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UNITED STATES OF AMERICA v. GOOGLE LLC — Entry #1574: Third STATUS REPORT on Google's Compliance with the Final Judgment by UNITED STATES OF AMERICA

Case: UNITED STATES OF AMERICA v. GOOGLE LLC dcd · 1:20-cv-03010

filed October 20, 2020

What this document is

Docket entry #1574 · filed November 10, 2026

Third STATUS REPORT on Google's Compliance with the Final Judgment by UNITED STATES OF AMERICA. (Gordon, Joseph)

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Case 1:20-cv-03010-APM            Document 1574        Filed 11/10/26      Page 1 of 22


                      IN THE UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF COLUMBIA


 United States of America, et al.,

                                                      Case No. 1:20-cv-03010-APM
                                 Plaintiffs,

                                                      HON. AMIT P. MEHTA
 v.

 Google LLC,

                                 Defendant.

 State of Colorado, et al.,
                                                      Case No. 1:20-cv-03715-APM
                                 Plaintiffs,
                                                      HON. AMIT P. MEHTA
 v.

 Google LLC,

                                 Defendant.


                   PLAINTIFFS’ THIRD STATUS REPORT AS TO
            THE ENFORCEMENT OF AND GOOGLE’S COMPLIANCE WITH
                            THE FINAL JUDGMENT

        Pursuant to the Court’s request at the hearing held on September 18, 2026, Hr’g

Tr. 59:03–11 (Sept. 18, 2026), and the Minute Entry of that same date, Plaintiffs in the above-

captioned cases jointly file this Status Report. 1


1 Unless otherwise stated, all references to “sections” herein are to sections of the Final

Judgment.


      Case 1:20-cv-03010-APM          Document 1574         Filed 11/10/26     Page 2 of 22


I.     INTRODUCTION

       Section VII.E requires Plaintiffs, with input from the Technical Committee (“TC”), to file

a status report within 90 days of the Effective Date of the Final Judgment to update the Court “as

to the enforcement of and Google’s compliance with this Final Judgment,” with additional status

reports due on future dates to be set by the Court. ECF No. 1462, § VII.E [hereinafter “Final J.”].

Plaintiffs filed the first such report on May 4, 2026 (“First Status Report”). ECF No. 1512. The

second status report was filed on September 17, 2026 (“Second Status Report”). ECF No. 1552.

       Part II below provides an update on TC Operations. Part III describes ongoing efforts by

Plaintiffs and the TC to implement and enforce the Final Judgment. Part IV describes Google’s

compliance with the Final Judgment to date, which also reflects information provided by

Google’s counsel and efforts by Plaintiffs and the TC to monitor Google’s compliance.

II.    UPDATE ON TC OPERATIONS

       Since the Second Status Report, the TC has continued building out its operations and

organization such that it can carry out its obligations under the Final Judgment.

       A.      Insurance and Indemnification

       Since the last Status Conference, held on October 30, 2026, the Parties and the TC’s legal

and insurance teams have consistently engaged to address outstanding issues relating to TC

indemnification and insurance. See ECF No. 1573 at 2–3. The first meet and confer was held on

October 30, 2026. Following that call, on November 2 and November 3, 2026, the TC’s legal and

insurance teams gathered additional information and provided Google with an updated proposal

regarding matters relating to indemnification, including insurance quotes and proposed language

amending the TC Members’ Indemnification Agreement. The Parties and the TC’s legal and

insurance teams then met and conferred on November 3, 2026, to discuss the updated proposal.


                                                 2


     Case 1:20-cv-03010-APM           Document 1574        Filed 11/10/26      Page 3 of 22


       On November 4, 2026, Google provided a counterproposal regarding insurance for TC

Members and TC Staff as well as spoke with the TC’s legal team regarding the same. On

November 5, 2026, Google provided a counterproposal regarding adjustments to the TC

Members’ Indemnification Agreement.

       On November 6, 2026, in response to Google’s requests, the TC’s legal and insurance

teams provided Google with policy documents for the various lines of insurance coverage. The

legal team further responded to Google’s counterproposal on the TC Members’ Indemnification

Agreement, accepting almost all of Google’s proposed changes. On November 9, 2026, Google

responded and requested additional information regarding the insurance policies, which the TC’s

legal and insurance teams are reviewing.

       As noted in the Joint Status Report filed on November 6, 2026, the Parties appear close to

reaching agreement on all outstanding disputes relating to TC insurance and amendments to the

TC Member Indemnification Agreements. ECF No. 1573 at 2. The Parties are continuing to

confer to reach agreement on these issues and will provide a further status update on this topic on

Friday, November 13, 2026, at which time the Parties will notify this Court if further guidance or

assistance is necessary.

       B.      TC Budget and Recent Hiring

       The TC has been actively planning for its next fiscal year, which will begin on

February 1, 2027. To that end, the TC submitted its proposed annual budget for the 2027-2028

fiscal year to Plaintiffs, who in turn reviewed and conferred with the TC regarding the same. On

October 30, 2026, Plaintiffs approved the budget (“Approved Annual Budget”), and the TC

provided Google a copy of the Approved Annual Budget and related invoice. Pursuant to the

Parties’ previous discussions, Plaintiffs and the TC understand that if Google has any objections


                                                3


     Case 1:20-cv-03010-APM            Document 1574        Filed 11/10/26      Page 4 of 22


to the Approved Annual Budget, Google will provide those objections to Plaintiffs and the TC in

writing by November 16, 2026, and will notify the Court of its intent to raise any outstanding

objections on November 30, 2026, with a proposal to file a Joint Status Report on such issues on

December 7, 2026.

