3TAPS, INC.'S ANSWER AND COUNTERCLAIM Case No. CV-12 ...

123456789101112131415161718192021222324252627searches that includes a map and alerts. Each of these services enhances search and interactioncapabilities for online classified ads in direct competition with craigslist’s antiquated capabilities.Indeed, in nearly every online classified ad product space, search innovators have been or arepoised to use the pre-staged index created by 3taps to compete against craigslist’s search andinteraction capabilities and, where successful, in onboarding as well.14. Notably, the specialized search engines that are powered by 3taps actually directtraffic to, rather than away from, craigslist. When a user searches for online classified ads oncraiggers or PadMapper and finds information about an ad that was originally onboarded ontocraigslist, the user then is redirected back to craigslist to complete the exchange, thus drivingbusiness back to craigslist. As a result, these specialized search engines actually benefit craigslist’sbusiness in the short run.15. craigslist’s response to this necessary and predictable outburst of innovation was notwhat one would expect from a company that purportedly prides itself on being a good citizen and asupporter of the unfettered use of publicly available information for the benefit of consumers. Noris it the behavior one would expect from a company that actually benefits from increased traffic asa result of 3taps’ innovation in the indexing market for online classified ads. Instead, craigslistrecognized that it was too late for it to compete on the merits and innovate in the markets forindexing and search—it knows that innovators in indexing and search can offer more attractiveproducts than craigslist in those markets and can rely on those superior offerings to challengecraigslist’s dominance in these markets, and eventually in the onboarding market as well. In turn,craigslist devised and implemented a multifaceted anticompetitive scheme to stop these nascentcompetitors in their tracks. While craigslist may have been too late to thwart the rapid growth ofAirBnB in the temporary housing rental space, it certainly was not going to tolerate 3tapsbecoming an indexing and categorization base from which other execution-focused specializedsearch engines could displace craigslist’s monopoly lock over other product spaces.16. The scheme, which is straightforward but effective, is comprised of four primaryfacets:283TAPS’ ANSWER AND COUNTERCLAIM28CASE NO.: 12-CV-3816-CRB