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

12345678910111213141516171819202122232425262728events, jobs, and other classified ads in specific market segments, such as apartment rentals, usedcars, used goods, services, romance, and friendship.93. A central part of the craigslist model of onboarding of classified ads is to allow foranonymized postings. As users put in new content to the website, their identities remainanonymous and users contact each other through the craigslist website, rather than through aninteraction application that facilitates real-time interactions. Where used properly, this practiceallows craigslist to monitor legitimately for spam and to protect the personal information of itsusers.94. As craigslist grew, it expanded to other U.S. cities (and eventually, to other citiesinternationally). Rather than create one mega-database of postings, craigslist cloned its initialwebsite for each local area, confining users to location-based postings and search activities, due totechnical as well as Terms of Use constraints. It therefore has no central searchable index acrosscities, but instead participates in all of the relevant markets through hundreds of distinct websites.95. Craigslist now operates over five hundred separate websites for each of the cities inwhich it offers onboarding services, indexes data, and offers search capabilities to users.96. This onboarding process limits the capabilities of the index and search features thatcraigslist offers to its users. Because each local website’s data is indexed separately, users oncraigslist cannot search across contiguous cities simultaneously. Thus, a user who lives close totwo major cities who is willing to purchase goods or services in both cities is forced to search ontwo separate craigslist sites to find the goods or services for which he or she is looking.97. Additionally, use of craigslist’s search product results in users simply obtaining allhits for a particular word or category. But craigslist’s data is not indexed in a way that allows usersto search and sort postings by certain important categories, such as the user that onboarded thecontent. This prevents a user from finding all of another particular user’s posts or from weedingout posts by a user who re-posts the same ad multiple times. Moreover, craigslist, through itsanticompetitive scheme, seeks to prevent any company from offering a product that wouldaccomplish these goals and has targeted companies like HuntSmartly and SnapStorewhich aimto provide a search-by-user feature for craigslist datawith cease and desist letters.3TAPS’ ANSWER AND COUNTERCLAIM46CASE NO.: 12-CV-3816-CRB