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AMIT P. MEHTA\n v.\n\n Google LLC,\n\n Defendant.\n\n State of Colorado, et al.,\n Case No. 1:20-cv-03715-APM\n Plaintiffs,\n HON. AMIT P. MEHTA\n v.\n\n Google LLC,\n\n Defendant.\n\n\n\n PLAINTIFFS\u2019 THIRD STATUS REPORT AS TO\n THE ENFORCEMENT OF AND GOOGLE\u2019S COMPLIANCE WITH\n THE FINAL JUDGMENT\n\n Pursuant to the Court\u2019s request at the hearing held on September 18, 2026, Hr\u2019g\n\nTr. 59:03\u201311 (Sept. 18, 2026), and the Minute Entry of that same date, Plaintiffs in the above-\n\ncaptioned cases jointly file this Status Report. 1\n\n\n\n\n1 Unless otherwise stated, all references to \u201csections\u201d herein are to sections of the Final\n\nJudgment.\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 2 of 22\n\n\n\n\nI. INTRODUCTION\n\n Section VII.E requires Plaintiffs, with input from the Technical Committee (\u201cTC\u201d), to file\n\na status report within 90 days of the Effective Date of the Final Judgment to update the Court \u201cas\n\nto the enforcement of and Google\u2019s compliance with this Final Judgment,\u201d with additional status\n\nreports due on future dates to be set by the Court. ECF No. 1462, \u00a7 VII.E [hereinafter \u201cFinal J.\u201d].\n\nPlaintiffs filed the first such report on May 4, 2026 (\u201cFirst Status Report\u201d). ECF No. 1512. The\n\nsecond status report was filed on September 17, 2026 (\u201cSecond Status Report\u201d). ECF No. 1552.\n\n Part II below provides an update on TC Operations. Part III describes ongoing efforts by\n\nPlaintiffs and the TC to implement and enforce the Final Judgment. Part IV describes Google\u2019s\n\ncompliance with the Final Judgment to date, which also reflects information provided by\n\nGoogle\u2019s counsel and efforts by Plaintiffs and the TC to monitor Google\u2019s compliance.\n\nII. UPDATE ON TC OPERATIONS\n\n Since the Second Status Report, the TC has continued building out its operations and\n\norganization such that it can carry out its obligations under the Final Judgment.\n\n A. Insurance and Indemnification\n\n Since the last Status Conference, held on October 30, 2026, the Parties and the TC\u2019s legal\n\nand insurance teams have consistently engaged to address outstanding issues relating to TC\n\nindemnification and insurance. See ECF No. 1573 at 2\u20133. The first meet and confer was held on\n\nOctober 30, 2026. Following that call, on November 2 and November 3, 2026, the TC\u2019s legal and\n\ninsurance teams gathered additional information and provided Google with an updated proposal\n\nregarding matters relating to indemnification, including insurance quotes and proposed language\n\namending the TC Members\u2019 Indemnification Agreement. The Parties and the TC\u2019s legal and\n\ninsurance teams then met and conferred on November 3, 2026, to discuss the updated proposal.\n\n\n\n\n 2\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 3 of 22\n\n\n\n\n On November 4, 2026, Google provided a counterproposal regarding insurance for TC\n\nMembers and TC Staff as well as spoke with the TC\u2019s legal team regarding the same. On\n\nNovember 5, 2026, Google provided a counterproposal regarding adjustments to the TC\n\nMembers\u2019 Indemnification Agreement.\n\n On November 6, 2026, in response to Google\u2019s requests, the TC\u2019s legal and insurance\n\nteams provided Google with policy documents for the various lines of insurance coverage. The\n\nlegal team further responded to Google\u2019s counterproposal on the TC Members\u2019 Indemnification\n\nAgreement, accepting almost all of Google\u2019s proposed changes. On November 9, 2026, Google\n\nresponded and requested additional information regarding the insurance policies, which the TC\u2019s\n\nlegal and insurance teams are reviewing.\n\n As noted in the Joint Status Report filed on November 6, 2026, the Parties appear close to\n\nreaching agreement on all outstanding disputes relating to TC insurance and amendments to the\n\nTC Member Indemnification Agreements. ECF No. 1573 at 2. The Parties are continuing to\n\nconfer to reach agreement on these issues and will provide a further status update on this topic on\n\nFriday, November 13, 2026, at which time the Parties will notify this Court if further guidance or\n\nassistance is necessary.\n\n B. TC Budget and Recent Hiring\n\n The TC has been actively planning for its next fiscal year, which will begin on\n\nFebruary 1, 2027. To that end, the TC submitted its proposed annual budget for the 2027-2028\n\nfiscal year to Plaintiffs, who in turn reviewed and conferred with the TC regarding the same. On\n\nOctober 30, 2026, Plaintiffs approved the budget (\u201cApproved Annual Budget\u201d), and the TC\n\nprovided Google a copy of the Approved Annual Budget and related invoice. Pursuant to the\n\nParties\u2019 previous discussions, Plaintiffs and the TC understand that if Google has any objections\n\n\n\n\n 3\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 4 of 22\n\n\n\n\nto the Approved Annual Budget, Google will provide those objections to Plaintiffs and the TC in\n\nwriting by November 16, 2026, and will notify the Court of its intent to raise any outstanding\n\nobjections on November 30, 2026, with a proposal to file a Joint Status Report on such issues on\n\nDecember 7, 2026.\n\n With respect to staffing, pursuant to the TC\u2019s staffing plan, the TC has continued to hire\n\nnew personnel progressively across the current fiscal year to meet the TC\u2019s needs as workloads\n\nincrease and Plaintiffs and the TC progress in implementing the remedies.\n\n C. Source Code Agreement, Access, and Supplemental Protective Order\n\n The Final Judgment provides that \u201c[t]he TC shall have access to Google\u2019s source code\n\nand algorithms, subject to a confidentiality agreement, as approved by Plaintiffs\u201d (\u201cSource Code\n\nAgreement\u201d). Final J. \u00a7 VII.A.7.d. On September 16, 2026, following an extensive meet and\n\nconfer process, the Parties submitted to the Court a Joint Status Report setting forth their\n\noutstanding disputes on the draft agreement. ECF No. 1549. On September 18, 2026, the Court\n\nheld a hearing on those disputes, after which the Parties were able to resolve the issues and\n\nfinalize the Source Code Agreement. Minute Entry dated Sept. 18, 2026; ECF No.1555. As of\n\nOctober 1, 2026, all five of the TC Members had signed the Source Code Agreement.\n\n Pursuant to the Source Code Agreement, Google is to provide access to certain Google\n\nHighly Sensitive Information (\u201cGHSI\u201d) through Google-managed Chromebook computers. ECF\n\nNo. 1555-1 at \u00a7 3.2. More specifically, Google has created a new remote environment especially\n\nfor the TC, which can be accessed by siloed Chromebooks provided by Google.\n\n The TC Members have received their individual Chromebooks. Additional steps are\n\nnecessary before the TC and staff can access GHSI, including but not limited to the algorithms\n\nand user data. To be operational, the remote environment needs to be loaded with material that\n\n\n\n\n 4\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 5 of 22\n\n\n\n\nwill enable the TC to access certain Google data, code, and programs. During the September 18\n\nhearing, the Court inquired as to Google giving the TC a \u201ctour\u201d of Google\u2019s network, so that the\n\nTC could see what types of information may be available. Hr\u2019g Tr. 29:19\u201330:14, 54:07\u201319\n\n(Sept. 18, 2026). On October 7, 2026, Google sent a letter to the TC advising that Google was in\n\nthe process of arranging \u201ctours\u201d of various Google systems and technical documentation. The\n\nletter further requested that the TC identify what data or code the TC believes it must inspect to\n\nperform its duties under the Final Judgment, as well as the types of exercises the TC intends to\n\nundertake to analyze or otherwise work with that information, so that Google may identify the\n\nappropriate programs to make available.\n\n On October 28, 2026, the TC provided a comprehensive response, proposing multiple\n\nstructured technical sessions and identifying the data, code, and documentation the TC needs to\n\ninspect. The TC further identified the types of exercises that it intends to undertake as well as the\n\ntools those exercises require. Also on October 28, the TC sent a separate letter requesting that\n\nGoogle arrange a virtual meeting or series of meetings during which Google engineers could\n\nguide the TC Members through various identified tasks, using the Chromebooks provided by\n\nGoogle and the services accessible through them. The letter further made clear that the sessions\n\nmust enable the TC Members to execute the tasks themselves, rather than solely observe\n\ndemonstrations performed by Google engineers.\n\n At Google\u2019s request, on November 3, 2026, a call was held between the TC, Google\u2019s\n\noutside and in-house counsel, and Google\u2019s point of contact for the TC for Chromebooks, to\n\ndiscuss the requests in the TC\u2019s October 28 letters. During that call, Google requested additional\n\nmeetings to clarify the TC\u2019s requests for six systems tours. The first clarification meeting and the\n\nfirst of seven tours occurred on November 9, 2026.\n\n\n\n\n 5\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 6 of 22\n\n\n\n\n In addition to the SCA, Google proposed entering a Supplemental Protective Order\n\n(\u201cSPO\u201d) to further safeguard GHSI, pursuant to a request made under paragraph 27 of the\n\nexisting Protective Order, ECF No. 98. The Parties are negotiating the contours of an SPO,\n\nwhich is critical for continuing progress in implementing the remedies. Following their most\n\nrecent meet and confer on November 10, 2026, the Parties appear close to agreement. To the\n\nextent they are unable to resolve any remaining disputes, the Parties will seek the Court\u2019s\n\nassistance.\n\n D. TC Website\n\n In furtherance of Sections VII.C.3 (TC complaint submissions) and IX.V (Qualified\n\nCompetitor certification) of the Final Judgment, the TC is developing a website to provide third\n\nparties with public information regarding this Court\u2019s remedies, as well as to implement\n\nprocesses for contacting the TC with inquiries, complaints, or other submissions. The initial\n\nrelease of the TC\u2019s website is now live at https://remediestc.org. This TC website currently\n\nincludes public information regarding this Court\u2019s remedies and a streamlined contact form for\n\nmessaging the TC. Plaintiffs and the TC expect that this website will be updated periodically to\n\nreflect updates relating to the implementation of the Final Judgment, including processes for\n\nsubmitting complaints to the TC and applying to become a Qualified Competitor.\n\nIII. IMPLEMENTING THE FINAL JUDGMENT\u2019S REMEDIES\n\n A. Syndication Remedies (Sections V and VI.B)\n\n Sections V.B and VI.B require Plaintiffs and the TC, with input from Google, to create\n\nand submit to the Court template search syndication and Search Text Ads 2 syndication licenses\n\n(\u201cRecommended Syndication Template\u201d). After an objection period previously agreed upon by\n\n\n\n2 The term \u201cSearch Text Ads\u201d is defined in Section IX.Y of the Final Judgment.\n\n\n\n\n 6\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 7 of 22\n\n\n\n\nthe Parties, see ECF No. 1528-1 at 2\u20134, Plaintiffs submitted the Recommended Syndication\n\nTemplate to the Court on October 9, 2026, which reflected Plaintiffs\u2019 and the TC\u2019s consideration\n\nof Google input, as well as the TC\u2019s expertise and analysis of Google\u2019s commercial syndication\n\nagreements and terms in alignment with the Final Judgment. ECF Nos. 1559, 1559-1. On\n\nOctober 16, 2026, the Parties submitted a Joint Status Report regarding the Recommended\n\nSyndication Template and Google\u2019s outstanding objections thereto. ECF No. 1562.\n\n The Court then held a hearing on October 30, 2026, during which this Court requested\n\n(1) additional information from the TC regarding the use of syndicated search results within\n\nGenAI Products and the pricing of remedial syndication services and (2) a status update from the\n\nParties regarding any remaining disputes relating to the Recommended Syndication Template.\n\nHr\u2019g Tr. 102:7\u201317, 103:4\u2013104:2, 105:8\u201315 (Oct. 30, 2026). On November 6, 2026, the Parties\n\nprovided an interim status update regarding the Recommended Syndication Template and\n\nproposed submitting a further update on November 16, 2026. ECF No. 1573.\n\n Plaintiffs and the TC are working diligently to provide this Court with additional\n\ninformation responsive to its technical and pricing questions. See Hr\u2019g Tr. 103:4\u2013104:2 (Oct. 30,\n\n2026). Plaintiffs expect to submit the TC\u2019s responses regarding the use of syndication within\n\nGenAI Products later this week. Given the time needed to compile additional information\n\nresponsive to this Court\u2019s pricing questions, including information provided by third parties,\n\nPlaintiffs expect to submit the TC\u2019s responses to those questions on a later date this month. See\n\nid. at 103:4\u2013104:12.\n\n In parallel, Plaintiffs and the TC are working expeditiously to address Google\u2019s\n\noutstanding objections to the Recommended Syndication Template while ensuring the\n\nRecommended Syndication Template remains in compliance with the Final Judgment and this\n\n\n\n\n 7\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 8 of 22\n\n\n\n\nCourt\u2019s envisioned purpose of the syndication remedies. See Hr\u2019g Tr. 5:6\u201323 (Oct. 30, 2026)\n\n(articulating purpose of providing a \u201cbridge for [Q]ualified [C]ompetitors to provide quality\n\nquery results that they, in their present state, didn\u2019t have the capability of doing\u201d). Plaintiffs are\n\nhopeful that the Parties will be able to resolve many of Google\u2019s objections within the month of\n\nNovember, such that a version of the Recommended Syndication Template can be finalized in\n\nDecember. However, Plaintiffs expect that certain disputes regarding the Recommended\n\nSyndication Template may remain following further conferrals between the Parties. The Parties\n\nwill provide this Court with a further status update regarding the timeline for implementing a\n\nversion of the Recommended Syndication Template next Monday, November 16, 2026.\n\n B. Data Sharing License Template (Section IV)\n\n Pursuant to Section IV.B, Google is required to make certain Web Search Index and User-\n\nside Data available to Qualified Competitors. 3 To that end, Section IV.C.3 requires Plaintiffs and\n\nthe TC, with input from Google, to create and submit to the Court a template license governing\n\nthe use of data shared pursuant to Section IV (\u201cRecommended Data Sharing Template\u201d).\n\nPlaintiffs and the TC provided Google the Recommended Data Sharing Template on\n\nSeptember 21, 2026, along with the Recommendation Statement and Basis Statement. Google\n\nsent Plaintiffs and the TC their objections on October 20, 2026. Plaintiffs and the TC are\n\ncontinuing to revise the template based on Google\u2019s objections and subsequent meet and confers\n\nwith Google. Plaintiffs intend to send an updated version of the Recommended Data Sharing\n\nTemplate to Google on November 12, 2026. Pursuant to the Court\u2019s Minute Order entered on\n\n\n\n\n3 The Terms \u201cQualified Competitor\u201d and \u201cUser-side Data\u201d are defined in Sections IX.V and\n\nIX.EE, respectively.\n\n\n 8\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 9 of 22\n\n\n\n\nOctober 27, 2026, the Parties will file the Recommended Data Sharing Template with the Court\n\non November 16, 2026, and will submit a Joint Status Report on November 23, 2026.\n\n C. Qualified Competitor Certification (Section IX.V)\n\n To benefit from the Court\u2019s syndication and data sharing remedies, an entity must become\n\na Qualified Competitor under the Final Judgment. To do that, the entity must: (1) meet Plaintiffs\u2019\n\napproved data security standards, as recommended by the TC; (2) agree to regular data security\n\nand privacy audits by the TC; (3) make a sufficient showing to Plaintiffs, in consultation with the\n\nTC, of a plan to invest and compete in or with the general search engine and/or Search Text Ads\n\nmarkets; and (4) pose no risk to the national security of the United States. See Final J. \u00a7 IX.V.\n\n Plaintiffs and the TC continue to develop the procedures for certifying Qualified\n\nCompetitors. Such procedures will include, for example, determining the certification criteria,\n\ncreating the application process, identifying the information that must be provided and how it\n\nwill be evaluated, and developing processes for managing Qualified Competitor audits. As\n\nreferenced in Part II.D supra, Plaintiffs and the TC expect to update the TC\u2019s website at the\n\nappropriate time with information regarding the Qualified Competitor process.\n\n D. Search Text Ads Auction Remedy (Section VI.A)\n\n Under the Final Judgment, \u201cPlaintiffs [must] submit a proposal to the Court, informed by\n\nthe [TC]\u2019s views, by which Google [must] periodically provide [to] the [TC] and Plaintiffs a\n\nreport outlining all changes to its Search Text Ads auction meeting certain parameters and, for\n\neach change (1) Google\u2019s public disclosure of that change or (2) a statement why no public\n\ndisclosure is necessary.\u201d Final J. \u00a7 VI.A.