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publisher's

content

inventory.

Therefore,

there

is

no

possible

substitution

between selling ad space for search and selling ad space for non-search. Some

respondents

to

the

market

investigation

submitted

that

  • -

    from

a

publisher's

perspective - the "needs of customers" change for search Moreover, the "technical basis" required for the search and been considered to be different. Indeed, it can also be publisher decides to allocate a given space on a web page

and non-search ads. non-search ads have noted that, when a to a non-search (e.g.

display) ad, this would space, since the latter entered by the user.

not be substitutable with a "search generated" advertising only appears on the page generated by the search query

  • 55.

    It can therefore be understood that, from a publisher's point of view, search and non-search ads are considered as rather complementary in the sense that search advertising "completes" or "complements" the sale of non-search advertising space by publishers39.

  • 56.

    In view of the above, the existence of a separate market for the provision of online advertising space can be concluded. Furthermore, in this market search and non-search advertising might exert some degree of constraint on each other, especially when considering the advertisers' perspective. From a publisher’s standpoint, the distinction between the two categories seems to be clearer. In any case, there is no need to define two separate markets for the provision of search and non-search advertising space as, under any of these market definitions, the transaction would not raise any competition concerns.

      • 6.1.2.

        Intermediation in online advertising

    • 57.

      The notifying party submitted that no intermediation market should be identified. In its view, direct sales are effectively constraining the providers of intermediation because a portion of the customers of intermediaries (marginal customers e.g. the large publishers) are able to switch to the direct channel in response to a price increase of intermediation. In the notifying party's view, the existence of these marginal customers would be a sufficient disincentive for intermediaries to raise prices. As a consequence, infra-marginal customers, that is to say the smallest publishers unable to have their own direct sales forces, would also be protected from price increases. Given the effective constraint exercised by the direct sales channel, the market for the sale of online space (or the purchase of online space by advertisers) would include both direct sales and intermediated sales.

58. For the purpose of identifying a separate market for intermediation, the distinction between large publishers and small publishers with no alternative to intermediation would be relevant if a hypothetical monopolist for intermediation services was able to price discriminate between publishers and charge higher prices to publishers not having the direct sales option. In the notifying party's view, this possibility has to be excluded for a number of reasons outlined hereunder.

39

They are not complementary in the "economic" sense that volumes of search advertising would increase if the price of non-search decreased (and vice-versa).

20

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