, on one Device
on (2) Apple setting Google Search or
any Google GenAI Product as the
Default Search Engine or default
GenAI Product with respect to any
proprietary Apple feature or
functionality on that same Device or
any other Device in the United States.
Any agreement containing a default
condition permitted by this provision
must expire after one year and must
expressly permit Apple to promote any
Third-Party General Search Service
and Third-Party GenAI Product.
N. Google shall not enter or
maintain any agreement requiring
Apple to distribute any Google GenAI
Assistant Application in any Apple
web browser or on any Apple mobile
or desktop device in the United States
unless the agreement expressly
permits Apple to promote any Third-
Party General Search Service or Third-
Party GenAI Product in the United
States.
N. Google shall not enter or
maintain any exclusive contract
relating to the distribution of Google
Search, the Google Search
Application, the Chrome Browser
Application, the Google Assistant
Application, and any Google GenAI
Product in the United States.
[No similar provision.] [No similar provision.]
[No similar provision.] O. Nothing in this Final
Judgment shall otherwise prohibit
Google from providing Consideration
to a manufacturer or wireless carrier
with respect to any Google product or
service in exchange for such entity’s
distribution, placement on any access
point, promotion, or licensing of that
Google product or service.
[No similar provision.]
O. Nothing in this Final
Judgment shall prohibit Google from
P. Nothing in this Final
Judgment shall prohibit Google from
N. Nothing in this Final
Judgment shall prohibit Google from
permits the Browser Developer to promote any Third-Party General Search Service and Third-Party GenAI Product. For clarity, this
provision does not prohibit Google from negotiating multiple such agreements with a Browser Developer as long as no agreement is
conditioned on another.”
2 Originally: “Google shall not enter or maintain any agreement requiring Apple to set Google Search or any Google GenAI Product as
the Default Search Engine or default GenAI Product in the United States with respect to any proprietary Apple feature or functionality,
including Safari, Siri, and Spotlight, unless the agreement (i) applies to no more than one Operating System Version and no more than
one Privacy Mode, (ii) terminates no more than one year after the date it is entered, and (iii) expressly permits Apple to promote any
Third-Party General Search Service and Third-Party GenAI Product. For clarity, this provision does not prohibit Google from
negotiating multiple such agreements with Apple as long as no agreement is conditioned on another.”
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57
distributing the Google Search
Application, the Google Assistant
Application, and any Google GenAI
Product through a single Application
Programming Kit (APK) as long as the
licensee has the option to disable end-
user access to any of those applications
and services that the licensee declines
to license.
distributing the Google Search
Application, the Google Assistant
Application, and a Google GenAI
Assistant Application through a single
Application Programming Kit (APK)
as long as the licensee has the option to
disable end-user access to any of those
applications and services that the
licensee declines to license.
distributing the Google Search
Application, the Google Assistant
Application, and any Google GenAI
Product through a single Application
Programming Kit (APK) as long as the
licensee has the option to disable end-
user access to any of those applications
and services that the licensee declines
to license.
IV. REQUIRED DISCLOSURES OF DATA
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Google’s Search Index:
Within thirty (30) days of a Qualified
Competitor’s certification pursuant to
Section IX.W, Google shall make
available to such Qualified
Competitor, at marginal cost, to
Qualified Competitors the following
data related to Google’s Search Index:
1. for each document in the
Google Search Index, a unique
identifier (DocID) and another
notation sufficient to denote all the
documents Google considers
duplicates of each other;
2. a DocID to URL map; and
3. for each DocID, the (A) time
that the URL was first seen, (B) time
that the URL was last crawled, (C)
spam score, and (D) device-type
flag.
This information shall be provided for
all websites in the full Search Index
Google uses for searches on
Google.com, the Google Search
Application, or any other current or
future Google general search products.
Nothing in Section IV is intended to
transfer intellectual property rights of
third parties to index users.
A. Google’s Web Search Index:
For the term of this Final Judgment,
Google will make available, at
Marginal Cost, to Qualified
Competitors the following data related
to Google’s Web Search Index on a
non-discriminatory basis while
safeguarding personal privacy and
security:
1. for each document in the
Google Web Search Index a unique
identifier (DocID) and another
notation sufficient to denote all the
documents Google considers
duplicates of each other;
2. a DocID to URL map; and
3. for each DocID the following
set of associated data: (A) time that
the URL was first seen, (B) time that
the URL was last crawled, (C) spam
score, and (D) device-type flag.
4. This information must be
provided for all websites in the Web
Search Index Google uses for
searches on Google.com, the Google
Search App, or future Google
general search products.
5. Google must make this
information available to Qualified
Competitors on a one-time basis at or
around the time they are so certified
as a Qualified Competitor.
6. Nothing in this Section IV is
intended to transfer intellectual
property rights of third parties to
index users.
A. Google’s Web Search Index:
Within thirty (30) days of a Qualified
Competitor’s certification pursuant to
Section IX.V, unless granted additional
time, Google shall make available, at
marginal cost, to Qualified
Competitors the following data related
to Google’s Web Search Index:
1. for each document in the
Google Web Search Index, a unique
identifier (DocID) and another
notation sufficient to denote all the
documents Google considers
duplicates of each other;
2. a DocID to URL map; and
3. for each DocID, the (A) time
that the URL was first seen, (B) time
that the URL was last crawled, (C)
spam score, and (D) device-type
flag.
The information shall be provided for
all websites in the full Web Search
Index Google uses for searches on
Google.com, the Google Search
Application, or any future Google
general search products. Nothing in
Section IV is intended to transfer
intellectual property rights of third
parties to index users.
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58
B. User-Side Data: For the term
of this Final Judgment, Google shall
make available, at marginal cost, to
Qualified Competitors the following
User-side Data on a non-
discriminatory basis while
safeguarding personal privacy and
security:
1. User-side Data used to build,
create, or operate the GLUE
statistical model(s); and
2. User-side Data used to train,
build, or operate the RankEmbed
model(s).
Google shall make this data available
to Qualified Competitors at least
twice, with the exact number and
frequency of such disclosures to be
determined by the Court after
consultation with Plaintiffs and the
Technical Committee (TC). Any cap
on the number of such disclosures
shall be informed, in part, by the utility
of the datasets disclosed after
appropriate privacy-enhancing
techniques have been applied. For
clarity, this Section IV.B shall not
require disclosure of intellectual
property or trade secrets, such as
algorithms, ranking signals, or post-
trained LLMs.
B. User-Side Data: For the term
of this Final Judgment, Google will
make available, at Marginal Cost, to
Qualified Competitors the following
User-side Data on a non-
discriminatory basis while
safeguarding personal privacy and
security:
1. User-side Data used to build,
create, or operate the GLUE
statistical model(s); and
2. User-side Data used to train,
build, or operate the RankEmbed
model(s).
3. For the avoidance of doubt,
“User-side Data” for purposes of
Section IV includes only the
underlying data, not the model itself
or any ranking signal or score, spam
score, information retrieval score,
information satisfaction score, query
interpretation information, query
suggestion information, query-based
salient term, or document salient
term.
4. The number of times a
Qualified Competitor may receive a
dataset will be capped by the Court
after consultation with the Technical
Committee. The cap on the number
of such disclosures will be informed,
in part, by the utility of the datasets
disclosed after appropriate privacy-
enhancing techniques have been
applied.
B. User-Side Data: For the term
of this Final Judgment, Google shall
make available, at marginal cost, to
Qualified Competitors the following
User-side Data on a non-
discriminatory basis while
safeguarding personal privacy and
security:
1. User-side Data used to build,
create, or operate the GLUE
statistical model(s); and
2. User-side Data used to train,
build, or operate the RankEmbed
model(s).
Google shall make this data available
to Qualified Competitors at least
twice, with the exact number and
frequency of such disclosures to be
determined by the Court after
consultation with Plaintiffs and the
Technical Committee (TC). Any cap
on the number of such disclosures
shall be informed, in part, by the utility
of the datasets disclosed after
appropriate privacy-enhancing
techniques have been applied. For
clarity, this Section IV.B shall not
require disclosure of intellectual
property or trade secrets, such as
algorithms, ranking signals, or post-
trained LLMs.
C. User-Side Data Sharing
Administration:
C. User-Side Data Sharing
Administration: These remedies are
intended to make this data available in
a way that provides suitable security
and privacy safeguards for the data the
Google must share.
C. User-Side Data Sharing
Administration:
1. Plaintiffs, in consultation with
the TC, shall promptly determine the
appropriate User-side Data privacy
and security safeguards to be applied
before Google shares the data
specified in Section IV.B with
Qualified Competitors. Google shall
have up to six (6) months from the
date that the Plaintiffs, in
1. Before this data specified in
Paragraph IV.B is shared with
Qualified Competitors, Google shall
apply adequate anonymization and
privacy-enhancing techniques to
ensure the data is anonymized and
secured, while attempting to
optimize its usefulness.
1. Plaintiffs, in consultation with
the TC, shall promptly determine the
appropriate User-side Data privacy
and security safeguards to be applied
before Google shares the data
specified in Section IV.B with
Qualified Competitors. Google shall
have up to six (6) months from the
date that the Plaintiffs, in
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59
consultation with the TC, determine
such privacy and security safeguards
to implement the technology and
provide any notice necessary to
comply with this Section IV, and
Google shall be deemed to have
implemented the technology once
Plaintiffs, in consultation with the
TC, determine that the technology,
including privacy and security
safeguards, is fully functional.
3. Google will have up to six (6)
months from the date that security
and privacy safeguards are finally
determined to implement the
technology and provide any notice
necessary to comply with this
Section IV.C.2.
consultation with the TC, determine
such privacy and security safeguards
to implement the technology and
provide any notice necessary to
comply with this Section IV, and
Google shall be deemed to have
implemented the technology once
Plaintiffs, in consultation with the
TC, determine that the technology,
including privacy and security
safeguards, is fully functional.
2. Google shall provide
sufficient information about each
dataset such that Qualified
Competitors can reasonably
understand what it contains,
including but not limited to a
description of what the dataset
contains, any sampling methodology
used to create the dataset, and any
anonymization or privacy-enhancing
technique that was applied.
Plaintiffs, in consultation with the
TC, may impose restrictions on what
information Google shares under this
Section IV.C.2 for the purposes of
(i) promoting data privacy and
security and (ii) ensuring privacy and
security safeguards are effectively
applied.
2. Google must provide
sufficient information about each
dataset such that Qualified
Competitors can reasonably
understand what it contains,
including but not limited to a
description of what the dataset
contains, any sampling methodology
used to create the dataset, and any
anonymization or privacy-enhancing
technique that was applied.
Plaintiffs, in consultation with the
Technical Committee, may
recommend restrictions on what
information Google shares under this
Paragraph IV.C.2 for the purposes of
(i) promoting data privacy and
security and (ii) ensuring privacy
and security safeguards are
effectively applied.
2. Google shall provide
sufficient information about each
dataset such that Qualified
Competitors can reasonably
understand what it contains,
including but not limited to a
description of what the dataset
contains, any sampling methodology
used to create the dataset, and any
anonymization or privacy-enhancing
technique that was applied.
Plaintiffs, in consultation with the
TC, may impose restrictions on what
information Google shares under
this Section IV.C.2 for the purposes
of (i) promoting data privacy and
security and (ii) ensuring privacy
and security safeguards are
effectively applied.
[No similar provision.] 4. The data specified in
Paragraph IV.A and B will be shared
pursuant to a license governing use.
The terms of the license shall include
a requirement that the Qualified
Competitor commit not to share or
sell the datasets, and shall use the
datasets for the exclusive purpose of
serving users located in the United
States through a General Search
Engine, Search Text Ads, and/or a
Third-Party GenAI Product.
3. The data specified in Sections
IV.A and B will be shared pursuant
to a license governing use. The
terms of the license shall include a
requirement that the Qualified
Competitor commit not to share or
sell the datasets unless authorized by
the Technical Committee or the
Court and shall use the datasets for
the exclusive purpose of serving
users through a General Search
Engine, Search Text Ads, and/or a
Third-Party GenAI Product. Within
six (6) months of the Effective Date
of this Final Judgment, Plaintiffs and
the Technical Committee, with input
from Google, shall create and submit
to the Court a template for such
license.
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60
V. REQUIRED SYNDICATION OF SEARCH RESULTS
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Search Syndication License:
Google shall take steps sufficient to
make available to any Qualified
Competitor, on financial terms no
worse than those offered to any other
user of Google’s search syndication
products, a syndication license whose
term will be five (5) years from the
date the license is signed, and which
shall require Google, via real-time
API(s), to make the following
information and data available in
response to each query issued or
submitted by a Qualified Competitor:
1. both desktop and mobile
versions of the ranked organic web
search results obtained from
crawling the web;
2. the user-facing query-
rewriting features that Google
provides under any of its current
search syndication agreements as of
the date of entry of this Final
Judgment, including user-facing
Search Features that enable query
correction, modification, or
expansion; and
3. the Local, Maps, Video,
Images, and Knowledge Panel
Search Feature content that Google
provides under any of its current
search syndication agreements as of
the date of the entry of this Final
Judgment.
A. Search Syndication: Google
must take steps sufficient to make
available to any Qualified Competitor
a syndication agreement whose term
will be five (5) years from the date
Google’s search syndication service,
as set forth in this Final Judgment, is
made available to the Qualified
Competitor, unless there are fewer than
five (5) years remaining before
expiration of the term of the Final
Judgment, in which case the term will
be the remainder of the term of the
Final Judgment. Google must make
available under the syndication
agreement the following information
and data in response to each query
submitted by a Qualified Competitor:
1. Both desktop and mobile
versions of the ranked organic web
search results obtained from
crawling the web (i.e., the ten blue
links) that Google provides under
current standard search syndication
agreements;
2. the user-facing query-
rewriting features that Google
provides under current standard
search syndication agreements,
including user-facing features that
enable query correction,
modification, or expansion; and
3. the Local, Maps, Video,
Images, and Knowledge Panel
search feature content that Google
provides under current standard
search syndication agreements. For
the avoidance of doubt, Google is
not required to syndicate content in a
manner inconsistent with its third-
party content license agreements.
A. Search Syndication License:
Google shall take steps sufficient to
make available to any Qualified
Competitor, on financial terms no
worse than those offered to any other
user of Google’s search syndication
products, a syndication license whose
term will be five (5) years from the
date the license is signed, and which
shall require Google, via real-time
API(s), to make the following
information and data available in
response to each query issued or
submitted by a Qualified Competitor:
1. both desktop and mobile
versions of the ranked organic web
search results obtained from
crawling the web;
2. the user-facing query-
rewriting features that Google
provides under any of its current
search syndication agreements as of
the date of entry of this Final
Judgment, including user-facing
Search Features that enable query
correction, modification, or
expansion; and
3. the Local, Maps, Video,
Images, and Knowledge Panel
Search Feature content that Google
provides under any of its current
search syndication agreements as of
the date of entry of this Final
Judgment.
B. Search Syndication License
Terms: The search syndication license
specified in Section V.A shall have the
following additional features:
B. Search Syndication
Agreement Terms: The search
syndication agreement must have the
following additional features:
B. Search Syndication License
Terms: The search syndication license
in Section V.A shall have the following
additional features:
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61
1. Google shall make syndicated
content available via an API.
1. Google will make syndicated
content available via an API.
1. Google shall make syndicated
content available via an API.
2. Google shall provide
responses with latency and reliability
functionally equivalent to what any
other user of Google’s search
syndication products would receive
as of the date of entry of this Final
Judgment.