\n\n As discussed in Plaintiffs\u2019 Second Status Report, the TC cannot fulfill its obligations\n\nunder Section VI.A without access to data from Google\u2019s Search Text Ads auction. ECF\n\n\n\n\n 9\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 10 of 22\n\n\n\n\nNo. 1552 at 14. In one of its demand letters sent to Google on October 28, 2026, regarding the\n\ntours of Google\u2019s systems, the TC described its request for materials and tours related to\n\nGoogle\u2019s Search Text Ads auctions. Please see Part II.C supra regarding those efforts. The TC\n\nwill continue to seek additional information related to the Search Text Ads auction remedy.\n\n E. Data Privacy Safeguards\n\n Contemporaneous with developing the Recommended Syndication Template and\n\nRecommended Index and Data Sharing Template, the TC has been developing protocols for\n\nhandling User-side Data and other security safeguards.\n\n To continue making meaningful progress in these data privacy initiatives, however, the\n\nTC must be able to understand Google\u2019s mechanisms for securing and operating critical system\n\ncomponents. Being able to access those systems is a necessary predicate to that effort. As\n\ndiscussed in Part II.C supra, the TC is currently engaging with Google to gain access to those\n\nsystems pursuant to the Source Code Agreement.\n\nIV. GOOGLE\u2019S COMPLIANCE WITH THE FINAL JUDGMENT\n\n A. Google Complaint Website (Section VII.C.2.a)\n\n The Final Judgment provides that \u201c[t]o facilitate the communication of complaints and\n\ninquiries by parties, the Compliance Officer shall place on Google\u2019s website, in a manner\n\nacceptable to the Plaintiffs, the procedures for submitting complaints.\u201d Final J. \u00a7 VII.C.2.a. In the\n\ntime since the Second Status Report, Google launched its complaint website, which can be found\n\nat https://support.google.com/legal-help-center/answer/18649250?hl=en. On October 13, 2026,\n\nthe website went live and was made searchable through web search and through search of\n\nGoogle\u2019s support pages.\n\n\n\n\n 10\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 11 of 22\n\n\n\n\n Google is monitoring information received through the website and will address any\n\ncomplaints concerning its compliance with the Final Judgment in accordance with Section 7.C of\n\nthe Final Judgment.\n\n B. Responses to Demand Letters\n\n Since the Second Status Report, the TC continues to issue demand letters to Google\n\npursuant to Section VII.A.7.c, seeking interviews and information relevant to forthcoming\n\nremedial recommendations as well as source code and data access. These additional demand\n\nletters include:\n\n \uf0a7 An October 15, 2026, follow-up letter seeking information regarding User-side Data. The\n TC received two responses from Google, one on October 26, 2026, and the other on\n October 30, 2026.\n\n \uf0a7 An October 15, 2026, follow-up seeking information on the web search index. The TC\n received one response from Google on October 26, 2026.\n\n \uf0a7 An October 27, 2026, demand letter requesting information regarding Google\u2019s\n syndication agreements and business. The TC received Google\u2019s response regarding the\n requested syndication agreements on November 6. Google\u2019s response indicated that it is\n pulling additional data in response to the request.\n\n \uf0a7 An October 28, 2026, demand letter requesting walkthroughs and information related to\n the Chromebooks that are to be issued to the TC.\n\n \uf0a7 An October 28, 2026, demand letter requesting additional information to address\n deficiencies in Google\u2019s response to the TC\u2019s July 21, 2026, demand letter entitled\n \u201cRequest for Information Concerning Section VI.A Search Text Ad Auction Disclosures.\u201d\n\n \uf0a7 An October 28, 2026, demand letter seeking walkthroughs and information related to\n Google\u2019s Search Text Ads system.\n\nWith respect to the October 28 demand letters, the TC and Google held a call on November 3,\n\n2026, to discuss the TC\u2019s demands. Pursuant to that call, the first of seven tours requested to date\n\ntook place on November 9, 2026.\n\n\n\n\n 11\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 12 of 22\n\n\n\n\n Plaintiffs and TC are working in good faith to resolve issues relating to these demand\n\nletters with Google. See Part II.C, supra. Plaintiffs will promptly seek the Court\u2019s assistance if\n\nthere are obstacles to obtaining the necessary information requested in these demand letters.\n\n C. Other Efforts\n\n Google continues its preparatory work to comply with the data-sharing and syndication\n\nrequirements in Sections IV\u2013VI of the Final Judgment.\n\n\n\nDated: November 10, 2026\n\n /s/ Joseph L. Gordon _\n Claire M. Maddox (D.C. Bar #498356)\n Travis R. Chapman (D.C. Bar #90031151)\n Danielle G. Hauck\n Grant M. Fergusson (D.C. Bar #90004882)\n Emma Waitzman (D.C. Bar #1738427)\n Ryan T. Karr\n Joseph L. Gordon (D.C. Bar #90027976)\n\n U.S. Department of Justice\n Antitrust Division\n Technology & Digital Platforms Section\n 450 Fifth Street NW, Suite 7100\n Washington, DC 20530\n Telephone: (202) 549-7155\n Claire.Maddox@usdoj.gov\n Travis.Chapman@usdoj.gov\n\n Counsel for Plaintiff United States of America\n\n\n\n\n 12\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 13 of 22\n\n\n\n\nBy: /s/ Amanda Wentz By: /s/ Charles Thimmesch\nAmanda J. Wentz Christopher Carr, Attorney General\nAssistant Attorney General Logan B. Winkles, Deputy Attorney\nOffice of the Arkansas Attorney General General\n101 West Capitol Avenue Ronald J. Stay, Jr., Senior Assistant\nLittle Rock, Arkansas 72201 Attorney General\nPhone: (501) 682-1178 Charles Thimmesch, Senior Assistant\nAmanda.Wentz@ArkansasAG.gov Attorney General\n Office of the Attorney General, State of\nCounsel for Plaintiff State of Arkansas Georgia\n 40 Capitol Square, SW\nBy: /s/ Carolyn D. Jeffries Atlanta, Georgia 30334-1300\nRob Bonta, Attorney General cthimmesch@law.georgia.gov\nPaula Blizzard, Senior Assistant Attorney\nGeneral Counsel for Plaintiff State of Georgia\nMichael Jorgenson, Supervising Deputy\nAttorney General By: /s/ Scott L. Barnhart\nBrian Wang, Deputy Attorney Theodore Edward Rokita, Attorney General\nGeneral Scott L. Barnhart, Chief Counsel and\nCarolyn D. Jeffries, Deputy Attorney Director, Consumer Protection Division\nGeneral (DC Bar No. 1600843) Office of the Attorney General, State of\nOffice of the Attorney General Indiana\nCalifornia Department of Justice Indiana Government Center South, Fifth\n455 Golden Gate Avenue, Suite 11000 Floor\nSan Francisco, California 94102 302 West Washington Street\nCari.Jeffries@doj.ca.gov Indianapolis, Indiana 46204\n Scott.Barnhart@atg.in.gov\nCounsel for Plaintiff State of California\n\nBy: /s/ Lee Istrail Counsel for Plaintiff State of Indiana\nJames Uthmeier, Attorney General\nR. Scott Palmer, Special Counsel, Complex\nEnforcement Chief, Antitrust Division\nLee Istrail, Assistant Attorney General\nOffice of the Attorney General, State of\nFlorida\nPL-01 The Capitol\nTallahassee, Florida 32399\nLee.Istrail@myfloridalegal.com\nScott.Palmer@myfloridalegal.com\n\nCounsel for Plaintiff State of Florida\n\n\n\n\n 13\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 14 of 22\n\n\n\n\nBy: /s/ Jonathan E. Farmer By: /s/ Alison Esbeck\nRussell Coleman, Attorney General Alison Esbeck\nJ. Christian Lewis, Commissioner of the Assistant Attorney General\nOffice of Consumer Protection Missouri Attorney General\u2019s Office\nPhilip R. Heleringer, Executive 815 Olive Street | Suite 200\nDirector of the Office of Consumer Saint Louis, Missouri 63101\nProtection Alison.esbeck@ago.mo.gov\nJonathan E. Farmer, Deputy Executive Phone: 314-340-4977\nDirector of the Office of Consumer\nProtection Counsel for Plaintiff State of Missouri\nOffice of the Attorney General,\nCommonwealth of Kentucky By: /s/ Anna Schneider\n1024 Capital Center Drive, Suite 200 Anna Schneider\nFrankfort, Kentucky 40601 Special Assistant Attorney General,\nPhilip.Heleringer@ky.gov Senior Counsel,\n Montana Office of Consumer Protection\nCounsel for Plaintiff P.O. Box 200151\nCommonwealth of Kentucky Helena, MT 59602-0150\n Phone: (406) 444-4500\nBy: /s/ Asyl Nachabe Anna.schneider@mt.gov\nLiz Murrill, Attorney General\nAsyl Nachabe, Assistant Attorney General Counsel for Plaintiff State of Montana\nOffice of the Attorney General, State of\nLouisiana By: /s/ Mary Frances Jowers\nPublic Protection Division Alan Wilson, Attorney General\n909 Poydras St. Suite 1850 W. Jeffrey Young, Chief Deputy\nNew Orleans, LA 70112 Attorney General\n(225) 326-6435 C. Havird Jones, Jr., Senior Assistant\nNachabeA@ag.louisiana.gov Deputy Attorney General\n Mary Frances Jowers, Assistant Deputy\nCounsel for Plaintiff State of Louisiana Attorney General\n Office of the Attorney General\nBy: /s/ Scott Mertens State of South Carolina\nDana Nessel, Attorney General 1000 Assembly Street\nScott Mertens, Assistant Attorney General Rembert C. Dennis\nMichigan Department of Attorney General Building\nP.O. Box 30736 P.O. Box 11549\nLansing, Michigan 48909 Columbia, South Carolina 29211-1549\nMertensS@michigan.gov mfjowers@scag.gov\n\nCounsel for Plaintiff State of Michigan Counsel for Plaintiff State of South Carolina\n\n\n\n\n 14\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 15 of 22\n\n\n\n\nBy: /s/ Diamante Smith\nKen Paxton, Attorney General\nRalph Molina, Deputy First Assistant\nAttorney General\nWilliam D. Wassdorf, Deputy Attorney\nGeneral for Civil Litigation\nThomas York, Division Chief, Antitrust\nDivision\nDiamante Smith, Assistant Attorney\nGeneral, Antitrust Division\nOffice of the Attorney General,\nState of Texas\nP.O. Box 12548\nAustin, Texas 78711-2548\n(512) 936-1162\nDiamante.Smith@oag.texas.gov\n\nCounsel for Plaintiff State of Texas\n\nBy: /s/ Caitlin M. Madden\nJoshua L. Kaul, Attorney General\nCaitlin M. Madden, Assistant\nAttorney General\nWisconsin Department of Justice\n17 W. Main St.\nPost Office Box 7857\nMadison, Wisconsin 53707-7857\ncaitlin.madden@Wisconsin.gov\n\nCounsel for Plaintiff State of Wisconsin\n\n\n\n\n 15\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 16 of 22\n\n\n\n\nPHILIP WEISER\nAttorney General of Colorado BRENNA BIRD\n Attorney General of Iowa\n/s/ Jonathan B. Sallet\nJonathan B. Sallet, DC Bar No. 336198 Noah Goerlitz, Assistant Attorney General\nSteven M. Kaufmann Office of the Attorney General of Iowa\nElizabeth W. Hereford 1305 E. Walnut St., 2nd Floor\nConor J. May Des Moines, IA 50319\nColorado Office of the Attorney General Telephone: (515) 725-1018\n1300 Broadway, 7th Floor E-Mail: Noah.goerlitz@ag.iowa.gov\nDenver, CO 80203\nTelephone: (720) 508-6000 Counsel for Plaintiff State of Iowa\nE-Mail: Jon.Sallet@coag.gov\nSteve.Kaufmann@coag.gov LETITIA JAMES\nElizabeth.Hereford@coag.gov Attorney General of New York\nConor.May@coag.gov\n Elinor R. Hoffmann\nCounsel for Plaintiff State of Colorado Morgan J. Feder\n Michael D. Schwartz\nMIKE HILGERS Office of the New York State Attorney\nAttorney General of Nebraska General\n 28 Liberty Street\nJustin C. McCully, Assistant Attorney New York, NY 10005\nGeneral Telephone: (212) 416-8513\nNebraska Department of Justice E-Mail: Elinor.hoffmann@ag.ny.gov\nOffice of the Attorney General Morgan.feder@ag.ny.gov\n2115 State Capitol Michael.schwartz@ag.ny.gov\nLincoln, NE 68509\nTelephone: (402) 471-9305 Counsel for Plaintiff State of New York\nE-Mail: Justin.mccully@nebraska.gov\n JEFF JACKSON\nCounsel for Plaintiff State of Nebraska Attorney General of North Carolina\n\nKRISTIN K. MAYES Kunal Janak Choksi\nAttorney General of Arizona Joshua Daniel Abram\n North Carolina Department of Justice\nRobert A. Bernheim, Unit Chief Counsel 114 W. Edenton St.\nJayme Weber, Senior Litigation Counsel Raleigh, NC 27603\nArizona Office of the Attorney General Telephone: (919) 716-6000\n400 West Congress, Ste. S-215 E-Mail: kchoksi@ncdoj.gov\nTucson, Arizona 85701 jabram@ncdoj.gov\nTelephone: (520) 628-6507\nE-Mail: Robert.Bernheim@azag.gov Counsel for Plaintiff State of North\nJayme.Weber@azag.gov Carolina\n\nCounsel for Plaintiff State of Arizona\n 16\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 17 of 22\n\n\n\n\nJONATHAN SKRMETTI WILLIAM TONG\nAttorney General of Tennessee Attorney General of Connecticut\n\nJ. David McDowell Nicole Demers\nAustin Ostiguy Office of the Attorney General of\nTyler Corcoran Connecticut\nOffice of the Attorney General and 165 Capitol Avenue, Suite 5000\nReporter Hartford, CT 06106\nP.O. Box 20207 Telephone: (860) 808-5202\nNashville, TN 37202 E-Mail: Nicole.demers@ct.gov\nTelephone: (615) 741-8722\nE-Mail: David.McDowell@ag.tn.gov Counsel for Plaintiff State of Connecticut\naustin.ostiguy@ag.tn.gov\nTyler.Corcoran@ag.tn.gov KATHLEEN JENNINGS\n Attorney General of Delaware\nCounsel for Plaintiff State of Tennessee\n Michael Andrew Undorf\nDEREK E. BROWN Delaware Department of Justice\nAttorney General of Utah Fraud and Consumer Protection Division\n 820 N. French St., 5th Floor\nMarie W.L. Martin, Division Director Wilmington, DE 19801\nUtah Office of Attorney General Telephone: (302) 683-8816\n160 E 300 S, 5th Floor E-Mail: Michael.undorf@delaware.gov\nP.O. Box 140811\nSalt Lake City, Utah 84114 Counsel for Plaintiff State of Delaware\nTelephone: (801) 440-9825\nE-Mail: BRIAN SCHWALB\nmwmartin@agutah.gov Attorney General of the District of\n Columbia\nCounsel for Plaintiff State of Utah\n Elizabeth Gentry Arthur\nSTEPHEN J. COX Office of the Attorney General for the\nAttorney General of Alaska District of Columbia\n 400 6th Street NW\nJeff Pickett Washington, DC 20001\nSenior Assistant Attorney General Telephone: (202) 724-6514\nState of Alaska, Department of Law E-Mail: Elizabeth.arthur@dc.gov\nOffice of the Attorney General\n1031 W. Fourth Avenue, Suite 200 Counsel for Plaintiff District of Columbia\nAnchorage, Alaska 99501\nTelephone: (907) 269-5275\nE-Mail: Jeff.pickett@alaska.gov\n\nCounsel for Plaintiff State of Alaska\n\n\n 17\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 18 of 22\n\n\n\n\nDOUGLAS MOYLAN KWAME RAOUL\nAttorney General of Guam Attorney General of Illinois\n\nNorman Lee Miller, Jr. Elizabeth Maxeiner\nOffice of the Attorney General of Guam Brian Yost\n590 S. Marine Corps Drive, Suite 901 Jennifer Coronel\nTamuning, Guam 96913 Office of the Attorney General of Illinois\nTelephone: (671) 475-2710 115 S. LaSalle St.\nE-Mail: nmillerjr@oagguam.org Chicago, IL 60603\n Telephone: (773) 590-7935\nCounsel for Plaintiff Territory Guam E-Mail: Elizabeth.maxeiner@ilag.gov\n Brian.yost@ilag.gov\nANNE E. LOPEZ Jennifer.coronel@ilag.gov\nAttorney General of Hawai\u2018i\n Counsel for Plaintiff State of Illinois\nRodney I. Kimura\nDepartment of the Attorney General, State KRIS W. KOBACH\nof Hawai\u2018i Attorney General of Kansas\n425 Queen Street\nHonolulu, HI 96813 Christopher Teters\nTelephone (808) 586-1180 Kansas Office of the Attorney General\nE-Mail: Rodney.i.kimura@hawaii.gov 120 S.W. 10th Avenue, 2nd Floor\n Topeka, KS 66612\nCounsel for Plaintiff State of Hawai\u2018i Telephone: (785) 296-3751\n E-Mail: chris.teters@ag.ks.gov\nRA\u00daL LABRADOR\nAttorney General of Idaho Counsel for Plaintiff State of Kansas\n\nJohn K. Olson AARON M. FREY\nOffice of the Idaho Attorney General Attorney General of Maine\nConsumer Protection Division\n954 W. Jefferson St., 2nd Floor Christina M. Moylan\nP.O. Box 83720 Office of the Attorney General of Maine\nBoise, ID 83720 6 State House Station\nTelephone: (208) 332-3549 August, ME 04333\nE-Mail: John.olson@ag.idaho.gov Telephone: (207) 626-8800\n E-Mail: Christina.moylan@maine.gov\nCounsel for Plaintiff State of Idaho\n Counsel for Plaintiff State of Maine\n\n\n\n\n 18\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 19 of 22\n\n\n\n\nANTHONY G. BROWN AARON D. FORD\nAttorney General of Maryland Attorney General of Nevada\n\nSchonette J. Walker Michelle C. Badorine\nMelissa English Lucas J. Tucker\nOffice of the Attorney General of Nevada Office of the Attorney General\nMaryland 100 N. Carson Street\n200 St. Paul Place, 19th Floor Carson City, NV 89701\nBaltimore, MD 21202 Telephone: (775) 684-1164\nTelephone: (410) 576-6480 E-Mail: mbadorine@ag.nv.gov\nE-Mail: swalker@oag.state.md.us ltucker@ag.nv.gov\nmenglish@oag.state.md.us\n Counsel for Plaintiff State of Nevada\nCounsel for Plaintiff State of Maryland\n JOHN FORMELLA\nANDREA CAMPBELL Attorney General of New Hampshire\nAttorney General of Massachusetts\n Brandon Garod\nJennifer E. Greaney Office of Attorney General of New\nOffice of the Attorney General of Hampshire\nMassachusetts 1 Granite Place South\nOne Ashburton Place, 18th Floor Concord, NH 03301\nBoston, MA 02108 Telephone: (603) 271-1217\nTelephone: (617) 963-2981 E-Mail: Brandon.h.garod@doj.nh.gov\nE-Mail: Jennifer, greaney@mass.gov\n Counsel for Plaintiff State of New\nCounsel for Plaintiff Commonwealth of Hampshire\nMassachusetts\n JENNIFER DAVENPORT\nKEITH ELLISON Acting Attorney General of New Jersey\nAttorney General of Minnesota\n Yale A. Leber\nZach Biesanz Abiola G. Miles\nSenior Enforcement Counsel Deputy Attorneys General\nOffice of the Minnesota Attorney General New Jersey Attorney General\u2019s Office\nAntitrust Division 25 Market Street, P.O. Box 106\n445 Minnesota Street, Suite 600 Trenton, NJ 08625\nSt. Paul, MN 55101 Telephone: (609) 376-2383\nTelephone: (651) 757-1257 E-Mail: Yale.Leber@law.njoag.gov\nE-Mail: Zach.biesanz@ag.state.mn.us Abiola.Miles@law.njoag.gov\n\nCounsel for Plaintiff State of Minnesota Counsel for Plaintiff State of New Jersey\n\n\n\n\n 19\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 20 of 22\n\n\n\n\nRA\u00daL TORREZ Counsel for Plaintiff State of Ohio\nAttorney General of New Mexico\n GENTNER DRUMMOND\nJudith E. Paquin Cholla Khoury Attorney General of Oklahoma\nAssistant Attorney General\nNew Mexico Office of the Attorney Cameron R. Capps\nGeneral Office of the Oklahoma Attorney General\n408 Galisteo St. 313 NE 21st Street\nSanta Fe, NM 87504 Oklahoma City, OK 73105\nTelephone: (505) 490-4885 Telephone: (405) 522-0858\nE-Mail: jpaquin@nmag.gov E-Mail: Cameron.capps@oag.ok.gov\nckhoury@nmag.gov\n Counsel for Plaintiff State of Oklahoma\nCounsel for Plaintiff State of New Mexico\n DAN RAYFIELD\nDREW WRIGLEY Attorney General of Oregon\nAttorney General of North Dakota\n Gina Ko, Assistant Attorney General\nElin S. Alm Oregon Department of Justice\nAssistant Attorney General 100 SW Market Street\nConsumer Protection and Antitrust Portland, OR 97201\nDivision Telephone: (503) 934-4400\nOffice of the Attorney General of North E-Mail: Gina.Ko@doj.oregon.gov\nDakota\n1720 Burlington Drive, Suite C Counsel for Plaintiff State of Oregon\nBismarck, ND 58504\nTelephone: (701) 328-5570 DAVID W. SUNDAY, JR.