       With respect to staffing, pursuant to the TC’s staffing plan, the TC has continued to hire

new personnel progressively across the current fiscal year to meet the TC’s needs as workloads

increase and Plaintiffs and the TC progress in implementing the remedies.

       C.      Source Code Agreement, Access, and Supplemental Protective Order

       The Final Judgment provides that “[t]he TC shall have access to Google’s source code

and algorithms, subject to a confidentiality agreement, as approved by Plaintiffs” (“Source Code

Agreement”). Final J. § VII.A.7.d. On September 16, 2026, following an extensive meet and

confer process, the Parties submitted to the Court a Joint Status Report setting forth their

outstanding disputes on the draft agreement. ECF No. 1549. On September 18, 2026, the Court

held a hearing on those disputes, after which the Parties were able to resolve the issues and

finalize the Source Code Agreement. Minute Entry dated Sept. 18, 2026; ECF No.1555. As of

October 1, 2026, all five of the TC Members had signed the Source Code Agreement.

       Pursuant to the Source Code Agreement, Google is to provide access to certain Google

Highly Sensitive Information (“GHSI”) through Google-managed Chromebook computers. ECF

No. 1555-1 at § 3.2. More specifically, Google has created a new remote environment especially

for the TC, which can be accessed by siloed Chromebooks provided by Google.

       The TC Members have received their individual Chromebooks. Additional steps are

necessary before the TC and staff can access GHSI, including but not limited to the algorithms

and user data. To be operational, the remote environment needs to be loaded with material that


                                                 4


     Case 1:20-cv-03010-APM            Document 1574         Filed 11/10/26      Page 5 of 22


will enable the TC to access certain Google data, code, and programs. During the September 18

hearing, the Court inquired as to Google giving the TC a “tour” of Google’s network, so that the

TC could see what types of information may be available. Hr’g Tr. 29:19–30:14, 54:07–19

(Sept. 18, 2026). On October 7, 2026, Google sent a letter to the TC advising that Google was in

the process of arranging “tours” of various Google systems and technical documentation. The

letter further requested that the TC identify what data or code the TC believes it must inspect to

perform its duties under the Final Judgment, as well as the types of exercises the TC intends to

undertake to analyze or otherwise work with that information, so that Google may identify the

appropriate programs to make available.

       On October 28, 2026, the TC provided a comprehensive response, proposing multiple

structured technical sessions and identifying the data, code, and documentation the TC needs to

inspect. The TC further identified the types of exercises that it intends to undertake as well as the

tools those exercises require. Also on October 28, the TC sent a separate letter requesting that

Google arrange a virtual meeting or series of meetings during which Google engineers could

guide the TC Members through various identified tasks, using the Chromebooks provided by

Google and the services accessible through them. The letter further made clear that the sessions

must enable the TC Members to execute the tasks themselves, rather than solely observe

demonstrations performed by Google engineers.

       At Google’s request, on November 3, 2026, a call was held between the TC, Google’s

outside and in-house counsel, and Google’s point of contact for the TC for Chromebooks, to

discuss the requests in the TC’s October 28 letters. During that call, Google requested additional

meetings to clarify the TC’s requests for six systems tours. The first clarification meeting and the

first of seven tours occurred on November 9, 2026.


                                                  5


       Case 1:20-cv-03010-APM         Document 1574        Filed 11/10/26      Page 6 of 22


        In addition to the SCA, Google proposed entering a Supplemental Protective Order

(“SPO”) to further safeguard GHSI, pursuant to a request made under paragraph 27 of the

existing Protective Order, ECF No. 98. The Parties are negotiating the contours of an SPO,

which is critical for continuing progress in implementing the remedies. Following their most

recent meet and confer on November 10, 2026, the Parties appear close to agreement. To the

extent they are unable to resolve any remaining disputes, the Parties will seek the Court’s

assistance.

        D.     TC Website

        In furtherance of Sections VII.C.3 (TC complaint submissions) and IX.V (Qualified

Competitor certification) of the Final Judgment, the TC is developing a website to provide third

parties with public information regarding this Court’s remedies, as well as to implement

processes for contacting the TC with inquiries, complaints, or other submissions. The initial

release of the TC’s website is now live at https://remediestc.org. This TC website currently

includes public information regarding this Court’s remedies and a streamlined contact form for

messaging the TC. Plaintiffs and the TC expect that this website will be updated periodically to

reflect updates relating to the implementation of the Final Judgment, including processes for

submitting complaints to the TC and applying to become a Qualified Competitor.

III.    IMPLEMENTING THE FINAL JUDGMENT’S REMEDIES

        A.     Syndication Remedies (Sections V and VI.B)

        Sections V.B and VI.B require Plaintiffs and the TC, with input from Google, to create

and submit to the Court template search syndication and Search Text Ads 2 syndication licenses

(“Recommended Syndication Template”). After an objection period previously agreed upon by


2 The term “Search Text Ads” is defined in Section IX.Y of the Final Judgment.


                                                 6


     Case 1:20-cv-03010-APM           Document 1574        Filed 11/10/26      Page 7 of 22


the Parties, see ECF No. 1528-1 at 2–4, Plaintiffs submitted the Recommended Syndication

Template to the Court on October 9, 2026, which reflected Plaintiffs’ and the TC’s consideration

of Google input, as well as the TC’s expertise and analysis of Google’s commercial syndication

agreements and terms in alignment with the Final Judgment. ECF Nos. 1559, 1559-1. On

October 16, 2026, the Parties submitted a Joint Status Report regarding the Recommended

Syndication Template and Google’s outstanding objections thereto. ECF No. 1562.

