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

12345678910111213141516171819202122232425262728143. These companies address consumer demand for searching across multipleneighborhoods and cities, searching across additional criteria, saving searches, and other additionalfeatures.144. Notably, after searching through the databases on craiggers, JeBoom, or PadMapper,a user who clicks on a craigslist ad that was returned in his or her search results then is redirectedto craigslist to complete an exchange. In this way, the search engines developed by 3taps and itspartners actually direct traffic (and therefore, business and revenues) to craigslist in the short run,rather than away from it.145. ITA’s relationship with Kayak in the airline industry provides a good example ofwhat would develop in the online classified ad industry, absent craigslist’s anticompetitive scheme.ITA is an indexing company that scrapes or uses APIs to collect data about flights from all majorairlines. It then provides this data to specialized search engines, like Kayak, which use the reindexeddata to provide users with a better search for airline tickets. It allows users to dosomething they could not do with each individual airline’s website: make side-by-sidecomparisons on a global rather than limited geographic basis—and to make these comparisonsacross competing alternatives.146. Similarly, AirBnB accomplished this feat in the vacation rental classified ad space.It attracted traffic by sending craigslist’s users messages indicating that AirBnB offered a servicewhere classified ads for vacation rentals could be posted and searched with better, more advancedtools and interaction services. As more craigslist users were directed to the AirBnB site as analternative space in which to post classifieds, craigslist lost significant traffic in this segment toAirBnB.147. AirBnB was able to accomplish this feat for several reasons that make it difficult forother specialized search engines to follow in its footsteps. Foremost, craigslist, at the time, did notview AirBnB as a significant threat because craigslist never had a large number of onboardedlistings in the vacation rental space. AirBnB was able to thrive while craigslist paid little attentionto its activities. Second, most start-up specialized search engines do not have the capital thatAirBnB has, and therefore they lack the resources to defend against the sham lawsuits that3TAPS’ ANSWER AND COUNTERCLAIM55CASE NO.: 12-CV-3816-CRB