\nE-Mail: ealm@nd.gov Attorney General of Pennsylvania\n\nCounsel for Plaintiff State of North Tracy W. Wertz\nDakota Joseph S. Betsko\n Pennsylvania Office of Attorney General\nD. ANDREW WILSON Strawberry Square\nAttorney General of Ohio Harrisburg, PA 17120\n Telephone: (717) 787-4530\nBeth Ann Finnerty, Section Chief, E-Mail: jbetsko@attorneygeneral.gov\nAntitrust twertz@attorneygeneral.gov\nSarah Mader, Assistant Attorney General,\nAntitrust Counsel for Plaintiff Commonwealth of\nOffice of the Attorney General of Ohio Pennsylvania\n30 E Broad Street, 26th Floor\nColumbus, OH 43215\nTelephone: (614) 466-4328\nE-Mail: Beth.Finnerty@ohioago.gov\nSarah.Mader@ohioago.gov\n\n 20\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 21 of 22\n\n\n\n\nLOURDES L. G\u00d3MEZ TORRES Dakota\nSecretary of Justice\n CHARITY R. CLARK\nTANIA L. FERN\u00c1NDEZ-MEDERO Attorney General of Vermont\nAssistant Secretary of Justice\n Christopher J. Curtis, Assistant Attorney\nSAMUEL WISCOVITCH-CORALI General\nDeputy Undersecretary Office of the Attorney General of\n Vermont\nPablo Tufi\u00f1o-Soto 109 State St.\nSenior Attorney Montpelier, VT 05609\nAntitrust Division Telephone: (802) 828-3170\nPuerto Rico Department of Justice E-Mail: christopher.curtis@vermont.gov\nP.O. Box 9020192 Counsel for Plaintiff State of Vermont\nSan Juan, Puerto Rico 00902-0192\nTelephone: (787) 721-2900, Ext. 1205 JAY JONES\nE-Mail: ptufino@justicia.pr.gov Attorney General of Virginia\n\nCounsel for Plaintiff Territory Puerto Tyler T. Henry\nRico Senior Assistant Attorney General\n Antitrust Unit\nPETER NERONHA Office of the Attorney General of Virginia\nAttorney General of Rhode Island 202 N. 9th Street\n Richmond, VA 23219\nStephen Provazza Telephone: (804) 692-0485\nRhode Island Office of the Attorney E-Mail: thenry@oag.state.va.us\nGeneral\n150 South Main Street Counsel for Plaintiff State of Virginia\nProvidence, RI 02903\nTelephone: (401) 274-4400 NICHOLAS W. BROWN\nE-Mail: SProvazza@riag.ri.gov Attorney General of Washington\n\nCounsel for Plaintiff State of Rhode Island Amy N.L. Hanson\n Senior Managing Assistant Attorney\nMARTIN J. JACKLEY General\nAttorney General of South Dakota 800 Fifth Avenue, Suite 2000\n Seattle, WA 98104\nYvette K. Lafrentz Telephone: (206) 464-5419\nOffice of the Attorney General of South E-Mail: Amy.hanson@atg.wa.gov\nDakota\n1302 E. Hwy 14, Suite 1 Counsel for Plaintiff State of Washington\nPierre, SD 57501\nTelephone: (605) 773-3215\nE-Mail: Yvette.lafrentz@state.sd.us\n\nCounsel for Plaintiff State of South\n 21\n\f Case 1:20-cv-03010-APM Document 1574 Filed 11/10/26 Page 22 of 22\n\n\n\n\nJOHN B. McCUSKEY\nAttorney General of West Virginia\n\nDouglas Lee Davis\nOffice of the Attorney General, State of\nWest Virginia\n1900 Kanawha Boulevard East\nBuilding 6, Suite 401\nP.O. Box 1789\nCharleston, WV 25305\nTelephone: (304) 558-8986\nE-Mail: Douglas.l.davis@wvago.gov\n\nCounsel for Plaintiff State of West\nVirginia\n\nKEITH KAUTZ\nAttorney General of Wyoming\n\nWilliam T. Young\nWyoming Attorney General\u2019s Office\n2320 Capitol Avenue\nKendrick Building\nCheyenne, WY 82002\nTelephone: (307) 777-7847\nE-Mail: William.young@wyo.gov\n\nCounsel for Plaintiff State of Wyoming\n\n\n\n\n 22\n\f","ocr_status":2,"date_upload":"2026-11-10T14:33:31.133386-08:00","document_number":"1574","attachment_number":null,"pacer_doc_id":"045012471437","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Status Report","acms_document_guid":""}],"date_created":"2026-11-10T14:32:57.039362-08:00","date_modified":"2026-11-10T15:21:51.727546-08:00","date_filed":"2026-11-10","time_filed":"17:31:35","entry_number":1574,"recap_sequence_number":"2026-11-10.001","pacer_sequence_number":5218,"description":"Third STATUS REPORT on Google's Compliance with the Final Judgment by UNITED STATES OF AMERICA. (Gordon, Joseph)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/485080709/","id":485080709,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/500941543/","id":500941543,"tags":[],"absolute_url":"","date_created":"2026-11-10T09:08:39.143671-08:00","date_modified":"2026-11-10T09:08:39.143680-08:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Status Report Order AND ~Util - Set/Reset Deadlines","acms_document_guid":""}],"date_created":"2026-11-10T09:08:39.133688-08:00","date_modified":"2026-11-10T09:08:39.133699-08:00","date_filed":"2026-11-10","time_filed":"11:21:34","entry_number":null,"recap_sequence_number":"2026-11-10.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/485070509/","id":485070509,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/500931240/","id":500931240,"tags":[],"absolute_url":"","date_created":"2026-11-10T08:23:35.492355-08:00","date_modified":"2026-11-10T08:23:35.492365-08:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Status Report Order","acms_document_guid":""}],"date_created":"2026-11-10T08:23:35.478399-08:00","date_modified":"2026-11-10T08:23:35.478409-08:00","date_filed":"2026-11-10","time_filed":null,"entry_number":null,"recap_sequence_number":"2026-11-10.001","pacer_sequence_number":null,"description":"MINUTE ORDER. The parties shall file an additional Joint Status Report regarding the status of indemnification of Technical Committee members and staff by November 13, 2026. The parties shall also file an additional Joint Status Report regarding the remedial syndication license template by November 16, 2026. Signed by Judge Amit P. Mehta on 11/10/2026. (lcapm2)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/484794072/","id":484794072,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/500642511/","id":500642511,"tags":[],"absolute_url":"/docket/18552824/1573/united-states-of-america-v-google-llc/","date_created":"2026-11-06T17:00:50.725118-08:00","date_modified":"2026-11-09T16:27:55.245107-08:00","sha1":"d9558de8a0d8e0d9f8d01adfca33fc82d08710d7","page_count":14,"file_size":227047,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1573.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1573.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/500642511.thumb.1068.png","thumbnail_status":1,"plain_text":" Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 1 of 14\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF COLUMBIA\n\n\n United States of America, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03010-APM\n\n v. HON. AMIT P. MEHTA\n Google LLC,\n\n Defendant.\n\n\n State of Colorado, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03715-APM\n\n v. HON. AMIT P. MEHTA\n Google LLC,\n\n Defendant.\n\n\n\n JOINT STATUS REPORT\n\n Pursuant to the Court\u2019s October 30, 2026 Minute Order, the Parties submit the following\n\nJoint Status Report to update the Court on progress relating to the remedial syndication license\n\ntemplate required under Sections V and VI.B of the Final Judgment, as well as to further update\n\nthe Court regarding the status of disputes relating to the indemnification of Technical Committee\n\nMembers and Staff.\n\nI. Status of Remedial Syndication License Template\n\n At the hearing on October 30, 2026, this Court requested that the Parties provide a status\n\nupdate regarding the remedial syndication license template and Google\u2019s objections thereto. Tr.\n\nof Status Hr\u2019g (Oct. 30, 2026), at 102:7\u201317, 105:8\u201315. Following that hearing, the Parties have\n\n\n 1\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 2 of 14\n\n\n\n\ncontinued to work diligently to further resolve Google\u2019s objections regarding the remedial\n\nsyndication license template and clarify disputes in need of the Court\u2019s attention. On Thursday,\n\nNovember 5, 2026, the Parties met and conferred regarding a process for expeditiously resolving\n\ndisputes regarding the remedial syndication license template. Plaintiffs therein agreed to provide\n\nGoogle with an updated version of the template submitted to this Court, ECF No. 1560-1, no\n\nlater than Friday, November 13, 2026. This updated template is intended to reflect this Court\u2019s\n\nguidance from the October 30 hearing and Plaintiffs\u2019 attempts to further resolve Google\u2019s\n\nobjections. The Parties jointly propose that they file a further status report on Monday,\n\nNovember 16, 2026, concerning the remedial syndication license template and the timeline for\n\nresolving outstanding disputes.\n\n At the hearing on October 30, 2026, this Court also requested that the Technical\n\nCommittee (\u201cTC\u201d) provide written submissions regarding the (1) use of syndicated search results\n\nwithin GenAI Products and (2) the pricing of remedial syndication. Tr. of Status Hr\u2019g (Oct. 30,\n\n2026), at 103:4\u2013104:2. Plaintiffs intend to file the TC\u2019s written submission regarding the use of\n\nsyndicated search results within GenAI Products within the next week.\n\nII. Indemnification of TC Members and TC Staff\n\n Since the last status conference, the Parties and the TC\u2019s legal and insurance teams held\n\nseveral meet and confers regarding possible options relating to indemnification, including TC\n\ninsurance and amendments to the TC Member Indemnification Agreements to reflect the Parties\u2019\n\nagreement in principle to expand the scope of indemnifiable conduct pursuant to Delaware Law.\n\nPursuant to these discussions, the Parties are close to reaching agreement on all outstanding\n\ndisputes relating to TC insurance and amendments to the TC Member Indemnification\n\nAgreements. The Parties are continuing to confer and expect to reach agreement by November\n\n\n\n 2\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 3 of 14\n\n\n\n\n13, 2026. Accordingly, the Parties request that the next status report on this topic be due one\n\nweek from today, on November 13, 2026.\n\n\n\nDated: November 6, 2026 Respectfully submitted,\n\n /s/ Grant M. Fergusson\n Claire M. Maddox (D.C. Bar #498356)\n Travis R. Chapman (D.C. Bar #90031151)\n Danielle Hauck\n Grant M. Fergusson (D.C. Bar #90004882)\n Joseph Gordon (D.C. Bar #90027976)\n Ryan T. Karr\n Emma Waitzman (D.C. Bar #1738427)\n\n U.S. Department of Justice\n Antitrust Division\n Technology & Digital Platforms Section\n 450 Fifth Street NW, Suite 7100\n Washington, DC 20530\n Telephone: (202) 549-7155\n Claire.Maddox@usdoj.gov\n\n Counsel for Plaintiff United States of America\n\n\n\n\n 3\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 4 of 14\n\n\n\n\nBy: /s/ Amanda Wentz By: /s/ Charles Thimmesch\nAmanda J. Wentz Christopher Carr, Attorney General\nAssistant Attorney General Logan B. Winkles, Deputy Attorney\nOffice of the Arkansas Attorney General General\n101 West Capitol Avenue Ronald J. Stay, Jr., Senior Assistant\nLittle Rock, Arkansas 72201 Attorney General\nPhone: (501) 682-1178 Charles Thimmesch, Senior Assistant\nAmanda.Wentz@ArkansasAG.gov Attorney General\n Office of the Attorney General, State of\nCounsel for Plaintiff State of Arkansas Georgia\n 40 Capitol Square, SW\nBy: /s/ Carolyn D. Jeffries Atlanta, Georgia 30334-1300\nRob Bonta, Attorney General cthimmesch@law.georgia.gov\nPaula Blizzard, Senior Assistant Attorney\nGeneral Counsel for Plaintiff State of Georgia\nMichael Jorgenson, Supervising Deputy\nAttorney General By: /s/ Scott L. Barnhart\nBrian Wang, Deputy Attorney Theodore Edward Rokita, Attorney General\nGeneral Scott L. Barnhart, Chief Counsel and\nCarolyn D. Jeffries, Deputy Attorney Director, Consumer Protection Division\nGeneral (DC Bar No. 1600843) Office of the Attorney General, State of\nOffice of the Attorney General Indiana\nCalifornia Department of Justice Indiana Government Center South, Fifth\n455 Golden Gate Avenue, Suite 11000 Floor\nSan Francisco, California 94102 302 West Washington Street\nCari.Jeffries@doj.ca.gov Indianapolis, Indiana 46204\n Scott.Barnhart@atg.in.gov\nCounsel for Plaintiff State of California\n\nBy: /s/ Lee Istrail Counsel for Plaintiff State of Indiana\nJames Uthmeier, Attorney General\nR. Scott Palmer, Special Counsel, Complex\nEnforcement Chief, Antitrust Division\nLee Istrail, Assistant Attorney General\nOffice of the Attorney General, State of\nFlorida\nPL-01 The Capitol\nTallahassee, Florida 32399\nLee.Istrail@myfloridalegal.com\nScott.Palmer@myfloridalegal.com\n\nCounsel for Plaintiff State of Florida\n\n\n\n\n 4\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 5 of 14\n\n\n\n\nBy: /s/ Jonathan E. Farmer By: /s/ Alison Esbeck\nRussell Coleman, Attorney General Alison Esbeck\nJ. Christian Lewis, Commissioner of the Assistant Attorney General\nOffice of Consumer Protection Missouri Attorney General\u2019s Office\nPhilip R. Heleringer, Executive 815 Olive Street | Suite 200\nDirector of the Office of Consumer Saint Louis, Missouri 63101\nProtection Alison.esbeck@ago.mo.gov\nJonathan E. Farmer, Deputy Executive Phone: 314-340-4977\nDirector of the Office of Consumer\nProtection Counsel for Plaintiff State of Missouri\nOffice of the Attorney General,\nCommonwealth of Kentucky By: /s/ Anna Schneider\n1024 Capital Center Drive, Suite 200 Anna Schneider\nFrankfort, Kentucky 40601 Special Assistant Attorney General,\nPhilip.Heleringer@ky.gov Senior Counsel,\n Montana Office of Consumer Protection\nCounsel for Plaintiff P.O. Box 200151\nCommonwealth of Kentucky Helena, MT 59602-0150\n Phone: (406) 444-4500\nBy: /s/ Asyl Nachabe Anna.schneider@mt.gov\nLiz Murrill, Attorney General\nAsyl Nachabe, Assistant Attorney General Counsel for Plaintiff State of Montana\nOffice of the Attorney General, State of\nLouisiana By: /s/ Mary Frances Jowers\nPublic Protection Division Alan Wilson, Attorney General\n909 Poydras St. Suite 1850 W. Jeffrey Young, Chief Deputy\nNew Orleans, LA 70112 Attorney General\n(225) 326-6435 C. Havird Jones, Jr., Senior Assistant\nNachabeA@ag.louisiana.gov Deputy Attorney General\n Mary Frances Jowers, Assistant Deputy\nCounsel for Plaintiff State of Louisiana Attorney General\n Office of the Attorney General\nBy: /s/ Scott Mertens State of South Carolina\nDana Nessel, Attorney General 1000 Assembly Street\nScott Mertens, Assistant Attorney General Rembert C. Dennis\nMichigan Department of Attorney General Building\nP.O. Box 30736 P.O. Box 11549\nLansing, Michigan 48909 Columbia, South Carolina 29211-1549\nMertensS@michigan.gov mfjowers@scag.gov\n\nCounsel for Plaintiff State of Michigan Counsel for Plaintiff State of South Carolina\n\n\n\n\n 5\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 6 of 14\n\n\n\n\nBy: /s/ Diamante Smith\nKen Paxton, Attorney General\nRalph Molina, Deputy First Assistant\nAttorney General\nWilliam D. Wassdorf, Deputy Attorney\nGeneral for Civil Litigation\nThomas York, Division Chief, Antitrust\nDivision\nDiamante Smith, Assistant Attorney\nGeneral, Antitrust Division\nOffice of the Attorney General,\nState of Texas\nP.O. Box 12548\nAustin, Texas 78711-2548\n(512) 936-1162\nDiamante.Smith@oag.texas.gov\n\nCounsel for Plaintiff State of Texas\n\nBy: /s/ Caitlin M. Madden\nJoshua L. Kaul, Attorney General\nCaitlin M. Madden, Assistant\nAttorney General\nWisconsin Department of Justice\n17 W. Main St.\nPost Office Box 7857\nMadison, Wisconsin 53707-7857\ncaitlin.madden@Wisconsin.gov\n\nCounsel for Plaintiff State of Wisconsin\n\n\n\n\n 6\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 7 of 14\n\n\n\n\nPHILIP WEISER\nAttorney General of Colorado BRENNA BIRD\n Attorney General of Iowa\n/s/ Jonathan B. Sallet\nJonathan B. Sallet, DC Bar No. 336198 Noah Goerlitz, Assistant Attorney General\nSteven M. Kaufmann Office of the Attorney General of Iowa\nElizabeth W. Hereford 1305 E. Walnut St., 2nd Floor\nConor J. May Des Moines, IA 50319\nColorado Office of the Attorney General Telephone: (515) 725-1018\n1300 Broadway, 7th Floor E-Mail: Noah.goerlitz@ag.iowa.gov\nDenver, CO 80203\nTelephone: (720) 508-6000 Counsel for Plaintiff State of Iowa\nE-Mail: Jon.Sallet@coag.gov\nSteve.Kaufmann@coag.gov LETITIA JAMES\nElizabeth.Hereford@coag.gov Attorney General of New York\nConor.May@coag.gov\n Elinor R. Hoffmann\nCounsel for Plaintiff State of Colorado Morgan J. Feder\n Michael D. Schwartz\nMIKE HILGERS Office of the New York State Attorney\nAttorney General of Nebraska General\n 28 Liberty Street\nJustin C. McCully, Assistant Attorney New York, NY 10005\nGeneral Telephone: (212) 416-8513\nNebraska Department of Justice E-Mail: Elinor.hoffmann@ag.ny.gov\nOffice of the Attorney General Morgan.feder@ag.ny.gov\n2115 State Capitol Michael.schwartz@ag.ny.gov\nLincoln, NE 68509\nTelephone: (402) 471-9305 Counsel for Plaintiff State of New York\nE-Mail: Justin.mccully@nebraska.gov\n JEFF JACKSON\nCounsel for Plaintiff State of Nebraska Attorney General of North Carolina\n\nKRISTIN K. MAYES Kunal Janak Choksi\nAttorney General of Arizona Joshua Daniel Abram\n North Carolina Department of Justice\nRobert A. Bernheim, Unit Chief Counsel 114 W. Edenton St.