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Mobile 2 device manufacturers, wireless carriers, and app developers are all dependent on cellular 3 ecosystems such as Android and depend on the power to distribute apps on those ecosystems. By stopping competitors in thirteen the markets for Android app distribution and for payment processing of digital content bought 14 within Android apps within the United States, Google has deprived the Plaintiff States and their 15 residents of the advantages of a aggressive marketplace and harmed the economic effectively-being of sixteen every State’s residents. Plaintiff 25 States seek to revive competitors. Federal and state competition and 4 shopper protection legal guidelines authorize States to bring actions to protect the economic properly-being of 5 their States and acquire injunctive and different relief to redress harm attributable to violations of those 6 laws. 7 28. The Attorneys General appear in their respective sovereign or quasi-sovereign eight capacities and below their respective statutory, common regulation, and equitable powers, and as parens 9 patriae on behalf of natural persons residing in their respective States pursuant to § 4C of the 10 Clayton Act, 15 U.S.C. § 26, and to 17 acquire injunctive and accompanying equitable relief based mostly upon Google’s anticompetitive 18 practices in violation of Sections 1 and a couple of of the Sherman Act, 15 U.S.C. This  da᠎ta has be​en creat​ed ᠎by GSA C᠎ontent Gener ator  DEMO᠎.

2 §§ 4 and 26, and 28 U.S.C. In the alternative, personal 13 jurisdiction and venue additionally could also be deemed correct underneath Section 12 of the Clayton Antitrust Act, 14 15 U.S.C. Google Play Store. 4 42. This Court has private jurisdiction over the Defendants, and venue is correct in 5 this Court beneath 15 U.S.C. Sixteen developers that distribute their Android apps by means of the Google Play Store. 7 43. Venue is proper in this District pursuant to 28 U.S.C § 1391(b) because Google 8 LLC and Google Payment maintain their principal places of business within the State of California 9 and on this District, as a result of a considerable a part of the occasions or omissions giving rise to the 10 Plaintiff States’ claims occurred in this District, and because, pursuant to 28 U.S.C. Google LLC is the primary operating subsidiary 23 of the publicly traded holding firm Alphabet Inc. The only member of Google LLC is XXVI 24 Holdings, Inc., a Delaware corporation with its principal place of enterprise in Mountain View, 25 California, and a wholly owned subsidiary of Alphabet Inc. Google LLC owns and operates 26 shopper companies corresponding to Android, Chrome, Gmail, Google Drive, Google Maps, Google Play, 27 3 Georgia v. Pennsylvania R. Co., 324 U.S.

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21 35. Defendant Google LLC is a Delaware restricted legal responsibility firm with its principal 22 place of enterprise in Mountain View, California. § 22, because Defendants may be present in or transact enterprise in this District. While some developers might see this as a marginal replace to Apple’s policy, it’s actually fairly massive. § 1391(c)(3), 11 any Defendants not resident within the United States could also be sued in any judicial district and their 12 joinder with others shall be disregarded in determining correct venue. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page sixteen of 144 1 JURISDICTION, Parties, AND VENUE 2 27. Plaintiff States, by and by way of their respective Attorneys General, convey this 3 action because the chief authorized officers of their respective States. 25 31. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 17 of 144 1 to the economic health. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 18 of 144 1 Google Search, YouTube, Google Cloud, and a wide range of digital advertising merchandise for 2 advertisers, promoting agencies, web publishers, and app builders. Case 3:21-cv-05227 Document 1 Filed 07/07/21 Page 19 of 144 1 41. This Court has material jurisdiction over this matter pursuant to 15 U.S.C. § 22 and 28 U.S.C.

15 34. The Attorneys General additional assert these claims primarily based upon their unbiased 16 authority to deliver this motion pursuant to Section 16 of the Clayton Act, 15 U.S.C. §§ 1-2. In addition, as 19 set forth below, individual states are asserting claims under state antitrust and client 20 protection statutes. In-app purchases and app 5 purchases comprise significant financial activity inside every State, with billions of dollars in 6 home revenue generated from in-app purchases in 2019. Anticompetitive practices in app 7 distribution and in-app funds thus have the potential to “stifle, impede, or cripple previous eight industries and forestall the institution of recent ones,” and thus “arrest the development of a 9 State or put it at a decided drawback.” three 10 32. Further, the pervasive reliance of businesses in every state on apps in mobile 11 ecosystems signifies that anticompetitive conduct within the app distribution market can significantly 12 impact “competition throughout the state.” 13 33. Google’s actions have had and continue to have a considerable impact upon the 14 commerce and commerce within every of the Plaintiff States. 21 Google Payment collects a fee of as much as 30% on many forms of processed funds, 22 including funds for apps bought by way of the Google Play Store and in-app purchases made 23 within those apps, and thus is a social gathering to the anticompetitive conduct at problem right here.

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