2. Google will provide Qualified
Competitors with latency and
reliability functionally equivalent to
what Google ordinarily provides to
other users of Google’s search
syndication products with respect to
queries originating in the United
States. For the avoidance of doubt,
Google’s obligations do not extend
to latency and reliability differences
that result from differences in
product implementation, users, or
are otherwise outside of Google’s
syndication products.
2. Google shall provide
Qualified Competitors with latency
and reliability functionally
equivalent to what any other user of
Google’s search syndication
products would receive as of the date
of entry of this Final Judgment. For
the avoidance of doubt, Google’s
obligations do not extend to latency
and reliability differences that result
from differences in product
implementation, users, or are
otherwise outside of Google’s
syndication products.
3. Google shall provide the
license on a non-discriminatory basis
to any Qualified Competitor on
terms no less favorable than the most
favorable terms Google provides
under any current search syndication
agreements as of the date of entry of
this Final Judgment.
3. Google will offer these
syndication services on a non-
discriminatory basis to Qualified
Competitors at market rates
consistent with ordinary commercial
terms agreed to by other users of
Google’s search syndication
products with respect to queries
originating in the United States.
3. Google shall provide the
license on a non-discriminatory
basis to any Qualified Competitor on
terms no less favorable than the most
favorable terms Google provides
under any current search syndication
agreements as of the date of entry of
this Final Judgment.
4. Syndication shall start with
significant access to the data
required by Section V.A above and
decline over the course of five (5)
years with an expectation that
Qualified Competitors will become
independent of Google over time
through investment in their own
search capabilities. Qualified
Competitors’ use of Google’s search
syndication services in the first year
of a syndication license available
under Section V.A shall be capped at
40% of the Qualified Competitors’
annual queries. The scope of
allowable syndication beyond the
first year of a syndication license
available under Section V.A shall be
determined by the Plaintiffs in
consultation with the TC.
4. Qualified Competitors’ use of
Google’s syndication services in the
first year will be capped at 40% of
Qualified Competitors’ annual U.S.
queries and decline over the course
of a 5-year period with an
expectation that Qualified
Competitors will become
independent of Google over time
through investment in their own
search capabilities. The pace of this
tapering, the methods for measuring
and determining the percentage, and
the application of the percentage will
be determined by the Court upon
consultation with the Technical
Committee in a manner that
facilitates competition while
incentivizing Qualified Competitors
to move promptly to become
independent of Google.
4. Qualified Competitors’ use of
Google’s syndication services in the
first year will be capped at 40% of
Qualified Competitors’ annual U.S.
queries and decline over the course
of a 5-year period with an
expectation that Qualified
Competitors will become
independent of Google over time
through investment in their own
search capabilities. The pace of this
tapering, the methods for measuring
and determining the percentage, and
the application of the percentage will
be determined by the Court upon
consultation with Plaintiffs and the
Technical Committee in a manner
that facilitates competition while
incentivizing Qualified Competitors
to move promptly to become
independent of Google.
5. Google may not consent to
Qualified Competitors exceeding
syndication limits set by Plaintiffs,
and Qualified Competitors shall
6. Google may not consent to
Qualified Competitors exceeding
syndication limits, and Qualified
Competitors must submit to the
5. Google may not consent to
Qualified Competitors exceeding
syndication limits, and Qualified
Competitors shall submit to the TC
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62
submit to their TC audits of
syndication frequency and scope.
The frequency and content of these
audits shall be determined by the
Plaintiffs in consultation with the
TC.
Technical Committee audits of
syndication frequency and scope.
The Technical Committee will make
recommendations regarding the
frequency and content of these
audits, and the Court will have final
authority over their frequency and
scope.
audits of syndication frequency and
scope. The frequency and content of
these audits shall be determined by
the Plaintiffs in consultation with the
TC.
6. Google may impose no
restrictions or conditions on how a
Qualified Competitor uses, displays,
or integrates information or services
obtained under this Section V
beyond the least restrictive terms
Google provides under any current
search syndication agreements as of
the date of entry of this Final
Judgment.
7. The only permitted use of the
information and data that Qualified
Competitors obtain from Google
pursuant to this Section V is to
display the search results to the end
user who submitted the associated
query, for the exclusive purpose of
serving users located in the United
States through a General Search
Engine, Search Text Ads, and/or a
Third-Party GenAI Product.
6. Google may impose no
restrictions or conditions on how a
Qualified Competitor uses, displays,
or integrates information or services
obtained under this Section V
beyond the least restrictive terms
Google provides under any current
search syndication agreements as of
the date of entry of this Final
Judgment.
7. Qualified Competitors may
elect, in their sole discretion, which
queries (some or all) for which they
will request syndicated results and
which syndication components to
display or use and may do so in any
manner they choose, except that
Google may impose restrictions on
the display or use of syndication
components no less favorable than
what it provides under any current
search syndication agreements as of
the date of entry of this Final
Judgment.
5. Qualified Competitors may
elect, in their sole discretion, the
queries (of those that are eligible for
syndication pursuant to paragraph
V.B.4) for which they will request
syndicated results and which
syndication components to call for.
7. Qualified Competitors may
elect, in their sole discretion, which
queries (some or all) for which they
will request syndicated results and
which syndication components to
display or use and may do so in any
manner they choose, except that
Google may impose restrictions on
the display or use of syndication
components no less favorable than
what it provides under any current
search syndication agreements as of
the date of entry of this Final
Judgment. Google is also permitted
to place its ordinary commercial
restrictions on scraping, indexing, or
crawling the syndicated results and
content.
8. Google may impose its
ordinary commercial terms and
policies. For the avoidance of doubt,
Google is permitted to place its
ordinary commercial restrictions on
the use and display of its syndicated
results and content. Google is also
permitted to place its ordinary
commercial restrictions on scraping,
indexing, crawling, or otherwise
storing or analyzing the syndicated
results and content.
8. It shall be the Qualified
Competitor’s sole discretion to
determine how much information to
share with Google regarding the end-
user, except that Google may require
a Qualified Competitor to share
information with Google regarding
the end-user, on terms no less
favorable than what any other user of
Google’s search syndication
products would receive as of the date
of entry of this Final Judgment, as is
9. It will be the Qualified
Competitor’s sole discretion to
determine how much information to
share with Google regarding the end-
user, except that Google may impose
its ordinary commercial terms as is
necessary for the purposes of
(1) search syndication functionality;
(2) spam and abuse detection; and
(3) legal or regulatory compliance.
8. It shall be the Qualified
Competitor’s sole discretion to
determine how much information to
share with Google regarding the end
user except that Google may require
a Qualified Competitor to share
information with Google regarding
the end user, on terms no less
favorable than what any other user of
Google’s search syndication
products would receive as of the date
of entry of this Final Judgment, as is
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63
necessary for the purposes of
(1) basic search syndication
functionality; (2) spam and abuse
detection; and (3) legal or regulatory
compliance.
necessary for the purposes of
(1) basic search syndication
functionality; (2) spam and abuse
detection; and (3) legal or regulatory
compliance.
9. Google may not retain or use
(in any way) syndicated queries or
other information it obtains under
Section V.A for its own products and
services beyond the most limited
retention and use permitted under
any of Google’s current search
syndication agreements as of the date
of entry of this Final Judgment.
10. Google is permitted to retain
or use data collected from Qualified
Competitors in provisioning of the
service under Section V for Google’s
own products and services to the
same extent Google retains or uses
data in the ordinary course from
other users of its search syndication
service.
9. Google may not retain or use
(in any way) syndicated queries or
other information it obtains under
Section V.A for its own products and
services beyond the most limited
retention and use permitted under
any of Google’s current search
syndication agreements as of the
date of entry of this Final Judgment.
10. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States. Synthetic queries are not
eligible for syndication under this
Final Judgment.
11. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States, from human end users of the
Qualified Competitor. Queries from
a syndicator of the Qualified
Competitor and synthetic queries are
not eligible for syndication under the
Final Judgment.
10. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States, from human end users of the
Qualified Competitor. Queries from
a syndicator of the Qualified
Competitor and synthetic queries are
not eligible for syndication under the
Final Judgment.
[No similar provision.] 12. If Google in good faith
believes a Qualified Competitor is in
breach of the terms of its agreement,
it may exercise its rights under the
agreement. Google must also
provide simultaneous notice to the
Technical Committee of the breach
and the actions Google is taking in
light of the breach.
11. If Google in good faith
believes a Qualified Competitor is in
breach of the terms of its agreement,
it may exercise its rights under the
agreement. Google must also
provide simultaneous notice to the
Technical Committee of the breach
and the actions Google is taking in
light of the breach.
[No similar provision.] [No similar provision.] Within sixty (60) days of the Effective
Date of this Final Judgment, Plaintiffs
and the Technical Committee, with
input from Google, shall create and
submit to the Court a template for such
license.
C. Existing Syndication
Agreements: The provisions of this
Section V shall have no effect on any
existing Google syndication
agreements with third parties or on its
ability to enter into syndication
agreements with third parties other
than Qualified Competitors, except
that Google shall permit any entity
with an existing syndication agreement
who becomes a Qualified Competitor,
C. Existing Syndication
Agreements: The provisions of this
Section V will have no effect on any
existing Google search syndication
agreements with third parties or on
Google’s ability to enter into search
syndication contracts with third parties
other than Qualified Competitors,
except that Google must permit any
entity with an existing search
syndication agreement who becomes a
C. Existing Syndication
Agreements: The provisions of this
Section V will have no effect on any
existing Google search syndication
agreements with third parties or on
Google’s ability to enter into search
syndication agreements with third
parties other than Qualified
Competitors, except that Google shall
permit any entity with an existing
search syndication agreement who
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64
at the Qualified Competitor’s sole
discretion, to terminate its existing
agreement in favor of the remedies in
this Section V.
Qualified Competitor, at the Qualified
Competitor’s sole discretion, to
terminate its existing agreement in
favor of the remedies in this Section V.
becomes a Qualified Competitor, at the
Qualified Competitor’s sole discretion,
to terminate its existing agreement in
favor of the remedies in this Section V.
VI. SEARCH TEXT AD AUCTION CHANGES AND SEARCH TEXT ADS SYNDICATION
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Search Text Ads Auction
Changes: Within a reasonable period
of time after the Technical
Committee’s appointment, Plaintiffs
shall submit a proposal to the Court,
informed by the Technical
Committee’s views, by which Google
shall periodically provide the
Technical Committee and Plaintiffs a
report outlining all changes to its
Search Text Ads auction meeting
certain parameters and, for each such
change, (1) Google’s public disclosure
of that change or (2) a statement why
no public disclosure is necessary.
Plaintiffs’ proposal shall detail the
types of changes that must be
disclosed, the frequency of disclosure,
the steps to mitigate undue burden on
Google, and the steps to ensure any
public disclosure of an ad auction
change (if not already made by
Google) avoids revealing Google’s
trade secrets, in accord with the
Court’s instructions in its September 2,
2025, Memorandum Opinion.
Plaintiffs have the right to challenge
any disclosure they deem inadequate.
For the avoidance of doubt, Google
need not report on auction
experiments, which are generally
tested on some fraction of Google’s
Search Text Ads traffic, but Google
shall disclose changes to the Search
Text Ads auction that result from any
such auction experiments.
A. Search Text Ads Auction
Changes: Within a reasonable period
of time after the Technical
Committee’s appointment, Plaintiffs
and the Technical Committee shall
submit a proposal to the Court, by
which Google shall periodically
provide the Technical Committee and
Plaintiffs a report outlining all changes
to its Search Text Ads auction meeting
certain parameters and, for each such
change, (1) Google’s public disclosure
of that change or (2) a statement why
no public disclosure is necessary. The
proposal shall detail the types of
changes that must be disclosed, the
frequency of disclosure, the steps to
mitigate undue burden on Google, and
the steps to ensure any public
disclosure of an ad auction change (if
not already made by Google) avoids
revealing Google’s trade secrets, in
accord with the Court’s instructions in
its September 2, 2025, Memorandum
Opinion. For the avoidance of doubt,
Google need not report on auction
experiments, which are generally
tested on some fraction of Google’s
Search Text Ads traffic. Should any of
these auction experiments result in ad
auction launches that fall within the
types of changes that must be disclosed
under this Section, Google shall
disclose such changes to Plaintiffs and
the Technical Committee.
A. Search Text Ads Auction
Changes: Within a reasonable period
of time after the Technical
Committee’s appointment, Plaintiffs
shall submit a proposal to the Court,
informed by the Technical
Committee’s views, by which Google
shall periodically provide the
Technical Committee and Plaintiffs a
report outlining all changes to its
Search Text Ads auction meeting
certain parameters and, for each
change, (1) Google’s public disclosure
of that change or (2) a statement why
no public disclosure is necessary.
Plaintiffs’ proposal shall detail the
types of changes that must be
disclosed, the frequency of disclosure,
the steps to mitigate undue burden on
Google, and the steps to ensure any
public disclosure of an ad auction
change (if not already made by
Google) avoids revealing Google’s
trade secrets, in accord with the
Court’s instructions in its September 2,
2025, Memorandum Opinion.
Plaintiffs have the right to challenge
any disclosure they deem inadequate.
For the avoidance of doubt, Google
need not report on auction
experiments, which are generally
tested on some fraction of Google’s
Search Text Ads traffic, but Google
shall disclose changes to the Search
Text Ads auction that result from any
such auction experiments.
B. Search Text Ads Syndication:
Google shall take steps sufficient to
make available to any Qualified
Competitor a Search Ads Syndication
License whose term will be five (5)
years from the date the license is
B. Search Text Ads Syndication:
Google must take steps sufficient to
make available to any Qualified
Competitor a Search Text Ads
syndication agreement whose term
will be five (5) years from the date
B. Search Text Ads Syndication:
Google shall take steps sufficient to
make available to any Qualified
Competitor a Search Text Ads
Syndication License whose term will
be five (5) years from the date the
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65
signed. The Search Text Ads
syndication agreement shall have the
following additional features:
Google’s Search Text Ads syndication
service, as set forth in this Final
Judgment, is made available to the
Qualified Competitor, unless there are
fewer than five (5) years remaining
before expiration of the term of the
Final Judgment, in which case the term
will be the remainder of the term of the
Final Judgment. The Search Text Ads
syndication agreement must have the
following additional features:
license is signed. The Search Text Ads
syndication agreement shall have the
following additional features:
1. Google shall provide latency,
reliability, and performance
functionally equivalent to what
Google provides any other user of
Google’s Search Text Ads
syndication products, e.g., AdSense
for Search, or any other current or
future products offering syndicated
Search Text Ads. Search Text Ads
syndication licenses to Qualified
Competitors shall include all types of
Search Text Ads (including any
assets, extensions, or similar Search
Text Ad variations) available
through its syndication products.
For the avoidance of doubt, Google
shall only provide syndication for
queries that originate in the United
States.
1. Google will provide latency,
reliability, and performance
functionally equivalent to what
Google ordinarily provides to other
users of Google’s Search Text Ads
syndication products, e.g., AdSense
for Search, with respect to queries
originating in the United States. For
the avoidance of doubt, Google’s
obligations do not extend to latency,
reliability, and performance
differences that result from
differences in product
implementation, users, or are
otherwise outside of Google’s
syndication products.
1. Google shall provide latency,
reliability, and performance
functionally equivalent to what
Google ordinarily provides to other
users of Google’s Search Text Ads
syndication products, e.g., AdSense
for Search, or any other current or
future products offering syndicated
Search Text Ads. Search Text Ads
syndication licenses to Qualified
Competitors shall include all types
of Search Text Ads (including any
assets, extensions, or similar Search
Text Ad variations) available
through its syndication products.