\nJayme Weber, Senior Litigation Counsel Raleigh, NC 27603\nArizona Office of the Attorney General Telephone: (919) 716-6000\n400 West Congress, Ste. S-215 E-Mail: kchoksi@ncdoj.gov\nTucson, Arizona 85701 jabram@ncdoj.gov\nTelephone: (520) 628-6507\nE-Mail: Robert.Bernheim@azag.gov Counsel for Plaintiff State of North\nJayme.Weber@azag.gov Carolina\n\nCounsel for Plaintiff State of Arizona\n 7\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 8 of 14\n\n\n\n\nJONATHAN SKRMETTI WILLIAM TONG\nAttorney General of Tennessee Attorney General of Connecticut\n\nJ. David McDowell Nicole Demers\nAustin Ostiguy Office of the Attorney General of\nTyler Corcoran Connecticut\nOffice of the Attorney General and 165 Capitol Avenue, Suite 5000\nReporter Hartford, CT 06106\nP.O. Box 20207 Telephone: (860) 808-5202\nNashville, TN 37202 E-Mail: Nicole.demers@ct.gov\nTelephone: (615) 741-8722\nE-Mail: David.McDowell@ag.tn.gov Counsel for Plaintiff State of Connecticut\naustin.ostiguy@ag.tn.gov\nTyler.Corcoran@ag.tn.gov KATHLEEN JENNINGS\n Attorney General of Delaware\nCounsel for Plaintiff State of Tennessee\n Michael Andrew Undorf\nDEREK E. BROWN Delaware Department of Justice\nAttorney General of Utah Fraud and Consumer Protection Division\n 820 N. French St., 5th Floor\nMarie W.L. Martin, Division Director Wilmington, DE 19801\nUtah Office of Attorney General Telephone: (302) 683-8816\n160 E 300 S, 5th Floor E-Mail: Michael.undorf@delaware.gov\nP.O. Box 140811\nSalt Lake City, Utah 84114 Counsel for Plaintiff State of Delaware\nTelephone: (801) 440-9825\nE-Mail: BRIAN SCHWALB\nmwmartin@agutah.gov Attorney General of the District of\n Columbia\nCounsel for Plaintiff State of Utah\n Elizabeth Gentry Arthur\nSTEPHEN J. COX Office of the Attorney General for the\nAttorney General of Alaska District of Columbia\n 400 6th Street NW\nJeff Pickett Washington, DC 20001\nSenior Assistant Attorney General Telephone: (202) 724-6514\nState of Alaska, Department of Law E-Mail: Elizabeth.arthur@dc.gov\nOffice of the Attorney General\n1031 W. Fourth Avenue, Suite 200 Counsel for Plaintiff District of Columbia\nAnchorage, Alaska 99501\nTelephone: (907) 269-5275\nE-Mail: Jeff.pickett@alaska.gov\n\nCounsel for Plaintiff State of Alaska\n\n\n\n 8\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 9 of 14\n\n\n\n\nDOUGLAS MOYLAN KWAME RAOUL\nAttorney General of Guam Attorney General of Illinois\n\nNorman Lee Miller, Jr. Elizabeth Maxeiner\nOffice of the Attorney General of Guam Brian Yost\n590 S. Marine Corps Drive, Suite 901 Jennifer Coronel\nTamuning, Guam 96913 Office of the Attorney General of Illinois\nTelephone: (671) 475-2710 115 S. LaSalle St.\nE-Mail: nmillerjr@oagguam.org Chicago, IL 60603\n Telephone: (773) 590-7935\nCounsel for Plaintiff Territory Guam E-Mail: Elizabeth.maxeiner@ilag.gov\n Brian.yost@ilag.gov\nANNE E. LOPEZ Jennifer.coronel@ilag.gov\nAttorney General of Hawai\u2018i\n Counsel for Plaintiff State of Illinois\nRodney I. Kimura\nDepartment of the Attorney General, State KRIS W. KOBACH\nof Hawai\u2018i Attorney General of Kansas\n425 Queen Street\nHonolulu, HI 96813 Christopher Teters\nTelephone (808) 586-1180 Kansas Office of the Attorney General\nE-Mail: Rodney.i.kimura@hawaii.gov 120 S.W. 10th Avenue, 2nd Floor\n Topeka, KS 66612\nCounsel for Plaintiff State of Hawai\u2018i Telephone: (785) 296-3751\n E-Mail: chris.teters@ag.ks.gov\nRA\u00daL LABRADOR\nAttorney General of Idaho Counsel for Plaintiff State of Kansas\n\nJohn K. Olson AARON M. FREY\nOffice of the Idaho Attorney General Attorney General of Maine\nConsumer Protection Division\n954 W. Jefferson St., 2nd Floor Christina M. Moylan\nP.O. Box 83720 Office of the Attorney General of Maine\nBoise, ID 83720 6 State House Station\nTelephone: (208) 332-3549 August, ME 04333\nE-Mail: John.olson@ag.idaho.gov Telephone: (207) 626-8800\n E-Mail: Christina.moylan@maine.gov\nCounsel for Plaintiff State of Idaho\n Counsel for Plaintiff State of Maine\n\n\n\n\n 9\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 10 of 14\n\n\n\n\nANTHONY G. BROWN AARON D. FORD\nAttorney General of Maryland Attorney General of Nevada\n\nSchonette J. Walker Michelle C. Badorine\nMelissa English Lucas J. Tucker\nOffice of the Attorney General of Nevada Office of the Attorney General\nMaryland 100 N. Carson Street\n200 St. Paul Place, 19th Floor Carson City, NV 89701\nBaltimore, MD 21202 Telephone: (775) 684-1164\nTelephone: (410) 576-6480 E-Mail: mbadorine@ag.nv.gov\nE-Mail: swalker@oag.state.md.us ltucker@ag.nv.gov\nmenglish@oag.state.md.us\n Counsel for Plaintiff State of Nevada\nCounsel for Plaintiff State of Maryland\n JOHN FORMELLA\nANDREA CAMPBELL Attorney General of New Hampshire\nAttorney General of Massachusetts\n Brandon Garod\nJennifer E. Greaney Office of Attorney General of New\nOffice of the Attorney General of Hampshire\nMassachusetts 1 Granite Place South\nOne Ashburton Place, 18th Floor Concord, NH 03301\nBoston, MA 02108 Telephone: (603) 271-1217\nTelephone: (617) 963-2981 E-Mail: Brandon.h.garod@doj.nh.gov\nE-Mail: Jennifer, greaney@mass.gov\n Counsel for Plaintiff State of New\nCounsel for Plaintiff Commonwealth of Hampshire\nMassachusetts\n JENNIFER DAVENPORT\nKEITH ELLISON Acting Attorney General of New Jersey\nAttorney General of Minnesota\n Yale A. Leber\nZach Biesanz Abiola G. Miles\nSenior Enforcement Counsel Deputy Attorneys General\nOffice of the Minnesota Attorney General New Jersey Attorney General\u2019s Office\nAntitrust Division 25 Market Street, P.O. Box 106\n445 Minnesota Street, Suite 600 Trenton, NJ 08625\nSt. Paul, MN 55101 Telephone: (609) 376-2383\nTelephone: (651) 757-1257 E-Mail: Yale.Leber@law.njoag.gov\nE-Mail: Zach.biesanz@ag.state.mn.us Abiola.Miles@law.njoag.gov\n\nCounsel for Plaintiff State of Minnesota Counsel for Plaintiff State of New Jersey\n\n\n\n\n 10\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 11 of 14\n\n\n\n\nRA\u00daL TORREZ Counsel for Plaintiff State of Ohio\nAttorney General of New Mexico\n GENTNER DRUMMOND\nJudith E. Paquin Cholla Khoury Attorney General of Oklahoma\nAssistant Attorney General\nNew Mexico Office of the Attorney Cameron R. Capps\nGeneral Office of the Oklahoma Attorney General\n408 Galisteo St. 313 NE 21st Street\nSanta Fe, NM 87504 Oklahoma City, OK 73105\nTelephone: (505) 490-4885 Telephone: (405) 522-0858\nE-Mail: jpaquin@nmag.gov E-Mail: Cameron.capps@oag.ok.gov\nckhoury@nmag.gov\n Counsel for Plaintiff State of Oklahoma\nCounsel for Plaintiff State of New Mexico\n DAN RAYFIELD\nDREW WRIGLEY Attorney General of Oregon\nAttorney General of North Dakota\n Gina Ko, Assistant Attorney General\nElin S. Alm Oregon Department of Justice\nAssistant Attorney General 100 SW Market Street\nConsumer Protection and Antitrust Portland, OR 97201\nDivision Telephone: (503) 934-4400\nOffice of the Attorney General of North E-Mail: Gina.Ko@doj.oregon.gov\nDakota\n1720 Burlington Drive, Suite C Counsel for Plaintiff State of Oregon\nBismarck, ND 58504\nTelephone: (701) 328-5570 DAVID W. SUNDAY, JR.\nE-Mail: ealm@nd.gov Attorney General of Pennsylvania\n\nCounsel for Plaintiff State of North Tracy W. Wertz\nDakota Joseph S. Betsko\n Pennsylvania Office of Attorney General\nD. ANDREW WILSON Strawberry Square\nAttorney General of Ohio Harrisburg, PA 17120\n Telephone: (717) 787-4530\nBeth Ann Finnerty, Section Chief, E-Mail: jbetsko@attorneygeneral.gov\nAntitrust twertz@attorneygeneral.gov\nSarah Mader, Assistant Attorney General,\nAntitrust Counsel for Plaintiff Commonwealth of\nOffice of the Attorney General of Ohio Pennsylvania\n30 E Broad Street, 26 th Floor\nColumbus, OH 43215\nTelephone: (614) 466-4328\nE-Mail: Beth.Finnerty@ohioago.gov\nSarah.Mader@ohioago.gov\n\n 11\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 12 of 14\n\n\n\n\nLOURDES L. G\u00d3MEZ TORRES Dakota\nSecretary of Justice\n CHARITY R. CLARK\nTANIA L. FERN\u00c1NDEZ-MEDERO Attorney General of Vermont\nAssistant Secretary of Justice\n Christopher J. Curtis, Assistant Attorney\nSAMUEL WISCOVITCH-CORALI General\nDeputy Undersecretary Office of the Attorney General of\n Vermont\nPablo Tufi\u00f1o-Soto 109 State St.\nSenior Attorney Montpelier, VT 05609\nAntitrust Division Telephone: (802) 828-3170\nPuerto Rico Department of Justice E-Mail: christopher.curtis@vermont.gov\nP.O. Box 9020192 Counsel for Plaintiff State of Vermont\nSan Juan, Puerto Rico 00902-0192\nTelephone: (787) 721-2900, Ext. 1205 JAY JONES\nE-Mail: ptufino@justicia.pr.gov Attorney General of Virginia\n\nCounsel for Plaintiff Territory Puerto Tyler T. Henry\nRico Senior Assistant Attorney General\n Antitrust Unit\nPETER NERONHA Office of the Attorney General of Virginia\nAttorney General of Rhode Island 202 N. 9th Street\n Richmond, VA 23219\nStephen Provazza Telephone: (804) 692-0485\nRhode Island Office of the Attorney E-Mail: thenry@oag.state.va.us\nGeneral\n150 South Main Street Counsel for Plaintiff State of Virginia\nProvidence, RI 02903\nTelephone: (401) 274-4400 NICHOLAS W. BROWN\nE-Mail: SProvazza@riag.ri.gov Attorney General of Washington\n\nCounsel for Plaintiff State of Rhode Island Amy N.L. Hanson\n Senior Managing Assistant Attorney\nMARTIN J. JACKLEY General\nAttorney General of South Dakota 800 Fifth Avenue, Suite 2000\n Seattle, WA 98104\nYvette K. Lafrentz Telephone: (206) 464-5419\nOffice of the Attorney General of South E-Mail: Amy.hanson@atg.wa.gov\nDakota\n1302 E. Hwy 14, Suite 1 Counsel for Plaintiff State of Washington\nPierre, SD 57501\nTelephone: (605) 773-3215\nE-Mail: Yvette.lafrentz@state.sd.us\n\nCounsel for Plaintiff State of South\n 12\n\f Case 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 13 of 14\n\n\n\n\nJOHN B. McCUSKEY\nAttorney General of West Virginia\n\nDouglas Lee Davis\nOffice of the Attorney General, State of\nWest Virginia\n1900 Kanawha Boulevard East\nBuilding 6, Suite 401\nP.O. Box 1789\nCharleston, WV 25305\nTelephone: (304) 558-8986\nE-Mail: Douglas.l.davis@wvago.gov\n\nCounsel for Plaintiff State of West\nVirginia\n\nKEITH KAUTZ\nAttorney General of Wyoming\n\nWilliam T. Young\nWyoming Attorney General\u2019s Office\n2320 Capitol Avenue\nKendrick Building\nCheyenne, WY 82002\nTelephone: (307) 777-7847\nE-Mail: William.young@wyo.gov\n\nCounsel for Plaintiff State of Wyoming\n\n\n\n\n 13\n\fCase 1:20-cv-03010-APM Document 1573 Filed 11/06/26 Page 14 of 14\n\n\n\n\n WILLIAMS & CONNOLLY LLP\n\n By: /s/ John E. Schmidtlein\n John E. Schmidtlein (D.C. Bar No. 441261)\n Benjamin M. Greenblum (D.C. Bar No. 979786)\n Colette T. Connor (D.C. Bar No. 991533)\n 680 Maine Avenue, SW\n Washington, DC 20024\n Tel: 202-434-5000\n jschmidtlein@wc.com\n bgreenblum@wc.com\n cconnor@wc.com\n\n WILSON SONSINI GOODRICH & ROSATI P.C.\n Michael Sommer (admitted pro hac vice)\n Franklin M. Rubinstein (D.C. Bar No. 476674)\n 1700 K Street, NW\n Washington, DC 20006\n Tel: 202-973-880\n msommer@wsgr.com\n frubinstein@wsgr.com\n\n ROPES & GRAY LLP\n Mark S. Popofsky (D.C. Bar No. 454213)\n 2099 Pennsylvania Avenue, NW\n Washington, DC 20006\n Tel: 202-508-4624\n Mark.Popofsky@ropesgray.com\n\n Matthew McGinnis (admitted pro hac vice)\n Prudential Tower\n 800 Boylston Street\n Boston, MA 02199\n Tel: 617-951-7703\n Matthew.McGinnis@ropesgray.com\n\n Counsel for Defendant Google LLC\n\n\n\n\n 14\n\f","ocr_status":2,"date_upload":"2026-11-06T17:00:56.161752-08:00","document_number":"1573","attachment_number":null,"pacer_doc_id":"045012465533","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Status Report","acms_document_guid":""}],"date_created":"2026-11-06T17:00:50.694278-08:00","date_modified":"2026-11-06T17:33:32.752103-08:00","date_filed":"2026-11-06","time_filed":"20:00:19","entry_number":1573,"recap_sequence_number":"2026-11-06.001","pacer_sequence_number":5213,"description":"Joint STATUS REPORT by UNITED STATES OF AMERICA. 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(Attachments: # 1 Text of Proposed Order)(Waitzman, Emma) (Entered: 10/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/482703058/","id":482703058,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487559/","id":498487559,"tags":[],"absolute_url":"/docket/18552824/1567/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:52.925715-07:00","date_modified":"2026-10-26T17:49:23.834036-07:00","sha1":"7e3742aa5490c0ae433c8a5ebabea3269af38ca1","page_count":78,"file_size":894231,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487559.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23T19:15:54.720922-07:00","document_number":"1567","attachment_number":null,"pacer_doc_id":"045012431080","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Redacted Document","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487562/","id":498487562,"tags":[],"absolute_url":"/docket/18552824/1567/1/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.184039-07:00","date_modified":"2026-10-26T18:02:23.160566-07:00","sha1":"bf7a4b09adc183b0cf861f9a1dea10cde0810c6c","page_count":19,"file_size":1813188,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.1.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487562.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-1 Filed 10/23/26 Page 1of 19\n\nExhibit 1\n\n\fCase 1:20-cv-03010-APM Document 1567-1 Filed 10/23/26 Page 2 of 19\n\nee\nGoogle\n\nWEB SEARCH SERVICE AGREEMENT\nFOR COMPANIES CERTIFIED AS QUALIFIED COMPETITORS\nPURSUANT TO U.S. v. GOOGLE FINAL JUDGMENT\n\n| COMPANY INFORMATION\n\nCOMPANY: [FILL IN THE COMPANY\u2019S FULL LEGAL NAME HERE]\n\nTechnical\n\nBusiness Contact: Legal Contact:\nContact:\n\nName:\n\nTitle:\n\nAddress, City, State,\nPostal Code:\n\nPhone:\n\nEmail:\n\n| TERM\n\nTERM: Starting on [INSERT DATE (MUST BE FIRST OF MONTH)] (\u201cEffective Date\u201d) and continuing for five years\nthrough [INSERT DATE (MUST BE THE LAST DAY OF MONTH)] (inclusive).\n\n| SERVICES\n\nWEB SEARCH SERVICE (\u201cWSS\u201d)\nIMAGE SEARCH SERVICE (\u201cIS\u201d)\nVIDEO SEARCH SERVICE (\u201cVS\u201d)\nKNOWLEDGE PANEL SERVICE (\u201cKP\u201d)\n\f0/23/26 Page 3of19\n\nThis Google Web Search Service Agreement for Companies Certified as Qualified Competitors\nPursuant to the U.S. v. Google Final Judgment including any attached exhibit(s) (\u201cAgreement\u201d) is entered into\nby Google LLC (\u201cGoogle\u201d) and [Fill in Company\u2019s full legal name] (\u201c\u201cCompany\u2019\u2019) and is effective as of the\nEffective Date. This Agreement is entered pursuant to the Final Judgment and is subject to the terms of the\nFinal Judgment and further order by the Court.\n\n1. Definitions. In this Agreement:\n\n1.1. \u201cAffiliate\u201d means any entity that directly or indirectly controls, is controlled by, or is under\ncommon control with, a party.\n\n1.2. \u201cApproved Client Application\u201d means a Client Application that provides a General Search\nEngine or GenAI Product as defined in the Final Judgment and that is either listed in Exhibit A or approved\nby Google in writing from time to time under Section 6.3(a), in each case, for the purpose of accessing the\nServices.\n\n1.3. \u201cBrand Elements\u201d means trade name(s), trademarks, logos, domain names, and other\ndistinctive brand elements.\n\n1.4. \u201cClient Application\u201d means any application, plug-in, helper, component, or other executable\ncode that runs on a user\u2019s desktop computer or mobile device (or any subsequent version of such\napplication).\n\n1.5. \u201cClient Application Guidelines\u201d means the policy guidelines applicable to the Approved Client\nApplication(s) as provided by Google to Company from time to time, including those located at the following\nURL: https://support.google.com/adsense/answer/ 10926790 (or any different URL(s) or additional URL(s)\nGoogle may provide to Company from time to time).\n\n1.6. \u201cCompany Content\u201d means any content served to End Users that is not provided by Google.\n\n1.7. \u201cConfidential Information\u201d means information that one party (or a Delegate, as defined\nbelow) discloses to the other party (or its Delegate) under this Agreement, and that is marked as confidential\nor would normally be considered confidential information under the circumstances. It does not include\ninformation that is independently developed by the recipient, is rightfully given to the recipient by a third\nparty without confidentiality obligations, or becomes public through no fault of the recipient.\n\n1.8. \u201cCourt\u201d means Judge Amit P. Mehta of the United States District Court of the District of\nColumbia.\n\n1.9. \u201cEnd User\u201d means an individual human end user of a Site or Approved Client Application who\nis in the United States.\n\na\n\n1.11. \u201cFinal Judgment\u201d means United States, et al. v. Google LLC, No. 20-cv-3010 (APM) (D.D.C.),\nECF No. 1462.\n\n1.12. \u201cGenAT\u201d or \u201cGenerative AI\u201d means a type of artificial intelligence that creates new content\nincluding but not limited to text, images, code, classifications, and other media using machine learning\nmodels.\n\n1.13. \u201cGenAI Product\u201d means any application, software, service, feature, tool, functionality, or\nproduct that involves or makes use of Generative AI capabilities or models and has among its principal\nfunctions answering information-seeking prompts across a wide variety of topics using a broad range of\npublicly available information.\n\f0/23/26 Page 4of19\n\n1.14. \u201cGeneral Search Engine\u201d or \u201cGSE\u201d means software or a service that produces links to\nwebsites and other relevant information in response to a user query or prompt and that seeks to fulfill a\nbroad array of informational needs.