LexDigerati http://manishin.com/law Glenn B. Manishin, Esq. :: Lawyering For the Information Age Tue, 11 Jun 2013 16:07:39 +0000 en-US hourly 1 http://wordpress.org/?v=3.5.1 Five Reasons Apple’s Private Antitrust Risks Are Minimal http://manishin.com/law/?p=3301 http://manishin.com/law/?p=3301#comments Tue, 11 Jun 2013 16:07:39 +0000 Glenn http://manishin.com/law/?p=3301 Tech business news these days is dominated by headlines about the trial of United States v. Apple, Inc., where the U.S. Department of Justice (DOJ) is charging Cupertino with masterminding a massive conspiracy among publishers to increase prices for e-books. Apple’s defense lawyers and CEO Tim Cook call the allegations “bizarre.” What is really bizarre, though, is the plethora of private treble-damages lawsuits seeking to hold Apple liable under the antitrust laws for its vertical integration strategy with iTunes, iPhone and the App Store.

Just a bit more than a decade ago, Apple Computer (having since changed its corporate name) was decidedly stuck in the backwater of the PC industry. Its introduction of the USB-only iMac in 1998 failed to change the marketplace dynamics, where Apple’s closed Macintosh design and refusal to license its Mac OS to other manufacturers was viewed as the source of diminishing relevance. Apple was such a non-entity that its presence was flatly rejected by the federal courts as part of the relevant market in the Microsoft monopolization cases. Pundits predicted that like the fabled Betamax, Apple’s proprietary strategy would lead to its ultimate competitive demise.

But then along came the “iLife” software suite and the first generation iPod. What differentiated these products was not that Apple invented the technologies — after all, MP3s had been around for years and digital cameras as well — but rather that they all worked well together. Since then, the same business model has been applied to iPads and iPhones: native sync integrated with the Mac OS and Apple’s iCloud service, plus software content, whether media or apps, available easily through Apple’s online stores, with the company taking a 30% cut of retail prices for third-party content.

A Billion AppsWhen the iPod and iPhone proved to be winners, big ones, Apple’s financial fortunes turned around dramatically. iTunes now is the largest digital music retailer, accounting for some 60% of all downloads, and the various iPhones are the most popular smartphones globally. Apple’s annual revenues soared from $5 billion in 2001 to $108 billion last year. But what short memories we have. The plaintiffs’ antitrust bar accuses Apple of unlawfully monopolizing these markets and has filed a series of sometimes confusing consumer class actions challenging Apple’s vertical integration and closed product systems. (Nine separate lawsuits have been unified into one action in California focusing on the tight grip Apple exerts on the iPhone’s services and applications; other individual and class suits are pending elsewhere.) The EU reportedly has investigated Apple’s App Store restrictions, and more recently its deals with European wireless carriers, to determine whether the company “abused” a “dominant position.”

It’s difficult if not impossible to discern the merits in competition claims that a company’s proprietary product design strategy should be held unlawful. Just as Kodak, once the single largest film, photo developing and camera company in the world, was permitted to introduce new products that were technologically integrated and incompatible with its competition, so too should Apple’s vertically integrated business practices be considered legal. Tech businesses can obviously live or die with their choice on interoperability, but it’s a valid business strategy either way.

Here are five straightforward reasons Apple’s private antitrust risks are minimal:

  • The early class action cases challenging Apple’s alleged iPod “tie” and use of incompatible DRM for its iTunes Music Store did not advance far on the merits, as the courts recognized quickly that “the introduction of technologically-related products, even if incompatible with the products offered by competitors, is alone neither a predatory nor anticompetitive act.”
  • Later private antitrust cases claiming that Apple’s deal with AT&T for the first two years of the iPhone’s history was illegal assert that Apple monopolized the “aftermarket” for voice and data services on the iPhone platform. (That itself is an end-run around the settled rule that one company’s products are not a relevant antitrust market.) Yet consumers knew full well of the two-year AT&T exclusivity commitment before buying an iPhone in 2007, and the voice and data services were provided by AT&T, not Apple — which for legal purposes makes AT&T an essential party. Exclusive dealing typically is not an antitrust issue unless it forecloses a substantial part of the marketplace, which even now, and more so when the iPhone was young, Apple is nowhere close to achieving.
  • Contentions that Apple’s iTunes service is improperly tied to the iPod and iPhone are factually wrong. Any MP3 file (and many other music and video formats) can be imported into iTunes and uploaded to Apple iOS devices, whether they come from artists, Amazon, another online music or video vendor, YouTube or even illegal peer-to-peer piracy. Even if “technological ties” were actionable, and they are not, there’s no compulsion and no technical mandate to buy from the iTunes Store, so consumers have not suffered any harm.
  • App Store challenges are misdirected because while Apple gets a cut, prices are set by app developers, meaning that the restrictions (such as prior approval) imposed by Apple have not had any exclusionary impact on competition. But more cogently, as Apple outside counsel Dan Wall argues, “There’s nothing illegal about creating a system that is closed.”
  • As the smartphone market stands now, plaintiffs cannot demonstrate monopolization because Apple’s share of that market, though growing, remains well below the Android OS collectively and far less than that of major vendors like Samsung. Without a monopoly share, unilateral practices by Apple are simply not illegal under American antitrust law. If Apple begins dominating the mobile advertising market, some of its ancillary practices (i.e., availability of data analytics to competing ad networks) might then come under scrutiny, but the mobile-ad market in general is young, many questions remain and, as in the 2007 Google-DoubleClick acquisition and the 2012 Google-ITA deal, fears that a dominant tech firm will extend its power into adjacent markets are frequently overstated.

Two years ago, Adobe launched a rather public campaign to have DOJ investigate Apple for restrictions excluding Flash technology from the iPhone. Nothing came of that initiative, which was the right competition policy result (whether or not one agrees with Apple’s product strategy) and in the interim Adobe has released a touch version of Photoshop for tablets, is moving to a SaaS model of subscription software, and HTML 5 video and applications now command most attention on the Web. As one commentator observed:

If Apple wants to stump for HTML 5 or some other standard it can. If your iPad doesn’t deliver Flash you can always get annoyed and buy something else. Apple simply doesn’t have the world domination market share in the iPhone or iPad for regulators to give a hoot.

The moral is that closed products can win competitively if they are superior but always run the risk of being leap-frogged technologically or shunned by consumers wanting to mix-and-match components. It’s a decision for markets, not governments.

Apple Store queueSome think the Samsung Galaxy or Google Nexus are poised to supplant Apple’s iPhone/iPad ecosystem by offering more advanced features, updated mobile OSs and a “cool” factor exploited constantly in television advertisements. Maybe Mozilla’s forthcoming Firefox mobile OS will do so. That those are “open” software and devices makes them no less or more favored under the antitrust laws. Apple’s proprietary strategy is working well in today’s marketplace, but as recent history so clearly shows, such a business model is fraught with risk. In the final analysis, the choice of a vertically integrated structure is unlikely to get Apple into antitrust trouble — either private or governmental, and whether in the United States or the EU — unless Tim Cook and company add some seriously bad acts to their competitive arsenal. Building your own mousetrap, especially a segment-leading proprietary one that consumers like, just doesn’t cut it.

It’s almost axiomatic at this point that the larger, wealthier and more powerful a company grows, the more it becomes viewed as a deep pocket. In short, the larger a corporation becomes, the more it is forced to contend with lawsuits, frequently unmeritorious. That’s where Apple stands today. Whether to spend its billions in cash on settlements or legal defense fees will test Mr. Cook’s powers of prediction as the company’s former CFO. Apple settled the iPod tying case but continues to aggressively litigate the consolidated iPhone exclusivity cases. On the pure antitrust merits, however, whether to pay off these class action plaintiffs is a decision Apple really should not have to make.

Note:  Originally prepared for and reposted with permission of the Disruptive Competition Project.