For the avoidance of doubt, Google’s
obligations do not extend to latency,
reliability, and performance
differences that result from
differences in product
implementation, users, or are
otherwise outside of Google’s
syndication products.
3. Google will make available to
Qualified Competitors all types of
Search Text Ads (including any
assets, extensions, or similar Search
Text Ad variations) that are available
through its Search Text Ads
syndication products.
2. Google shall provide the
Search Ads Syndication License to
Qualified Competitors on financial
terms no worse than those offered to
any other user of Google’s Search
Text Ads syndication products.
2. Google will offer these
syndication services on a non-
discriminatory basis to Qualified
Competitors at market rates
consistent with ordinary commercial
terms agreed to by other users of
Google’s Search Text Ads
syndication products, e.g., AdSense
for Search, with respect to queries
originating in the United States.
2. Google shall provide the
Search Text Ads Syndication
License to Qualified Competitors on
financial terms no worse than those
offered to any other user of Google’s
Search Text Ads syndication
products.
3. Google shall not require
Qualified Competitors to share more
information with Google regarding
the end-user than it requires from
any other user of Google’s Search
Text Ads syndication products.
11. It will be the Qualified
Competitor’s sole discretion to
determine how much information to
share with Google regarding the end-
user, except that Google may impose
its ordinary commercial terms for the
3. Google shall not require
Qualified Competitors to share more
information with Google regarding
the end user than it requires from any
other user of Google’s Search Text
Ads syndication products.
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66
purposes of (1) ad syndication
functionality; (2) spam and abuse
detection; and/or (3) legal or
regulatory compliance.
4. The only permitted use of the
information and data that Qualified
Competitors obtain from Google
pursuant to this Section VI is to
display the ad results to the end user
who submitted the associated query,
as further detailed in this section.
7. The only permitted use of the
information and data that Qualified
Competitors obtain from Google
pursuant to this Section VI is to
display the ad results to the end user
who submitted the associated query,
for the exclusive purpose of serving
users located in the United States
through a General Search Engine,
Search Text Ads, and/or a Third-
Party GenAI Product.
4. The only permitted use of the
information and data that Qualified
Competitors obtain from Google
pursuant to this Section VI is to
display the ad results to the end user
who submitted the associated query,
as further detailed in this section,
except as permitted by Section
VI.B.9.
5. Google shall (i) make the
purchase of ads syndicated under this
Section VI.B available to advertisers
on a nondiscriminatory basis
comparable to, and no more
burdensome than, the availability of
Google’s other Search Text Ads;
(ii) include Qualified Competitors in
its Search Partner Network; and
(iii) provide advertisers the option to
appear on each individual Qualified
Competitor’s sites on a site-by-site
basis (i.e., an advertiser can choose
to appear as a syndicated result on a
Qualified Competitor’s site
regardless of whether it opts into the
Search Partner Network or chooses
to appear on any other site, including
Google.com) to the same extent
advertisers have such choice for any
Google Search Text Ads Syndicator
as of the date of entry of this Final
Judgment.
4. Google will make the
purchase of ads syndicated under
this Section VI available to
advertisers on a nondiscriminatory
basis comparable to, and no more
burdensome than, the availability of
Google’s other Search Text Ads, and
must offer advertisers the choice to
opt into showing ads on Qualified
Competitors’ websites, consistent
with Google’s ordinary commercial
terms, policies, and functionality
offered to other users of Google’s
Search Text Ads syndication
products.
5. Google shall (i) make the
purchase of ads syndicated under
this Section VI.B available to
advertisers on a non-discriminatory
basis comparable to, and no more
burdensome than, the availability of
Google’s other Search Text Ads and
(ii) include Qualified Competitors in
its Search Partner Network.
6. Qualified Competitors shall
have the same formatting flexibility
available to any other user of
Google’s Search Text Ads
syndication products, shall be free to
use other providers of syndicated
search ads or display their own ads,
5. Qualified Competitors shall
have the same formatting flexibility
with respect to the Search Text Ads
syndicated pursuant to this Judgment
as Google makes available to other
users of Google’s Search Text Ads
syndication products.
6. Qualified Competitors shall
have the same formatting flexibility
available to any other user of
Google’s Search Text Ads
syndication products, shall be free to
use other providers of syndicated
search ads or display their own ads,
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67
and shall not be required to provide
Google ads with preferential
placement over equivalent ads
requested from other sources.
Google may place only ordinary-
course restrictions on the use or
display of syndicated ad content
intended to guard against “trick or
click” schemes, ensure the proper
ordering of ads, guarantee ad quality,
protect the advertiser, or prevent ad
misuse, and may place restrictions
on scraping, indexing, or crawling
syndicated results, but such
restrictions shall be no more
restrictive than those applied to any
other user of Google’s Search Text
Ads syndication products.
6. Qualified Competitors shall
be free to use other providers of
syndicated search ads or display
their own ads, and Qualified
Competitors shall not be required to
provide Google ads with preferential
placement over equivalent ads
requested from other sources.
and shall not be required to provide
Google ads with preferential
placement over equivalent ads
requested from other sources.
Google may place only ordinary-
course restrictions on the use or
display of syndicated ad content, but
such restrictions shall be no more
restrictive than those applied to any
other user of Google’s Search Text
Ads syndication products. Google is
also permitted to place its ordinary
commercial restrictions on scraping,
indexing, or crawling the syndicated
ads.
8. Google may impose its
ordinary commercial terms and
policies. For the avoidance of doubt,
Google is permitted to place its
ordinary commercial restrictions on
the use and display of its syndicated
ads. Google is also permitted to
place its ordinary commercial
restrictions on scraping, indexing,
crawling, or otherwise storing or
analyzing the syndicated ads.
7. Google may only retain or use
(in any way) syndicated queries or
other information it obtains under
this Section VI.B to “build, improve,
and maintain” its ad infrastructure in
the same manner it used such
information as of the date of entry of
this Final Judgment.
9. Google is permitted to retain
or use data collected from Qualified
Competitors in provisioning of the
service under Section VI for
Google’s own products and services
for the purpose of building,
improving, and maintaining its ads
infrastructure and shared ads
systems. Google’s use of Qualified
Competitors’ data for these purposes
will be the same as Google’s use of
data from other users of its Search
Text Ads syndication products.
7. Google is permitted to retain
or use data collected from Qualified
Competitors in provisioning of the
service under Section VI for
Google’s own products and services
for the purpose of building,
improving, and maintaining its ads
infrastructure and shared ads
systems. Google’s use of Qualified
Competitors’ data for these purposes
will be the same as Google’s use of
data from other users of its Search
Text Ads syndication products.
8. Google need not grant
Qualified Competitors the right to set
a minimum cost per click for
syndicated ads unless failing to do so
would violate Section VI.B.1.
10. Google need not grant
Qualified Competitors the right to
set a minimum cost per click for
syndicated ads.
8. Google need not grant
Qualified Competitors the right to
set a minimum cost per click for
syndicated ads unless failing to do so
would violate Section VI.B.1.
9. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States, from human end users.
Synthetic queries are not eligible for
syndication under the Final
Judgment.
12. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States, from human end users of the
Qualified Competitor. Queries from
a syndicator of the Qualified
Competitor and synthetic queries are
not eligible for syndication under the
Final Judgment.
9. For the avoidance of doubt,
this Final Judgment only requires
Google to provide syndication for
queries that originate in the United
States, from human end users.
Synthetic queries are not eligible for
syndication under the Final
Judgment. Queries from a
syndicator of the Qualified
Competitor are not eligible for
syndication under the Final
Judgment, unless such Qualified
Competitor has been certified as a
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Competitor to a Google ads platform
(e.g., Google Ads).
10. If Google in good faith
believes a Qualified Competitor is in
breach of the terms of its agreement
under this Section VI, Google may
exercise its rights under the
agreement. Before exercising such
rights, Google shall first provide
simultaneous notice to the Technical
Committee and the Plaintiffs of the
breach and the actions Google is
taking in light of the breach. Google
shall provide this notice in time such
that Plaintiffs have a reasonable
period of time to raise objections. If
Plaintiffs object and seek a
resolution by the Court, Google may
not take any action until the later of
(i) two weeks after Plaintiffs seek
Court intervention, if the Court does
not act, or (ii) until further order of
the Court, if the Court intervenes.
13. If Google in good faith
believes a Qualified Competitor is in
breach of the terms of its agreement,
it may exercise its rights under the
agreement. Google must also
provide simultaneous notice to the
Technical Committee of the breach
and the actions Google is taking in
light of the breach.
10. If Google in good faith
believes a Qualified Competitor is in
breach of the terms of its agreement
under this Section VI, Google may
exercise its rights under the
agreement. Before exercising such
rights, Google shall first provide
simultaneous notice to the Technical
Committee and the Plaintiffs of the
breach and the actions Google is
taking in light of the breach. Google
shall provide this notice in time such
that Plaintiffs have a reasonable
period of time to raise objections. If
Plaintiffs object and seek a
resolution by the Court, Google may
not take any action until the later of
(i) two weeks after Plaintiffs seek
Court intervention, if the Court does
not act, or (ii) until further order of
the Court, if the Court intervenes.
Google may seek expedited
consideration from the Court if the
circumstances warrant such
treatment.
11. Google shall be entitled to
propose additional terms to the
Search Text Ad syndication
agreements with Qualified
Competitors as necessary to
guarantee ad quality, protect
advertisers, and prevent ad misuse.
Qualified Competitors are free to
reject these proposed additional
terms. Google shall provide
simultaneous notice to the Technical
Committee and the Plaintiffs of any
such term and allow Plaintiffs a
reasonable period of time to raise
objections. If Plaintiffs object and
seek a resolution by the Court,
Google may not modify its Search
Text Ad syndication agreements
under this Section VI until the later
of (i) two weeks after Plaintiffs seek
Court intervention, if the Court does
not act, or (ii) until further order of
the Court, if the Court intervenes.
14. Google will be entitled to
propose additional terms to the
Search Text Ad syndication
agreements with Qualified
Competitors as necessary to
guarantee ad quality, protect
advertisers, and prevent ad misuse.
11. Google shall be entitled to
propose additional terms to the
Search Text Ad syndication
agreements with Qualified
Competitors as necessary to
guarantee ad quality, protect
advertisers, and prevent ad misuse.
Qualified Competitors are free to
reject these proposed additional
terms. Google shall provide
simultaneous notice to the Technical
Committee and the Plaintiffs of any
such term and allow Plaintiffs a
reasonable period of time to raise
objections. If Plaintiffs object and
seek a resolution by the Court,
Google may not modify its Search
Text Ad syndication agreements
under this Section VI until the later
of (i) two weeks after Plaintiffs seek
Court intervention, if the Court does
not act, or (ii) until further order of
the Court, if the Court intervenes.
Google may seek expedited
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69
consideration from the Court if the
circumstances warrant such
treatment.
12. Qualified Competitors may
elect, in their sole discretion, which
queries (some or all) for which they
will request syndicated search text ad
results and which syndication
components to display or use and
may do so in any manner they
choose, except that Google may
impose restrictions on the display or
use of syndication components no
less favorable than what it provides
under current search text ad
syndication agreements as of the date
of entry of this Final Judgment.
15. Qualified Competitors may
elect, in their sole discretion, the
queries for which they will request
syndicated ad results.
12. Qualified Competitors may
elect, in their sole discretion, the
queries for which they will request
syndicated ad results.
[No similar provision.] [No similar provision.] Within sixty (60) days of the Effective
Date of this Final Judgment, Plaintiffs
and the Technical Committee, with
input from Google, shall create and
submit to the Court a template for such
license.
C. Existing Syndication
Agreements: The provisions of this
Section VI shall have no effect on any
existing Google search text ad
syndication agreements with third
parties or on its ability to enter into
search text ad syndication agreements
with third parties other than Qualified
Competitors, except that Google shall
permit any entity with an existing
search text ad syndication agreement
who becomes a Qualified Competitor,
at the Qualified Competitor’s sole
discretion, to terminate its existing
agreement in favor of the remedies in
this Section VI.
C. Existing Syndication
Agreements: The provisions of this
Section VI will have no effect on any
existing Google Search Text Ad
syndication agreements with third
parties or on Google’s ability to enter
into Search Text Ad syndication
contracts with third parties other than
Qualified Competitors, except that
Google must permit any entity with an
existing Search Text Ad syndication
agreement who becomes a Qualified
Competitor, at the Qualified
Competitor’s sole discretion, to
terminate its existing agreement in
favor of the remedies in this
Section VI.
C. Existing Syndication
Agreements: The provisions of this
Section VI shall have no effect on any
existing Google Search Text Ad
syndication agreements with third
parties or on Google’s ability to enter
in Search Text Ad syndication
agreements with third parties other
than Qualified Competitors, except
that Google shall permit any entity
with an existing Search Text Ad
syndication agreement who becomes a
Qualified Competitor, at the Qualified
Competitor’s sole discretion, to
terminate its existing agreement in
favor of the remedies in this
Section VI.
VII. COMPLIANCE, ADMINISTRATION, AND ENFORCEMENT PROCEDURES
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Technical Committee: A. Technical Committee: A. Technical Committee:
1. Within sixty (60) days of entry
of this Final Judgment, the Court will
appoint, pursuant to the procedures
below, a five-person Technical
Committee (“TC”) to assist in
1. Within sixty (60) days of entry
of this Final Judgment, the Court
will appoint, pursuant to the
procedures below, a five-person
Technical Committee (“TC”) to
1. Within sixty (60) days of entry
of this Final Judgment, the Court
will appoint, pursuant to the
procedures below, a five-person
Technical Committee to assist in
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70
enforcement of and compliance with
this Final Judgment.
assist in enforcement of and
compliance with this Final
Judgment.
enforcement of and compliance with
this Final Judgment.
2. The TC members shall be
experts in some combination of
software engineering, information
retrieval, artificial intelligence,
economics, behavioral science, as
well as data privacy and data
security. No TC member may have a
conflict of interest that could prevent
them from performing their duties in
a fair and unbiased manner. In
addition, unless Plaintiffs
specifically consent, no TC member:
2. The TC members must be
experts in some combination of
software engineering, information
retrieval, artificial intelligence,
economics, behavioral science, and
data privacy and data security. No
TC member may have a conflict of
interest that could prevent them from
performing their duties in a fair and
unbiased manner. In addition, unless
the Court approves, no TC member:
2. The TC members shall be
experts in some combination of
software engineering, information
retrieval, artificial intelligence,
economics, behavioral science, and
data privacy and data security. No
TC member may have a conflict of
interest that could prevent them from
performing their duties in a fair and
unbiased manner. In addition, unless
the Court so approves, no TC
member:
a. may have been employed in
any capacity by Google or any
Competitor to Google within the
six-month period directly
predating their appointment to the
TC;
a. may have been employed in
any capacity by Google or any
Competitor to Google within the
six-month period directly
predating their appointment to the
TC;
a. may have been employed in
any capacity by Google or any
Competitor to Google within the
six-month period directly
predating their appointment to the
TC;
b. may have been retained by
any party as a consulting or
testifying expert in this action; or
b. may have been retained as a
consulting or testifying expert by
any part in this action; or
b. may have been retained by
any party as a consulting or
testifying expert in this action; or
c. may perform any work for
Google or any Competitor of
Google during the time that they
serve on the TC and for one (1)
year after ceasing to serve on the
TC.
c. may perform any work for
Google or any Competitor of
Google during the time that they
serve on the TC and for one (1)
year after ceasing to serve on the
TC.
c. may perform any work for
Google or any Competitor of
Google during the time that they
serve on the TC and for one (1)
year after ceasing to serve on the
TC.