\n\n1.15. \u201cGoogle Branding Guidelines\u201d means the brand treatment guidelines applicable to the\n\ndifferent URL Google may provide to Company from time to time).\n\n1.16. \u201cGoogle Technical Protocols\u201d means technical protocols and/or any other technical\nrequirements and specifications applicable to the Services as provided, and updated, by Google to Company\nfrom time to time.\n\n1.17. \u201cIntellectual Property Rights\u201d means all patent rights, copyrights, trademark rights, rights in\ntrade secrets, database rights, moral rights, domain names, rights in or relating to Confidential Information,\nand any other intellectual property rights (registered or unregistered) throughout the world.\n\n1.18. \u201cMonthly Forecast\u201d means the projected volume of United States Queries from Sites and\nApproved Client Applications that Company expects to send to Google through Requests each month.\n\n1.19. \u201cPeak QPS\u201d means the maximum number of Requests a system handles during its busiest single\nsecond of traffic during a month.\n\n1.20. \u201cPlaintiffs\u201d means the plaintiffs as defined in the Final Judgment.\n1.21. \u201cQPS\u201d means Queries per second.\n\n1.22. \u201cQuery\u201d means (a) a text query entered and submitted into a Search Box on a Site or on an\nApproved Client Application by an End User (whether by typing or voice input); or (b) a text query from\nGoogle\u2019s query re-writing features (\u201cdid you mean,\u201d \u201cpeople also ask,\u201d and autocomplete) that the End User\nselects.\n\n1.23. \u201cRequest\u201d means a request that is sent by Company to Google for a Results Set. For the\navoidance of doubt, synthetic queries are not Requests.\n\n1.24. \u201cResult\u201d means an individual search result from the web provided through the applicable\nService.\n\n1.25. \u201cResults Page\u201d means any Site page or Approved Client Application screen that contains any\nResults.\n\n1.26. \u201cResults Set\u201d means a set of one or more Results.\n\n1.27. \u201cSearch Box\u201d means a search box (or other means approved by Google) into which End Users\nenter search queries.\n\n1.28. \u201cServices\u201d means the Services listed on the front page(s) of this Agreement.\n\n1.29. \u201cSite(s)\u201d means a Web site(s) that provides a General Search Engine or GenAI Product as\ndefined in the Final Judgment, and that is located at the URL(s) listed in Exhibit A or approved by Google in\nwriting from time to time under Section 6.3(a).\n\n1.30.\n\n1.31. \u201cTechnical Committee\u201d means the five-person committee of experts appointed by the Court\npursuant to Final Judgment Section VIIA.\n\nbo\n\f0/23/26 Page 5of19\n\n1.32. In this Agreement, (i) \u201cincluding\u201d means \u201cincluding but not limited to,\u201d (ii) examples are\nillustrative and not the sole examples of a particular concept, (ili) unless expressly stated otherwise, \u201cdays\u201d\nmeans calendar days.\n\n2. Launch, Permitted Use, and Implementation and Maintenance of the Services.\n\n2.1. Launch. The parties will each use reasonable efforts to launch the Services into live use within\n30 days from the Effective Date. Company will not launch any implementation of the Services into live use,\nincluding without limitation any implementation on or through an Approved Client Application, until Google\nhas approved such implementations in writing (email to suffice), which a\n\nwithheld or delayed.\n\nroval will not be unreasonably\n\n2.2. Permitted Use. Company agrees that the only permitted use of the Services (or any part\nthereof) is for Company to, subject to the terms of this Agreement, send a Request to Google for a Results\nSet that Company then displays on the applicable Site or Approved Client Application to the End User who\nentered the associated Query (as applicable) (the \u201cPermitted Use\u201d). Company will not, and will not\nknowingly or negligently allow any third party to, use the Services, Results (or part thereof), or other\ninformation obtained through use of the Services for any purpose other than the Permitted Use. For the\n\navoidance of doubt, Company may not issue Requests to Google that contain synthetic queries.\n\n2.3. Implementation and Maintenance.\n\n(a) For the remainder of the Term, Google will make the Services available for use by Company and\nCompany will implement and maintain the Services on the Sites and Approved Client Applications. For\n\nclarity, Company may not implement the Services on a property that is not a Site or Approved Client\n\n(b) Company will ensure, with respect to every Site and Approved Client Application, Company:\n\n(@) is the technical and editorial decision maker in relation to each page and Approved Client\nApplication, including Results Pages, on which the Services are implemented; and\n\n(i) has control over the way in which the Services are implemented on each of those pages and\n\nApproved Client Applications.\n\n(c) Company will ensure that the Services are implemented and maintained in accordance with the\nfollowing:\n\n71\n(i) the Google Branding Guidelines; and\n\n(ii) the Google Technical Protocols.\n\f0/23/26 Page 6of 19\n\n(d) Google will, upon receiving a Request sent in compliance with this Agreement, provide a Results\nSet when available. Company will then display the Results Set on the applicable Site or Approved Client\nApplication.\n\ni) Web Search Service Results:\n\nFor the avoidance of doubt, Company will not modify any individual WSS Result in a WSS Results Set before\ndisplaying it to the End User.\n\n(e) Company will ensure that: (1) each Request is sent in compliance with this Agreement; (ii) each\nRequest is generated by a Query; and (iil) each Request contains the Query that generated that Request. For\nthe avoidance of doubt, Company will not make more than one Request per Query per Results Page and\nCompany will not send synthetic queries to Google.\n\n(g) Company will ensure that at all times during the applicable Term, Company:\n\n(@) has a clearly labeled and easily accessible privacy policy in place relating to the Site(s) and\nApproved Client Application(s); and\n\n(i) provides the End User with clear and comprehensive information about any information\nstored or accessed on the End User\u2019s computer or device in connection with the Services.\n\n(h) Company will take reasonable steps to ensure that an End User gives consent to the storing and\naccessing of information on the End User\u2019s computer or device where such activity occurs in connection with\nthe Services and obtaining such consent is required by law.\n\n(i) Google and Company agree to the Google Ads controller-controller data protection terms\navailable at: https: //privacy.google.com/businesses/controllerterms/ (or any different or additional URL\nGoogle may provide to Company from time to time).\n\n3. Syndication Limits, Restrictions, and Compliance.\n\n3.1. Syndication Limits.\n\n(a) Company must comply with the syndication limits enumerated in the Final Judgment, which\nstates that Company\u2019s use of the Services will be capped to 40% of the Company\u2019s annual United States\nQueries from Company\u2019s General Search Engine or GenAI Product and decline over the course of the Term.\nThe pace of this tapering, the methods for measuring and determining the percentage, and the application of\nthe percentage will be determined by the Court upon consultation with Plaintiffs and the Technical\nCommittee. For the avoidance of doubt, the Company must comply with these syndication limits and\ntapering requirements as determined by the Court, and may not circumvent them, including by directly, or\nthrough any third party, using automated means to access content from any Google services in violation of\nthe machine-readable instructions on Google\u2019s web pages (for example, robots.txt files that disallow crawling,\ntraining, or other activities).\n\n(b) Within the first 45 days when Google and the Company are preparing to launch the Services,\nCompany must provide Google and the Technical Committee with twelve months of Monthly Forecasts and\nPeak QPS, for review. If the Technical Committee approves Company\u2019s Monthly Forecasts and Peak QPS,\nGoogle will use them to accommodate Peak QPS for the Services. For each subsequent year the Company\nreceives the Services, Company will provide an updated set of twelve months of Monthly Forecasts and Peak\nQPS, for the Technical Committee to review and approve. Google will work with the Technical Committee\nto develop reasonable protocols that safeguard the Monthly Forecasts\u2019 commercially sensitive information.\n\f0/23/26 Page 7 of 19\n\n(c) If Company consistently falls below its Monthly Forecasts or Peak QPS for a period of three\nmonths or longer, Google may request that the Technical Committee revise the Monthly Forecasts or Peak\nQPS for the remainder of any given year.\n\n(d) Any increase to the Company\u2019s Monthly Forecasts or Peak QPS must be approved by the\nTechnical Committee. Company will provide to Google and the Technical Committee: at least three months\nnotice if Company expects to increase any Monthly Forecast by less than 5% of its forecasted Peak QPS; and\nat least six months notice if Company expects to increase any Monthly Forecast by more than 5% of its\nforecasted Peak QPS.\n\n(e) Company warrants that the Monthly Forecasts and Peak QPS provided to Google and the\nTechnical Committee are accurate estimates made in good faith.\n\n(f) Google will not be obligated to make the Services available in excess of the Peak QPS limits in\nthe Monthly Forecasts approved by the Technical Committee.\n\n3.2. Restrictions. Company will not, and will not knowingly or negligently allow any third party to:\n\n\u2014 obscure or \u2014 the display of all, or any part of, any Results,\n\n(b) edit, filter, truncate, append terms to or otherwise modify any Query;\n(c) implement any click tracking or other click monitoring of Results;\n\n(d) enter into any type of arrangement with a third party where either party receives a financial\nbenefit in connection with the Results (including any co-branding, white labeling or sub-syndication\narrangement). For the avoidance of doubt, nothing in this Section 3.2(d) is intended to prevent Company\nfrom displaying advertisements on a Results Page.\n\n(e) directly or indirectly, (i) offer incentives to End Users to generate impressions, Requests or clicks\non Results, (ii) fraudulently generate impressions, Requests or clicks on Results or (iii) modify impressions,\nRequests or clicks on Results;\n\n(f) \u201ccrawl\u201d, \u201cspider\u201d, index or in any non-transitory manner store or cache, or use in any manner\nResults (or part thereof) or other information obtained by Company through use of the Services beyond what\nis necessary to present Results to the End User who submitted the associated Query. For the avoidance of\ndoubt, this provision prohibits reverse engineering or using the Services (including any Results) to ground or\ntrain any model;\n\n(g) except for content provided by Google, display on any Site or Approved Client Application, any\ncontent that violates or encourages conduct that would violate , the Google Branding Guidelines, the\nGoogle Technical Protocols, or the Client Application Guidelines;\n\n(h) monetize IS Results or VS Results, including by serving or displaying advertisements on or in\nconnection with, any IS Results or VS Results;\n\n() Without limiting the scope of its other obligations under the Agreement, Company shall ensure\nthat it has obtained or observed relevant rights to any third party content provided on any search results page,\nincluding, but not limited to, any applicable terms of service, or observing the industry practice known as the\nrobots exclusion protocol, as further described at http: // www.robottxt.org. Company shall obtain or observe\nsuch rights in good faith use of user agents, source addresses, crawl rates and so forth. This clause shall be\nwithout prejudice to the other provisions in this Section 3.2.\n\n3.3. Compliance.\n\n(a) Company will not knowingly or negligently allow any use of or access to the Services through\nany Site or Approved Client Application that is not in compliance with the terms of this Agreement.\nCompany will use commercially reasonable efforts to monitor for any such access or use and will, if any such\naccess or use is detected, take all reasonable steps requested by Google to disable this access or use.\n\n6\n\f0/23/26 Page 8 of 19\n\n(b) If Company is not in compliance with this Agreement at any time, Google may with notice to\n\nCompany (such notice = forth such \u2014\u2014 in reasonable _\u2014 \u2014 \u2014 of all -\n\nany part of) the Services\nuntil Company implements adequate corrective modifications as reasonably required and\n\ndetermined by Google;\n\n4. Client Applications. Company will, and will ensure that any Approved Client Application(s) will,\ncomply with the Client Application Guidelines, as provided by Google to Company from time to time.\n\n5. No Exclusivity. This Agreement is non-exclusive. Provided Company complies with this Agreement,\nincluding and the Google Branding Guidelines, Company may display results from other search\nresult providers on the Sites or Approved Client Applications.\n\n6. Changes and Modifications.\n\n6.1. By Google. If Google modifies , the Google Branding Guidelines, the Google\nTechnical Protocols, or the Client Application Guidelines and the modification requires action by Company,\nCompany will take the necessary action no later than 30 days from receipt of notice from Google (or such\nlonger period as required by applicable law or permitted by Google in writir\n\n6.2. By Company. Company will use commercially reasonable efforts to provide Google with at\nleast 15 days prior notice of any change in code or serving technology that could reasonably be expected to\naffect the delivery or display of any Results,\n\n6.3. Site and Approved Client Application List Changes.\n\n(a) Company may notify Google from time to time that it wishes to add URL(s) to the Site(s) or\nClient Application(s) to the Approved Client Application(s), in each such case, by sending notice to Google at\nleast 45 days before Company wishes the addition to take effect. Google may approve or disapprove the\nrequest in its reasonable discretion, this approval or disapproval to be in writing. Regardless of whether\nGoogle approves a URL or Client Application, Google will not be obligated to provide any Services to that\nURL or Client Application until the Technical Committee determines that the URL or Client Application is\nentitled to use the Services under the Final Judgment.\n\n(b) If there is a change in control of any Site or Approved Client Application (such that the\nconditions set out in Section 2.3(b)(i) or 2.3(b) (ii) are not met):\n\n@) Company will provide notice to Google at least 30 days before the change; and\n\n(i) from the date of that change in control of the Site or Approved Client Application, that Site\not Approved Client Application will be treated as removed from this Agreement. Company will ensure that\nfrom that date, the Services are no longer implemented on that Site or Approved Client Application.\n\n7. Data.\n\n7.1. Definition of Company Data. As between Company and Google, any data or information sent\nby Company to Google during the Term, including, without limitation, data or information submitted as a\nRequest to Google (\u201cCompany Data\u2019\u2019), will remain the property of Company.\n\f0/23/26 Page9of19\n\n7.2. Definition of Google Data. As between Company and Google, any data or information\ncollected by Google (\u201cGoogle Data\u201d) will remain the property of Google.\n\n7.3. Permitted and Prohibited Uses.\n\nCompany Data.\n\nGoogle Data.\n\n(c) Legally Required Uses. Notwithstanding the foregoing or anything to the contrary herein,\nGoogle may use the Google Data, and either party may use the Company Data to the extent required by law\nin order to comply with legal process, preventing fraud or imminent harm, and ensuring the security of its\nnetwork and Services.\n\n>\n\n8. Intellectual Property. Except to the extent expressly stated otherwise in this Agreement, neither party\nwill acquire any right, title, or interest in any Intellectual Property Rights belonging to the other party, or to\nthe other party\u2019s licensors.\n\n9. Brand Elements.\n\n9.1\n\n9.2\n\n10. Payment.\n\n10.1. Payments.\n\n10.2. Payee. In accordance with applicable laws and regulations, Google operates multiple local\nGoogle Affiliates to process transactions, and payments from Company to Google may be made to one or\nmore of these Google Affiliates as specified by Google, which will satisfy Company\u2019s payment obligations\nunder this Agreement.\n\n10.3. Offset.\n\f0/23/26 Page 10of 19\n\nInvoices.\n\n10.5. \u2018Taxes.\n\n10.6. Currency & Bank Charges.\n\n11. Warranties; Disclaimers.\n\nWarranties.\n\nCompany Warranties. Company warrants that:\n\nDisclaimers.\n\n12. Indemnification.\n\n12.1. By Company.\n\nBy Google.\n\f0/23/26 Page 11of 19\n\n12.3. General.\n\n13. Limitation Of Liability.\n\n\f0/23/26 Page 12 of 19\n\n14. Confidentiality; Publicity.