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

123456789101112onboarding of online classified ad content. It has an approximately 90% share in the overallmarket for the onboarding of classified ads across all segments, while its two closest competitors,Backpage and eBay Classifieds, only have approximately 7% and 1.5% shares, respectively. Otherdistant competitors, such as OLX and Oodle, have even smaller shares.41. Upon information and belief, craigslist onboards approximately 1.2-1.5 millionposts per day, whereas Backpage onboards only 100,000 new posts and eBay Classifieds onboards20,000. Distant competitors like OLX and Oodle onboard even fewer posts.42. According to reports from Hitwise, craigslist’s local sites account for all but three ofthe top 100 online classified ad websites.43. Upon information and belief, craigslist also has monopoly power or a dangerousprobability of achieving monopoly power in the submarkets for onboarding of online classified ads,such as for apartment rentals, sale of general goods, and sale of general services.131415161718192021222324252627Apartment Rentals: Upon information and belief, craigslist’s share inthe apartment rental submarket is over 65% and may be as high as 77%.It competes against the niche onboarding sites PadMapper, Lovely, andother similar sites, which currently have de minimis shares because ofcraigslist’s anticompetitive scheme.Sale of Goods: Upon information and belief, craigslist’s share in the saleof goods submarket is over 65% and may be as high as 90%. craigslistdoes not face any significant competition from niche onboarding sites inthis submarket.Sale of Services: Upon information and belief, craigslist’s share in thesale of services submarket is at least 55% and may be even higher.There is a dangerous probability that craigslist will obtain monopolypower in this submarket as it drives more users to its site as a result ofnetwork effects, whereby users are driven to the craigslist site to gainaccess to the large numbers of buyers that craigslist already attracts.283TAPS’ ANSWER AND COUNTERCLAIMcraigslist does not face meaningful, across-the-board competition from35CASE NO.: 12-CV-3816-CRB