3. Within thirty (30) days of
entry of this Final Judgment,
Plaintiff United States (after
consultation with the Co-Plaintiff
States), the Colorado Plaintiff States,
and Google shall each select one
member of the TC, and a majority of
those three members will then select
the remaining two members.
Plaintiff United States’ appointee
shall serve as chair. The selection
and approval process shall be as
follows:
3. Within thirty (30) days of
entry of this Final Judgment,
Plaintiff United States (after
consultation with the Co-Plaintiff
States), the Colorado Plaintiff States,
and Google will each select one
member of the TC, and a majority of
those three members will then select
the remaining two members.
Plaintiff United States’ appointee
will serve as chair. The selection and
approval process will be as follows:
3. Within thirty (30) days of
entry of this Final Judgment,
Plaintiff United States (after
consultation with the Co-Plaintiff
States), the Colorado Plaintiff States,
and Google shall each select one
member of the TC, and a majority of
those three members will then select
the remaining two members.
Plaintiff United States’ appointee
shall serve as chair. The selection
and approval process shall be as
follows:
a. As soon as practicable after
submission of this Final Judgment
to the Court, the Plaintiffs as a
group shall identify to Google the
individuals they propose to select
as their designees to the TC, and
Google shall identify to Plaintiffs
a. As soon as practicable after
submission of this Final Judgment
to the Court, the Plaintiffs as a
group will identify to Google the
individuals they propose to select
as their designees to the TC, and
Google will identify to Plaintiffs
a. As soon as practicable after
submission of this Final Judgment
to the Court, the Plaintiffs as a
group shall identify to Google the
individuals they propose to select
as their designees to the TC, and
Google shall identify to Plaintiffs
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71
the individual it proposes to select
as its designees. No party may
object to a selection on any ground
other than failure to satisfy the
requirements of Section VII.A.2
above. Any such objection shall be
made within ten (10) business days
of receipt of notification of
selection.
the individual it proposes to select
as its designee. No party may
object to a selection on any ground
other than failure to satisfy the
requirements of Paragraph VII.A.2
above. Any such objection must
be made within ten (10) business
days of the receipt of notification
of selection.
the individual it proposes to select
as its designee. No party may
object to a selection on any ground
other than failure to satisfy the
requirements of Section VII.A.2
above. Any such objection shall
be made within ten (10) business
days of receipt of notification of
selection.
b. The Plaintiffs shall apply to
the Court for appointment of the
persons selected pursuant to
Section VII.A.3.a) above. Any
objections to the eligibility of a
selected person that the parties
have failed to resolve between
themselves will be decided by the
Court based solely on the
requirements stated in Section
VII.A.2 above.
b. The Plaintiffs will apply to the
Court for appointment of the
persons selected pursuant to
Paragraph VII.A.3.a above. Any
objections to the eligibility of a
selected person that the parties
have failed to resolve between
themselves will be decided by the
Court based solely on the
requirements stated in Paragraph
VII.A.2 above.
b. The Plaintiffs shall apply to
the Court for appointment of the
persons selected pursuant to
Section VII.A.3.a above. Any
objections to the eligibility of a
selected person that the parties
have failed to resolve between
themselves will be decided by the
Court based solely on the
requirements stated in Section
VII.A.2 above.
c. As soon as practicable after
their appointment by the Court, the
three members of the TC selected
by the Plaintiffs and Google (the
“Standing Committee Members”)
shall identify to the Plaintiffs and
Google the persons that they in
turn propose to select as the
remaining members of the TC.
The Plaintiffs and Google shall not
object to these selections on any
grounds other than failure to
satisfy the requirements of Section
VII.A.2 above. Any such
objection shall be made within ten
(10) business days of receipt of
notification of the selection and
shall be served on the other party
as well as on the Standing
Committee Members.
c. As soon as practicable after
their appointment by the Court, the
three members of the TC selected
by the Plaintiffs and Google (the
“Standing Committee Members”)
will identify to the Plaintiffs and
Google the persons that they in
turn propose to select as the
remaining members of the TC.
The Plaintiffs and Google must not
object to these selections on any
grounds other than failure to
satisfy the requirements of
Paragraph VII.A.2 above. Any
such objection must be made
within ten (10) business days of
the receipt of notification of the
selection and must be served on
the other party as well as on the
Standing Committee Members.
c. As soon as practicable after
their appointment by the Court, the
three members of the TC selected
by the Plaintiffs and Google (the
“Standing Committee Members”)
shall identify to the Plaintiffs and
Google the persons that they in
turn propose to select as the
remaining members of the TC.
The Plaintiffs and Google shall not
object to these selections on any
grounds other than failure to
satisfy the requirements of Section
VII.A.2 above. Any such
objection shall be made within ten
(10) business days of receipt of
notification of selection and shall
be served on the other party as well
as on the Standing Committee
Members.
d. The Plaintiffs shall apply to
the Court for appointment of the
persons selected by the Standing
Committee Members. If the
Standing Committee Members
cannot agree on the fourth or fifth
members of the TC, that member
or members shall be appointed by
the Court. Any objection by
Plaintiffs or Google to the
eligibility of the person selected by
d. The Plaintiffs will apply to the
Court for appointment of the
persons selected by the Standing
Committee Members. If the
Standing Committee Members
cannot agree on the fourth or fifth
members of the TC, that member
or members will be appointed by
the Court. Any objection by
Plaintiffs or Google to the
eligibility of the person selected by
d. The Plaintiffs shall apply to
the Court for appointment of the
persons selected by the Standing
Committee Members. If the
Standing Committee Members
cannot agree on the fourth or fifth
members of the TC, that member
or members shall be appointed by
the Court. Any objection by
Plaintiffs or Google to the
eligibility of the person selected by
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72
the Standing Committee Members
which the parties have failed to
resolve among themselves shall
also be decided by the Court based
solely on the requirements stated
in Section VII.A.2 above.
the Standing Committee Members
which the parties have failed to
resolve among themselves will
also be decided by the Court based
solely on the requirements stated
in Paragraph VII.A.2 above.
the Standing Committee Members
which the parties have failed to
resolve among themselves shall
also be decided by the Court based
solely on the requirements stated
in Section VII.A.2 above.
4. The Standing Committee
Members shall serve for an initial
term of thirty-six (36) months; the
remaining members shall serve for
an initial term of thirty (30) months.
At the end of a TC member’s term,
the party that originally selected
them may, in its sole discretion,
either request re-appointment by the
Court to additional terms of the same
length, or replace the TC member in
the same manner as provided for in
Section VII.A.3 above. In the case
of the fourth and fifth members of
the TC, those members shall be re-
appointed or replaced in the manner
provided in Section VII.A.3 above.
4. The Standing Committee
Members will serve for an initial
term of thirty-six (36) months; the
remaining members will serve for an
initial term of thirty (30) months. At
the end a TC member’s term, the
party that originally selected them
may, in its sole discretion, either
request re-appointment by the Court
to additional terms of the same
length, or replace the TC member in
the same manner as provided for in
Paragraph VII.A.3 above. In the
case of the fourth and fifth members
of the TC, those members will be re-
appointed or replaced in the manner
provided in Paragraph VII.A.3
above.
4. The Standing Committee
Members shall serve for an initial
term of thirty-six (36) months; the
remaining members shall serve for
an initial term of thirty (30) months.
At the end of a TC member’s term,
the party that originally selected
them may, in its sole discretion,
either request re-appointment by the
Court to additional terms of the same
length, or replace the TC member in
the same manner as provided for in
Section VII.A.3 above. In the case
of the fourth and fifth members of
the TC, those members shall be re-
appointed or replaced in the manner
provided in Section VII.A.3 above.
5. If Plaintiffs determine that a
member of the TC has failed to act
diligently and consistently with the
purposes of this Final Judgment, or
if a member of the TC resigns, or for
any other reason ceases to serve in
their capacity as a member of the TC,
the person or persons that originally
selected the TC member shall select
a replacement member in the same
manner as provided for in Section
VII.A.3 above.
5. If any party determines that a
member of the TC has failed to act
diligently and consistently with the
purposes of this Final Judgment,
they may petition the Court for
removal of that member. If a
member of the TC is removed by the
Court, resigns, or for any other
reason ceases to serve in their
capacity as a member of the TC, the
person or persons that originally
selected the TC member will select a
replacement member in the same
manner as provided for in Paragraph
VII.A.3 above.
5. If any party determines that a
member of the TC has failed to act
diligently and consistently with the
purposes of this Final Judgment,
they may petition the Court for
removal of that member. If a
member of the TC is removed by the
Court, resigns, or for any other
reason ceases to serve in their
capacity as a member of the TC, the
person or persons that originally
selected the TC member shall select
a replacement member in the same
manner as provided for in Section
VII.A.3 above.
6. Promptly after appointment of
the TC by the Court, the Plaintiffs
shall enter into a Technical
Committee Services Agreement
(“TC Services Agreement”) with
each TC member that grants the
rights, powers, and authorities
necessary to permit the TC to
perform its duties under this Final
Judgment. Google shall indemnify
each TC member and hold them
harmless against any losses, claims,
6. Promptly after appointment of
the TC by the Court, the Plaintiffs
will enter into a Technical
Committee Services Agreement
(“TC Services Agreement”) with
each TC member that grants the
rights, powers, and authorities
necessary to permit the TC to
perform its duties under this Final
Judgment. Google must indemnify
each TC member and hold them
harmless against any losses, claims,
6. Promptly after appointment of
the TC by the Court, the Plaintiffs
shall enter into a Technical
Committee Services Agreement
(“TC Services Agreement”) with
each TC member that grants the
rights, powers, and authorities
necessary to permit the TC to
perform its duties under this Final
Judgment. Google shall indemnify
each TC member and hold them
harmless against any losses, claims,
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73
damages, liabilities or expenses
arising out of, or in connection with,
the performance of the TC’s duties,
except to the extent that such
liabilities, losses, damages, claims,
or expenses result from misfeasance,
gross negligence, willful or wanton
acts, or bad faith by the TC member.
The TC Services Agreements shall
include the following:
damages, liabilities or expenses
arising out of, in connection with, the
performance of the TC’s duties,
except to the extent that such
liabilities, losses, damages, claims,
or expenses result from misfeasance,
gross negligence, willful or wanton
acts, or bad faith by the TC member.
The TC Services Agreement must
include the following:
damages, liabilities, or expenses
arising out of, or in connection with,
the performance of the TC’s duties,
except to the extent that such
liabilities, losses, damages, claims,
or expenses result from misfeasance,
gross negligence, willful or wanton
acts, or bad faith by the TC member.
The TC Services Agreements shall
include the following:
a. The TC members shall serve,
without bond or other security, at
the cost and expense of Google on
such terms and conditions as the
Plaintiffs approve, including the
payment of reasonable fees and
expenses.
a. The TC members will serve,
without bond or security, at the
cost and expense of Google on
such terms and conditions as the
parties agree, including the
payment of reasonable fees and
expenses. To the extent that the
parties cannot agree on the terms
of a TC Services Agreement, the
parties will submit such
disagreement to the Court for
resolution.
a. The TC members shall serve,
without bond or other security, at
the cost and expense of Google on
such terms and conditions as the
parties agree, including payment
of reasonable fees and expenses.
To the extent that the parties
cannot agree on the terms of a TC
Services Agreement, the parties
will submit such disagreement to
the Court for resolution.
b. The TC Services Agreement
shall provide that each member of
the TC must comply with the
limitations provided for in Section
VII.A.2 above.
b. The TC Services Agreement
will provide that each member of
the TC must comply with the
limitations provided for in
Paragraph VII.A.2 above.
b. The TC Services Agreement
shall provide that each member of
the TC must comply with the
limitations provided for in Section
VII.A.2 above.
7. The TC shall have the
following powers and duties:
7. The TC has the following
powers and duties:
7. The TC shall have the
following powers and duties:
a. The TC shall have the power
and authority to monitor Google’s
implementation of and compliance
with its obligations under this
Final Judgment, in the manner
describe further herein.
b. The TC will have the power to
advise and make
recommendations about the
standards to be applied for
assessing, and the ultimate
determination of whether a third
party should qualify as a Qualified
Competitor for purposes of this
Final Judgment, see Paragraph
IX.T.
a. The TC shall have the power
and authority to monitor Google’s
implementation of and compliance
with its obligations under this
Final Judgment, in the manner
described further herein.
d. The TC will have the power to
advise Plaintiffs and the Court
about an appropriate cap on User-
side Data disclosures to be made to
Qualified Competitors, see
Paragraph IV.B.4.
e. The TC will have the power to
advise Plaintiffs and the Court
about appropriate User-side Data
security and privacy safeguards,
see Paragraph IV.C.
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f. The TC will have the power to
audit Qualified Competitors’ use
of search and search text ads
syndication services, see
Paragraph IX.T.
g. The TC will have the power to
conduct data security and privacy
safeguard audits of Qualified
Competitors, see Paragraph IX.T.
h. The TC will have the power to
advise Plaintiffs and the Court
about an appropriate tapering rate
for search syndication, see
Paragraph V.B.4.
i. The TC will have the power to
develop and propose parameters
that inform Google what types of
Search Text Ads auction changes
must be brought to the attention of
Plaintiffs and the Technical
Committee, and receive
disclosures from Google about
Search Text Ads auctions changes,
see Paragraph VI.A.
b. The TC shall have the power
to recommend reasonable data
security standards applicable to
Qualified Competitors, which
shall be approved by the Plaintiffs.
c. The TC will have the power to
recommend reasonable data
security standards applicable to
Qualified Competitors, which will
be submitted to the Court for
review and determination, see
Paragraph IX.T.
b. The TC shall have the power
to recommend reasonable data
security standards applicable to
Qualified Competitors, which
shall be approved by the Plaintiffs.
c. The TC may, on reasonable
notice to Google:
j. The TC may make reasonable
and proportional requests
necessary to perform its duties, on
reasonable notice to Google, to:
c. The TC may, on reasonable
notice to Google:
1. interview, either
informally or on the record,
any Google personnel, who
may have their individual
counsel present; any such
interview will be subject to
the reasonable convenience
of such personnel and
without restraint or
interference by Google;
1. interview any Google
personnel, who may have
counsel present; any such
interview will be subject to
the reasonable convenience
of such personnel and
without restraint or
interference by Google;
i. interview, either
informally or on the record,
any Google personnel, who
may have their individual
counsel present; any such
interview will be subject to
the reasonable convenience
of such personnel and
without restraint or
interference by Google;
2. inspect and copy any
document in the possession,
custody, or control of
Google personnel;
2. provide non-
privileged documents and
records in its possession,
custody, or control;
ii. inspect and copy any
document in the possession,
custody, or control of
Google personnel;
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3. obtain reasonable
access to any system or
equipment to which Google
personnel have access;
3. obtain reasonable
access to systems or
equipment to the extent
necessary to perform testing
regarding appropriate User-
side Data security and
privacy safeguards, see
Paragraph IV.C; and
iii. obtain reasonable
access to any system or
equipment to which Google
personnel have access;
4. obtain reasonable
access to, and inspect, any
physical facility, building or
other premises to which
Google personnel have
access; and
4. obtain reasonable
access to any physical
facilities, building or other
premises to the extent
necessary to perform testing
regarding appropriate User-
side Data security and
privacy safeguards, see
Paragraph IV.C.
iv. obtain reasonable
access to, and inspect, any
physical facility, building, or
other premises to which
Google personnel have
access; and
5. require Google
personnel to provide
documents, data and other
information, and to submit
reports to the TC containing
such material, in such form
as the TC may reasonably
direct.