\n\n14.1. Confidentiality. The recipient will not disclose the other party\u2019s Confidential Information,\nexcept to Affiliates, employees, agents, professional advisors, or third-party contractors (\u201cDelegates\u201d) who\nneed to know it and who have a legal obligation to keep it confidential. The recipient will use the other\nparty\u2019s Confidential Information only to exercise rights and fulfill obligations under this Agreement while\nusing reasonable care to protect the Confidential Information. The recipient will ensure that its Delegates are\nalso subject to the same non-disclosure and use obligations. The recipient may disclose Confidential\nInformation when required by law after giving reasonable notice to the other party, and the opportunity to\nseek confidential treatment, a protective order or similar remedies or relief prior to disclosure, if permitted by\nlaw.\n\n14.2. In the event that Company is required to file a copy of this Agreement or a summary of this\nAgreement with the Securities and Exchange Commission, Company will seek confidential treatment for any\nsuch filing, will give Google reasonable prior notice and opportunity to review any such filing so that Google\nmay provide Company with specific redaction requests, and will use its reasonable efforts to redact the\nAgreement (including as to all Google redaction requests) or alternatively provide an agreement summary, in\neach case if and to the extent permitted by applicable laws and regulations.\n\n14.3. Publicity. Neither party may make any public statement regarding this Agreement without the\nother\u2019s written approval.\n\n15. Term and Termination.\n\n15.1. Term. The term of this Agreement is the Term stated on the front pages of this Agreement,\nunless earlier terminated as provided in this Agreement.\n\n15.2. Termination.\n\n(a) Termination for Convenience. Company may terminate this Agreement for convenience at\nany time with notice to Google.\n\n(b) Google may terminate this Agreement immediately if Company is no longer entitled to receive\nthe Services under the Final Judgment, including if Google is no longer required to offer the Services under\nthe Final Judgment.\n\nc) Termination for Cause.\n\n(d) Google may terminate this Agreement, or the provision of any Service, immediately with notice\nif pornographic content that is illegal under U.S. law is displayed on any Site or Approved Client Application.\n\n(e) If Google in good faith believes a Qualified Competitor is in breach of the terms of its\nAgreement, it may exercise its rights under the Agreement. Before exercising such rights, Google must\nprovide simultaneous notice to the Technical Committee of the breach and the actions Google is taking in\nlight of the breach.\n\n11\n\f0/23/26 Page 13 of 19\n\nne\nae\nce\n\n16. Miscellaneous.\n\n16.1. Compliance with Laws. Each party will comply with all applicable laws, rules, ordinances,\njudicial and administrative orders, and regulations in exercising its rights and fulfilling its obligations under\nthis Agreement.\n\n16.2. Notices. All notices must be in English and in writing. Notices of termination or breach must\n(a) be addressed to the other party\u2019s primary point of contact and to the other party\u2019s Legal Department,\nwhich for Google 1 ; and (b) reference this Agreement\u2019s title and\nEffective Date. All other notices must be addressed to the other party\u2019s primary contact. Emails are written\nnotices. Notice will be treated as given on receipt, as confirmed by written or electronic records.\n\nroval Standards; Application of Requirements.\n\n16.4. Assignment. Neither party may assign any part of this Agreement.\n\n16.5. Change of Control. Upon the earlier of (a) entering into an agreement providing for a change\nof control (for example, through a stock purchase or sale, merger, asset sale, liquidation or other similar form\nof corporate transaction), (b) the board of directors of Company recommending its shareholders approve a\nchange of control, or (c) the occurrence of a change of control (each, a \u201cChange of Control Event\u201d), the\nCompany will notify the Technical Committee and Google. Google will suspend the Services until the\nTechnical Committee conducts the certification process required by the Final Judgment and certifies that\nCompany is still certified as such after the Change in Control Event.\n\n16.6. Governin\n\n16.7. | Equitable Relief. Nothing in this Agreement will limit either party\u2019s ability to seek equitable\nrelief.\n\f0/23/26 Page 14of 19\n\nEntire Agreement; Amendments.\n\n16.9. No Waiver. Neither party will be treated as having waived any rights by not exercising (or\n\ndelaying the exercise of) any rights under this Agreement.\n\n16.10. Severability. If any term (or part of a term) of this Agreement is invalid, illegal or\nunenforceable, the rest of the Agreement will remain in effect.\n\n16.11. Survival. The following sections of this Agreement will survive any expiration or termination of\nthis Agreement: 7 (Data), 8 (antellectual Property), an 1\n(Confidentiality; Publicity), , and 16 (Miscellaneous).\n\n16.12. No Agency. This Agreement does not create an agency, partnership, or joint venture between\nthe parties.\n\n16.13. No Third Party Beneficiaries. This Agreement does not confer any benefits on any third\nparty unless it expressly states that it does.\n\n16.14. Force Majeure. Neither party will be liable for failure or delay in performance to the extent\ncaused by circumstances beyond its reasonable control.\n\n16.15. Signatures. The parties may sign this Agreement using counterparts and electronic copies as\noriginals. The parties may also sign this Agreement electronically if permitted by applicable law.\n\nSigned:\n\nGoogle Company\nBy: By:\n\nPrint Name: Print Name:\nTitle: Title:\n\nDate: Date:\n\f0/23/26 Page 15 of 19\n\nEXHIBIT A\n\nSites and Approved Client Applications:\n\nFor clarity, all Sites and Approved Client Applications deemed approved under this Exhibit A remain subject\nto compliance with this Agreement, and nothing in this Agreement is intended to approve any\nimplementation that is not compliant with this Agreement (including any applicable policies and guidelines)\nor to relieve Company of the obligation to correct any non-compliant Sites or Approved Client Applications.\n\nNothing in this Agreement restricts Google\u2019s right to, at any time, cease provision of Services to non-\ncompliant Sites or Approved Client Applications, including those listed as approved under this Exhibit A.\n\n14\n\f0/23/26 Page 16 of 19\n\nEXHIBIT B\nFEES\n\nWeb Search Service (\u201cWSS\u201d) Fees\na USD / 1000 Requests for Results Sets\n\nImage Search Service (\u201cIS\u201d) Fees\na USD / 1000 Requests for Results Sets\n\nVideo Search Service (\u201cVS\u201d) Fees\ni USD / 1000 Requests for Results Sets\n\nKnowledge Panel Service (\u201cKP\u201d) Fees\n\n)\n\nNote that all fees are additive.\n\nCURRENCY: USD\n\f0/23/26 Page 17 of 19\n\nEXHIBIT C\n\nWI\n\n16\n\f0/23/26 Page 18 of 19\n\n\f0/23/26 Page 19 of 19\n\n","ocr_status":1,"date_upload":"2026-10-23T19:16:00.043207-07:00","document_number":"1567","attachment_number":1,"pacer_doc_id":"045012431081","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487563/","id":498487563,"tags":[],"absolute_url":"/docket/18552824/1567/2/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.205370-07:00","date_modified":"2026-10-26T17:32:13.903925-07:00","sha1":"47760468464983a4d4f3d97da167063dd80cf7bd","page_count":33,"file_size":2387808,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.2.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487563.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-2 Filed 10/23/26 Page 1 of 33\n\nExhibit 2\n\n\fCase 1:20-cv-03010-APM Document 1567-2\n\nFiled 10/23/26\n\nPage 2 of 33\n\nGoogle\n\nADSENSE FOR SEARCH AGREEMENT\n\nFOR COMPANIES CERTIFIED AS QUALIFIED COMPETITORS\nPURSUANT TO U.S. v. GOOGLE FINAL JUDGMENT\n\n| COMPANY INFORMATION\n\nCOMPANY: [FILL IN THE COMPANY\u2019S FULL LEGAL NAME HERE]\n\nBusiness Contact:\n\nLegal Contact:\n\nTechnical Contact:\n\nName:\n\nTitle:\n\nAddress, City, State,\nPostal Code:\n\nPhone:\n\nEmail:\n\nTERM\n\nTERM: Starting on [INSERT DATE (MUST BE FIRST OF MONTH)] (\u201cEffective Date\u2019\u2019) and continuing for five years\nthrough [INSERT DATE (MUST BE THE LAST DAY OF MONTH)].\n\nSERVICE\n\nADSENSE FOR SEARCH (\u201cAFS\u201d)\n\n\f6 Page 3 of 33\n\nThis Google AdSense for Search Agreement for Companies Certified as Qualified Competitors\nPursuant to the U.S. v. Google Final Judgment including any attached exhibit(s) (\u201cAgreement\u201d) is entered into\nby Google LLC (\u201cGoogle\u201d) and [Fill in Company\u2019s full legal name] (\u201c\u201cCompany\u2019\u2019) and is effective as of the\nEffective Date. This Agreement is entered pursuant to the Final Judgment and is subject to the terms of the\nFinal Judgment and further order by the Court.\n\n1. Definitions. In this Agreement:\n\n1.1. \u201cAd\u201d or \u201cResult\u201d means an individual Search Text Ad provided through the Service.\n\n1.3. \u201cAd Revenues\u201d\n\n1.4. \u201cAdSense for Search Restricted Access Features (RAFs) Policy\u201d or the \u201cRAF Policy\u201d\nmeans the policy located at https://support.google.com/adsense/answer/16262554?hl=en or such\nreplacement URL, and additional URLs, as notified by Google to Company, each as updated from time to\ntime.\n\n1.5. \u201cAd Set\u201d means a set of one or more Ads.\n\n1.6. \u201cAffiliate\u201d means any entity that directly or indirectly controls, is controlled by, or is under\ncommon control with, a party.\n\n1.7. \u201cApproved Client Application\u201d means a Client Application that rans on an End User\u2019s\ndesktop computer, that provides a General Search Engine or GenAI Product as defined in the Final\nJudgment, and that is either listed in Exhibit A or approved by Google in writing from time to time under\nSection 10.3(a), in each case, for the purpose of accessing the Service.\n\n1.8. \u201cBrand Elements\u201d means trade name(s), trademarks, logos, domain names, and other\ndistinctive brand elements.\n\n1.9. \u201cClick Tracking\u201d means click tracking or other click monitoring of Ads or Ad Sets on the Sites\nby Company.\n\n1.10. \u201cClient Application\u201d means any application, plug-in, helper, component, or other executable\ncode that runs on a user\u2019s desktop computer or mobile device (or any subsequent version of such\napplication).\n\n1.11. \u201cClient Application Guidelines\u201d means the policy guidelines applicable to the Approved Client\nApplication(s) as provided by Google to Company from time to time, including those located at the following\nURL: https://support.google.com/adsense/answer/ 10926790 (or any different URL(s) or additional URL(s)\nGoogle may provide to Company from time to time).\n\n1.12. \u201cCompany Content\u201d means any content served to End Users that is not provided by Google.\n\n1.13. \u201cConfidential Information\u201d means information that one party (or a Delegate, as defined\nbelow) discloses to the other party (or its Delegate) under this Agreement, and that is marked as confidential\nor would normally be considered confidential information under the circumstances. It does not include\ninformation that is independently developed by the recipient, is rightfully given to the recipient by a third\nparty without confidentiality obligations, or becomes public through no fault of the recipient.\n\n1.14. \u201cCourt\u201d means Judge Amit P. Mehta of the United States District Court of the District of\nColumbia.\n\n1.15. \u201cDesktop Ads\u201d means Ads that are displayed in response to Queries submitted by End Users\nnot using Mobile Devices or Tablet Devices.\n\f6 Page 4 of 33\n\n1.16. \u201cEnd User\u201d means an individual human end user of a Site or Approved Client Application who\nis in the United States.\n\n1.17. \u201cFinal Judgment\u201d means United States, et al. v. Google LLC, No. 20-cv-3010 (APM) (D.D.C,),\nECF No. 1462.\n\n1.18. \u201cGenAI Product\u201d means any application, software, service, feature, tool, functionality, or\nproduct that involves or makes use of Generative AI capabilities or models and has among its principal\nfunctions answering information-seeking prompts across a wide variety of topics using a broad range of\npublicly available information.\n\n1.19. \u201cGenAI\u201d or \u201cGenerative AI\u201d means a type of artificial intelligence that creates new content\nincluding but not limited to text, images, code, classifications, and other media using machine learning\nmodels.\n\n1.20. \u201cGeneral Search Engine\u201d or \u201cGSE\u201d means software or a service that produces links to\nwebsites and other relevant information in response to a user query or prompt and that seeks to fulfill a\n1.21. \u201cGoogle Branding Guidelin\n\nbroad array of informational needs.\nes\u201d means the brand treatment guidelines applicable to the\n\ndifferent URL Google may provide to Company from time to time).\n\n1.22. \u201cGoogle Program Guidelines\u201d means the policy and implementation guidelines applicable to\n\nthe Services and as located at the following URLs:\n\n(or any different URL(s) or additional URL(s) as\n\nGoogle may provide to Company from time to time).\n\n1.23. \u201cGoogle Technical Protocols\u201d means technical protocols and/or any other technical\nrequirements and specifications applicable to the Service as provided, and updated, by Google to Company\nfrom time to time.\n\n1.24. \u201cIntellectual Property Rights\u201d means all patent rights, copyrights, trademark rights, rights in\ntrade secrets, database rights, moral rights, domain names, rights in or relating to Confidential Information,\nand any other intellectual property rights (registered or unregistered) throughout the world.\n\n1.25. \u201cMobile Ads\u201d means Ads displayed in response to Queries submitted by End Users using\nMobile Devices.\n\n1.26. \u201cMobile Device\u201d means a mobile device, as determined by Google in its sole discretion\nconsistent with the mobile device definitions used by Google for advertiser reporting, pricing, and feature\nserving.\n\n1.27. \u201cMobile & Tablet Queries\u201d means Queries from Mobile Devices or Tablet Devices.\n\n1.28. \u201cMonthly Forecast\u201d means the projected volume of U.S. Queries from Sites, Approved Client\nApplications, and Syndicated Properties that Company expects to send to Google through Requests each\nmonth.\n\n1.29. \u201cNet Ad Revenues\u201d\n\n1.30. \u201cPeak QPS\u201d means the maximum number of Requests a system handles during its busiest single\nsecond of traffic during a month.\n\n1.31. \u201cPlaintiffs\u201d means the plaintiffs as defined in the Final Judgment.\n\n1.32. \u201cQPS\u201d means Queries per second.\n\f6 Page 5of 33\n\n1.33. \u201cQuery\u201d means (a) a text query entered and submitted into a Search Box on a Site or on an\nApproved Client Application by an End User (whether by typing or voice input) or (b) if applicable, a text\n\nquery from Google\u2019s query re-writing features (\u2018did you mean,\u201d \u201cpeople also ask,\u201d and autocomplete) that\nthe End User selects.\n\n1.34. \u201cRequest\u201d means a request that is sent by Company to Google for an Ad Set. For the avoidance\nof doubt, synthetic queries are not Requests.\n\n1.35. \u201cRestricted Access Feature\u201d or \u201cRAF\u201d means a feature of the Service that is listed in the RAF\nPolicy and that Google has made available to Company.\n\n1.36. \u201cResults Page\u201d means any Site page that contains any Results.\n1.37. \u201cSearch Box\u201d means a search box into which End Users enter search queries.\n\n1.38. \u201cSearch Text Ad\u201d means a general search text advertisement, which is an ad that resembles an\norganic link on a search engine results page. Search Text Ads can include images and often appear at the top\nof the search engine results page with a designation indicating that they are paid advertisements. If, during the\nTerm, Google makes a syndication service generally available that provides publishers with Search Text Ads\nfor Al Overviews that appear on the publishers\u2019 properties, then, subject to any additional or different terms\nthat the Court or Technical Committee may agree to apply, \u201cSearch Text Ad\u201d will also include those Search\nText Ads.\n\n1.39. \u201cService\u201d means the provision of Search Text Ads through Google\u2019s AdSense for Search\nservice.\n\n1.40. \u201cSite(s)\u201d means a Web site(s) that provides a General Search Engine or Gen AI Product as\ndefined in the Final Judgment, and that is located at the URL(s) listed in Exhibit A or approved by Google in\nwriting from time to time under Section 10.3(a).\n\n1.41. \u201cSubsyndicate\u201d means the owner of a Syndicated Property, as reported to Google.\n\n1.42. \u201cSyndicated Approved Client Application\u201d means an Approved Client Application that: (1) 1s\nnot owned and operated by Company, and Gi) either is listed in Attachment 1 to Exhibit D (Terms for\nSyndicated Properties), or 1s approved by Google from time to time under Section 10.3(a), in each case, for\nthe purpose of accessing a Service on a Syndicated Site.\n\n1.43. \u201cSyndicated Property\u201d means a Syndicated Approved Client Application or a Syndicated Site.\n1.44. \u201cSyndicated Site\u201d means a Site that: (@) is not owned and operated by Company, and (11) 1s\neither listed in Attachment 1 to Exhibit D (Terms for Syndicated Properties), or is approved by Google from\n\ntime to time under Section 10.3(a).\n\n1.45. \u201cTablet Ads\u201d means Ads displayed in response to Queries submitted by End Users using Tablet\nDevices.