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than 5). A survey of European and United States publishers provided by the notifying party indicated that the median number of ad network participation by European publishers was 2 (while it was 5 in the United States)157. The notifying party also provided (partial) information on the participation to ad networks of the top 50 EU websites (based on NielsenNetRatings). The data indicates that about half of the publishers that use intermediation platforms use more than one ad network and/or ad exchange.

307.

The prevalence of multi-homing is consistent with the fact that many ad

networks and ad exchanges have developed in parallel and are growing. The market investigation has revealed that a large number of ad networks have experienced significant growth in recent years (growth in net revenues has been more than 50% for a large number of ad networks). Both small and large networks have also seen the number of publishers and advertisers participating grow in recent years.

308.

The fact that several ad networks are able to coexist and grow is further

illustrated by data on the reach achieved by a number of ad networks. Reach, that is to say the number of unique visitors per month relative to the online population, is an important parameter for joining a network, however, it is one

amongst other parameters such as advertisers/publishers participating

the targeting capabilities or the

in

the

network.

The

notifying

quality of party has

provided

data

on

the

reach

achieved

by

a

number

of

ad

networks

(relative

to

the

United States online population) showing Advertising.com, ValueClick, Tribal Fusion, Lithium, Specific Media, DRIVEpm and others,

that ad networks such as Casale Media Network, Blue each achieved reach percentages

of more than 50% showing that many co-existing large online population with their members158.

ad

networks

are

able

to

reach

a

  • 309.

    In any case, both the parties and respondents to the market investigation seem to agree that the intermediation market is growing (as targeting improves, additional inventory can be optimally sold through ad networks).

  • 310.

    To sum up, post-merger the new entity will control both a large intermediation platform (AdSense) and a leading supplier of ad serving tools for display ads. It will thrive to attract additional publishers to its intermediation platform but the evidence reviewed does not support the view that the new entity would have the ability to foreclose competitors in intermediation markets through leveraging of its leading position in ad serving. In view of the presence of credible alternatives to which customers (publishers/advertisers/ad networks) can switch and the evidence that network effects are not strong enough to induce tipping, any strategy to attract publishers/advertisers to AdSense through input foreclosure or a variety of bundling/tweaking strategies is unlikely to be able to foreclose rivals in intermediation markets.

157

Source: expert opinion commissioned by the parties, submitted on 29 October 2007, Exhibit 6.

158

While this data relates to the United States, it illustrates that participation to ad networks or ad exchanges is not exclusive.

81

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