[No similar provision. v. require Google
personnel to provide
documents, data, and other
information, and to submit
reports to the TC containing
such material, in such form
as the TC may reasonably
direct.
[No similar provision.] 5. To the extent that
Google and the TC cannot
agree on the reasonable
scope of any such request,
the parties may submit such
disagreement to the Court
for resolution.
[No similar provision.]
d. The TC shall have access to
Google’s source code and
algorithms, subject to a
confidentiality agreement, as
approved by the Plaintiffs and to
be agreed to by the TC members
pursuant to Section VII.A.8 below,
and by any staff or consultants
who may have access to the source
code and algorithms. The TC may
study, interrogate and interact with
the source code and algorithms in
order to perform its functions and
duties, including the handling of
complaints and other inquiries
from third parties.
[No similar provision.] d. The TC shall have access to
Google’s source code and
algorithms, subject to a
confidentiality agreement, as
approved by the Plaintiffs and to
be agreed to by the TC members
pursuant to Section VII.A.8 below,
and by any staff or consultants
who may have access to the source
code and algorithms. The TC may
study, interrogate, and interact
with the source code and
algorithms in order to perform its
functions and duties, including the
handling of complaints and other
inquiries from third parties.
e. The TC shall receive
complaints from Google’s
[No similar provision.] e. The TC shall receive
complaints from Google’s
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76
Compliance Officer (as described
in Section VII.B below), third
parties, or the Plaintiffs and handle
them in the manner specified in
Section VII.C below.
Compliance Officer (as described
in Section VII.B below), third
parties, or the Plaintiffs and handle
them in the manner specified in
Section VII.C below.
f. The TC shall report in writing
to the Plaintiffs, initially every
three (3) months for three (3) years
and thereafter every six (6) months
until expiration of this Final
Judgment, the actions it has
undertaken in performing its duties
pursuant to this Final Judgment,
including the identification of each
business practice reviewed and
any recommendations made by the
TC.
k. The TC must report in writing
to the parties, initially every three
(3) months for three (3) years and
thereafter every six (6) months
until expiration of this Final
Judgment, the actions it has
undertaken in performing its duties
pursuant to this Final Judgment.
f. The TC shall report in writing
to the Plaintiffs, initially every
three (3) months for three (3) years
and thereafter every six (6) months
until expiration of this Final
Judgment, the actions it has
undertaken in performing its duties
pursuant to this Final Judgment,
including the identification of each
business practice reviewed and
any recommendations made by the
TC.
g. Regardless of when reports
are due, when the TC has reason to
believe that there may have been a
failure by Google to comply with
any term of this Final Judgment, or
that Google is attempting to
circumvent any provision of this
Final Judgment or the intended
purposes of this Final Judgment,
the TC shall immediately notify
the Plaintiffs in writing setting
forth the relevant details.
[No similar provision.] g. Regardless of when reports
are due, when the TC has reason to
believe that there may have been a
failure by Google to comply with
any term of this Final Judgment, or
that Google is attempting to
circumvent any provision of this
Final Judgment or the intended
purposes of this Final Judgment,
the TC shall immediately notify
the Plaintiffs in writing setting
forth the relevant details.
h. TC members may
communicate with third parties
about how their complaints or
inquiries might be resolved with
Google, so long as the
confidentiality of information
obtained from Google is
maintained.
[No similar provision.] h. TC members may
communicate with third parties
about how their complaints or
inquiries might be resolved with
Google, so long as the
confidentiality of information
obtained from Google is
maintained.
i. The TC may hire at the cost
and expense of Google, with prior
notice to Google and subject to
approval by the Plaintiffs, such
staff or consultants (all of whom
must meet the qualifications of
Sections VII.A.2.a–c) as are
reasonably necessary for the TC to
carry out its duties and
responsibilities under this Final
Judgment. The compensation of
any person retained by the TC
shall be based on reasonable and
l. The TC may hire at the cost
and expense of Google, with prior
notice to Google and subject to
approval by the parties, such staff
or consultants (all of whom must
meet the qualifications of
Paragraphs VII.A.2.a-c) as are
reasonably necessary for the TC to
carry out its duties and
responsibilities under this Final
Judgment. The compensation of
any person retained by the TC will
be based on reasonable and
i. The TC may hire at the cost
and expense of Google, with prior
notice to Google and subject to
approval by the Plaintiffs, such
staff or consultants (all of whom
must meet the qualifications of
Sections VII.A.2.a–c) as are
reasonably necessary for the TC to
carry out its duties and
responsibilities under this Final
Judgment. The compensation of
any person retained by the TC
shall be based on reasonable and
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77
customary terms commensurate
with the individual’s experience
and responsibilities.
customary terms commensurate
with the individual’s experience
and responsibilities, and subject to
approval by the parties. To the
extent that the parties cannot agree
on such a request, the parties will
submit such disagreement to the
Court for resolution.
customary terms commensurate
with the individual’s experience
and responsibilities.
j. The TC shall account for all
reasonable expenses incurred,
including agreed upon fees for the
TC members’ services, subject to
the approval of the Plaintiffs.
Google’s failure to promptly pay
the TC’s accounted-for costs and
expenses, including for agents and
consultants, shall constitute a
violation of this Final Judgment
and may result in sanctions
imposed by the Court. Google
may, on application to the Court,
object to the reasonableness of any
such fees or other expenses only if
Google has conveyed such
objections to the Plaintiffs and the
TC within ten (10) calendar days
of receiving the invoice for such
fees or other expenses. On any
such application, (a) Google shall
bear the burden to demonstrate
unreasonableness; (b) Google
shall establish an escrow account
into which it deposits the disputed
costs and expenses until the
dispute is resolved; and (c) the TC
members shall be entitled to
recover all costs incurred on such
application (including reasonable
attorneys’ fees and costs),
regardless of the Court’s
disposition of such application,
unless the Court expressly finds
that the TC’s opposition to the
application was without
substantial justification.
m. The TC must account for all
reasonable expenses incurred,
including agreed upon fees for the
TC members’ services, subject to
the approval of the parties. To the
extent that the parties cannot agree
on the reasonableness of such
expenses, the parties will submit
such disagreement to the Court for
resolution.
j. The TC shall account for all
reasonable expenses incurred,
including agreed upon fees for the
TC members’ services, subject to
the approval of the Plaintiffs.
Google’s failure to promptly pay
the TC’s accounted-for costs and
expenses, including for agents and
consultants, shall constitute a
violation of this Final Judgment
and may result in sanctions
imposed by the Court. Google
may, on application to the Court,
object to the reasonableness of any
such fees or other expenses only if
Google has conveyed such
objections to the Plaintiffs and the
TC within ten (10) calendar days
of receiving the invoice for such
fees or other expenses. On any
such application, (a) Google shall
bear the burden to demonstrate
unreasonableness; (b) Google
shall establish an escrow account
into which it deposits the disputed
costs and expenses until the
dispute is resolved; and (c) the TC
members shall be entitled to
recover all costs incurred on such
application (including reasonable
attorneys’ fees and costs),
regardless of the Court’s
disposition of such application,
unless the Court expressly finds
that the TC’s opposition to the
application was without
substantial justification.
[No similar provision.] a. For the avoidance of doubt,
neither the TC nor Plaintiffs will
have the right to make final
decisions as to the requirements of
this Final Judgment. Google will
have the right to object to and be
k. Google may object to and be
heard by the Court on any
recommendation from the TC or
Plaintiffs as to the interpretations
or substantive requirements of this
Final Judgment.
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78
heard by the Court on any
recommendation from the TC or
Plaintiffs as to the interpretations
of or substantive requirements of
this Final Judgment.
8. Each TC member, and any
consultants or staff hired by the TC,
shall sign a confidentiality
agreement prohibiting disclosure of
any information obtained in the
course of performing his or her
duties as a member of the TC or as a
person assisting the TC, to anyone
other than another TC member or a
consultant or staff hired by the TC,
Google, the Plaintiffs, or the Court.
All information gathered by the TC
in connection with this Final
Judgment and any report and
recommendations prepared by the
TC shall be treated as Highly
Confidential under the Protective
Order in this case, and shall not be
disclosed to any person other than
another TC member or a consultant
or staff hired by the TC, Google, the
Plaintiffs, and the Court except as
allowed by the Protective Order
entered in the Action or by further
order of this Court. No member of
the TC may make any public
statements relating to the TC’s
activities.
8. Each TC member, and any
consultants or staff hired by the TC,
must sign a confidentiality
agreement prohibiting disclosure of
any information obtained in the
course of performing his or her
duties as a member of the TC or as a
person assisting the TC, to anyone
other than another TC member or a
consultant or staff hired by the TC,
Google, the Plaintiffs, or the Court.
All information gathered by the TC
in connection with this Final
Judgment and any report and
recommendations prepared by the
TC must be treated as Highly
Confidential under the Protective
Order in this case, and must not be
disclosed to any person other than
another TC member or a consultant
or staff hired by the TC, Google, the
Plaintiffs, and the Court except as
allowed by the Protective Order
entered in the Action or by further
order of this Court. No member of
the TC may make any public
statements relating to the TC’s
activities.
8. Each TC member, and any
consultants or staff hired by the TC,
shall sign a confidentiality
agreement prohibiting disclosure of
any information obtained in the
course of performing his or her
duties as a member of the TC or as a
person assisting the TC, to anyone
other than another TC member or a
consultant or staff hired by the TC,
Google, the Plaintiffs, or the Court.
All information gathered by the TC
in connection with this Final
Judgment and any report and
recommendations prepared by the
TC shall be treated as Highly
Confidential under the Protective
Order in this case, and shall not be
disclosed to any person other than
another TC member or a consultant
or staff hired by the TC, Google, the
Plaintiffs, and the Court except as
allowed by the Protective Order
entered in the Action or by further
order of this Court. No member of
the TC may make any public
statements relating to the TC’s
activities.
B. Internal Compliance Officer: C. Internal Compliance Officer: B. Internal Compliance Officer:
1. Google shall designate, within
thirty (30) days of entry of this Final
Judgment, an employee of Google as
the internal Compliance Officer with
responsibility for administering
Google’s antitrust compliance
program and helping to ensure
compliance with this Final
Judgment.
1. Google shall designate, within
30 days of entry of this Final
Judgment, an internal Compliance
Officer who shall be an employee of
Google with responsibility for
administering Google’s antitrust
compliance program and helping to
ensure compliance with this Final
Judgment.
1. Google shall designate, within
thirty (30) days of entry of this Final
Judgment, an employee of Google as
the internal Compliance Officer with
responsibility for administering
Google’s antitrust compliance
program and helping to ensure
compliance with this Final
Judgment.
2. Within seven (7) days of the
Compliance Officer’s appointment,
Google shall identify to the Plaintiffs
the Compliance Officer’s name,
business address, telephone number,
and email address. Within fifteen
(15) days of a vacancy in the
2. Within seven (7) days of the
Compliance Officer’s appointment,
Google must identify to the Plaintiffs
the Compliance Officer’s name,
business address, telephone number,
and email address. Within fifteen
(15) days of a vacancy in the
2. Within seven (7) days of the
Compliance Officer’s appointment,
Google shall identify to the Plaintiffs
the Compliance Officer’s name,
business address, telephone number,
and email address. Within fifteen
(15) days of a vacancy in the
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79
Compliance Officer position,
Google shall appoint a replacement
and identify to the Plaintiffs the
replacement Compliance Officer’s
name, business address, telephone
number, and email address.
Google’s initial or replacement
appointment of the Compliance
Officer is subject to the approval of
the Plaintiffs.
Compliance Officer position,
Google must appoint a replacement
and identify to the Plaintiffs the
replacement Compliance Officer’s
name, business address, telephone
number, and email address.
Compliance Officer position,
Google shall appoint a replacement
and identify to the Plaintiffs the
replacement Compliance Officer’s
name, business address, telephone
number, and email address.
Google’s initial or replacement
appointment of the Compliance
Officer is subject to the approval of
the Plaintiffs.
3. The Compliance Officer shall
supervise the review of Google
activities to ensure that they comply
with this Final Judgment. The
Compliance Officer may be assisted
by other employees of Google.
3. The Compliance Officer shall
supervise the review of Google’s
activities to ensure that they comply
with this Final Judgment. The
Compliance Officer may be assisted
by other employees of Google.
3. The Compliance Officer shall
supervise the review of Google
activities to ensure that they comply
with this Final Judgment. The
Compliance Officer may be assisted
by other employees of Google.
4. The Compliance Officer shall
be responsible for performing the
following activities:
4. The Compliance Officer shall
be responsible for performing the
following activities:
4. The Compliance Officer shall
be responsible for performing the
following activities:
a. within thirty (30) days after
entry of this Final Judgment,
distributing a copy of the Final
Judgment to all officers and
directors of Google;
a. within 45 days after entry of
this Final Judgment, distributing a
copy of the Final Judgment to all
officers and directors of Google;
a. within forty-five (45) days
after entry of this Final Judgment,
distributing a copy of the Final
Judgment to all officers and
directors of Google;
b. distributing a copy of this
Final Judgment to any person who
succeeds to a position described in
Section VII.B.4.a above within
thirty (30) days of the date the
person starts that position.
b. promptly distributing a copy
of this Final Judgment to any
person who succeeds to a position
described in Paragraph VII.C.4.a;
b. promptly distributing a copy
of this Final Judgment to any
person who succeeds to a position
described in Section VII.B.4.a
above;
c. ensuring that those persons
designated by Section VII.B.4.a
above are annually trained on the
meaning and requirements of this
Final Judgment and the U.S.
antitrust laws and advising them
that Google’s legal advisors are
available to confer with them
regarding any question concerning
compliance with this Final
Judgment or the U.S. antitrust
laws;
c. ensuring that those persons
designated in Paragraph VII.C.4.a
are annually briefed on the
meaning and requirements of this
Final Judgment and the U.S.
antitrust laws and advising them
that Google’s legal advisors are
available to confer with them
regarding any question concerning
compliance with this Final
Judgment or the U.S. antitrust law;
c. ensuring that those persons
designated by Section VII.B.4.a
above are annually briefed on the
meaning and requirements of this
Final Judgment and the U.S.
antitrust laws and advising them
that Google’s legal advisors are
available to confer with them
regarding any question concerning
compliance with this Final
Judgment or the U.S. antitrust
laws;
d. obtaining from each person
designated in Section VII.B.4.a
above an annual written
certification that he or she: (i) has
read and agrees to abide by the
terms of this Final Judgment; and
(ii) has been advised and
understands that his or her failure
d. obtaining from each person
designated in Paragraph VII.C.4.a
an annual written certification that
he or she: (i) has read and agrees to
abide by the terms of this Final
Judgment; and (ii) has been
advised and understands that his or
her failure to comply with this
d. obtaining from each person
designated in Section VII.B.4.a
above an annual written
certification that he or she: (i) has
read and agrees to abide by the
terms of this Final Judgment and
(ii) has been advised and
understands that his or her failure
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80
to comply with this Final
Judgment may result in a finding
of contempt of court;
Final Judgment may result in a
finding of contempt of court;
to comply with this Final
Judgment may result in a finding
of contempt of court;
e. maintaining a record of all
persons to whom a copy of this
Final Judgment has been
distributed and from whom the
certification described in Section
VII.B.4.d above has been
obtained;
e. maintaining a record of all
persons to whom a copy of this
Final Judgment has been
distributed and from whom the
certification described in
Paragraph VII.C.4.d has been
obtained;
e. maintaining a record of all
persons to whom a copy of this
Final Judgment has been
distributed and from whom the
certification described in Section
VII.B.4.d above has been
obtained;
f. annually communicating to all
employees that they may disclose
to the Compliance Officer, without
reprisal for such disclosure,
information concerning any
violation or potential violation of
this Final Judgment or the U.S.
antitrust laws by Google, and
establishing a confidential avenue
for any employee to report
potential violations.