       The Court then held a hearing on October 30, 2026, during which this Court requested

(1) additional information from the TC regarding the use of syndicated search results within

GenAI Products and the pricing of remedial syndication services and (2) a status update from the

Parties regarding any remaining disputes relating to the Recommended Syndication Template.

Hr’g Tr. 102:7–17, 103:4–104:2, 105:8–15 (Oct. 30, 2026). On November 6, 2026, the Parties

provided an interim status update regarding the Recommended Syndication Template and

proposed submitting a further update on November 16, 2026. ECF No. 1573.

       Plaintiffs and the TC are working diligently to provide this Court with additional

information responsive to its technical and pricing questions. See Hr’g Tr. 103:4–104:2 (Oct. 30,

2026). Plaintiffs expect to submit the TC’s responses regarding the use of syndication within

GenAI Products later this week. Given the time needed to compile additional information

responsive to this Court’s pricing questions, including information provided by third parties,

Plaintiffs expect to submit the TC’s responses to those questions on a later date this month. See

id. at 103:4–104:12.

       In parallel, Plaintiffs and the TC are working expeditiously to address Google’s

outstanding objections to the Recommended Syndication Template while ensuring the

Recommended Syndication Template remains in compliance with the Final Judgment and this


                                                 7


     Case 1:20-cv-03010-APM             Document 1574         Filed 11/10/26       Page 8 of 22


Court’s envisioned purpose of the syndication remedies. See Hr’g Tr. 5:6–23 (Oct. 30, 2026)

(articulating purpose of providing a “bridge for [Q]ualified [C]ompetitors to provide quality

query results that they, in their present state, didn’t have the capability of doing”). Plaintiffs are

hopeful that the Parties will be able to resolve many of Google’s objections within the month of

November, such that a version of the Recommended Syndication Template can be finalized in

December. However, Plaintiffs expect that certain disputes regarding the Recommended

Syndication Template may remain following further conferrals between the Parties. The Parties

will provide this Court with a further status update regarding the timeline for implementing a

version of the Recommended Syndication Template next Monday, November 16, 2026.

        B.      Data Sharing License Template (Section IV)

        Pursuant to Section IV.B, Google is required to make certain Web Search Index and User-

side Data available to Qualified Competitors. 3 To that end, Section IV.C.3 requires Plaintiffs and

the TC, with input from Google, to create and submit to the Court a template license governing

the use of data shared pursuant to Section IV (“Recommended Data Sharing Template”).

Plaintiffs and the TC provided Google the Recommended Data Sharing Template on

September 21, 2026, along with the Recommendation Statement and Basis Statement. Google

sent Plaintiffs and the TC their objections on October 20, 2026. Plaintiffs and the TC are

continuing to revise the template based on Google’s objections and subsequent meet and confers

with Google. Plaintiffs intend to send an updated version of the Recommended Data Sharing

Template to Google on November 12, 2026. Pursuant to the Court’s Minute Order entered on


3 The Terms “Qualified Competitor” and “User-side Data” are defined in Sections IX.V and

IX.EE, respectively.


                                                   8


     Case 1:20-cv-03010-APM            Document 1574        Filed 11/10/26      Page 9 of 22


October 27, 2026, the Parties will file the Recommended Data Sharing Template with the Court

on November 16, 2026, and will submit a Joint Status Report on November 23, 2026.

       C.      Qualified Competitor Certification (Section IX.V)

       To benefit from the Court’s syndication and data sharing remedies, an entity must become

a Qualified Competitor under the Final Judgment. To do that, the entity must: (1) meet Plaintiffs’

approved data security standards, as recommended by the TC; (2) agree to regular data security

and privacy audits by the TC; (3) make a sufficient showing to Plaintiffs, in consultation with the

TC, of a plan to invest and compete in or with the general search engine and/or Search Text Ads

markets; and (4) pose no risk to the national security of the United States. See Final J. § IX.V.

       Plaintiffs and the TC continue to develop the procedures for certifying Qualified

Competitors. Such procedures will include, for example, determining the certification criteria,

creating the application process, identifying the information that must be provided and how it

will be evaluated, and developing processes for managing Qualified Competitor audits. As

referenced in Part II.D supra, Plaintiffs and the TC expect to update the TC’s website at the

appropriate time with information regarding the Qualified Competitor process.

       D.      Search Text Ads Auction Remedy (Section VI.A)

       Under the Final Judgment, “Plaintiffs [must] submit a proposal to the Court, informed by

the [TC]’s views, by which Google [must] periodically provide [to] the [TC] and Plaintiffs a

report outlining all changes to its Search Text Ads auction meeting certain parameters and, for

each change (1) Google’s public disclosure of that change or (2) a statement why no public

disclosure is necessary.” Final J. § VI.A.

