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

1234567891011121314151617181920212223242526272827. Through the activities alleged in these counterclaims, craigslist has improperlymaintained its monopoly power in various online classified ad product markets and submarkets inlocal geographic markets throughout the United States.28. craigslist’s anticompetitive scheme already has caused injury to competition in thesemarkets and to 3taps’s business and property (including 3taps’ websites craiggers and JeBoom),and unless enjoined, will continue to do so.I. The Relevant Antitrust Product MarketsA. The Market for Onboarding of Online Classified Ad Content29. There is a relevant product market for the “onboarding” of online classified adcontent. Onboarding refers to the creation, posting, editing, and deletion of users’ online classifiedads. After a user’s ad is posted online, onboarding exchanges then curate and moderate the posts tothwart spam and inappropriate user content.30. The outer boundaries of the relevant product market for onboarding are determinedby the reasonable interchangeability of use or the cross-elasticity of demand between onboardingof online classified ad content and potential substitutes for onboarding.31. Onboarding of classified ad content is not reasonably interchangeable withonboarding of other forms of online advertising—like search, display/banner, digital video, mobile,or rich media. The target audience and business models for other forms of online advertisingdistinguish general online advertising from online classified advertising. Indeed, experts in thefield of online advertising distinguish the supply and demand for online classified ads from otherforms of online advertising. For example, the 2011 Internet Advertising Revenue Report publishedby Price Waterhouse Cooper and the Interactive Advertising Bureau provides supply and demandinformation for different segments of the online advertising industry, finding that revenues in theonline classified ad market were approximately $2.6 billion in 2011, or 8-10% of the overall onlineadvertising industry. Onboarding of other forms of online advertising is beyond the outerboundaries of the relevant product market because unique supply and demand exists for theonboarding of classified ads.32. From the perspective of a user who wishes to onboard a post or a user who wishes3TAPS’ ANSWER AND COUNTERCLAIM32CASE NO.: 12-CV-3816-CRB