Is there a market for organic search engine results and can their manipulation give rise to antitrust liability?

Abstract

Google has been accused of manipulating its organic search results to favor its own services. We explore possible choices of relevant antitrust markets that might make these various antitrust allegations meaningful. We argue that viewing Internet search in isolation ignores the two-sided nature of the search-advertising platform and the feedback effects that link the provision of organic search results to consumers on the one hand, and the sale to businesses of advertising on the other. We conclude that the relevant market in which Google competes with respect to Internet search is at least as broad as a two-sided search-advertising market. We also ask whether Google has a duty to provide organic search results that are neutral with respect to whether the displayed listing is for a Google rather than a non-Google business. We articulate and apply a standard that asks whether various practices related to Google's organic search results would harm competition that would have otherwise occurred.