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

12345678any niche onboarding sites in this submarket. craigslist’s anticompetitivescheme inhibits new competitors from entering the market.Other Submarkets: craigslist is a privately-held company that does notpublish statistics regarding traffic and postings for many of the classifiedad categories offered on its website. Upon information and belief,craigslist may have monopoly power—or alternatively, may have thedangerous probability of achieving monopoly power—in other classifiedad submarkets.910111213141516171819202122232425262744. The direct evidence of craigslist’s actual control of the market for onboarding ofclassified ads, as well as its monopoly market shares, demonstrate that craigslist has monopolypower in the market for onboarding of online classified ads, as well as in the relevant submarketsfor onboarding of online classified ads.B. The Market for Search-Engine Indexing of Classified Ad Content45. A second relevant product market exists for search-engine indexing of onboardedclassified ad content. Indexing refers to the collection, parsing, categorization, organization, andstorage of data to facilitate fast and accurate retrieval of information for search engines. Data iseither normalized (i.e., coded by location or structured annotations, such as the number ofbathrooms or bedrooms in an apartment) or left free form (e.g., raw words).46. Indexing allows the results of an analysis of onboarded data to be organized intorapidly searchable alphabetical or numerical data structures that power search requests and efficientadd, edit, or delete functions for updates to the data. For example, in contrast to craigslist’s index,3taps’ index enables the efficient addition of latitude and longitude specifications to classified adsin the housing market. These latitude and longitude specifications then can be used to create maps(as PadMapper does) in the downstream market for the search of online classified ads.47. Indexing also allows for rapid summarization and subtotaling of data to allow usersto see the total number of matching postings in an adjoining location or category. For example,indexing enables a search engine to tally specific keywords across categories, and therefore helps28search engines find more relevant postings.3TAPS’ ANSWER AND COUNTERCLAIM36CASE NO.: 12-CV-3816-CRB