Disco Project

 

]]> http://manishin.com/law/?feed=rss2&p=3301 0 Twitter Digest For Week of 06-03-2013 http://manishin.com/law/?p=3331 http://manishin.com/law/?p=3331#comments Mon, 10 Jun 2013 04:32:12 +0000 Glenn http://manishin.com/law/?p=3331 twitter_logo

 

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]]> http://manishin.com/law/?feed=rss2&p=3298 0 Twitter Digest For Week of 05-20-2013 http://manishin.com/law/?p=3295 http://manishin.com/law/?p=3295#comments Mon, 27 May 2013 04:31:40 +0000 Glenn http://manishin.com/law/?p=3295 twitter_logo

 

]]> http://manishin.com/law/?feed=rss2&p=3295 0 Foundem Has Lost It http://manishin.com/law/?p=3280 http://manishin.com/law/?p=3280#comments Thu, 23 May 2013 18:15:50 +0000 Glenn http://manishin.com/law/?p=3280 In the ongoing saga of governmental antitrust investigations of Google, recent weeks have witnessed a new level of rhetoric and disingenuous use of the regulatory process to handicap, rather than promote, competition and innovation. The current case in point relates once again to search neutrality, but this time complaining rivals remarkably object to getting exactly what they’ve asked for over many years.

Just a little less than four months after the U.S. Federal Trade Commission (FTC) closed its monopolization investigation into alleged “search bias” by Google, the European Commission (EC) — the pan-European competition authority for the 30-nation European Economic Area (EEA) — released a set of proposed commitments by Google designed to resolve the competition “concerns” preliminarily outlined by EC competition chief Joaquin Almunia. That set off a firestorm of criticism from so-called “vertical” competitors (e.g., travel booking or consumer shopping sites), led by UK firm Foundem, a plaintiff against Google in its own antitrust lawsuit in England.

FoundemThe first and most basic competition concern asserted by the EC was that Google gives preference to its own services, like travel search, by placing those “specialised” (in European spelling) search results above “organic” or “natural” search results. Google proposes to label these specialized results as paid placements and to add equally prominent links to vertical rivals alongside. Under the commitments Google would auction links for commercial services to qualifying rivals using a lengthy set of rules for transparent and equal treatment. It is precisely the paid link insertion remedy that Google critic and long-time legal adversary Gary Reback called for at an April 2013 FairSearch.org event in Washington, DC.

Foundem opposes that solution. But making heads or tails of Foundem’s rather incoherent response to Google’s EC settlement proposal is difficult. In part that’s because the response is a hodge-podge of discredited claims, incorrect assumptions and fuzzy reasoning. In part it’s because Foundem’s use of over-the-top language and Chicken Little predictions makes it impossible to decipher facts and reality from mere opinions and sour grapes. For instance:

If the Commission were to adopt Google’s proposals in anything like their present form, it would be unwittingly playing into Google’s hands — aiding and abetting Google in its long running strategy to transition commercial searches away from its natural search results and into its paid advertisements. Under these proposals, Google would not only continue to profit from the traffic it hijacks from rivals, but it would now also profit from the traffic it sends to rivals…. Any vertical search companies that survive the transition to such a radically altered and unfavourable marketplace would be left eking out a living on the slimmest of margins from the scraps left over from the traffic, and now revenues, that Google would be diverting to its own services.

If one separates the adjectives from Foundem’s substantive criticisms, there are four principal contentions it makes.

1. “Universal Search” labeling does not fix organic search manipulation. Foundem says the EC proposal addresses only the “preference” of Google’s own links in a prominent area of its redesigned Universal Search results pages, not the use of search algorithms allegedly to demote links to vertical rivals. “Instead, with a flourish of misdirection, they focus exclusively on its [sic] Universal Search inserts.” Because the commitments “ignore Google’s natural search results, they are misdirected in their application and fall far short of their target.”

2. Paid Rival Links would benefit Google financially. Foundem complains that Google’s proposal to insert paid links to vertical rivals for commercial searches will allow it to “monetise” (again in European spelling) rivals’ Web traffic. The proposal, Foundem claims, would allow Google to become “the main beneficiary of its rivals’ vertical search services as well as its own,” which would “extend Google’s existing monopoly powers and could eventually leave it in sole possession of the efficient, low-overhead, business model that has characterised and fuelled the internet revolution.”