       As discussed in Plaintiffs’ Second Status Report, the TC cannot fulfill its obligations

under Section VI.A without access to data from Google’s Search Text Ads auction. ECF


                                                 9


      Case 1:20-cv-03010-APM          Document 1574         Filed 11/10/26      Page 10 of 22


No. 1552 at 14. In one of its demand letters sent to Google on October 28, 2026, regarding the

tours of Google’s systems, the TC described its request for materials and tours related to

Google’s Search Text Ads auctions. Please see Part II.C supra regarding those efforts. The TC

will continue to seek additional information related to the Search Text Ads auction remedy.

        E.     Data Privacy Safeguards

        Contemporaneous with developing the Recommended Syndication Template and

Recommended Index and Data Sharing Template, the TC has been developing protocols for

handling User-side Data and other security safeguards.

        To continue making meaningful progress in these data privacy initiatives, however, the

TC must be able to understand Google’s mechanisms for securing and operating critical system

components. Being able to access those systems is a necessary predicate to that effort. As

discussed in Part II.C supra, the TC is currently engaging with Google to gain access to those

systems pursuant to the Source Code Agreement.

IV.     GOOGLE’S COMPLIANCE WITH THE FINAL JUDGMENT

        A.     Google Complaint Website (Section VII.C.2.a)

        The Final Judgment provides that “[t]o facilitate the communication of complaints and

inquiries by parties, the Compliance Officer shall place on Google’s website, in a manner

acceptable to the Plaintiffs, the procedures for submitting complaints.” Final J. § VII.C.2.a. In the

time since the Second Status Report, Google launched its complaint website, which can be found

at https://support.google.com/legal-help-center/answer/18649250?hl=en. On October 13, 2026,

the website went live and was made searchable through web search and through search of

Google’s support pages.


                                                 10


     Case 1:20-cv-03010-APM          Document 1574         Filed 11/10/26      Page 11 of 22


        Google is monitoring information received through the website and will address any

complaints concerning its compliance with the Final Judgment in accordance with Section 7.C of

the Final Judgment.

        B.         Responses to Demand Letters

        Since the Second Status Report, the TC continues to issue demand letters to Google

pursuant to Section VII.A.7.c, seeking interviews and information relevant to forthcoming

remedial recommendations as well as source code and data access. These additional demand

letters include:

       An October 15, 2026, follow-up letter seeking information regarding User-side Data. The
        TC received two responses from Google, one on October 26, 2026, and the other on
        October 30, 2026.

       An October 15, 2026, follow-up seeking information on the web search index. The TC
        received one response from Google on October 26, 2026.

       An October 27, 2026, demand letter requesting information regarding Google’s
        syndication agreements and business. The TC received Google’s response regarding the
        requested syndication agreements on November 6. Google’s response indicated that it is
        pulling additional data in response to the request.

       An October 28, 2026, demand letter requesting walkthroughs and information related to
        the Chromebooks that are to be issued to the TC.

       An October 28, 2026, demand letter requesting additional information to address
        deficiencies in Google’s response to the TC’s July 21, 2026, demand letter entitled
        “Request for Information Concerning Section VI.A Search Text Ad Auction Disclosures.”

       An October 28, 2026, demand letter seeking walkthroughs and information related to
        Google’s Search Text Ads system.

With respect to the October 28 demand letters, the TC and Google held a call on November 3,

2026, to discuss the TC’s demands. Pursuant to that call, the first of seven tours requested to date

took place on November 9, 2026.


                                                 11


    Case 1:20-cv-03010-APM            Document 1574         Filed 11/10/26      Page 12 of 22


       Plaintiffs and TC are working in good faith to resolve issues relating to these demand

letters with Google. See Part II.C, supra. Plaintiffs will promptly seek the Court’s assistance if

there are obstacles to obtaining the necessary information requested in these demand letters.

       C.      Other Efforts

       Google continues its preparatory work to comply with the data-sharing and syndication

requirements in Sections IV–VI of the Final Judgment.


Dated: November 10, 2026

                                              /s/ Joseph L. Gordon _
                                              Claire M. Maddox (D.C. Bar #498356)
                                              Travis R. Chapman (D.C. Bar #90031151)
                                              Danielle G. Hauck
                                              Grant M. Fergusson (D.C. Bar #90004882)
                                              Emma Waitzman (D.C. Bar #1738427)
                                              Ryan T. Karr
                                              Joseph L. Gordon (D.C. Bar #90027976)

                                              U.S. Department of Justice
                                              Antitrust Division
                                              Technology & Digital Platforms Section
                                              450 Fifth Street NW, Suite 7100
                                              Washington, DC 20530
                                              Telephone: (202) 549-7155
                                              Claire.Maddox@usdoj.gov
                                              Travis.Chapman@usdoj.gov

                                              Counsel for Plaintiff United States of America


                                                 12


    Case 1:20-cv-03010-APM            Document 1574    Filed 11/10/26      Page 13 of 22