[No similar provision.] [No similar provision.]
g. establishing and maintaining
the website provided for in Section
VII.C.2.a below;
f. establishing and maintaining
the website provided for in
Paragraph VII.D.2.b;
f. establishing and maintaining
the website provided for in Section
VII.C.2.a below;
[No similar provision.] g. preparing the Annual
Compliance Report described in
Paragraph VII.B.2 and any Interim
Report requested as described in
Paragraph VII.B.3.a;
[No similar provision.]
h. receiving complaints from
third parties, the TC, and the
Plaintiffs concerning Google’s
compliance with this Final
Judgment and following the
appropriate procedures set forth in
Section VII.C below;
h. receiving complaints from
third parties or the Plaintiffs
concerning Google’s compliance
with this Final Judgment and
following the appropriate
procedures set forth in Paragraph
VII.D;
g. receiving complaints from
third parties, the TC, and the
Plaintiffs concerning Google’s
compliance with this Final
Judgment and following the
appropriate procedures set forth in
Section VII.C below;
i. maintaining a record of all
complaints received and action
taken by Google with respect to
each such complaint; and
i. maintaining a record of all
complaints received and action
taken by Google with respect to
each such complaint; and
h. maintaining a record of all
complaints received and action
taken by Google with respect to
each such complaint; and
j. ensuring Google retains all
relevant documents and
electronically stored information,
regardless of medium or form,
related to this Final Judgment and
all complaints received and or
action taken by Google with
respect to any complaint.
j. ensuring employees retain all
relevant documents and
electronically stored information,
regardless of medium or form,
regarding all complaints received
pursuant to Paragraph VII.D.1 and
action taken by Google with
respect to any such complaint.
i. ensuring Google retains all
relevant documents and
electronically stored information,
regardless of medium or form,
related to this Final Judgment and
all complaints received and/or
action taken by Google with
respect to any complaint.
5. Google shall within thirty (30)
days further appoint a senior
[No similar provision.] 5. Google shall within thirty (30)
days further appoint a senior
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81
business executive, who has
visibility into any Google entity with
obligations under this Final
Judgment, whom Google shall make
available to update the Court on
Google’s compliance at regular
status conferences or as otherwise
ordered.
business executive, who has
visibility into any Google entity with
obligations under this Final
Judgment, whom Google shall make
available to update the Court on
Google’s compliance at regular
status conferences or as otherwise
ordered.
6. Google shall retain (if it has
not already) a licensed attorney in
good standing in California to collect
documents and interview employees
and generally review Google’s
document retention practices and
Google’s compliance with its legal
discovery obligations under this case
and final judgment. This attorney
shall be retained for a term no shorter
than eighteen (18) months. This
attorney (and any team this attorney
assembles) shall present to the Audit
and Compliance Committee (or any
successor Board Committee) on the
retention of documents and Google’s
compliance with its discovery
obligations.
[No similar provision.] [No similar provision.]
C. Voluntary Dispute Resolution: D. Voluntary Dispute Resolution: C. Voluntary Dispute Resolution:
1. Third parties may submit
complaints concerning Google’s
compliance with this Final Judgment
to the Plaintiffs, the TC, or the
Compliance Officer.
1. Third parties may submit
complaints concerning Google’s
compliance with this Final Judgment
to the Plaintiffs or the Compliance
Officer.
1. Third parties may submit
complaints concerning Google’s
compliance with this Final Judgment
to the Plaintiffs, the TC, or the
Compliance Officer.
2. Third parties, the TC, or
Plaintiffs in their discretion may
submit to the Compliance Officer
any complaints concerning Google’s
compliance with this Final
Judgment. Without in any way
limiting their authority to take any
other action to enforce this Final
Judgment, the Plaintiffs may submit
complaints to the Compliance
Officer whenever doing so would be
consistent with the public interest.
2. Submissions to the
Compliance Officer.
2. Third parties, the TC, or
Plaintiffs in their discretion may
submit to the Compliance Officer
any complaints concerning Google’s
compliance with this Final
Judgment. Without in any way
limiting their authority to take any
other action to enforce this Final
Judgment, the Plaintiffs may submit
complaints to the Compliance
Officer whenever doing so would be
consistent with the public interest.
a. Third parties or Plaintiffs in
their discretion may submit to the
Compliance Officer any
complaints concerning Google’s
compliance with this Final
Judgment. Without in any way
limiting their authority to take any
other action to enforce this Final
Judgment, the Plaintiffs may
submit complaints related to
Google’s compliance with this
Final Judgment to the Compliance
Officer whenever doing so would
be consistent with the public
interest.
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a. To facilitate the
communication of complaints and
inquiries by parties, the
Compliance Officer shall place on
Google’s website, in a manner
acceptable to the Plaintiffs, the
procedures for submitting
complaints. To encourage
whenever possible the informal
resolution of complaints and
inquiries, the website shall provide
a mechanism for communicating
complaints and inquiries to the
Compliance Officer.
b. To facilitate the
communication of complaints and
inquiries by parties, the
Compliance Officer shall place on
Google’s corporate website, in a
manner reasonably acceptable to
the Plaintiffs, the procedures for
submitting complaints. To
encourage whenever possible the
informal resolution of complaints
and inquiries, the website must
provide a mechanism for
communicating complaints and
inquiries to the Compliance
Officer.
a. To facilitate the
communication of complaints and
inquiries by parties, the
Compliance Officer shall place on
Google’s website, in a manner
acceptable to the Plaintiffs, the
procedures for submitting
complaints. To encourage
whenever possible the informal
resolution of complaints and
inquiries, the website shall provide
a mechanism for communicating
complaints and inquiries to the
Compliance Officer.
b. Google has thirty (30) days
after receiving a complaint to
attempt to resolve or to reject it.
c. Google shall have 30 days
after receiving a complaint to
attempt to resolve or to reject it.
b. Google has thirty (30) days
after receiving a complaint to
attempt to resolve or to reject it.
c. Within thirty (30) days of
receiving a complaint, the
Compliance Officer shall advise
the TC and Plaintiffs of the nature
of the complaint and its
disposition. The TC may then
propose to the Plaintiffs further
actions consistent with this Final
Judgment, including consulting
with Plaintiffs regarding the
complaint.
[No similar provision.] c. Within thirty (30) days of
receiving a complaint, the
Compliance Officer shall advise
the TC and Plaintiffs of the nature
of the complaint and its
disposition. The TC may then
propose to the Plaintiffs further
actions consistent with this Final
Judgment, including consulting
with Plaintiffs regarding the
complaint.
3. The Compliance Officer, third
parties, or the Plaintiffs in their
discretion may submit to the TC any
complaints concerning Google’s
compliance with this Final
Judgment.
[No similar provisions.] 3. The Compliance Officer, third
parties, or the Plaintiffs in their
discretion may submit to the TC any
complaints concerning Google’s
compliance with this Final
Judgment.
a. The TC shall investigate the
complaints it receives and shall
consult with the Plaintiffs
regarding its investigation. At
least once during its investigation,
and more often when it may help
resolve the complaints informally,
the TC shall meet with the
Compliance Officer to allow
Google to respond to the substance
of the complaints and to determine
whether the complaints can be
resolved without further
proceedings.
a. The TC shall investigate the
complaints it receives and shall
consult with the Plaintiffs
regarding its investigation. At
least once during its investigation,
and more often when it may help
resolve the complaints informally,
the TC shall meet with the
Compliance Officer to allow
Google to respond to the substance
of the complaints and to determine
whether the complaints can be
resolved without further
proceedings.
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b. Following its investigation,
the TC shall advise Google and the
Plaintiffs of its conclusion and its
proposal for cure.
b. Following its investigation,
the TC shall advise Google and the
Plaintiffs of its conclusion and its
proposal for cure.
c. Reports and recommendations
from the TC may be received into
evidence by the Court in
connection with any effort by any
Plaintiff to enforce this Final
Judgment but shall not be
otherwise made available in any
other court or tribunal related to
any other matter. No member of
the TC shall be required to testify
by deposition, in court, or before
any other tribunal regarding any
matter related to this Final
Judgment.
c. Reports and recommendations
from the TC may be received into
evidence by the Court in
connection with any effort by any
Plaintiff to enforce this Final
Judgment but shall not be
otherwise made available in any
other court or tribunal related to
any other matter. No member of
the TC shall be required to testify
by deposition, in court, or before
any other tribunal regarding any
matter related to this Final
Judgment.
d. The TC may preserve the
anonymity of any third-party
complainant where it deems it
appropriate to do so upon the
request of the Plaintiffs or the third
party, or in its discretion.
d. The TC may preserve the
anonymity of any third-party
complainant where it deems it
appropriate to do so upon the
request of the Plaintiffs or the third
party, or in its discretion.
D. Compliance Inspection: B. Annual Compliance Report
and Compliance Inspection:
D. Compliance Inspection:
1. Without in any way limiting
the sovereign enforcement authority
of each of the Colorado Plaintiff
States, the Colorado Plaintiff States
shall form a committee to coordinate
their enforcement of this Final
Judgment. Neither a Co-Plaintiff
State nor a Colorado Plaintiff State
may take any action to enforce this
Final Judgment without first
consulting with the United States
and with the Colorado Plaintiff
States’ enforcement committee.
1. Without limiting the sovereign
enforcement authority of each of the
Plaintiff States, the Plaintiff States
will form a committee to coordinate
their enforcement of this Final
Judgment (“Plaintiff States’
Committee”). No Plaintiff State
shall take any action to enforce this
Final Judgment without first
consulting with the United States
and with the Plaintiff States’
Committee.
1. Without in any way limiting
the sovereign enforcement authority
of each of the Colorado Plaintiff
States, the Colorado Plaintiff States
shall form a committee to coordinate
their enforcement of this Final
Judgment. Neither a Co-Plaintiff
State nor a Colorado Plaintiff State
may take any action to enforce this
Final Judgment without first
consulting with the United States
and with the Colorado Plaintiff
States’ enforcement committee.
[No similar provision.] 2. Google will prepare and
submit, on an annual basis, a written
report describing its compliance with
this Final Judgment (“Annual
Compliance Report”).
[No similar provision.]
2. For the purposes of
determining or securing compliance
with this Final Judgment or of
determining whether this Final
Judgment should be modified or
vacated, upon written request of an
3. To determine and enforce
compliance with this Final
Judgment, upon written request and
on reasonable notice to Google and
subject to any lawful privilege, a
duly authorized representative of the
2. For the purposes of
determining or securing compliance
with this Final Judgment or of
determining whether this Final
Judgment should be modified or
vacated, upon written request of an
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84
authorized representative of the
Assistant Attorney General for the
Antitrust Division (after consultation
with the Co-Plaintiff States and the
Colorado Plaintiff States’
enforcement committee) or of the
Attorney General of a Co-Plaintiff
State or the Attorney General of a
Colorado Plaintiff State (after
consultation with the United States
and the Colorado Plaintiff States’
enforcement committee), as the case
may be, and reasonable notice to
Google, Google shall permit, from
time to time and subject to legally
recognized privileges, authorized
representatives, including agents
retained by any Plaintiff:
United States (after consultation
with the Plaintiff States’ Committee)
or of the Attorney General of a
Plaintiff State (after consultation
with the United States and the
Plaintiff States’ Committee), may:
authorized representative of the
Assistant Attorney General for the
Antitrust Division (after consultation
with the Co-Plaintiff States and the
Colorado Plaintiff States’
enforcement committee) or of the
Attorney General of a Co-Plaintiff
State or the Attorney General of a
Colorado Plaintiff State (after
consultation with the United States
and the Colorado Plaintiff States’
enforcement committee), as the case
may be, and reasonable notice to
Google, Google shall permit, from
time to time and subject to legally
recognized privileges, authorized
representatives, including agents
retained by any Plaintiff:
[No similar provision.] a. request from Google no more
than one interim written report per
year (“Interim Report”), under
oath if requested, regarding
Google’s compliance with this
Final Judgment;
[No similar provision.]
a. to have access during
Google’s office hours to inspect
and copy, or at the option of the
Plaintiff, to require Google to
provide electronic copies of all
books, ledgers, accounts, records,
data, and documents in the
possession, custody, or control of
Google relating to any matters
contained in this Final Judgment;
and
b. make reasonable requests to
Google for production of non-
privileged documents and records
in its possession, custody, or
control sufficient to verify the
matters contained in Google’s
Annual Compliance Report or
Interim Report; and
a. to have access during
Google’s office hours to inspect
and copy, or at the option of the
Plaintiff, to require Google to
provide electronic copies of all
books, ledgers, accounts, records,
data, and documents in the
possession, custody, or control of
Google relating to any matters
contained in this Final Judgment;
and
b. to interview, either informally
or on the record, Google’s officers,
employees, or agents, who may
have their individual counsel
present, relating to any matters
contained in this Final Judgment.
The interviews shall be subject to
the reasonable convenience of the
interviewee and without restraint
or interference by Google.
c. subject to the reasonable
convenience of Google and
without restraint or interference
from it, interview officers,
employees, or agents of Google,
who may have counsel present,
sufficient to verify the matters
contained in Google’s Annual
Compliance Report or Interim
Report.
b. to interview, either informally
or on the record, Google’s officers,
employees, or agents, who may
have their individual counsel
present, relating to any matters
contained in this Final Judgment.
The interviews shall be subject to
the reasonable convenience of the
interviewee and without restraint
or interference by Google.
3. Upon the written request of an
authorized representative of the
Assistant Attorney General for the
Antitrust Division (after consultation
with the Co-Plaintiff States and the
[No similar provision.] 3. Upon the written request of an
authorized representative of the
Assistant Attorney General for the
Antitrust Division (after consultation
with the Co-Plaintiff States and the
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85
Colorado Plaintiff States’
enforcement committee) or of the
Attorney General of a Co-Plaintiff
State or the Attorney General of a
Colorado Plaintiff State (after
consultation with the United States
and the Co-Plaintiff States’
enforcement committee), Google
shall submit written reports or
respond to written interrogatories,
under oath if requested, relating to
any matters contained in this Final
Judgment.
Colorado Plaintiff States’
enforcement committee) or of the
Attorney General of a Co-Plaintiff
State or the Attorney General of a
Colorado Plaintiff State (after
consultation with the United States
and the Colorado Plaintiff States’
enforcement committee), Google
shall submit written reports or
respond to written interrogatories,
under oath if requested, relating to
any matters contained in this Final
Judgment.
[No similar provision.] 4. No information or documents
obtained by the means provided in
this section shall be divulged by the
United States or the Plaintiff States
to any person, except in the course of
legal proceedings to which the
United States is a party, or for the
purpose of securing compliance with
this Final Judgment, or as otherwise
required by law.
[No similar provision.]
