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

12345678910111213141516171819202122232425262728power downstream search offerings by relying on craigslist’s RSS feeds.53. To the extent the data is available, third-party indexers such as 3taps also can sourcethe raw data associated with content posted on classified ad onboarding websites from generalsearch engines (e.g., Google, Bing, etc.). Again, this is a slower, less efficient, and more expensivemeans of obtaining raw data for use in indexing than an API. 3taps historically has used thismethod to produce its index.54. Third-party indexers must use one of these methods to collect raw data in order tocreate a useful and competitive index. In turn, these indexes can be used downstream by real-timesearch engines that compete with craigslist in one or more search markets. 3taps has sourced rawdata from general search engines and indexed onboarded classified ad content for use indownstream search applications for classified ads. In this way, 3taps functions as a bridge betweencompetitors in the onboarding market and competitors in the search market.55. The outer boundaries of the relevant product market for indexing are determined bythe reasonable interchangeability of use or the cross-elasticity of demand between indexing ofonline classified ad content and potential substitutes for indexing.56. From the perspective of downstream providers of search engines (including thecraigslist-captive search engine) and from the perspective of downstream search users, there are noreasonable substitutes for indexing of classified ad content. Indexing is necessary for data to bequickly and efficiently searched, but indexing raw data is computationally complex and resourceintensive.57. Many search engine companies in the downstream markets for the search ofclassified ads target particular classified ad submarkets. Because of a lack of resources, specializedtechnical expertise, and time, these companies depend on search-engine indexing companies toanalyze the raw data for use in their search engine tools. Searching raw data that has not been prestagedby indexing is too inefficient and slow to enable these search engine companies to buildusable services on top of the onboarded data.58. For example, many third-party specialized search engines require indexed data toproduce their products. These search engines—like PadMapper in the housing sector, Kayak in the3TAPS’ ANSWER AND COUNTERCLAIM38CASE NO.: 12-CV-3816-CRB