By: /s/ Amanda Wentz                              By: /s/ Charles Thimmesch
Amanda J. Wentz                                   Christopher Carr, Attorney General
Assistant Attorney General                        Logan B. Winkles, Deputy Attorney
Office of the Arkansas Attorney General           General
101 West Capitol Avenue                           Ronald J. Stay, Jr., Senior Assistant
Little Rock, Arkansas 72201                       Attorney General
Phone: (501) 682-1178                             Charles Thimmesch, Senior Assistant
Amanda.Wentz@ArkansasAG.gov                       Attorney General
                                                  Office of the Attorney General, State of
Counsel for Plaintiff State of Arkansas           Georgia
                                                  40 Capitol Square, SW
By: /s/ Carolyn D. Jeffries                       Atlanta, Georgia 30334-1300
Rob Bonta, Attorney General                       cthimmesch@law.georgia.gov
Paula Blizzard, Senior Assistant Attorney
General                                           Counsel for Plaintiff State of Georgia
Michael Jorgenson, Supervising Deputy
Attorney General                                  By: /s/ Scott L. Barnhart
Brian Wang, Deputy Attorney                       Theodore Edward Rokita, Attorney General
General                                           Scott L. Barnhart, Chief Counsel and
Carolyn D. Jeffries, Deputy Attorney              Director, Consumer Protection Division
General (DC Bar No. 1600843)                      Office of the Attorney General, State of
Office of the Attorney General                    Indiana
California Department of Justice                  Indiana Government Center South, Fifth
455 Golden Gate Avenue, Suite 11000               Floor
San Francisco, California 94102                   302 West Washington Street
Cari.Jeffries@doj.ca.gov                          Indianapolis, Indiana 46204
                                                  Scott.Barnhart@atg.in.gov
Counsel for Plaintiff State of California

By: /s/ Lee Istrail                               Counsel for Plaintiff State of Indiana
James Uthmeier, Attorney General
R. Scott Palmer, Special Counsel, Complex
Enforcement Chief, Antitrust Division
Lee Istrail, Assistant Attorney General
Office of the Attorney General, State of
Florida
PL-01 The Capitol
Tallahassee, Florida 32399
Lee.Istrail@myfloridalegal.com
Scott.Palmer@myfloridalegal.com

Counsel for Plaintiff State of Florida


                                             13


    Case 1:20-cv-03010-APM           Document 1574    Filed 11/10/26      Page 14 of 22


By: /s/ Jonathan E. Farmer                       By: /s/ Alison Esbeck
Russell Coleman, Attorney General                Alison Esbeck
J. Christian Lewis, Commissioner of the          Assistant Attorney General
Office of Consumer Protection                    Missouri Attorney General’s Office
Philip R. Heleringer, Executive                  815 Olive Street | Suite 200
Director of the Office of Consumer               Saint Louis, Missouri 63101
Protection                                       Alison.esbeck@ago.mo.gov
Jonathan E. Farmer, Deputy Executive             Phone: 314-340-4977
Director of the Office of Consumer
Protection                                       Counsel for Plaintiff State of Missouri
Office of the Attorney General,
Commonwealth of Kentucky                         By: /s/ Anna Schneider
1024 Capital Center Drive, Suite 200             Anna Schneider
Frankfort, Kentucky 40601                        Special Assistant Attorney General,
Philip.Heleringer@ky.gov                         Senior Counsel,
                                                 Montana Office of Consumer Protection
Counsel for Plaintiff                            P.O. Box 200151
Commonwealth of Kentucky                         Helena, MT 59602-0150
                                                 Phone: (406) 444-4500
By: /s/ Asyl Nachabe                             Anna.schneider@mt.gov
Liz Murrill, Attorney General
Asyl Nachabe, Assistant Attorney General         Counsel for Plaintiff State of Montana
Office of the Attorney General, State of
Louisiana                                        By: /s/ Mary Frances Jowers
Public Protection Division                       Alan Wilson, Attorney General
909 Poydras St. Suite 1850                       W. Jeffrey Young, Chief Deputy
New Orleans, LA 70112                            Attorney General
(225) 326-6435                                   C. Havird Jones, Jr., Senior Assistant
NachabeA@ag.louisiana.gov                        Deputy Attorney General
                                                 Mary Frances Jowers, Assistant Deputy
Counsel for Plaintiff State of Louisiana         Attorney General
                                                 Office of the Attorney General
By: /s/ Scott Mertens                            State of South Carolina
Dana Nessel, Attorney General                    1000 Assembly Street
Scott Mertens, Assistant Attorney General        Rembert C. Dennis
Michigan Department of Attorney General          Building
P.O. Box 30736                                   P.O. Box 11549
Lansing, Michigan 48909                          Columbia, South Carolina 29211-1549
MertensS@michigan.gov                            mfjowers@scag.gov

Counsel for Plaintiff State of Michigan          Counsel for Plaintiff State of South Carolina


                                            14


    Case 1:20-cv-03010-APM             Document 1574   Filed 11/10/26   Page 15 of 22


By: /s/ Diamante Smith
Ken Paxton, Attorney General
Ralph Molina, Deputy First Assistant
Attorney General
William D. Wassdorf, Deputy Attorney
General for Civil Litigation
Thomas York, Division Chief, Antitrust
Division
Diamante Smith, Assistant Attorney
General, Antitrust Division
Office of the Attorney General,
State of Texas
P.O. Box 12548
Austin, Texas 78711-2548
(512) 936-1162
Diamante.Smith@oag.texas.gov

Counsel for Plaintiff State of Texas

By: /s/ Caitlin M. Madden
Joshua L. Kaul, Attorney General
Caitlin M. Madden, Assistant
Attorney General
Wisconsin Department of Justice
17 W. Main St.
Post Office Box 7857
Madison, Wisconsin 53707-7857
caitlin.madden@Wisconsin.gov

