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

12345678910111213141516171819202122232425262728innovative companies from cutting into these revenues.III.3TAPS, SEARCH ENGINES, AND INTERACTION DEVELOPERS RISE TOCHALLENGE CRAIGSLIST’S ENTRENCHED MONOPOLY POSITIONS137. New potential entrants are poised to enter each of the Relevant Markets in whichcraigslist competes. For example, 3taps, Craiggers, and JeBoom—and other competitors in theindexing and search marketplaces—have all researched and developed indexing or search tools thatrespond to the consumer demands that craigslist is unwilling to address.A. 3taps138. 3taps competes directly with craigslist in indexing. 3taps is an indexing companythat collects onboarded online classified ad content from general search engines and re-indexes thisdata for use in the downstream search market.139. 3taps does not access craigslist’s servers to collect information, and it therefore doesnot use craigslist’s bandwidth to offer its indexing product. Rather, as discussed above, 3tapssources its data from publicly available websites other than craigslist.140. 3taps addresses customer demand for more advanced searching—across multiplegeographies, with the potential to save preferences and searches—by providing an index that canfacilitate this type of search. Because specialized, real-time search engines cannot run quickly orefficiently enough to be useful to consumers without 3taps’ indexed data, companies like craiggersor PadMapper could not offer their search services to consumers without 3taps.141. Thus, while 3taps does not operate directly in the onboarding market for onlineclassified ads, it is the crucial bridge between onboarding and real-time search services. 3tapsprovides a path into the onboarding playing field for real-time search engine companies that have asuperior product and would offer an attractive alternative to craigslist.B. Craiggers, JeBoom, PadMapper, and Other Online Classified Search Engines142. For example, craiggers, JeBoom, PadMapper, and Lovely, as well as otherspecialized, real-time classified ad search engines, offer search and display offerings that competedirectly with craigslist in the search market by using information indexed by indexing companies,such as 3taps.3TAPS’ ANSWER AND COUNTERCLAIM54CASE NO.: 12-CV-3816-CRB