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Google's search ads business with non-search intermediation, the proposed concentration does not bring about any significant change of incentives. Indeed, Google could already engage in this type of bundling, especially with regard to intermediation of contextual ads, but also in relation to the intermediation of display ads, namely by making use of the required ad serving technology under a contractual arrangements with DoubleClick or any of DoubleClick's competitors. As has been explained above, not all ad networks and ad exchanges have their own in-house ad serving technology, but a substantial number of ad networks and ad exchanges make use of third party ad serving technology, including DFA and DFP. As Google could do the same already today, the merger does not change Google's incentive to engage in this wider form of bundling to any significant extent.

          • 7.3.2.2.3.

            Overall likely impact on competition

    • 356.

      Finally, even in the very unlikely event that the merged entity nevertheless engages in a foreclosure strategy involving the bundling of Google's search ad services or (search) ad intermediation services with DoubleClick's ad serving (and possibly including also non-search intermediation in the bundle), such a strategy would be very unlikely to have a significant detrimental effect on competition. As recognised by the Non-Horizontal Merger Guidelines, it is only when a sufficiently large fraction of market output is affected by foreclosure resulting from the merger that the merger may significantly impede effective competition. If there remain effective players in either market, competition is unlikely to deteriorate.

    • 357.

      The proposed concentration is unlikely to result in the elimination of a sufficient number of competitors in ad serving so as to significantly impede competition. Even if, despite the obstacles and disincentives described above, (i) the merged entity in the present case decided to bundle Google's search ad services or (search) ad intermediation services with DoubleClick's ad serving, and (ii) this foreclosure strategy caused most or all smaller, non-integrated competitors in the ad serving market to exit the market, the implementation of this strategy by the merged entity would still be very unlikely to cause competitors such as Microsoft, Yahoo! and AOL to cease offering ad serving or search ad services. Each of these competitors is vertically integrated and has access to considerable financial resources, which will enable it to continue to exert significant competitive pressure on the merged entity after the proposed concentration has been completed.

          • 7.3.2.2.4.

            Conclusion

    • 358.

      In the light of this analysis, bundling of Google's search ad offering with DoubleClick's ad serving technology seems unlikely to occur as a result of the proposed transaction. In any event, even if it did occur, it would not result in a significant impediment to effective competition.

      • 7.3.3.

        Foreclosure based on the combination of Google and DoubleClick's assets

359.

Finally, in the case of the third category of foreclosure scenarios set out

above, third-parties have alleged that the mere assets with Google's assets, and in particular

combination of DoubleClick's the combination of customer

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