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

12345678910111213141516171819202122232425262728greater than it currently has. For example, ITA was acquired by Google for $700 million in 2011.3taps believes that its indexing business similarly would be valued in the hundreds or millions ofdollars, or more, but for craigslist’s anticompetitive scheme.194. 3taps also was forced to shut down craiggers as a result of craigslist’santicompetitive scheme and has lost the value of its significant investment in craiggers and suffereddamage to its property in the search market. Further, craiggers has lost users and tremendous valueto its business as a going concern. Other major search providers are worth hundreds of millions ofdollars. For example, as of last week, Kayak’s market capitalization was over $1 billion, whileTrulia, which searches real estate listings, had a market capitalization of over $600 million. Asdescribed above, AirBnB has been valued at approximately $1.3 billion. 3taps believes that, butfor craigslist’s anticompetitive scheme, craiggers would be worth hundreds of millions of dollars,as well.195. Finally, unless craigslist’s anticompetitive scheme is enjoined, JeBoom may sufferthe same fate as craiggers. As a result, 3taps would suffer damage to its property in the searchmarket and lose the value of its substantial capital investments in JeBoom, as well as the value ofJeBoom’s business opportunities and value as a going concern. At the very least, if JeBoom isdeprived of craigslist data, the value of its business would decline substantially.3TAPS’ ANSWER AND COUNTERCLAIMCAUSES OF ACTIONCOUNT I(Sherman Act § 2 claim for monopolization and attempted monopolization of the onboardingmarket and related submarkets)196. 3taps repeats and incorporates by reference the allegations set forth in Paragraphs 1through 195 as if fully set forth herein.197. Section 2 of the Sherman Act (15 U.S.C. § 2) prohibits, inter alia, the willfulmonopolization of any part of the trade and commerce among the States, as well as attempts tomonopolize any part of the trade and commerce among the States.198. craigslist has monopoly power in the Relevant Market for the onboarding ofclassified ad content, and it has maintained this power through anticompetitive behavior.65CASE NO.: 12-CV-3816-CRB