[No similar provision.] 5. If, at the time information or
documents are furnished by Google
to the United States or the Plaintiff
States, Google identifies in writing
the material in any such information
or documents to which a claim of
protection may be asserted under
Rule 26(c)(1)(G) of the Federal
Rules of Civil Procedure, and
Google marks each pertinent page of
such material, “Confidential and
Sensitive Commercial Information
Subject to Rule 26(c)(1)(G)” then
the United States shall give 10
business days’ notice prior to
divulging such material in any legal
proceeding.
4. If, at the time information or
documents are furnished by Google
to the Plaintiffs, Google identifies in
writing the material in any such
information or documents to which a
claim of protection may be asserted
under Rule 26(c)(1)(G) of the
Federal Rules of Civil Procedure,
and Google marks each pertinent
page of such material, “Confidential
and Sensitive Commercial
Information Subject to Rule
26(c)(1)(G),” then the Plaintiffs shall
give five (5) business days’ notice
prior to divulging such material in
any legal proceeding, unless good
cause is shown for a shorter notice
period.
[No similar provision.] 6. Google shall have the right to
claim protection from public
disclosure, under the Freedom of
Information Act, 5 U.S.C. § 552, or
any other applicable law or
regulation, for any material it
submits to the United States or the
Plaintiff States under this Final
Judgment. After appropriate
consideration of such claim of
5. Google shall have the right to
claim protection from public
disclosure, under the Freedom of
Information Act, 5 U.S.C. § 552, or
any other applicable law or
regulation, for any material it
submits to the Plaintiffs under this
Final Judgment. After appropriate
consideration of such claim of
protection, Plaintiffs, as the case may
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86
protection, the United States or the
Plaintiff States, as the case may be,
will either assert that the material is
protected from disclosure under law
or give Google 10 business days’
notice of its intent to disclose the
material.
be, will either assert that the material
is protected from disclosure under
law or give Google ten (10) business
days’ notice of its intent to disclose
the material.
[No similar provision.] [No similar provision.] E. Status Reports to the Court:
1. Plaintiffs, with input from the
Technical Committee, shall file a
status report within ninety (90) days
of the Effective Date of this Final
Judgment, and then on future dates
as set by the Court, updating the
Court as to the enforcement of and
Google’s compliance with this Final
Judgment.
VIII. EFFECTIVE DATE AND EXPIRATION
Plaintiffs’ Proposal Google’s Proposal Final Judgment
The Final Judgment will take effect
sixty (60) days after the date on which
it is entered (the “Effective Date”), and
Plaintiffs shall report the date on
which Google has substantially
implemented all provisions of this
Final Judgment, except for Section
VII.A, which shall take effect
immediately upon entry. Unless the
Court grants an extension or early
termination is granted, this Final
Judgment will expire six (6) years
from the Effective Date. This Final
Judgment may be terminated upon
notice by the United States (after
consultation with the Co-Plaintiff
States), the Colorado Plaintiff States’
enforcement committee, and Google
that continuation of this Final
Judgment is no longer necessary to
restore competition in the
monopolized markets.
A. Subject to the outcome of any
motion to stay this Final Judgment
pending appeal, this Final Judgment
shall take effect 60 days after the date
on which it is entered, except that the
portions of Section VII.A that require
the parties to take steps toward
forming the Technical Committee and
that address the start of its work shall
take effect immediately.
The Final Judgment will take effect
sixty (60) days after the date on which
it is entered (the “Effective Date”), and
Plaintiffs shall report the date on
which Google has substantially
implemented all provisions of this
Final Judgment, except for Section
VII.A, which shall take effect
immediately upon entry. Unless the
Court grants an extension or early
termination is granted, this Final
Judgment will expire six (6) years
from the Effective Date. This Final
Judgment may be terminated upon
notice by the United States (after
consultation with the Co-Plaintiff
States), the Colorado Plaintiff States’
enforcement committee, and Google
that continuation of this Final
Judgment is no longer necessary to
restore competition in the
monopolized markets.
B. Pursuant to Local Rule 54.2,
the deadline for any motion under
Federal Rule of Civil Procedure
54(d)(2)(B) and the proceedings as to
any such motion shall be held in
abeyance pending the conclusion of
any appeals from this Final Judgment.
C. Unless this Court grants an
extension, this Final Judgment will
expire on the sixth anniversary of the
date on which it takes effect.
IX. DEFINITIONS
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. “API” or “application
programming interface” means a
mechanism that allows different
A. “API” or “application
programming interface” means a
mechanism that allows different
A. “API” or “application
programming interface” means a
mechanism that allows different
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87
software components to communicate
with each other.
software components to communicate
with each other.
software components to communicate
with each other.
B. “Apple” means Apple, Inc., a
corporation organized and existing
under the laws of the State of
California, headquartered in
Cupertino, California, its successors
and assigns, and its subsidiaries,
divisions, groups, affiliates,
partnerships, and joint ventures, and
their directors, officers, managers,
agents, and employees.
[No similar provision.] B. “Apple” means Apple Inc., a
corporation organized and existing
under the laws of the State of
California, headquartered in
Cupertino, California, its successors
and assigns, and its subsidiaries,
divisions, groups, affiliates,
partnerships, and joint ventures, and
their directors, officers, managers,
agents, and employees.
C. “Browser Developer” means a
developer, owner, or operator of a
Third-Party Browser and includes, by
way of example, Apple, Mozilla Corp.,
and Samsung Electronics Co., Ltd.
B. “Browser Developer” means a
developer, owner, or operator of a
Third-Party Browser and includes, by
way of example, Apple, Mozilla Corp.,
and Samsung Electronics Co., Ltd.
C. “Browser Developer” means a
developer, owner, or operator of a
Third-Party Browser and includes, by
way of example, Apple, Mozilla Corp.,
and Samsung Electronics Co., Ltd.
D. “Chrome Browser
Application” means the browser
software application currently
marketed by Google as “Google
Chrome” and its successors.
C. “Chrome Browser
Application” means the browser
software application currently
marketed by Google as “Google
Chrome” and its successors.
D. “Chrome Browser
Application” means the browser
software application currently
marketed by Google as “Google
Chrome” and its successors.
E. “Competitor” means any
provider of, or potential entrant in the
provision of (i) a General Search
Engine (GSE) in the United States,
(ii) Search Text Ads in the United
States, or (iii) a GenAI Product in the
United States.
D. “Competitor” means any
provider of, or potential entrant in the
provision of (i) a General Search
Engine (GSE) in the United States,
(ii) Search Text Ads in the United
States or (iii) a Third-Party GenAI
Product in the United States. For the
avoidance of doubt, “Competitor” does
not include specialized vertical search
providers, whether or not they offer a
GenAI product.
E. “Competitor” means any
provider of or potential entrant in the
provision of (i) a General Search
Engine (GSE) in the United States,
(ii) Search Text Ads in the United
States, or (iii) a GenAI Product in the
United States.
F. “Consideration” means
anything of value, including monetary
payment; provision of preferential
licensing terms; technical, marketing,
and sales support; developer support;
or hardware or software certification or
approval.
E. “Consideration” means any
monetary payment; provision of
preferential licensing terms; technical,
marketing, and sales support;
developer support; or hardware or
software certification or approval.
F. “Consideration” means
anything of value, including any
monetary payment; provision of
preferential licensing terms; technical,
marketing, and sales support;
developer support; or hardware or
software certification or approval.
G. “Default Search Engine”
means a search engine that is set by a
Browser Developer to respond to user
queries if a user takes no action to
select a particular search engine.
G. “Default Search Engine”
means a search engine that is set by a
Browser Developer to respond to user
queries if a user takes no action to
select a particular search engine.
G. “Default Search Engine”
means a search engine that is set by a
Browser Developer to respond to user
queries if a user takes no action to
select a particular search engine.
H. “Device” or “device” means
any single smartphone, tablet, laptop,
or desktop. For clarity, any two
devices are different devices, even if
they are the same make and model
F. “Covered Device” means a
smartphone, tablet, laptop, or desktop,
excluding any device on which the
ChromeOS operating system or a
H. “Device” or “device” means
any single smartphone, tablet, laptop,
or desktop, excluding any device on
which the ChromeOS operating
system or a successor to the
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(e.g., two Samsung Galaxy S25s are
two devices; two Apple iPhone 16 Pros
are two devices).
successor to the ChromeOS operating
system is installed.
ChromeOS operating system is
installed. For clarity, any two devices
are different devices, even if they are
the same make and model (e.g., two
Samsung Galaxy S25s are two devices;
two Apple iPhone 16 Pros are two
devices).
I. “GenAI” or “Generative AI”
is a type of artificial intelligence that
creates new content including but not
limited to text, images, code,
classifications, and other media using
machine learning models.
H. “GenAI” or “Generative AI”
is a type of artificial intelligence that
creates new content including but not
limited to text, images, code,
classifications, and other media using
machine learning models.
I. “GenAI” or “Generative AI”
is a type of artificial intelligence that
creates new content including but not
limited to text, images, code,
classifications, and other media using
machine learning models.
J. “GenAI Product” means any
application, software, service, feature,
tool, functionality, or product that
involves or makes use of Generative
AI capabilities or models. It can
include GenAI Search Access Points.
[No similar provision.] J. “GenAI Product” means any
application, software, service, feature,
tool, functionality, or product that
involves or makes use of Generative
AI capabilities or models and has
among its principal functions
answering information-seeking
prompts across a wide variety of topics
using a broad range of publicly
available information.
K. “General Search Engine” or
“GSE” means software or a service
that produces links to websites and
other relevant information in response
to a user query or prompt.
I. “General Search Engine” or
“GSE” means software or a service
that produces links to websites and
other relevant information in response
to a user query or prompt, and that
attempts to answer all queries (rather
than only regarding particular topics).
“General Search Engine” or “GSE”
also has the meaning defined and used
in the Court’s Memorandum Opinion
of August 5, 2024, ECF 1032.
K. “General Search Engine” or
“GSE” means software or a service
that produces links to websites and
other relevant information in response
to a user query or prompt and that
seeks to fulfill a broad array of
informational needs.
L. “Google” means
(1) Defendant Google LLC, a limited
liability company organized and
existing under the laws of the State of
Delaware, headquartered in Mountain
View, California; (2) its successors and
assigns, subsidiaries, divisions,
groups, affiliates, partnerships, and
joint ventures controlling or
overseeing Google Search (including
syndicated products), Search Text Ads
(including syndicated products) the
Chrome Browser Application, the
Google Search Application, the
Google Assistant Application, and any
related Google GenAI Product; and
J. “Google” means Defendant
Google LLC, a limited liability
company organized and existing under
the laws of the State of Delaware,
headquartered in Mountain View,
California; (2) its successors and
assigns, subsidiaries, divisions, and
groups controlling or overseeing
Google Search (including syndicated
products), Search Text Ads (including
syndicated products), the Chrome
Browser Application, the Google
Search Application, the Google
Assistant Application, and any Google
GenAI Assistant Application; and
(3) the directors, officers, managers,
L. “Google” means
(1) Defendant Google LLC, a limited
liability company organized and
existing under the laws of the State of
Delaware, headquartered in Mountain
View, California; (2) its successors and
assigns, subsidiaries, divisions,
groups, affiliates, partnerships, and
joint ventures controlling or
overseeing Google Search (including
syndicated products), Search Text Ads
(including syndicated products), the
Chrome Browser Application, the
Google Search Application, the
Google Assistant Application, and any
related Google GenAI Product; and
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89
(3) the directors, officers, managers,
agents, and employees of such entities
specified in this Section IX.L who
oversee Google Search (including
syndicated products), Search Text Ads
(including syndicated products) the
Chrome Browser Application, the
Google Search Application, the
Google Assistant Application, and any
related Google GenAI Product.
agents, and employees of such entities
specified in this Paragraph IX.J who
oversee Google Search (including
syndicated products), Search Text Ads
(including syndicated products), the
Chrome Browser Application, the
Google Search Application, the
Google Assistant Application, and any
Google GenAI Assistant Application.
(3) the directors, officers, managers,
agents, and employees of such entities
specified in this Section IX.L who
oversee Google Search (including
syndicated products), Search Text Ads
(including syndicated products), the
Chrome Browser Application, the
Google Search Application, the
Google Assistant Application, and any
related Google GenAI Product. For
clarity, the term “affiliates” includes
any Alphabet Inc.–related entity that
controls or oversees the
aforementioned products.
M. “Google Assistant
Application” means (1) the user-facing
mobile assistive service software
application marketed by Google as
“Google Assistant” and its successors
and (2) any Google GenAI Product.
K. “Google Assistant
Application” means the user-facing
mobile assistive service software
application marketed by Google as
“Google Assistant” and its successors.
M. “Google Assistant
Application” means the user-facing
mobile assistive service software
application marketed by Google as
“Google Assistant” and its successors.
N. “Google GenAI Product”
means any GenAI Product offered by
Google including by way of example,
the stand-alone user-facing mobile
software application currently
marketed by Google as the “Google
Gemini” application (and that
application’s functionally equivalent
successors).
L. “Google GenAI Assistant
Application” means the stand-alone
user-facing mobile software
application currently marketed by
Google as the “Google Gemini”
application (and that application’s
functionally equivalent successors)
and any future user-facing software
application owned by Google or its
affiliates that makes use of generative
AI capabilities or models and has
among its principal functions
answering information-seeking
prompts across a wide variety or topics
using a broad range of publicly
available information, provided,
however, that this term shall not
include Google Search, the Google
Search Application, the Chrome
Browser Application, or the Google
Assistant Application.
N. “Google GenAI Product”
means any GenAI Product offered by
Google, including by way of example,
the stand-alone user-facing mobile
software application currently
marketed by Google as the “Google
Gemini” application (and that
application’s functionally equivalent
successors).
O. “Google Play” means the
user-facing mobile software
application distribution service
currently marketed by Google as the
“Play Store” and its successors.
M. “Google Play” means the
user-facing mobile software
application distribution service
currently marketed by Google as the
“Play Store” and its successors.
O. “Google Play” means the
user-facing mobile software
application distribution service
currently marketed by Google as the
“Play Store” and its successors.
P. “Google Search” means the
web search and search advertising
services offered by Google at
Google.com.
N. “Google Search” means the
web search and search advertising
services offered by Google at
Google.com.
P. “Google Search” means the
web search and search advertising
services offered by Google at
Google.com.
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Q. “Google Search Application”
means the user-facing mobile online
search software application currently
marketed by Google as the “Google
app” or the “Google Search app” (and
its successors).
O. “Google Search Application”
means the user-facing mobile online
search software application currently
marketed by Google as the “Google
app” or the “Google Search app” (and
its successors).
Q. “Google Search Application”
means the user-facing mobile online
search software application currently
marketed by Google as the “Google
app” or the “Google Search app” (and
its successors).
R. The terms “include” and
“including” should be read as
“including but not limited to,” and any
use of either word is not limited in any
way to any examples provided.
[No similar provision.] R. The terms “include” and
“including” should be read as
“including but not limited to,” and any
use of either word is not limited in any
way to any examples provided.
S. “Marginal Cost” or “marginal
cost” means the direct total production
cost of producing an additional unit of
a good or service, which is determined
by calculating the change in direct total
production cost resulting from Google
providing the additional unit(s) of data
or services required under this Final
Judgment.
P. “Marginal Cost” means the
direct total production cost of
producing an additional unit of a good
or service, as determined by
calculating the change in direct total
production cost resulting from
providing the additional unit(s) of data
or services.
S. “Marginal Cost” or “marginal
cost” means the direct total production
cost of producing an additional unit of
a good or service, which is determined
by calculating the change in direct total
production cost resulting from Google
providing the additional unit(s) of data
or services required under this Final
Judgment.
