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with of Google's users visiting another general search service in a single month. If users try other general search services, yet chose to return to Google, this can only demonstrate that Google is successfully competing by offering innovative and high- quality service showing the most relevant results.

(v) None of the "other factors" under Section 19(4) of the Act give Google market power None of the other factors the Investigation Report relies on can establish Google's dominance in search. First, Google's size and resources do not distinguish it from its rivals, such as Microsoft, Yahoo!, and Amazon. Second, search is not subject to direct or indirect network effects. Third, returning high-quality search results is largely dependent on technological capabilities unrelated to query scale; the benefits of scale are subject to significant diminishing returns. Fourth, search is not characterised by substantial barriers to entry and expansion - particularly given recent developments in cloud computing and open-source PUBLIC VERSION software. Fifth, Google is not vertically integrated in a way that conveys market power in search. Sixth, users and websites do not "depend" on Google - as shown by traffic source data contained in the Investigation Report itself.