\n\n1.46. \u201cTablet Device\u201d means a tablet device, as determimed by Google in its sole discretion consistent\nwith the tablet device definitions used by Google for advertiser reporting, pricing, and feature serving.\n\n1.47. \u201cTechnical Committee\u201d means the five-person committee of experts appointed by the Court\npursuant to Final Judgment Section VITA.\n\n1.48. In this Agreement, (1) \u201cincluding\u201d means \u201cincluding but not limited to,\u201d (11) examples are\nillustrative and not the sole examples of a particular concept, (111) unless expressly stated otherwise, \u201cdays\u201d\nmeans calendar days.\n\n2. Launch, Permitted Use, and Implementation and Maintenance of the Service.\n\n2.1. Launch. The parties will each use reasonable efforts to launch the Service into live use within 30\ndays from the Effective Date. Company will not launch any implementation of the Service into live use,\n\n3\n\f6 Page 6 of 33\n\nincluding without limitation any implementation on or through an Approved Client Application, and such\nimplementations will not be payable by Google, until Google has approved such implementations in writing\nroval will not be unreasonably withheld or delayed.\n\n2.2. Permitted Use. Company agrees that the only permitted use of the Service (or any part thereof)\nis for Company to, subject to the terms of this Agreement, send a Request to the Service for an Ad Set that\nCompany then displays on the applicable Site or Syndicated Site to the End User who entered the associated\nQuery (as applicable) (the \u201cPermitted Use\u2019). Company will not, and will not knowingly or negligently allow\nany third party to, use the Service, Ads (or part thereof), or other information obtained through use of the\nService for any purpose other than the Permitted Use. For the avoidance of doubt, Company may not issue\nRequests to Google that contain synthetic queries.\n\n2.3. Implementation and Maintenance.\n\n(a) For the remainder of the Term, Google will make available and Company will implement and\nmaintain the Service on the Sites and Approved Client Applications. For clarity, Company may not\n\n\u2014 the Service on a i that is not a Site, \u2014 Client \u2014 ot Syndicated \u2014\n\n(b) Company will ensure that with respect to every Site and Approved Client Application, except for\nSyndicated Properties, Company:\n\n(i) is the technical and editorial decision maker in relation to each page, including Results Pages,\nand each Approved Client Application, on which the Service is implemented; and\n\n(ii) has control over the way in which the Service is implemented on each of those pages and\nApproved Client Applications.\n\n(c) Company will provide the name of the Subsyndicate that owns and operates each Syndicated\nProperty. For the period during which the Service is used on a Syndicated Property, Company will ensure\nthat with respect to every such Syndicated Property, the named Subsyndicate owns and operates such\nSyndicated Property and all corresponding Results Pages, where \u201coperate\u201d means that the Subsyndicate\nmaintains and has final administrative authority over the Syndicated Property and all corresponding Results\nPages.\n\n(d) Company will ensure that the Service is implemented and maintained in accordance with the\nfollowing:\n\n(t) the Google Program Guidelines;\n(ii) the Google Branding Guidelines; and\n\n(iii) the Google Technical Protocols.\n\f6 Page 7 of 33\n\n(e) Company will ensure that Ads are displayed in a single continuous block and are not interspersed\nwith any other advertisements or content.\n\n(f) Company will ensure that: (i) each Request is sent in compliance with this Agreement; (ii) each\nRequest is generated by a Query; and (ii) each Request contains the Query that generated that Request. For\nthe avoidance of doubt, Company will not send synthetic queries to Google.\n\n(g) Google will, upon receiving a Request sent in compliance with this Agreement, provide an Ad\nSet when available. Company will then display the Ad Set (as applicable) on the applicable Site.\n\n(h) Company will ensure that at all times during the applicable Term, Company:\n\n(i) has a clearly labeled and easily accessible privacy policy in place relating to the Site(s) and\nApproved Client Application(s); and\n\n(ii) provides the End User with clear and comprehensive information about cookies and other\ninformation stored or accessed on the End User\u2019s computer or device in connection with the Service,\nincluding information about End Users\u2019 options for cookie management.\n\n@) Company will use commercially reasonable efforts to ensure that an End User gives consent to\nthe storing and accessing of cookies and other information on the End User\u2019s computer or device in\nconnection with the Service where such consent is required by law.\n\n(j) Google and Company agree to the Google Ads controller-controller data protection terms\navailable at: https://privacy.google.com/businesses/controllerterms/ (or any different or additional URL\nGoogle may provide to Company from time to time).\n\n2.4. Mobile & Tablet Queries. Notwithstanding anything to the contrary in this Agreement,\nCompany, based on its good faith determination of an End User\u2019s device type, will not, and will not allow any\nthird party to (a) directly or indirectly access the Service through any application, plug-in, helper, component\nor other executable code that runs on an End User\u2019s Mobile Device or Tablet Device; (b) access the Service\nfor Mobile & Tablet Queries obtained as a result of such End Users downloading any application, plug-in,\nhelper, component or other executable code; (c) allow any third party sites or applications, except for\nexplicitly approved mobile Syndicated Sites listed in Exhibit D, to access the Service for Mobile & Tablet\nQueries; or (d) except for explicitly approved mobile Syndicated Sites listed in Exhibit D, enter into any type\nof arrangement with a third party where either party receives a financial benefit in connection with the Results\nor Ad revenue for Mobile & Tablet Queries. Upon notice from Google, Company will immediately cease\naccessing, and cease allowing any third party to access, the Service, in violation of Section 2.4(a)-(d) above, on\nor through any End User device identified by Google as a Mobile Device or Tablet Device. For the\navoidance of doubt, nothing in this Section 2.4 is intended to prevent Company from displaying third party\nads on a Results Page.\n\n3. Syndication Limits, Restrictions, and Compliance.\n\n3.1. Syndication Limits.\n\n(a) Within the first 45 days when Google and the Company are preparing to launch the Service,\nCompany must provide Google and the Technical Committee with twelve months of Monthly Forecasts and\nPeak QPS, for review. If the Technical Committee approves Company\u2019s Monthly Forecasts and Peak QPS,\nGoogle will use them to accommodate Peak QPS for the Service. For each subsequent year the Company\n\n2\n\f6 Page 8 of 33\n\nreceives the Service, Company will provide an updated set of twelve months of Monthly Forecasts and Peak\nQPS for the Technical Committee to review and approve. Google will work with the Technical Committee to\ndevelop reasonable protocols that safeguard the Monthly Forecasts\u2019 commercially sensitive information.\n\n(b) If Company consistently falls below its Monthly Forecasts or Peak QPS for a period of three\nmonths or longer, Google may request that the Technical Committee revise the Monthly Forecasts or Peak\nQPS for the remainder of any given year.\n\n(c) Any increase to the Company\u2019s Monthly Forecasts or Peak QPS must be approved by the\nTechnical Committee. Google requires the Company to provide at least three months notice should the\nCompany seek to increase any Monthly Forecast by less than 5% of its forecasted Peak QPS. Google requires\nthe Company to provide at least six months notice should the Company seek to increase any Monthly\nForecast by more than 5% of its forecasted Peak QPS.\n\n(d) Company warrants that the Monthly Forecasts and Peak QPS provided to Google and the\nTechnical Committee are accurate estimates made in good faith.\n\n(ec) Google will not be obligated to make the Service available in excess of the Peak QPS limits in the\nMonthly Forecasts approved by the Technical Committee.\n\n3.2. Restrictions. Company will not, and will not knowingly or negligently allow any third party to:\n(a) modify, obscure, or prevent the display of all, or any part of, any Results;\n(b) edit, filter, truncate, append terms to, or otherwise modify any Query;\n\n(c) implement any click tracking or other click monitoring of Results except as provided in Section 5\n(Click Tracking) below;\n\n(d) display any Results in pop-ups, pop-unders, exit windows, expanding buttons, animation, or\nother similar methods;\n\n(e) interfere with the display of, or frame, any Results Page or any page accessed by clicking on any\nResults;\n\n(f) display any content between any Results and any page accessed by clicking on those Results or\nplace any interstitial content immediately before any Results Page containing any Results;\n\nment under which a third party and Company\n\nincluding any co-\n\ne of arran\n\nenter into any\n\nbranding, white labeling or sub-syndication arrangement),\nFor the avoidance of doubt, nothing in this Section 3.2(g) is intended to prevent Company\nfrom displaying third party ads on a Results Page;\n\n(h) directly or indirectly, (i) offer incentives to End Users to generate impressions, Requests, or\nclicks on Results, (ii) deceptively generate impressions, Requests, or clicks on Results or (iii) modify\nimpressions, Requests, or clicks on Results;\n\n2 \u00ab6\n\n@ \u201ccrawl\u201d, \u201cspider\u201d, index or in any non-transitory manner store or cache, or use in any manner\nResults (or part thereof) or other information obtained by Company through use of the Service beyond what\nis necessary to present Results to the End User who submitted the associated Query. For the avoidance of\ndoubt, this provision prohibits reverse engineering or using the Service (including any Results) to ground or\ntrain any model;\n\n(j) except for content provided by Google, display on any Site or Approved Client Application, any\ncontent that violates or encourages conduct that would violate the Google Program Guidelines, the Google\n\nBranding Guidelines, the Google Technical Protocols, or the Client Application Guidelines, (\u201cUnacceptable\nCone acim,\n\f6 Page 9 of 33\n\nQ) use the Service to directly or indirectly monetize error pages. Indirect monetization of error\npages includes, but is not limited to, having a search box or text links on error pages that resolve to pages\ncontaining Ads. Errors include, but are not limited to, DNS errors or HTTP response codes of types 3xx,\n\n4xx, or 5xx;\n\n(m) Without limiting the scope of its other obligations under the Agreement, Company shall ensure\nthat it has obtained or observed relevant rights to any third party content provided on any search results page,\nincluding, but not limited to, any applicable terms of service, or observing the industry practice known as the\nrobots exclusion protocol, as further described at http://www.robottxt.org. Company shall obtain or observe\nsuch rights in good faith use of user agents, source addresses, crawl rates and so forth. This clause shall be\nwithout prejudice to the other provisions in this Section 3.2.\n\nCustomer Content.\n\n3.3. Compliance.\n\n(a) Company will not knowingly or negligently allow any use of or access to the Service through any\nSite, Approved Client Application, or Syndicated Property that is not in compliance with the terms of this\nAgreement. Company will use commercially reasonable efforts to monitor for any such access or use and\nwill, if any such access or use is detected, take all reasonable steps requested by Google to disable this access\n\nor use.\n\n(b) If Company is not in compliance with this Agreement at any time, Google may with notice to\n\nCompany (such notice setting forth such noncompliance in reasonable detail), suspend provision of all (or\nany a of) the Service\n\nuntil Company implements adequate corrective modifications as reasonably required and reasonably\ndetermined by Google;\n\n(c) Google may restrict, suspend, or terminate Company\u2019s right to use any RAF in accordance with\nthe RAF Policy, even if Company implements adequate corrective modifications in response to any finding of\nnon-compliance in accordance with Section 3.3(b).\n\n4. Client Applications. Company will, and will ensure that all Approved Client Application(s) and all\nSyndicated Approved Client Applications will, comply with the Google Program Guidelines and the Client\nApplication Guidelines, as provided by Google to Company from time to time. When evaluating the rights\nand obligations of Syndicated Approved Client Applications, any reference in the Guidelines listed in the\nimmediately preceding sentence to \u201cApproved Client Applications\u201d will be deemed to apply equally to\nSyndicated Approved Client Applications. For the avoidance of doubt, all Queries originating from an\nApproved Client Application must resolve to a Results Page on a Site and all Queries originating from a\nSyndicated Approved Client Application must resolve to a Results Page on the applicable Syndicated Site.\n\n5. Click Tracking. To the extent permitted under the RAF Policy, Company may implement Click\nTracking in accordance with the Google Technical Protocols, Google Program Guidelines, and this\nAgreement. Company is responsible for the implementation and operation of any Click Tracking.\n\fPage 10 of 33\n\n6. No Exclusivity. This Agreement is non-exclusive. Provided Company complies with this Agreement,\nincluding the Google Program Guidelines and the Google Branding Guidelines, Company may display ads\nfrom other ad providers on the Sites or Syndicated Sites.\n\n8. Client IDs. Google will provide Company with client IDs and channel IDs, as reasonably requested by\nCompany from time to time. In addition, Company will deploy such number of client IDs as Google may\nreasonably request. In the event Google provides Company with notice of its election to substitute an existing\nclient ID associated with a Site, Approved Client Application, or Syndicated Property for a new or different\nclient ID, Company will deploy such new or different client ID to the applicable Site, Approved Client\nApplication, or Syndicated Property within five (5) business days of receiving Google\u2019s notice, provided that\nany such change does not materially affect Company\u2019s ability to monitor or obtain applicable reports for any\nsuch Site, Approved Client Application, or Syndicated Property (or section or page thereof). The Company\nwill use client IDs as reasonably instructed by Google, and will provide such information to Google as\nGoogle may reasonably request with respect to the use and application of any client IDs.\n\n9. Third Party Distribution.\n\n9.1. Syndicated Properties. If the Technical Committee determines that a Syndicated Site or\nSyndicated Approved Client Application is entitled to use the Service under the Final Judgment, and the\nSyndicated Properties are approved by Google pursuant to Section 10.3(a), Company may sub-syndicate the\nService in accordance with Exhibit D (Sub-Syndication Terms) and, in connection with such sub-syndication,\n\nCompany may share revenue received hereunder with Subsyndicates.\n\n10. Changes and Modifications.\n\n10.1. By Google. If Google modifies the Google Program Guidelines, the Google Branding\nGuidelines, the Google Technical Protocols, the RAF Policy, or the Client Application Guidelines and the\nmodification requires action by Company, Company will take the necessary action no later than 30 days from\n\fPage 11 of 33\n\nreceipt of notice from Google (or such longer period as required by applicable law or permitted by Google in\n\n10.2. By Company. Company will use commercially reasonable efforts to provide Google with at\nleast 15 days prior notice of any change in code or serving technology that could reasonably be expected to\naffect the delivery or display of any Results,\n\n10.3. Site and Approved Client Application List Changes.\n\n(a) Company may notify Google from time to time that it wishes to add or remove URL(s) to the\nSite(s) or add or remove Client Application(s) to the Approved Client Application(s), in each such case, by\nsending notice to Google at least 45 days before Company wishes the addition or deletion to take effect.\nGoogle may approve or disapprove a request to add a URL or Client Application in its reasonable discretion,\nthis approval or disapproval to be in writing. Regardless of whether Google approves a URL or Client\nApplication, Google will not be obligated to provide the Service to that URL or Client Application until the\nTechnical Committee determines that the URL or Client Application is entitled to use the Service under the\nFinal Judgment.\n\n(b) If there is a change in control of any Site or Approved Client Application (such that the\nconditions set out in Section 2.3(b)(1) or 2.3(b) (ii) are not met) or of any Syndicated Property (such that the\nconditions set out in Section 2.3(c) are not met):\n\n(t) Company will provide notice to Google at least 30 days before the change; and\n\n(ii) from the date of that change in control of the Site, Approved Client Application, or\nSyndicated Property, that Site, Approved Client Application, or Syndicated Property will be treated as\nremoved from this Agreement. Company will ensure that from that date, the Service is no longer\nimplemented on that Site, Approved Client Application, or Syndicated Property.