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

12345678910111213141516171819202122232425262728described below, it’s terms of use block a user’s ability to use any of these tools.75. craigslist’s monopoly power is evidenced directly by its ability to excludecompetitors from the market for real-time search of indexed online classified ad content. As aresult of its anticompetitive scheme, craigslist has caused the exit of numerous nascent searchcompetitors, including craiggers, HuntSmartly, Invatory, for-sale-alert.com, list-alert.com, Tempest,jumpoffcampus.com, wishcan.com, and SnapStore. In addition, absent relief from this court,several other search competitors are likely to exit the market, including PadMapper, JeBoom, andLovely.76. craigslist’s monopoly power also is evidenced indirectly by its share in the searchmarket and submarkets. Because of craigslist’s historical control of the onboarding markets, aswell as its control over indexed data, craigslist historically has controlled the markets related toreal-time search of indexed online classified ad content. Its share in the search market thereforeroughly equates to its share in the onboarding market and submarkets: 90% for general onboardedcontent, 65% or more in the relevant onboarding submarkets for apartment listings and the sale ofgoods, and 55% or more in the relevant onboarding submarket for the sale of services, as describedabove in Paragraphs 40 and 43.77. Significantly, craigslist’s dominance in each of these markets is interrelated. Forexample, competitors like PadMapper would not be able to provide a useful search tool withoutaccess to onboarded classified ads and the underlying facts and public data that craigslistimproperly seeks to control. As a result of craiglist’s anticompetitive scheme, PadMapper isinhibited from attracting users to its search site to demonstrate the superiority of its search andinteraction tools—like the PadMapper map based on latitude and longitude coordinates of housingpostings or message.me features. PadMapper therefore has a harder time gaining a critical mass ofusers to break into the onboarding market. In fact, PadMapper.com experienced a dramatic declinein visits once craigslist data was removed from the site, a fact confirmed by traffic statistics fromalexa.com, as well as the allegations in paragraph 73 of craigslist’s Complaint.II.Relevant Geographic Market78. The relevant geographic markets are each of the local city-by-city markets in the3TAPS’ ANSWER AND COUNTERCLAIM42CASE NO.: 12-CV-3816-CRB