Counsel for Plaintiff State of Wisconsin


                                              15


   Case 1:20-cv-03010-APM           Document 1574   Filed 11/10/26      Page 16 of 22


PHILIP WEISER
Attorney General of Colorado                    BRENNA BIRD
                                                Attorney General of Iowa
/s/ Jonathan B. Sallet
Jonathan B. Sallet, DC Bar No. 336198           Noah Goerlitz, Assistant Attorney General
Steven M. Kaufmann                              Office of the Attorney General of Iowa
Elizabeth W. Hereford                           1305 E. Walnut St., 2nd Floor
Conor J. May                                    Des Moines, IA 50319
Colorado Office of the Attorney General         Telephone: (515) 725-1018
1300 Broadway, 7th Floor                        E-Mail: Noah.goerlitz@ag.iowa.gov
Denver, CO 80203
Telephone: (720) 508-6000                       Counsel for Plaintiff State of Iowa
E-Mail: Jon.Sallet@coag.gov
Steve.Kaufmann@coag.gov                         LETITIA JAMES
Elizabeth.Hereford@coag.gov                     Attorney General of New York
Conor.May@coag.gov
                                                Elinor R. Hoffmann
Counsel for Plaintiff State of Colorado         Morgan J. Feder
                                                Michael D. Schwartz
MIKE HILGERS                                    Office of the New York State Attorney
Attorney General of Nebraska                    General
                                                28 Liberty Street
Justin C. McCully, Assistant Attorney           New York, NY 10005
General                                         Telephone: (212) 416-8513
Nebraska Department of Justice                  E-Mail: Elinor.hoffmann@ag.ny.gov
Office of the Attorney General                  Morgan.feder@ag.ny.gov
2115 State Capitol                              Michael.schwartz@ag.ny.gov
Lincoln, NE 68509
Telephone: (402) 471-9305                       Counsel for Plaintiff State of New York
E-Mail: Justin.mccully@nebraska.gov
                                                JEFF JACKSON
Counsel for Plaintiff State of Nebraska         Attorney General of North Carolina

KRISTIN K. MAYES                                Kunal Janak Choksi
Attorney General of Arizona                     Joshua Daniel Abram
                                                North Carolina Department of Justice
Robert A. Bernheim, Unit Chief Counsel          114 W. Edenton St.
Jayme Weber, Senior Litigation Counsel          Raleigh, NC 27603
Arizona Office of the Attorney General          Telephone: (919) 716-6000
400 West Congress, Ste. S-215                   E-Mail: kchoksi@ncdoj.gov
Tucson, Arizona 85701                           jabram@ncdoj.gov
Telephone: (520) 628-6507
E-Mail: Robert.Bernheim@azag.gov                Counsel for Plaintiff State of North
Jayme.Weber@azag.gov                            Carolina

Counsel for Plaintiff State of Arizona
                                           16


   Case 1:20-cv-03010-APM             Document 1574   Filed 11/10/26     Page 17 of 22


JONATHAN SKRMETTI                                 WILLIAM TONG
Attorney General of Tennessee                     Attorney General of Connecticut

J. David McDowell                                 Nicole Demers
Austin Ostiguy                                    Office of the Attorney General of
Tyler Corcoran                                    Connecticut
Office of the Attorney General and                165 Capitol Avenue, Suite 5000
Reporter                                          Hartford, CT 06106
P.O. Box 20207                                    Telephone: (860) 808-5202
Nashville, TN 37202                               E-Mail: Nicole.demers@ct.gov
Telephone: (615) 741-8722
E-Mail: David.McDowell@ag.tn.gov                  Counsel for Plaintiff State of Connecticut
austin.ostiguy@ag.tn.gov
Tyler.Corcoran@ag.tn.gov                          KATHLEEN JENNINGS
                                                  Attorney General of Delaware
Counsel for Plaintiff State of Tennessee
                                                  Michael Andrew Undorf
DEREK E. BROWN                                    Delaware Department of Justice
Attorney General of Utah                          Fraud and Consumer Protection Division
                                                  820 N. French St., 5th Floor
Marie W.L. Martin, Division Director              Wilmington, DE 19801
Utah Office of Attorney General                   Telephone: (302) 683-8816
160 E 300 S, 5th Floor                            E-Mail: Michael.undorf@delaware.gov
P.O. Box 140811
Salt Lake City, Utah 84114                        Counsel for Plaintiff State of Delaware
Telephone: (801) 440-9825
E-Mail:                                           BRIAN SCHWALB
mwmartin@agutah.gov                               Attorney General of the District of
                                                  Columbia
Counsel for Plaintiff State of Utah
                                                  Elizabeth Gentry Arthur
STEPHEN J. COX                                    Office of the Attorney General for the
Attorney General of Alaska                        District of Columbia
                                                  400 6th Street NW
Jeff Pickett                                      Washington, DC 20001
Senior Assistant Attorney General                 Telephone: (202) 724-6514
State of Alaska, Department of Law                E-Mail: Elizabeth.arthur@dc.gov
Office of the Attorney General
1031 W. Fourth Avenue, Suite 200                  Counsel for Plaintiff District of Columbia
Anchorage, Alaska 99501
Telephone: (907) 269-5275
E-Mail: Jeff.pickett@alaska.gov

Counsel for Plaintiff State of Alaska


                                             17


   Case 1:20-cv-03010-APM              Document 1574   Filed 11/10/26       Page 18 of 22


