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achieved by Google with this activity illustrates that direct competition between Google and unbundled solutions including DoubleClick ad serving tools is today virtually non-existent.

  • 215.

    The fact that Google had decided pre-merger to develop a new ad serving product for advertiser-side display ad serving, management, and reporting, Google Ad Manager for Advertisers, “GFA”, which is still in the early stages of development and not currently available, confirms that Google’s current offering is not interchangeable with DoubleClick’s products. Google also only recently decided to begin developing a publisher-side ad serving solution, Google For Publisher, “GFP”. GFP is still in development and not currently available123.

  • 216.

    Secondly, Google's solution operates as a closed network, imposing a number of restraints to participating publishers and advertisers. Indeed, in order to use AdSense, publishers must join Google’s Publisher Network. Ad network providers, such as Google, share the advertising revenue generated by its network with the publishers providing the inventory. The revenues transferred by the intermediary to the publisher are considered as a traffic acquisition cost (TAC) and depend on the relative bargaining power of the intermediary and the publisher. The negotiation may be subject to some degree of asymmetry of information in that the publisher may not know exactly the total amount of ad revenues generated by its inventory via the platform and the agreement may not refer to a precise share of total ad revenues124.

  • 217.

    On the contrary, DoubleClick ad serving tools could be used in unbundled solutions involving direct sales of ad space or intermediation via open ad exchanges that can be used on an as-needed basis, with no guarantees or minimums (an “open” network). With such solutions, advertisers have more control over which inventory they wish to purchase, while publishers have more control over which advertisers will be allowed to buy their inventory. Such solutions seem to involve a minor transfer of revenues to intermediaries, or no transfer at all in case of direct sales.

  • 218.

    For the reasons elucidated in paragraphs 212-217, bundled solutions seem to be preferred by smaller players, or larger players interested in the acquisition or sale of remnant inventory, while unbundled solutions are normally preferred by the large players and, in particular, for the acquisition/sale of premium content.


A complainant has provided a survey of the top EU and United States

websites (on the basis of page view) showing that a large proportion of these top websites uses both AdSense and DoubleClick. In addition, the survey indicated


In the United States, GFP is in beta testing with [>50]* testers. In the EU, GFP was being tested at one site, namely, the United Kingdom website of […]*, a United States-based company with Internet traffic and sales generated mainly in the United Kingdom. The company initially switched most of its traffic to GFP for testing, but has since switched most of its traffic away from GFP and at the same time concluded an agreement with Yahoo! for ad sales and ad serving in the United Kingdom and Ireland, which will possibly evolve into a worldwide agreement.


According to some respondents to the market investigation, this type of “opacity” characterises Google’s AdSense network.


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