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Thirteen 285. The Google Play Store and Google Play Billing are separate products in separate 14 markets. These two merchandise might be bought separately, and there’s demand for separate products on 15 the part of each customers and developers. Frameworks out there out there. Residents of the Plaintiff States have paid more for 12 Android apps than they would have paid in a competitive market. 23 293. As a result of Google’s anticompetitive conduct, Plaintiff States and their 24 residents and common economies have suffered and proceed to endure damages. Eight 279. Google has engaged in a steady course of unlawful anticompetitive conduct. 24 276. Google’s conduct has substantial anticompetitive results, including increased 25 prices to consumers and costs to developers, decreased innovation and quality of service, and 26 reduced output of apps. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 79 of 144 1 272. On account of Google’s anticompetitive conduct, Plaintiff States and their 2 residents and general economies have suffered and proceed to suffer damages. 18 281. On account of Google’s anticompetitive conduct, Plaintiff States and their 19 residents and common economies have suffered and proceed to suffer damages. Alternatively, to the extent that any such procompetitive benefits 9 exist, they are outweighed by the anticompetitive results of Google’s conduct and could have 10 been achieved by less anticompetitive and fewer harmful means.

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Alternatively, to the extent that these agreements provide any 15 procompetitive benefits, those advantages are outweighed by the anticompetitive results of the 16 agreements and could have been achieved through much less anticompetitive and less harmful means. Alternatively, to the extent that these agreements present any four procompetitive benefits, these benefits are outweighed by the anticompetitive effects of the 5 agreements and could have been achieved via less anticompetitive and less dangerous means. 21 300. Google’s conduct has substantial anticompetitive results, together with elevated 22 prices to customers and prices to developers, lowered innovation and high quality of service, and 23 lowered output of apps. 25 Plaintiff State residents were additional injured because Google’s institution and maintenance of 26 supracompetitive pricing has prompted a reduction in the output and provide of Android apps, which 27 would have been more abundantly obtainable in a aggressive market. 5 Plaintiff States have a quasi-sovereign curiosity in preventing illegal anticompetitive conduct 6 affecting a large number of their residents and the financial system of the State generally.

Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 83 of 144 1 Plaintiff States have a quasi-sovereign interest in preventing unlawful anticompetitive conduct 2 affecting numerous their residents and the financial system of the State generally. Plaintiff State residents have been further injured because Google’s 20 establishment and maintenance of supracompetitive pricing has triggered a discount within the output 21 and provide of Android apps and in-app purchases, which would have been extra abundantly 22 available in a aggressive market. 9 267. Google’s conduct has substantial anticompetitive effects, including increased 10 prices to customers and prices to builders, reduced innovation and high quality of service, and 11 lowered output of apps. 15 Plaintiff State residents have been further injured because Google’s institution and maintenance of 16 supracompetitive pricing has brought about a reduction within the output and supply of Android apps, which 17 would have been more abundantly accessible in a competitive market. 22 Plaintiff States have a quasi-sovereign curiosity in stopping illegal anticompetitive conduct 23 affecting a large number of their residents and the financial system of the State typically.

9 280. Google’s anticompetitive conduct has harmed competition and harmed the ten general economies and a substantial variety of residents of the Plaintiff States in a way the eleven antitrust laws had been intended to prevent. Residents of the Plaintiff States have paid extra for 22 Android apps than they’d have paid in a competitive market. Lower-cost market alternatives that would have been out there had Google not 19 restrained competitors. Lower-cost 14 market options that will have been available had Google not restrained competitors. Lower-price 24 market alternatives that would have been accessible had Google not restrained competition. Eleven 290. This unlawful tying considerably impacts interstate commerce in the tied market. 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 make use of of 1 Google Play Store 2 (Against all Defendants) three 282. Plaintiff States repeat and reallege each previous allegation of this Complaint as 4 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 8 9 (Against all Defendants except Google Payment) 10 273. Plaintiff States repeat and reallege each previous allegation of this Complaint as 11 if fully set forth herein.