T. “Operating System Version”
means a particular desktop or mobile
operating system including, by way of
example, Microsoft Windows, Apple
iOS, Apple Mac OS, Apple iPad OS, or
Android.
Q. “Operating System Version”
means a web browser version or a
version of any proprietary Apple
feature or functionality, including Siri
and Spotlight, designed to be installed
and used on a particular desktop or
mobile operating system including, by
way of example, Microsoft Windows,
Apple iOS, Apple Mac OS, Apple iPad
OS, or Android.
T. “Operating System Version”
means a web browser version or a
version of any proprietary Apple
feature or functionality, including Siri
and Spotlight, designed to be installed
and used on a particular desktop or
mobile operating system including, by
way of example, Microsoft Windows,
Apple iOS, Apple Mac OS, Apple iPad
OS, or Android.
U. “Person” or “person” means
any natural person, corporate entity,
partnership, association, joint venture,
government entity, or trust.
[No similar provision.] [No similar provision.]
[No similar provision.] R. “Plaintiff States” means the
States and Commonwealths of
Arkansas, California, Georgia, Florida,
Indiana, Kentucky, Louisiana,
Michigan, Missouri, Mississippi,
Montana, South Carolina, Texas, and
Wisconsin, Colorado, Nebraska,
Arizona, Iowa, New York, North
Carolina, Tennessee, Utah, Alaska,
Connecticut, Delaware, District of
Columbia, Guam, Hawaii, Idaho,
Illinois, Kansas, Maine, Maryland,
Massachusetts, Minnesota, Nevada,
New Hampshire, New Jersey, New
Mexico, North Dakota, Ohio,
Oklahoma, Oregon, Pennsylvania,
[No similar provision.]
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Puerto Rico, Rhode Island, South
Dakota, Vermont, Virginia,
Washington, West Virginia, and
Wyoming.
V. “Privacy Mode” means a
mode within a web browser or an
Apple product or service such as Siri
or Spotlight that is designed to offer a
preconfigured privacy setting and
includes, by way of example, Private
Browsing in Apple Safari, Private
mode in Mozilla Firefox, and Secret
mode in Samsung Internet.
S. “Privacy Mode” means a
mode within a web browser that is
designed to offer a preconfigured
privacy setting and includes, by way of
example, Private Browsing in Apple
Safari, Private mode in Mozilla
Firefox, and Secret mode in Samsung
Internet.
U. “Privacy Mode” means a
mode within a web browser or an
Apple product or service such as Siri or
Spotlight that is designed to offer a
preconfigured privacy setting and
includes, by way of example, Private
Browsing in Apple Safari, Private
mode in Mozilla Firefox, and Secret
mode in Samsung Internet.
W. “Qualified Competitor”
means a Competitor who meets the
Plaintiffs’ approved data security
standards as recommended by the
Technical Committee and agrees to
regular data security and privacy audits
by the Technical Committee, who
makes a sufficient showing to the
Plaintiffs, in consultation with the
Technical Committee, of a plan to
invest and compete in or with the GSE
and/or Search Text Ads markets, and
who does not pose a risk to the national
security of the United States.
T. “Qualified Competitor”
means a Competitor who applies to be
so designated and: (i) meets the data
security standards as determined by the
Court in consultation with the
Technical Committee; (ii) agrees to
and satisfactorily passes regular data
security and privacy audits by the
Technical Committee; (iii) does not
pose a risk to the national security of
the United States, as determined by the
Court; and (iv) makes a sufficient
showing of a plan to invest and
compete with General Search Engines
and/or Search Text Ads providers, as
determined by the Court in
consultation with the Technical
Committee. To remain eligible as a
Qualified Competitor, the Competitor
must apply for re-certification on an
annual basis and establish that it
continues to meet the criteria set forth
in (i) – (iv). To continue to be in
compliance with (iv) for purposes of
re-certification, the Qualified
Competitor must show that it is making
sufficient efforts to invest and compete
with General Search Engines and/or
Search Text Ads providers. Google
will have the right to object to and be
heard by the Court on the qualification
of, and continuing eligibility of, any
proposed Qualified Competitor,
including on the basis of
noncompliance with data security,
privacy, or contractual access or use
restrictions.
V. “Qualified Competitor”
means a Competitor who meets the
Plaintiffs’ approved data security
standards as recommended by the
Technical Committee and agrees to
regular data security and privacy audits
by the Technical Committee; who
makes a sufficient showing to the
Plaintiffs, in consultation with the
Technical Committee, of a plan to
invest and compete in or with the GSE
and/or Search Text Ads markets; and
who does not pose a risk to the national
security of the United States. To
remain eligible as a Qualified
Competitor, the Competitor must apply
for re-certification on an annual basis
starting from the date of original
certification as a Qualified Competitor
and establish that it continues to meet
the definition of a Qualified
Competitor. The Technical Committee
shall establish appropriate procedures
for the re-certification process.
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X. “Search Access Point” means
any software, application, interface,
digital product, or service where a user
can enter a query or prompt and, in
response to at least some user queries
or prompts, receive (or be directed to a
place to receive) a response that
includes information from a GSE,
including links to websites. Search
Access Points include OS-level Search
Access Points, browsers (including
Search Access Points within browsers
such as browser address bars), search
apps, and GenAI Products that can
retrieve and display information from
a GSE, including links to websites.
[No similar provision.] W. “Search Access Point” means
any software, application, interface,
digital product, or service where a user
can enter a query or prompt and, in
response to at least some user queries
or prompts, receive (or be directed to a
place to receive) a response that
includes information from a GSE,
including links to websites. Search
Access Points include OS-level Search
Access Points, browsers (including
Search Access Points within browsers
such as browser address bars), search
apps, and GenAI Products that can
retrieve and display information from
a GSE, including links to websites.
Y. “Search Feature” in Google
Search means any user-facing content
on a SERP that is not an organic link.
Search Features include images,
featured snippets, hotel units, query
expansion features like auto-complete,
“did you mean” prompts, spelling
corrections, and related searches.
[No similar provision.] X. “Search Feature” in Google
Search means any user-facing content
on a SERP that is not an organic link.
Search Features include images,
featured snippets, hotel units, query
expansion features like auto-complete,
“did you mean” prompts, spelling
corrections, and related searches.
AA. “Search Text Ad” means a
general search text advertisement,
which is an ad that resembles an
organic link on a SERP. Search Text
Ads can include images and often
appear at the top of the SERP with a
designation indicating that they are
paid advertisements. “Search Text Ad”
also includes Search Text Ads
appearing in or in connection with
Google AI Overviews.
U. “Search Text Ad” means a
general search text advertisement,
which is an ad that resembles an
organic text link on a search engine
results page. “Search Text Ad” also
has the meaning defined and used in
the Court’s Memorandum Opinion of
August 5, 2024, ECF 1032, at 60, and
includes Search Text Ads appearing in
or in connection with Google AI
Overviews.
Y. “Search Text Ad” means a
general search text advertisement,
which is an ad that resembles an
organic link on a SERP. Search Text
Ads can include images and often
appear at the top of the SERP with a
designation indicating that they are
paid advertisements. “Search Text Ad”
also includes Search Text Ads
appearing in or in connection with
Google AI Overviews.
BB. “SERP” or “Search Engine
Results Page” means the results
provided by a search engine, in
response to a user query, including
links and other features and content,
including from a broad index of the
web.
[No similar provision.] Z. “SERP” or “Search Engine
Results Page” means the results
provided by a search engine, in
response to a user query, including
links and other features and content,
drawn from a broad index of the web.
[No similar provision.] V. “Specialized Vertical
Provider” means a platform that
responds to queries with information
centered on a particular subject matter.
[No similar provision.]
CC. “Technical Committee” or
“TC” means the five-person
committee of experts appointed by the
Court pursuant to Section VII.A.
W. “Technical Committee” or
“TC” means the five-person
committee of experts appointed by the
Court pursuant to Paragraph VII.A.
AA. “Technical Committee” or
“TC” means the five-person
committee of experts appointed by the
Court pursuant to Section VII.A.
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DD. “Third-Party Browser” means
any web browser that is not Google
Chrome or another proprietary Google
web browser and includes, by way of
example, Apple Safari, Mozilla
Firefox, and Samsung Internet.
X. “Third-Party Browser” means
any web browser that is not Google
Chrome or another proprietary Google
web browser and includes, by way of
example, Apple Safari, Mozilla
Firefox, and Samsung Internet.
BB. “Third-Party Browser” means
any web browser that is not Google
Chrome or another proprietary Google
web browser and includes, by way of
example, Apple Safari, Mozilla
Firefox, and Samsung Internet.
[No similar provision.] Y. “Third-Party GenAI Assistive
Service” means a user-facing software
application not owned by Google or its
affiliates that makes use of generative
AI capabilities or models and has
among its principal functions
answering information-seeking
prompts across a wide variety of topics
using a broad range of publicly
available information.
[No similar provision.]
FF. “Third-Party GenAI Product”
means any GenAI Product that is not
owned by Google.
Z. “Third-Party GenAI Product”
means any application, software,
service, feature, tool, functionality, or
product not owned by Google or its
affiliates that involves or makes use of
generative AI capabilities or models
and has among its principal functions
answering information-seeking
prompts across a wide variety of topics
using a broad range of publicly
available information. For clarity,
“Third-Party GenAI Product” does not
include specialized vertical search
services, whether or not they offer a
GenAI Product.
CC. “Third-Party GenAI Product”
means any GenAI Product that is not
owned by Google.
EE. “Third-Party General Search
Service” means a web search service
that can respond to a broad range of
search query categories and offers
functionality that is substantially
similar to Google Search, and is not
owned by Google or its affiliates.
AA. “Third-Party General Search
Service” means a web search service
that can respond to a broad range of
search query categories and offers
functionality that is substantially
similar to Google Search, and is not
owned by Google or its affiliates.
DD. “Third-Party General Search
Service” means a web search service
that can respond to a broad range of
search query categories and offers
functionality that is substantially
similar to Google Search and is not
owned by Google or its affiliates.
GG. “User-side Data” means all
data that can be obtained from users in
the United States, directly through a
search engine’s interaction with the
user’s Device, including software
running on that Device, by automated
means. User-side Data includes
information Google collects when
answering commercial, tail, and local
queries.
BB. “User-side Data” means all
data that can be obtained from users in
the United States, directly through a
search engine’s interaction with the
user’s device, including software
running on that device, by automated
means. User-side Data includes
information Google collects when
answering commercial, tail, and local
queries.
EE. “User-side Data” means all
data that can be obtained from users in
the United States, directly through a
search engine’s interaction with the
user’s Device, including software
running on that Device, by automated
means. User-side Data includes
information Google collects when
answering commercial, tail, and local
queries.
Z. “Search Index” means any
databases that store and organize
CC. “Web Search Index” means
databases that store and organize
FF. “Web Search Index” means
databases that store and organize
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94
information about websites and their
content that is crawled from the web.
information about websites and their
content that is crawled from the web.
For the avoidance of doubt, it does not
include Google’s vertical indexes or its
video, images, or other specialized
indexes that contain information not
crawled from the web.
information about websites and their
content that is crawled from the web.
For the avoidance of doubt, it does not
include Google’s vertical indexes or its
video, images, or other specialized
indexes that contain information not
crawled from the web.
X. THIRD-PARTY RIGHTS
Plaintiffs’ Proposal Google’s Proposal Final Judgment
Nothing in this Final Judgment is
intended to confer upon any other
persons any rights or remedies of any
nature whatsoever or by reason of this
Final Judgment other than the right to
submit complaints to the Compliance
Officer and the TC.
Nothing in this Final Judgment is
intended to confer upon any other
persons any rights or remedies of any
nature.
Nothing in this Final Judgment is
intended to confer upon any other
persons any rights or remedies of any
nature whatsoever or by reason of this
Final Judgment other than the right to
submit complaints to the Compliance
Officer and the TC.
XI. RETENTION OF JURISDICTION AND ENFORCEMENT OF FINAL JUDGMENT
Plaintiffs’ Proposal Google’s Proposal Final Judgment
A. Jurisdiction is retained by this
Court for the purpose of enabling any
of the parties to this Final Judgment to
apply to this Court at any time for such
further orders or directions as may be
necessary or appropriate for the
construction or carrying out of this
Final Judgment, for the modification
of any of its provisions (including an
order to divest any relevant Google
business), for the enforcement of
compliance with this Final Judgment,
and for the punishment of any
violation of this Final Judgment. For
example, Plaintiffs may request that
the Court revisit its decision on a
payment ban, including but not limited
to a ban on default payments, if
competition is not substantially
restored by this Order. In any motion
to modify this Final Judgment,
Plaintiffs need not show any change in
circumstances, but need only
demonstrate that modification is
necessary to achieve the intended
purposes of this Final Judgment to
restore competition in the
monopolized markets. In any action to
This Court retains jurisdiction for the
purpose of enabling any of the parties
to this Final Judgment to apply for
such further orders or directions as
may be necessary or appropriate to
carry out or construe this Final
Judgment, to modify or terminate any
of its provisions, and to enforce
compliance.
A. Jurisdiction is retained by this
Court for the purpose of enabling any
of the parties to this Final Judgment to
apply to this Court at any time for such
further orders or directions as may be
necessary or appropriate for the
construction or carrying out of this
Final Judgment, for the modification
of any of its provisions, for the
enforcement of compliance with this
Final Judgment, and for the
punishment of any violation of this
Final Judgment.
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95
enforce this Final Judgment, Google
must show by a preponderance of the
evidence that its actions are in
compliance with this Final Judgment.
B. The Court may act sua sponte
to issue orders or directions for the
construction or carrying out of this
Final Judgment, for the enforcement of
compliance, and for the punishment of
any violation.
[No similar provision.] [No similar provision.]
C. This Final Judgment should be
interpreted to give full effect to the
procompetitive purposes of the U.S.
antitrust laws and to restore the
competition the Court found was
harmed by Google’s illegal conduct.
[No similar provision.] [No similar provision.]
D. For a period of four (4) years
following the expiration of this Final
Judgment, if any Plaintiff has evidence
that Google violated this Final
Judgment before it expired, that
Plaintiff may file an action against
Google in this Court requesting that
the Court order (1) Google to comply
with the terms of this Final Judgment
for an additional term of at least four
(4) years following the filing of the
enforcement action; (2) all appropriate
contempt remedies; and (3) additional
relief needed to ensure Google
complies with the terms of this Final
Judgment.
[No similar provision.] B. For a period of four (4) years
following the expiration of this Final
Judgment, if any Plaintiff has evidence
that Google violated this Final
Judgment before it expired, that
Plaintiff may file an action against
Google in this Court requesting that
the Court order (1) Google to comply
with the terms of this Final Judgment
for an additional term of at least four
(4) years following the filing of the
enforcement action; (2) all appropriate
contempt remedies; and (3) additional
relief needed to ensure Google
complies with the terms of this Final
Judgment.
E. In connection with a
successful effort by any Plaintiff to
enforce this Final Judgment against
Google, whether litigated or resolved
before litigation, Plaintiff may request
that the Court order Google to
reimburse that Plaintiff for the fees and
expenses of its attorneys, as well as all
other costs, including experts’ fees,
incurred in connection with that effort
to enforce this Final Judgment,
including in the investigation of the
potential violation.
[No similar provision.] [No similar provision.]
Case 1:20-cv-03010-APM Document 1461 Filed 12/05/25 Page 95 of 95