3. Google should be prohibited from applying site quality algorithms. Foundem asserts that the use of website quality metrics designed to weed out malware, spam and search-manipulated sites that lack content is inherently anticompetitive, but that Google’s corresponding commitment to include all vertical rivals absent “some clearly defined Harmful Practices (such as illegal content and consumer deception)” or with “prior individual approval from the [European] Commission” is inadequate.

4. The Google commitments do not extend to non-search services. Foundem complains that ”vertical search was simply the natural first target for Google. Google can (and will, if it isn’t stopped) extend the same abusive practices into other sectors, including e-commerce, auctions, and social networks.” It opposes the proposed commitments because they do not cover these other Internet-based services.

Each of these criticisms is misplaced, but none more so than the claim that the Google proposal should be rejected because it somehow misses the big problem in search. The EC’s principal competition concern was that Google gave undue preference to its own vertical services with the invention of Universal Search. Therefore, inserting links to rivals in that same “preferential,” prominently outlined space above organic search results provides obvious parity between Google’s shopping service, for instance, and Foundem’s consumer electronics listings. The second concern was that Universal Search deceives users into thinking results are something other than promotion of Google’s own commercial services because the lack of a clear distinction between a promoted link and normal search results “left some consumers less able to make an informed choice.” Hence, as I’ve addressed in detail before, a label remedy is precisely the right solution to what is, at heart, a contention of misleading trade practices.

The FTC notably concluded that Google’s switch to Universal Search was a bona fide search innovation that benefited consumers. Mr. Almunia has made essentially the same concession. To the extent Foundem believes the practice is inherently anticompetitive and should be banned, as it appears, its critique is inapposite to an evaluation of the effectiveness of Google’s proposed EC commitments. Even in Europe, competition authorities do not outlaw products developed by firms with market power, and EC competition law, like that in the US, is strongly disinclined to sanction an antitrust case based on allegations of “anticompetitive product design.”

The reason for this restraint is simple: competition officials and courts are not engineers or businessmen and thus have no objective basis on which to assess whether product designs are “good” or not. That is a decision left to the marketplace, with consumers literally voting with their clicks and wallets. Indeed, such reserve is essential in technology markets, where product innovation occurs at the speed of light in and in which user interface and consumer experience are so subtle and competitively important. It is the reason former FTC chairman Jon Leibowitz — on behalf of a unanimous, politically diverse five-commissioner agency — rejected calls that antitrust should be used to “regulate the intricacies of Google’s search algorithms.” Ditto Mr. Almunia, who likewise told the Financial Times back in January that his concern is “the way they present their own services” and that he was “not discussing the algorithm” used for Internet search.

Foundem’s other critiques are nonsensical. Including Paid Rival Links alongside Google’s own universal shopping and commercial links (themselves paid) requires someone to set a fair price. That is something bureaucrats and antitrust agencies again do not do well, if at all, but an auction does perfectly. There is plainly no room to include links for every commercial search site on every Google search results page, so an auction system allocates that scarce space to businesses based on their own financial calculus of the benefit of preferential placement. That’s not monetizing rivals’ traffic and does not require Foundem or any other Google competitor to participate. If these Paid Rival Links are as worthless as Foundem implies, then its prediction of Google using them as a way to usurp competitors’ revenues is especially silly, because the auction prices will be negligible. Indeed, to suggest that paid placement is for some reason invalid as a competitive search service represents the height of hubris for Foundem, whose business model is to sell all search results. If paid placement is OK for Foundem it is equally permissible for any other search firm, small or big or anywhere in between.

It’s hard to take seriously a company which contends that site quality algorithms are invalid, when we all know the entire SEO, pornography and content piracy industries try their damnedest to game search results and avoid content filters established by responsible search engines like Google. Foundem never explains why the objective criteria Google has committed to apply do not resolve its allegation that rival links were targeted for demotion unfairly. While I personally disagree with the need or justification for any such remedy, the fact is that Google’s proposed settlement directly addresses organic link results by precluding exactly the type of targeted “link demotion” that FairSearch.org, Mr. Reback and Foundem itself have long alleged Google engages in as a matter of ordinary course.

