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

12345678910111213141516171819202122232425262728classified ads free of charge. It only charges for postings in three submarkets for the onboarding ofclassified ad content: (1) $25-$75 for online job postings in each category in select cities, (2) $10for brokered apartment listings in New York City and Boston, and (3) $10 for posting therapeuticservices ads in the United States.C. craigslist’s Onboarding Dominance Naturally Gave It MonopolyPower in the Related Markets For Indexing And Search104. craigslist’s dominance in onboarding led to a natural acquisition of monopoly powerin the related markets for the search-engine indexing of onboarded classified ad content and thesearch of that indexed data.1. Search-Engine Indexing105. Because of craigslist’s overwhelming dominance in the online classified adonboarding market, as well as several related submarkets, craigslist also dominates and controls thesearch-engine indexing of onboarded classified ads.106. Because craigslist controls 90% of onboarded content across all segments, no otherfirm can enter the market for search-engine indexing of classified ads without access to informationuploaded onto the craigslist website. Similarly, in each relevant submarket, craigslist controls 65-90% of onboarded content (or, in the example of the sale of services, 55% or more of onboardedcontent).107. craigslist’s monopoly power is demonstrated by its historic ability to keep itscontent out of the indexing market. For example, Yahoo! Pipes is a platform that providesaggregated data from internet websites for use by developers of mashups (which both index thedata and/or use the data in downstream search offerings.) In the past, Yahoo! Pipes tried to includecraigslist content from craigslist RSS feeds in its platform. Once craigslist realized that Yahoo!Pipes was including data from its RSS feeds, craigslist took steps to block Yahoo! Pipes’s access tothe RSS feed.108. Notably, even if craigslist allowed Yahoo! Pipes unfettered access to the RSS feeds,these feeds would not enable Yahoo! Pipes’ developers to create an efficient and useful index. TheRSS feeds—which craigslist provides only for non-commercial use—are only updated every3TAPS’ ANSWER AND COUNTERCLAIM48CASE NO.: 12-CV-3816-CRB