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

12345678910111213141516171819202122232425262728craigslist has filed, or threatened to file, against them.148. Many search engine companies provide more streamlined and innovative platformson which users can onboard new classified content. These companies also offer or supportinteraction applications, like identity services, messaging tools—like Message.Me or mobi-digger,which send messages directly between two users—payment tools—like PayPal or CloudCash—orcredit verification tools. Other tools include creative visualizations, such as tremaps orsteamgraphs, which display creative, visually-compelling versions of onboarded content.149. As users experience the better search offerings of these companies, they are morelikely to onboard new content directly to these competitor sites—which is exactly what craigslistfears. craigslist fears that it may lose its monopoly power in the onboarding space to new entrantsin the market for the real-time search of online classified ads that offer both onboarding and searchservices. Accordingly, craigslist now has taken anticompetitive steps—described below—toensure that it does not lose its monopoly power to any of these specialized search engines.150. PadMapper provides an example of this phenomenon. While PadMapper beganexclusively as a search tool, craigslist knows that users are beginning to onboard unique content toPadMapper’s affiliated site, PadLister. Thus, craigslist is now targeting PadMapper in the searchspace to prevent it from becoming a competitor in both the onboarding and search markets.151. Without 3taps, which offers the essential bridge that allows specialized searchengines to attract users, these companies cannot break into the search or onboarding productmarkets. And in the face of craigslist’s anticompetitive scheme, most, if not all, of these nascentsearch engine developers are likely to abandon their efforts.CRAIGSLIST’S OVERALL SCHEME152. Rather than innovating and competing to maintain its dominance, craigslist remainsdetermined to ignore the innovation curve, and therefore, has engaged in an anticompetitivescheme to illegally maintain its monopoly control over the onboarding, indexing, and searchmarkets for online local classified ads. This scheme is designed both to stop 3taps fromsuccessfully acting as the indexing bridge between the onboarding and search markets and todirectly injure craigslist’s search competitors, such as PadMapper, craiggers, and Lovely, in the3TAPS’ ANSWER AND COUNTERCLAIM56CASE NO.: 12-CV-3816-CRB