Lastly, consider for a brief moment Foundem’s odd criticism that Google has not offered proposals for “other sectors” like auctions and social networks. Foundem itself does not operate in those markets, which are obviously not Internet search. With the rather spectacular failure to date of Google+ to challenge Facebook and Twitter, or any Google service to take on eBay, no one has even claimed Google has any chance of monopolizing these very different markets. When and if there are problems of Google accumulating market power in new services against entrenched Web firms — an eventuality that is all but inconceivable today — antitrust authorities can intervene. To do so in a case about allegations of Web search dominance and abuse is unseemly by any standard, European or American.

Note:  Originally prepared for and reposted with permission of the Disruptive Competition Project.

Disco Project

 

]]> http://manishin.com/law/?feed=rss2&p=3280 0 Twitter Digest For Week of 05-13-2013 http://manishin.com/law/?p=3278 http://manishin.com/law/?p=3278#comments Mon, 20 May 2013 04:39:44 +0000 Glenn http://manishin.com/law/?p=3278 twitter_logo

 

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]]> http://manishin.com/law/?feed=rss2&p=3275 0 Defamation, Autocomplete And Search Royalties: How Not To Govern the Internet http://manishin.com/law/?p=3249 http://manishin.com/law/?p=3249#comments Mon, 06 May 2013 16:09:33 +0000 Glenn http://manishin.com/law/?p=3249 With the controversy surrounding the International Telecommunications Union (a UN treaty organization) just recently subsiding, it is time to take a look at Internet governance from a different perspective. We all know that laws and legal principles differ among countries. What many do not realize is that these laws — most completely non-tech oriented — are having a massive and negative impact on Internet innovation.

In America we proudly have the First Amendment, the fair use doctrine and the DMCA. The first limits the reach of liability for libel (defamation) at least to cases, for non-celebrities, where a publisher is at fault (i.e., negligent). Section 230 of the last allows ISPs, websites and Internet hosts a legal safe harbor from copyright and other legal offenses resulting from user-generated content or any other content that a customer, client or some third-party has published. These landmark legal regimes are hallowed in the U.S., for instance used to strike down overreaching Web censorship efforts by federal government. Fair use, in turn, permits non-commercial or transformative use of a portion of copyrighted content. Think Google image search thumbnails or blockquotes from a news source in someone’s blog or a movie clip in a televised review.

Things are very different elsewhere. Three cases in point.

  1. In Germany and perhaps soon other EU nations, search engines that display snippets of indexed Web pages in response to user queries are now by statute responsible for paying copyright royalties to the original publisher, regardless of whether the content owner charges for its stories with a paywall. 
  2. In France, Italy, Ireland,  Australia and now Japan, courts permit individuals to recover for libel based on autocomplete and search results that return incorrect or harmful personal information, but against the search provider, not the writer or content publisher.
  3. A Denmark court ruled deep linking illegal, as did Germany, leading some to believe that linking to a website other than the front page was illegal throughout Europe. While the German courts overturned that decision, it was Agence France Presse (AFP) which eventually sued Google News for brazenly daring to send search  traffic to the organization’s news articles.

AutomcompleteThese results are foreign, literally, to U.S. jurisprudence. But they also illustrate a vitally important point. Legal regimes that have nothing to do with the Web are being applied in ways which upset existing services users take for granted and that threaten to impede future innovation.  Linking is inherent in HTML and represents the essence of the Web. No one in America would argue seriously today that a hypertext URL link represents copyright violation. Search “autocomplete,” in turn, is not a creative activity, but a very useful technical advancement; it applies computer algorithms based on past searches to predict what the current user wants to see, speeding the retrieval of information from the Web.

Permitting autocomplete defamation suits against Google or Bing because other Web users have searched for information that damages an individual’s reputation is alien to our American way of thinking. It’s censoring completely accurate factual information about stuff on the Web, although that stuff may itself be factually wrong.  The augmentation of liability is also just plain silly, because both autocomplete queries and search results themselves merely return an indexed link to something someone else has posted on the Web.

