The identification and measurement of market power and entry barriers, and the evaluation of collusive, exclusionary, or predatory conduct or conduct violating FTC-enforced consumer protection statutes, in markets featuring "platform" businesses #FTC-2018

Submission Number:
Brian Chappell
North Carolina
Initiative Name:
The identification and measurement of market power and entry barriers, and the evaluation of collusive, exclusionary, or predatory conduct or conduct violating FTC-enforced consumer protection statutes, in markets featuring "platform" businesses
Google is morphing from a turnstile to the web into a portal designed to keep people on and is thus harming consumers and businesses alike. I am specifically commenting on behalf of myself and all businesses that have been displaced by Google over the years. Consumers and businesses are harmed when Google raises the costs of people trying to share helpful information with consumers. They do this by not letting users leave Google as I document below. If users dont go to websites, then businesses cant make money. I am a professional Webmaster with over 13 years experience observing and interacting with Google activities. I have managed over 50 different businesses, websites, and search engine traffic in those 13 years. Through my involvement in the industry, I have gotten to know some of the employees at Google on the Search team that attempt to publicly interact with the greater Webmaster community. Google holds a near monopolistic position around the market of Information [1] and Google is walking a slippery line with how they are portraying information through their SERPs (Search Engine Result Page, i.e., what you see when you search for something through Google). In the past 3 years Google has been very aggressive with how they showcase the worlds information without prominently displaying non-Google websites. When webmasters first let Google crawl their site it was with the intention of Google showing that information in their search engine and showing webmasters websites alongside that information. Google is presenting search results and links to Googles own sites and interests to the detriment of non-Google clients. (see Appendix examples) Obviously such an approach to content steering would give Google results significant priorities, and should come as no surprise. They no longer want to send users to websites unless they are making a cut off each click. I believe this because 2 years ago I had dinner with a Googler that works on the search quality team. He explained that Googles new strategy was to keep users on Google; no longer did they want to send them to your website. I have been watching this slowly play out and I am now bringing it to your attention as the effect of this policy becomes more apparent. It is my professional opinion that Free search traffic (also known as Organic results in the SERPs) will die a slow death unless Googles practices of removing Organic traffic are stopped. Exit traffic off Google properties should be Paid for by businesses in Googles eyes and / or limited at all costs (i.e. keep them circulating on Google properties during research phases) Evidence of this is displayed by watching the systemic routing of organic traffic while better featuring paid traffic. Below you will find data that supports my claim showing just how much free traffic Google has taken back. This is a graph of the reduction of organic traffic (the free traffic in search engines). This data set came from the team at in 2017. Looking at 2015 vs 2017 data for all keywords ranking organically on the first page, weve seen a dramatic change in CTR (click through rate to websites). Below weve normalized our actual CTR on a 110 scale, representing a total drop of 25% of click share on desktop and 55% on mobile. Organic receives 25% less desktop CTR and 55% less mobile CTR compared to two years ago as of 2017 when this data was pulled. [2] With such a strategy, Google will likely continue to displace websites and become the dominant platform for the worlds information at the expense of businesses and consumers. I, as well as hundreds of thousands of other businesses in the US, cannot afford to run our businesses without free search engine traffic. I want my children to still have an opportunity to innovate, just how the advent of the Internet gave me an opportunity. I urge the FTC to once again, take a very deep look at Google. Google started executing the above strategy on the back of the closing of the last FTC investigation. Note: I am also concerned over retaliatory actions taken by Google against the many businesses I represent in bringing this information to you. I have seen anecdotal evidence over the years of Google harming companies to set a Public Relations storyline. [3] I am willing to testify to the above experience. My message to anyone at Google reading this, it didnt have to be this way. You could have shaped the product to be much different than what it is today. [1] [2] [3]