DOUGLAS MOYLAN                                     KWAME RAOUL
Attorney General of Guam                           Attorney General of Illinois

Norman Lee Miller, Jr.                             Elizabeth Maxeiner
Office of the Attorney General of Guam             Brian Yost
590 S. Marine Corps Drive, Suite 901               Jennifer Coronel
Tamuning, Guam 96913                               Office of the Attorney General of Illinois
Telephone: (671) 475-2710                          115 S. LaSalle St.
E-Mail: nmillerjr@oagguam.org                      Chicago, IL 60603
                                                   Telephone: (773) 590-7935
Counsel for Plaintiff Territory Guam               E-Mail: Elizabeth.maxeiner@ilag.gov
                                                   Brian.yost@ilag.gov
ANNE E. LOPEZ                                      Jennifer.coronel@ilag.gov
Attorney General of Hawai‘i
                                                   Counsel for Plaintiff State of Illinois
Rodney I. Kimura
Department of the Attorney General, State          KRIS W. KOBACH
of Hawai‘i                                         Attorney General of Kansas
425 Queen Street
Honolulu, HI 96813                                 Christopher Teters
Telephone (808) 586-1180                           Kansas Office of the Attorney General
E-Mail: Rodney.i.kimura@hawaii.gov                 120 S.W. 10th Avenue, 2nd Floor
                                                   Topeka, KS 66612
Counsel for Plaintiff State of Hawai‘i             Telephone: (785) 296-3751
                                                   E-Mail: chris.teters@ag.ks.gov
RAÚL LABRADOR
Attorney General of Idaho                          Counsel for Plaintiff State of Kansas

John K. Olson                                      AARON M. FREY
Office of the Idaho Attorney General               Attorney General of Maine
Consumer Protection Division
954 W. Jefferson St., 2nd Floor                    Christina M. Moylan
P.O. Box 83720                                     Office of the Attorney General of Maine
Boise, ID 83720                                    6 State House Station
Telephone: (208) 332-3549                          August, ME 04333
E-Mail: John.olson@ag.idaho.gov                    Telephone: (207) 626-8800
                                                   E-Mail: Christina.moylan@maine.gov
Counsel for Plaintiff State of Idaho
                                                   Counsel for Plaintiff State of Maine


                                              18


   Case 1:20-cv-03010-APM           Document 1574   Filed 11/10/26     Page 19 of 22


ANTHONY G. BROWN                                AARON D. FORD
Attorney General of Maryland                    Attorney General of Nevada

Schonette J. Walker                             Michelle C. Badorine
Melissa English                                 Lucas J. Tucker
Office of the Attorney General of               Nevada Office of the Attorney General
Maryland                                        100 N. Carson Street
200 St. Paul Place, 19th Floor                  Carson City, NV 89701
Baltimore, MD 21202                             Telephone: (775) 684-1164
Telephone: (410) 576-6480                       E-Mail: mbadorine@ag.nv.gov
E-Mail: swalker@oag.state.md.us                 ltucker@ag.nv.gov
menglish@oag.state.md.us
                                                Counsel for Plaintiff State of Nevada
Counsel for Plaintiff State of Maryland
                                                JOHN FORMELLA
ANDREA CAMPBELL                                 Attorney General of New Hampshire
Attorney General of Massachusetts
                                                Brandon Garod
Jennifer E. Greaney                             Office of Attorney General of New
Office of the Attorney General of               Hampshire
Massachusetts                                   1 Granite Place South
One Ashburton Place, 18th Floor                 Concord, NH 03301
Boston, MA 02108                                Telephone: (603) 271-1217
Telephone: (617) 963-2981                       E-Mail: Brandon.h.garod@doj.nh.gov
E-Mail: Jennifer, greaney@mass.gov
                                                Counsel for Plaintiff State of New
Counsel for Plaintiff Commonwealth of           Hampshire
Massachusetts
                                                JENNIFER DAVENPORT
KEITH ELLISON                                   Acting Attorney General of New Jersey
Attorney General of Minnesota
                                                Yale A. Leber
Zach Biesanz                                    Abiola G. Miles
Senior Enforcement Counsel                      Deputy Attorneys General
Office of the Minnesota Attorney General        New Jersey Attorney General’s Office
Antitrust Division                              25 Market Street, P.O. Box 106
445 Minnesota Street, Suite 600                 Trenton, NJ 08625
St. Paul, MN 55101                              Telephone: (609) 376-2383
Telephone: (651) 757-1257                       E-Mail: Yale.Leber@law.njoag.gov
E-Mail: Zach.biesanz@ag.state.mn.us             Abiola.Miles@law.njoag.gov

Counsel for Plaintiff State of Minnesota        Counsel for Plaintiff State of New Jersey


                                           19


   Case 1:20-cv-03010-APM              Document 1574   Filed 11/10/26      Page 20 of 22


