Streetmap.EU Ltd v Google Inc
Google's display of its own map in search results was not an abuse of its dominance in search, because it was not reasonably likely to harm competition appreciably in the market for online maps and was objectively justified.
Facts
Streetmap, a British provider of online maps, claimed that Google had abused its dominant position in the market for general search, by displaying a thumbnail of Google Maps at the top of its search results for location queries, with a link to Google Maps, while links to other map providers appeared only further down. Streetmap claimed that this caused it to lose traffic and revenue.
Legal principle
Roth J dismissed the claim. He held that, to establish an abuse in this context, it was necessary to show that the conduct was reasonably likely to have an appreciable effect on competition in the market for online maps, and not merely that it had some effect. The evidence did not show that Google's conduct was reasonably likely to have an appreciable effect on competition, because Streetmap had been losing ground for other reasons. In any event, the conduct was objectively justified, because it improved the quality of Google's search service, and was proportionate. The decision was given before the Commission's Google Shopping decision.
Related cases on predatory and excessive pricing, refusal to supply and essential facilities
- AKZO Chemie BV v Commission Case C-62/86, [1991] ECR I-3359
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- Competition and Markets Authority v Flynn Pharma Ltd [2020] EWCA Civ 339
- Huawei Technologies Co Ltd v ZTE Corp Case C-170/13, EU:C:2015:477
- IMS Health GmbH & Co OHG v NDC Health GmbH & Co KG Case C-418/01, [2004] ECR I-5039
- Istituto Chemioterapico Italiano SpA and Commercial Solvents Corp v Commission Joined Cases 6 and 7/73, [1974] ECR 223
- Konkurrensverket v TeliaSonera Sverige AB Case C-52/09, [2011] ECR I-527
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