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

12345678910111213141516171819202122232425262728onboarding and indexing submarket for the sale of services). Because of this control over the datathat needs to be indexed, craigslist’s share in the indexing market roughly equates to its share in theonboarding market and submarkets: 90% for general onboarded content, 65% or more in therelevant onboarding submarkets for apartment listings and the sale of goods, and 55% or more inthe relevant onboarding submarket for the sale of services, as described above in Paragraphs 40 and43.63. Accordingly, craigslist has monopoly power in the market for search-engineindexing of onboarded classified ad content.C. The Relevant Market for Real-Time Search Servicesof Indexed Online Classified Ad Content64. A third relevant product market—and related submarkets—exists for “real-time”search services for indexed classified ad content. A real-time search engine provides the mostrecent results for a set of search criteria, as opposed to PageRank search services, which return themost authoritative results for a set of search criteria. For real-time search engines, the unit of datais a posting, whereas for PageRank search engines, the unit of data is a webpage.65. In the market for real-time search of indexed online classified ad content, real-timesearch service providers enable users to search simultaneously for online classified ads in multiplecities on multiple websites across multiple criteria.66. The outer boundaries of the relevant product market for search are determined bythe reasonable interchangeability of use or the cross-elasticity of demand between real-time searchof indexed online classified ad content and potential substitutes for search.67. “Real-time search services” is a relevant antitrust product market because no othersearch service is as useful and convenient to consumers. There are no reasonable substitutes forthis product.68. A small but non-transitory increase in price for real-time search services of indexedonline classified ad content would not cause users to switch to other products or to otherwisechange their activities sufficiently to make such a price increase unprofitable to the hypotheticalmonopolist. Therefore, there is no cross-elasticity of demand between real-time search services of3TAPS’ ANSWER AND COUNTERCLAIM40CASE NO.: 12-CV-3816-CRB