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

123456789101112131415161718192021222324252627the onboarding and search markets, craigslist has chosen not to compete on the merits, but rather toimplement an anticompetitive scheme (detailed below) to thwart competition in the RelevantMarkets.engines.B. craigslist’s Interaction with Google and Other General Search Engines125. Historically, craigslist has been more than willing to interact with general search126. As the internet evolved in the late 1990s, Google co-founder Larry Page developed apatented method of searching the internet that established the relevance and authority of web pagesas a basis for web search. This type of search feature, unlike an indexed system that brings back allresults that hit on a certain set of criteria, uses a concept that has become known as “PageRank.”PageRank is based on how many incoming links a web page has. This method of search quicklysupplanted other models used by Lycos, Alta Vista, and Yahoo.127. Because PageRank search engines return hits based on which page is the most“authoritative” based on its number of links, these search engines are inadequate vehicles forsearching classified ads to execute an exchange of a particular type of product or service. In fact,PageRank search tools will tend to find the oldest and most stale classified ad postings.128. Additionally, these search engines do not return the “best” classified ads becauseuser ratings of buyer/seller experiences also represent another form of relevance and authority inthe realm of exchange space – something for which a PageRank system does not account.129. Accordingly, Google and Bing searches only indicate that craigslist is anauthoritative place to go for classified ads, but these search engines do not offer an alternativespace in which users can post and search for classified ads or where users can execute the best realtimeexchange.130. craigslist has long provided Google with its content data, presumably because itdirected traffic to craigslist, and, in turn, increased the frequency of exchange transactions oncraigslist. craigslist saw PageRank search engines as a way to increase its reach: any hits in aPageRank search would direct some additional users to craigslist, but without increasing28competition against craigslist in the indexing or search markets.3TAPS’ ANSWER AND COUNTERCLAIM52CASE NO.: 12-CV-3816-CRB