By moving liability beyond the content publisher to search intermediaries like Google and Microsoft, these countries are playing with fire. It is one thing for U.S. tech companies to tailor their offerings a bit in order to comply with repressive foreign regimes; at least some information gets through to the citizens. It is quite another for these and other tech firms to change their business models or service offerings merely to avoid unjustified efforts to delve into their deep financial pockets as an easy remedy for folks pissed about some bad remarks about them appearing on the Web. And the copyright royalty movement for publishers is even more absurd.  As EFF commented:

Newspapers across Europe in particular have sought to prevent third parties from linking to or displaying excerpts of their news content unless those sites provide proper notice to the news publisher and pay royalty fees for what the papers determine to be “commercial use.” Rather than revel in the benefits of more traffic, these newspapers demand that search engines and third-party sites give them a cut of profits that come associated with the sale of advertisements.

By using copyright royalties as an unvarnished mechanism to protect brick-and-mortar newspaper publisher revenues, these European countries are unabashedly applying their non-tech laws to punish disruptive technologies, in a way that harms the openness of the Web, deprives their citizens of the full benefits of Internet content and represents blatant economic protectionism. In February, Google defused French President François Hollande’s threat to pass a compensation law by agreeing to spend €60 million to support French publishers developing their online businesses, but France is now reconsidering such a law, in Germany’s wake. Earlier, and remarkably, France fined Google some $660,000, this time on competition grounds, for providing Google Maps free of charge, thus challenging traditional atlas and gazette publishers. And in Belgium, the courts have ordered Google to remove its cache of all indexed content for Belgian publishers.

One Japanese court justified imposing defamation liability on search providers on the ground that ”A situation has been created by which illegally submitted documents can be easily viewed,” according to chief judge Hisaki Kobayashi as quoted in the Mainichi Shimbun newspaper. That’s precisely the problem. The whole utility of the Internet lies in making information more easily available. If that content is wrong or damaging, the answer lies in going after those responsible for it, not search engines, ISPs or web hosting providers.

In the U.S., this is why Congress early on (1998) created a “notice-and-takedown” paradigm. (Attempts to evade the legal protections available in the U.S. by relying on older common law rationales like “false light” invasion of privacy have, to date, all been unsuccessful.) If YouTube gets a copyright notice and removes the offending content, it is immune from monetary liability. That’s great for the Internet and innovation, but bad for Viacom — which has to police for infringing Cartoon Network clips — and for traditional newspapers, which must go after small bloggers and others who pirate their content. Our system does not allow the costs of content protection and compliance to be shifted from content publishers to Web hosts and search providers. Yet that’s not the case in Europe at all. YouTube users in Germany regularly encounter a notice that the streaming service cannot show a requested music clip because of a continuing dispute with Gema, the German songwriters’ rights society, over music royalties, and Google rightfully says the same thing will happen to German Google News users because it would be forced on cost grounds to stop posting news links and article snippets.

Kashmir Hill put it quite nicely in Forbes about the potential for disastrous consequences:

An American court would likely never come to the same conclusion, but the [French autocomplete defamation case] sets a bad precedent for Google in Europe. There are quite a few people and companies out there who may have suggestions for their names that could be considered defamatory. (Ahem. Max Mosley.) Who else is going to line up to sue Google over the crowd-sourced caprices of autocomplete? If the lawsuits pile up, will Google have to bid the feature au revoir?

If the rest of the world really wants to have a global system for Internet governance, as many urged before the ITU over the Obama Administration’s objections, they had first better get on board by updating their legal systems to remove archaic rules like these that serve only to retard technological progress and Balkanize the World Wide Web. And just as Yahoo! opposed (and finally defeated) French efforts more than a decade ago to impose liability on it for hosting an auction site on which users posted ads for Nazi memorabilia — the sale of which is illegal in France — Google should be commended for leading the opposition to the latest use of copyright and damages liability as a means of censorship of the Web. The German society of start-up entrepreneurs, to its credit, thinks so as well.

Note:  Originally prepared for and reposted with permission of the Disruptive Competition Project.

Disco Project

 

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