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that AdSense and DoubleClick ads were sometimes served at similar positions on the web page across all websites surveyed that is to say there was no systematic tendency for DoubleClick ads to be in one position and AdSense ads to be in another position on the surveyed web pages. As a consequence, the complainant concluded that ads served through AdSense and DoubleClick are substitute channels for distributing ad inventory to advertisers. In fact, the notifying party provided the list of DoubleClick's EEA publishers that also served ads through AdSense in 2006 and identified only […]* publishers out of DoubleClick's publisher customer base of […]* (i.e. [15-20%]*) which used both DoubleClick and AdSense. The revenues generated by most of them are very low, representing a tiny fraction of AdSense's gross revenues. Therefore, not only is the pool of common customers limited, but also, the fact that there are overlapping customers does not necessarily mean that the ad space used for AdSense and the ad space used to serve ads with DoubleClick tools either directly or through other intermediaries are the closest alternatives to one another for any given publisher125.


Google's closest competitors are likely to be other major search engines that

are also providers of ad space and have developed similar networks such as Yahoo! or Microsoft. These operators will be the closest choice for advertisers with a preference for search ads (and publishers able to display such ads) and a preferred choice for bundled solutions. Consequently, other advertising closed networks are likely to be the next best alternative. Some of these networks, such as Advertising.com, have reached already sizeable proportions in the market. The unbundled solutions using third-party ad serving technology such as DoubleClick are likely to constitute more distant alternatives.

Conclusion on actual horizontal competition


In view of this analysis, it does not seem likely that Google and DoubleClick

are today exerting a significant competitive constraint on each other’s Therefore, the operation does not seem to significantly impede competition with regards to the elimination of actual competition.

activities. effective

      • 7.2.2.

        Potential Competition


          DoubleClick as potential competitor in online ad intermediation


Several complainants assert that the merger would eliminate potential

competition between Google and DoubleClick. While harm brought forward by these complainants differ with

the various theories of regard to the details and


Indeed, the fact that publisher A uses AdSense to serve ads on the top of its web page while publisher B uses DoubleClick on the top of its web page does not necessarily mean that for each of these publishers AdSense and DoubleClick are close substitutes (i.e. publisher A may not consider DoubleClick served display ads to be substitutes for the top of its web page while publisher B may not consider AdSense to be suitable for its top web page). Moreover, the survey of websites by the complainant did indicate some tendencies (while not systematic). Considering the web pages where ads where served by either DoubleClick or AdSense, the survey indicated that 76% of the combined DoubleClick and AdSense ads located on the top right of the page were served by DoubleClick (and 24% by AdSense). On the contrary, of the combined DoubleClick and AdSense ads located at the bottom of the surveyed web pages, 33% were served by DoubleClick and 67% by AdSense.


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