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music pattern pattern design art design vector illustration ui playlist tunes player beats fun play record music circle rounded geometric pattern 19 299. Google has unlawfully maintained that monopoly power via the conduct and 20 contractual relationships described above. 17 298. Google has monopoly power within the IAP Processing Market by way of Google Play 18 Billing. 7 Fifth Cause of Action: Sherman Act § 2 Monopoly Maintenance within the In-App Payment Processing Market 8 9 (Against all Defendants) 10 295. Plaintiff States repeat and reallege every previous allegation of this Complaint as eleven if fully set forth herein. 7 Third Cause of Action: Sherman Act § 1 Unreasonable Restraints of Trade Concerning the Android App Distribution Market: App Developers eight 9 (Against all Defendants except Google Payment) 10 273. Plaintiff States repeat and reallege each preceding allegation of this Complaint as 11 if totally set forth herein. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page eighty one of 144 Fourth Cause of Action: Sherman Act § 1 Unlawful Tying of Google Play Billing to use of 1 Google Play Store 2 (Against all Defendants) 3 282. Plaintiff States repeat and reallege each preceding allegation of this Complaint as 4 if totally set forth herein. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 82 of 144 1 That price additionally reduces app developers’ capacity to put money into and create further apps and in-app 2 content that will in any other case profit customers.

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Limiting access to approved Microsoft apps might lessen his ought to try to perform common upkeep for the machine. 15 Plaintiff State residents had been further injured because Google’s institution and upkeep of sixteen supracompetitive pricing has brought about a discount in the output and supply of Android apps, which 17 would have been more abundantly available in a aggressive market. Plaintiff State residents were further injured as a result of Google’s 20 establishment and upkeep of supracompetitive pricing has triggered a reduction within the output 21 and provide of Android apps and in-app purchases, which would have been extra abundantly 22 accessible in a competitive market. Residents of the Plaintiff States have paid extra for 12 Android apps than they might have paid in a aggressive market. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 83 of 144 1 Plaintiff States have a quasi-sovereign curiosity in stopping unlawful anticompetitive conduct 2 affecting a lot of their residents and the economy of the State usually.

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Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page eighty of 144 1 277. These agreements serve no legitimate or procompetitive goal that could justify 2 their anticompetitive effects, and thus unreasonably restrain competition within the Android App 3 Distribution Market. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page eighty four of 144 1 anticompetitive effects of Google’s conduct and could have been achieved by way of much less 2 anticompetitive and less dangerous means. Alternatively, to the extent that these agreements provide any 4 procompetitive advantages, those benefits are outweighed by the anticompetitive effects of the 5 agreements and could have been achieved by means of much less anticompetitive and fewer dangerous means. Three 294. Google has thus engaged in a per se illegal tying arrangement; the Court does not 4 want to evaluate the anticompetitive results of Google’s conduct or its purported justifications. Additionally, 20 Plaintiff States have suffered and proceed to endure irreparable harm for which no enough 21 remedy at regulation exists and therefore seek an injunction ending Google’s anticompetitive conduct. Additionally, 25 Plaintiff States have suffered and proceed to undergo irreparable injury for which no enough 26 remedy at legislation exists and subsequently search an injunction ending Google’s anticompetitive conduct.

Three 304. Google’s anticompetitive conduct has harmed competition and harmed the four normal economies and a substantial variety of residents of the Plaintiff States in a fashion the 5 antitrust legal guidelines had been intended to forestall. 13 292. Google’s anticompetitive conduct has harmed competitors and harmed the 14 normal economies and a substantial variety of residents of the Plaintiff States in a manner the 15 antitrust legal guidelines had been supposed to stop. 9 280. Google’s anticompetitive conduct has harmed competition and harmed the ten common economies and a considerable number of residents of the Plaintiff States in a fashion the eleven antitrust legal guidelines were meant to stop. 18 281. Because of Google’s anticompetitive conduct, Plaintiff States and their 19 residents and normal economies have suffered and continue to endure damages. 23 293. Because of Google’s anticompetitive conduct, Plaintiff States and their 24 residents and common economies have suffered and continue to undergo damages. 24 276. Google’s conduct has substantial anticompetitive results, together with increased 25 costs to customers and prices to builders, reduced innovation and quality of service, and 26 lowered output of apps. 21 300. Google’s conduct has substantial anticompetitive effects, including elevated 22 costs to consumers and prices to builders, decreased innovation and high quality of service, and 23 lowered output of apps.

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