RAÚL TORREZ                                        Counsel for Plaintiff State of Ohio
Attorney General of New Mexico
                                                   GENTNER DRUMMOND
Judith E. Paquin Cholla Khoury                     Attorney General of Oklahoma
Assistant Attorney General
New Mexico Office of the Attorney                  Cameron R. Capps
General                                            Office of the Oklahoma Attorney General
408 Galisteo St.                                   313 NE 21st Street
Santa Fe, NM 87504                                 Oklahoma City, OK 73105
Telephone: (505) 490-4885                          Telephone: (405) 522-0858
E-Mail: jpaquin@nmag.gov                           E-Mail: Cameron.capps@oag.ok.gov
ckhoury@nmag.gov
                                                   Counsel for Plaintiff State of Oklahoma
Counsel for Plaintiff State of New Mexico
                                                   DAN RAYFIELD
DREW WRIGLEY                                       Attorney General of Oregon
Attorney General of North Dakota
                                                   Gina Ko, Assistant Attorney General
Elin S. Alm                                        Oregon Department of Justice
Assistant Attorney General                         100 SW Market Street
Consumer Protection and Antitrust                  Portland, OR 97201
Division                                           Telephone: (503) 934-4400
Office of the Attorney General of North            E-Mail: Gina.Ko@doj.oregon.gov
Dakota
1720 Burlington Drive, Suite C                     Counsel for Plaintiff State of Oregon
Bismarck, ND 58504
Telephone: (701) 328-5570                          DAVID W. SUNDAY, JR.
E-Mail: ealm@nd.gov                                Attorney General of Pennsylvania

Counsel for Plaintiff State of North               Tracy W. Wertz
Dakota                                             Joseph S. Betsko
                                                   Pennsylvania Office of Attorney General
D. ANDREW WILSON                                   Strawberry Square
Attorney General of Ohio                           Harrisburg, PA 17120
                                                   Telephone: (717) 787-4530
Beth Ann Finnerty, Section Chief,                  E-Mail: jbetsko@attorneygeneral.gov
Antitrust                                          twertz@attorneygeneral.gov
Sarah Mader, Assistant Attorney General,
Antitrust                                          Counsel for Plaintiff Commonwealth of
Office of the Attorney General of Ohio             Pennsylvania
30 E Broad Street, 26th Floor
Columbus, OH 43215
Telephone: (614) 466-4328
E-Mail: Beth.Finnerty@ohioago.gov
Sarah.Mader@ohioago.gov

                                              20


   Case 1:20-cv-03010-APM              Document 1574   Filed 11/10/26      Page 21 of 22


LOURDES L. GÓMEZ TORRES                            Dakota
Secretary of Justice
                                                   CHARITY R. CLARK
TANIA L. FERNÁNDEZ-MEDERO                          Attorney General of Vermont
Assistant Secretary of Justice
                                                   Christopher J. Curtis, Assistant Attorney
SAMUEL WISCOVITCH-CORALI                           General
Deputy Undersecretary                              Office of the Attorney General of
                                                   Vermont
Pablo Tufiño-Soto                                  109 State St.
Senior Attorney                                    Montpelier, VT 05609
Antitrust Division                                 Telephone: (802) 828-3170
Puerto Rico Department of Justice                  E-Mail: christopher.curtis@vermont.gov
P.O. Box 9020192                                   Counsel for Plaintiff State of Vermont
San Juan, Puerto Rico 00902-0192
Telephone: (787) 721-2900, Ext. 1205               JAY JONES
E-Mail: ptufino@justicia.pr.gov                    Attorney General of Virginia

Counsel for Plaintiff Territory Puerto             Tyler T. Henry
Rico                                               Senior Assistant Attorney General
                                                   Antitrust Unit
PETER NERONHA                                      Office of the Attorney General of Virginia
Attorney General of Rhode Island                   202 N. 9th Street
                                                   Richmond, VA 23219
Stephen Provazza                                   Telephone: (804) 692-0485
Rhode Island Office of the Attorney                E-Mail: thenry@oag.state.va.us
General
150 South Main Street                              Counsel for Plaintiff State of Virginia
Providence, RI 02903
Telephone: (401) 274-4400                          NICHOLAS W. BROWN
E-Mail: SProvazza@riag.ri.gov                      Attorney General of Washington

Counsel for Plaintiff State of Rhode Island        Amy N.L. Hanson
                                                   Senior Managing Assistant Attorney
MARTIN J. JACKLEY                                  General
Attorney General of South Dakota                   800 Fifth Avenue, Suite 2000
                                                   Seattle, WA 98104
Yvette K. Lafrentz                                 Telephone: (206) 464-5419
Office of the Attorney General of South            E-Mail: Amy.hanson@atg.wa.gov
Dakota
1302 E. Hwy 14, Suite 1                            Counsel for Plaintiff State of Washington
Pierre, SD 57501
Telephone: (605) 773-3215
E-Mail: Yvette.lafrentz@state.sd.us

Counsel for Plaintiff State of South
                                              21


   Case 1:20-cv-03010-APM             Document 1574   Filed 11/10/26   Page 22 of 22


JOHN B. McCUSKEY
Attorney General of West Virginia

Douglas Lee Davis
Office of the Attorney General, State of
West Virginia
1900 Kanawha Boulevard East
Building 6, Suite 401
P.O. Box 1789
Charleston, WV 25305
Telephone: (304) 558-8986
E-Mail: Douglas.l.davis@wvago.gov

Counsel for Plaintiff State of West
Virginia

KEITH KAUTZ
Attorney General of Wyoming

William T. Young
Wyoming Attorney General’s Office
2320 Capitol Avenue
Kendrick Building
Cheyenne, WY 82002
Telephone: (307) 777-7847
E-Mail: William.young@wyo.gov

Counsel for Plaintiff State of Wyoming


                                             22