\n\n11. Data.\n\n11.1. Definition of Company Data. As between Company and Google, any data or information sent\nby Company to Google during the Term, including, without limitation, data or information submitted as a\nRequest to Google (\u201cCompany Data\u201d), will remain the property of Company.\n\n11.2. Definition of Google Data. As between Company and Google, any data or information\ncollected by Google, including, without limitation, data or information from clicks on the Ads displayed on\nthe Site or a Syndicated Site (\u201cGoogle Data\u201d), will remain the property of Google.\n\n11.3. Permitted and Prohibited Uses.\n\nCompany Data.\n\n\fPage 12 of 33\n\nb) Google Data.\n\n(c) Data Shared with Advertisers.\n\n(d) Legally Required Uses. Notwithstanding the foregoing or anything to the contrary herein,\nGoogle may use the Google Data, and either party may use the Company Data to the extent required by law,\nin order to comply with legal process, preventing fraud or imminent harm, and ensuring the security of its\nnetwork and Services.\n\n12. Intellectual Property. Except to the extent expressly stated otherwise in this Agreement, neither party\nwill acquire any right, title, or interest in any Intellectual Property Rights belonging to the other party, or to\nthe other party\u2019s licensors.\n\n13. Brand Elements.\n\n14. Payment.\n\n14.1. Payments.\n\n\fPage 13 of 33\n\n(c) Payor. In accordance with applicable laws and regulations, Google operates multiple local\nGoogle Affiliates to process transactions, and payments from Google to Company may be made by one or\nmore of these Google Affiliates, which will satisfy Google\u2019s payment obligations under this Agreement.\n\n14.3. Currency & Bank Charges.\n\n15. Warranties; Disclaimers.\n\n16. Indemnification.\n\n\fPage 14 of 33\n\n17. Limitation of Liability.\n\n\fPage 15 of 33\n\n18. Confidentiality; Publicity.\n\n18.1. Confidentiality. The recipient will not disclose the other party\u2019s Confidential Information,\nexcept to Affiliates, employees, agents, professional advisors, or third-party contractors (\u201cDelegates\u201d) who\nneed to know it and who have a legal obligation to keep it confidential. The recipient will use the other\nparty\u2019s Confidential Information only to exercise rights and fulfill obligations under this Agreement while\nusing reasonable care to protect the Confidential Information. The recipient will ensure that its Delegates are\nalso subject to the same non-disclosure and use obligations. The recipient may disclose Confidential\n\na\n\n13\n\fPage 16 of 33\n\nInformation when required by law after giving reasonable notice to the other party, and the opportunity to\nseek confidential treatment, a protective order or similar remedies or relief prior to disclosure, if permitted by\nlaw.\n\n18.2. Exceptions. Notwithstanding Section 18.1 (Confidentiality), Google may (a) inform advertisers\nof Company\u2019s participation in the Service; and (b) share with advertisers Site-specific and Approved Client\nApplication-specific statistics, the Site URL, the name and platform of the Approved Client Applications, and\nrelated information collected by Google through its provision of the Service to Company. Disclosure of\ninformation by Google under this Section 18.2 will be subject to the terms of the Google Privacy Policy\nlocated at the following URL: http:/ / www.google.com / ptivacypolicy.html (or a different URL Google may\nprovide to Company from time to time).\n\n18.3. Subsyndicates.\n\n18.4. In the event that Company is required to file a copy of this Agreement or a summary of this\nAgreement with the Securities and Exchange Commission, Company will seek confidential treatment for any\nsuch filing, will give Google reasonable prior notice and opportunity to review any such filing so that Google\nmay provide Company with specific redaction requests, and will use its reasonable efforts to redact the\nAgreement (including as to all Google redaction requests) or alternatively provide an agreement summary, in\neach case if and to the extent permitted by applicable laws and regulations.\n\n18.5. Publicity. Neither party may make any public statement regarding this Agreement without the\nother\u2019s written approval.\n\n19. Term and Termination.\n\n19.1. Term. The term of this Agreement is the Term stated on the front pages of this Agreement,\nunless earlier terminated as provided in this Agreement.\n\n19.2. \u2018Termination.\n\n(a) Termination for Convenience. Company may terminate this Agreement for convenience at\nany time with notice to Google.\n\n(b) Google may terminate this Agreement immediately if Company is no longer entitled to receive\nthe Services under the Final Judgment, including if Google is no longer required to offer the Service under\nthe Final Judgment.\n\nc) Termination for Cause.\n\n(d) Breach of terms and conditions of this Agreement by a Subsyndicate or Syndicated Property will\nbe handled under Exhibit D (Terms for Syndicated Properties).\n\n(ec) Google may terminate this Agreement, or the provision of the Service, immediately with notice if\n\npornographic content that is illegal under U.S. law is displayed on any Site, Approved Client Application, or\nSyndicated Property.\n\n14\n\fPage 17 of 33\n\n(f) If Google in good faith believes Company is in breach of the terms of this Agreement, Google\nmay exercise its rights under the Agreement. Before exercising such rights, Google shall first provide\nsimultaneous notice to the Technical Committee and the Plaintiffs of the breach and the actions Google is\ntaking in light of the breach. Google shall provide this notice in time such that Plaintiffs have a reasonable\nperiod of time to raise objections. If Plaintiffs object and seek a resolution by the Court, Google may not take\nany action until the later of (i) two weeks after Plaintiffs seek Court intervention, if the Court does not act, or\n(ii) until further order of the Court, if the Court intervenes. Google may seek expedited consideration from\nthe Court if the circumstances warrant such treatment.\n\n20. Miscellaneous.\n\n20.1. Compliance with Laws. Each party will comply with all applicable laws, rules, ordinances,\njudicial and administrative orders, and regulations in exercising its rights and fulfilling its obligations under\nthis Agreement.\n\n20.2. Notices. All notices must be in English and in writing. Notices of termination or breach must\n(a) be addressed to the other party\u2019s primary point of contact and to the other party\u2019s Legal Department,\nwhich for Google rs and (b) reference this Agreement\u2019s title and\nEffective Date. All other notices must be addressed to the other party\u2019s primary contact. Emails are written\nnotices. Notice will be treated as given on receipt, as confirmed by written or electronic records.\n\nroval Standards; Application of Requirements.\n\n20.4. Assignment. Neither party may assign any part of this Agreement.\n\n20.5. Change of Control. Upon the earlier of (a) entering into an agreement providing for a change\nof control (for example, through a stock purchase or sale, merger, asset sale, liquidation or other similar form\nof corporate transaction), (b) the board of directors of Company recommending its shareholders approve a\nchange of control, or (c) the occurrence of a change of control (each, a \u201cChange of Control Event\u201d), the\nCompany will notify the Technical Committee and Google. Google will suspend the Service until the\nTechnical Committee conducts the certification process required by the Final Judgment and certifies that the\nCompany is still certified as such after the Change in Control Event.\n\n15\n\fPage 18 of 33\n\n20.7. Equitable Relief. Nothing in this Agreement will limit either party\u2019s ability to seek equitable\nrelief.\n\n20.8. Entire Agreement; Amendments.\n\n(@) Google shall provide simultaneous notice to the Technical Committee and the Plaintiffs of\nany such amendment and allow Plaintiffs a reasonable period of time to raise objections. If Plaintiffs object\nand seek a resolution by the Court, the amendment will not be effective until a date after the later of (i) two\nweeks after Plaintiffs seek Court intervention, if the Court does not act, or (ii) until further order of the\nCourt, if the Court intervenes. Google may seek expedited consideration from the Court if the circumstances\nwarrant such treatment, in which case the amendment will not be effective until a date after the expedited\nproceedings are completed.\n\n20.9. No Waiver. Neither party will be treated as having waived any rights by not exercising (or\ndelaying the exercise of) any rights under this Agreement.\n\n20.10. Severability. If any term (or part of a term) of this Agreement is invalid, illegal or\nunenforceable, the rest of the Agreement will remain in effect.\n\n20.11. Survival. The following sections of this Agreement will survive any expiration or termination of\nbis Aeon 1! Dr) teas a i8\n\n(Confidentiality; Publicity), , and 20 (Miscellaneous).\n\n20.12. No Agency. This Agreement does not create an agency, partnership, or joint venture between\nthe parties.\n\n20.13. No Third Party Beneficiaries. This Agreement does not confer any benefits on any third\nparty unless it expressly states that it does.\n\n20.14. Force Majeure. Neither party will be liable for failure or delay in performance to the extent\ncaused by circumstances beyond its reasonable control.\n\n20.15. Signatures. The parties may sign this Agreement using counterparts and electronic copies as\noriginals. The parties may also sign this Agreement electronically if permitted by applicable law.\n\fPage 19 of 33\n\nSigned:\n\nGoogle Company\nBy: By:\n\nPrint Name: Print Name:\nTitle: Title:\n\nDate: Date:\n\n17\n\fPage 20 of 33\n\nEXHIBIT A\nSites and Approved Client Applications:\nFor clarity, all Sites and Approved Client Applications deemed approved under this Exhibit A remain subject\nto compliance with this Agreement, and nothing in this Agreement is intended to approve any\nimplementation that is not compliant with this Agreement (including any applicable policies and guidelines)\n\nor to relieve Company of the obligation to correct any non-compliant Sites or Approved Client Applications.\n\nNothing in this Agreement restricts Google\u2019s right to, at any time, cease provision of Service to non-\ncompliant Sites or Approved Client Applications, including those listed as approved under this Exhibit A.\n\n18\n\fvu\n\u00a9\nD\nN\nbf\noO\nsh\nw\nw\n\nEXHIBIT B\n\nCURRENCY: USD\n\nREVENUE SHARE PERCENTAGE:\n\nCompany-owned Sites: Effective Date - September 30, 2027\n\no\n\n&\n\n3\n~\n\nMobile and Tablet\n\nCompany-owned Sites: October 1, 2027 - Expiry of Term\n\no\noO\no\na\n\u00b0\n~\n\f\u00a9\nD\nN\nNo\noO\nsh\nw\nw\n\nMobile and Tablet\n\nSyndicated Properties - Effective Date - September 30, 2027\n\no\n\n&\n\n3\n~\n\nMobile and Tablet\n\nSyndicated Properties - October 1, 2027 - Expiry of Term\n\no\n\n&\n\n3\n~\n\nNO\no\n\fPage 23 of 33\n\nMobile and Tablet\n\fAML\n| |\n\fPage 25 of 33\n\n\fPage 26 of 33\n\n\fPage 27 of 33\n\n[OPTIONAL] EXHIBIT D\n\nSub-Syndication Terms\n\n1. Conditions to Permitted Distribution.\n\n\fPage 28 of 33\n\n2. Syndication\n\no Ee\n\n\u00a5\na\n~\n\u00b0\n+\n9\n\fPage 29 of 33\n\n4. Notice of Syndicated Agreement Termination.\n\n5. Suspension and Termination.\n\n\fPage 30 of 33\n\n6. Policy Updates.\n\n7. Payment; Fees.\n\n8. No Rights Under this\n\n9. Order of Precedence.\n\n\fPage 31 of 33\n\nAttachment 1 to Exhibit D\n\nSyndicated Properties\n\nSyndicated Site and\n\nSyndicated Approved\nClient Application Search Results Client Application\nOwner(s) Page/Site URL\n\nAny URLs or Client Applications listed in this Attachment 1 to Exhibit D are subject to the terms that apply\nto Syndicated Sites or Syndicated Approved Client Applications.\n\nFor clarity, all Syndicated Sites and Syndicated Approved Client Applications deemed approved under this\nExhibit D remain subject to compliance with this Agreement, and nothing in this Agreement 1s intended to\napprove any implementation that is not compliant with this Agreement (including any applicable policies\nand guidelines) or to relieve Company of the obligation to correct any non-compliant Syndicated Sites or\nSyndicated Approved Client Applications. Nothing in this Agreement restricts Google\u2019s right to, at any time,\ncease provision of the Service to non-compliant Syndicated Sites or Syndicated Approved Client\nApplications, including those listed as approved under this Exhibit D.\n\n29\n\fPage 32 of 33\n\n[OPTIONAL] EXHIBIT E\nAdditional Provisions for Permitted Sites\n\ni\n|\n\n30\n\fPage 33 of 33\n\nMl\n\n31\n","ocr_status":1,"date_upload":"2026-10-23T19:16:04.139642-07:00","document_number":"1567","attachment_number":2,"pacer_doc_id":"045012431082","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487564/","id":498487564,"tags":[],"absolute_url":"/docket/18552824/1567/3/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.223893-07:00","date_modified":"2026-10-26T18:07:25.221195-07:00","sha1":"797cd7e39cab3f73d07a1a4ba8758383e20e3ef4","page_count":3,"file_size":262316,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.3.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487564.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-3 Filed 10/23/26 Page 1 of 3\n\n\n\n\n Exhibit 3\n\f Case 1:20-cv-03010-APM Document 1567-3 Filed 10/23/26 Page 2 of 3\n\n\n\n\nCOLETTE T. CONNOR\n (202) 434-5170\n cconnor@wc.com\n\n\n\n\n August 10, 2026\n\n Via Email\n\n Remedies Technical Committee, Inc.\n tc@remediestc.org\n\n Re: United States, et al. v. Google LLC, No. 20-cv-3010-APM (D.D.C.) & State of\n Colorado, et al. v. Google LLC, No. 20-cv-3715-APM (D.D.C.)\n\n Technical Committee Members:\n\n I write in response to your invitation for Google to provide input regarding syndication\n license terms and pricing. Google has prepared proposed template agreements for Search\n syndication services required under Final Judgment \u00a7 V.A1 and Search Text Ads syndication\n services required under Final Judgment \u00a7 VI.B, enclosed as Exhibits 1 and 2. Because Google\n has not previously offered its Websearch Syndication Services (\u201cWSS\u201d) through a stand-alone\n negotiated agreement, and consistent with the Final Judgment\u2019s requirement that Google offer\n these services separately, the attached agreements separate those terms that apply only to the\n Search syndication services from those terms that apply only to the Search Text Ads syndication\n services. Accordingly, Google is also attaching the\n\n , Google\u2019s Search Text Ads syndication\n service. At this time, the\n\n\n In Exhibit B of the template license agreements, Google has included the proposed\n pricing terms. Because Google has previously offered WSS only in combination with AFS,\n\n 1\n As Google noted in Appendix B to its May 8, 2026 correspondence, Google\u2019s search syndication products for U.S.\n customers do not provide syndicated local or maps content. Instead, Google offers APIs through its Maps Platform,\n which is operated separately from Google\u2019s Websearch Syndication (\u201cWSS\u201d) product. Google is preparing\n proposed template licenses for Local/Maps services, which we will send separately.\n\n 2\n See, e.g.,\n\f Case 1:20-cv-03010-APM Document 1567-3 Filed 10/23/26 Page 3 of 3\n\n\n\n\nAugust 10, 2026\nPage 2\n\nGoogle refers to the price of its Programmable Search Engine (\u201cProSE\u201d) product without ads.\nSimilarly, Google has never offered stand-alone image search, video search, or Knowledge\nPanel.\n The Knowledge Panel pricing is based on the publicly\navailable pricing for Bing\u2019s Search APIs before those products were deprecated in 2025.\n\n\n\n\n In addition, note that Google is in the process of developing systems and processes to\nenable Qualified Competitors to subsyndicate AFS.\n Google\u2019s current processes for onboarding subsyndicates\nand offering reporting features are not scalable. As Google refines this process, it may request\nmodifications to Sections 8, 18.3, and Exhibit D Sections 1.7 and 3 of the AFS agreement.\n\n Finally, Google is in the process of responding to the Technical Committee\u2019s demand\nletter dated July 31, 2026 and will provide that information by August 14, 2026.\n\n\n Sincerely,\n\n /s/ Colette T. Connor\n\n Colette T. Connor\n\n\n\n\n3\n IAC is not a current syndication customer, as its agreement expired at the end of April 2026 and IAC declined to\nrenew the services.\n\f","ocr_status":1,"date_upload":"2026-10-23T19:16:06.355610-07:00","document_number":"1567","attachment_number":3,"pacer_doc_id":"045012431083","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487565/","id":498487565,"tags":[],"absolute_url":"/docket/18552824/1567/4/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.241915-07:00","date_modified":"2026-10-26T17:56:14.810565-07:00","sha1":"bd58478a75b80a97374decfb3ef2ffafcb116fd3","page_count":55,"file_size":722167,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.4.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.4.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487565.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 1 of 55\n\n\n\n\n Exhibit 4\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 2 of 55\n\n\n\n\n [TEMPLATE] QUALIFIED COMPETITOR SYNDICATION LICENSE AGREEMENT\n\n This Qualified Competitor Syndication License Agreement (\u201cAgreement\u201d) is entered\ninto this ___ day of ____, [2026] by and between _____________ (\u201cSignatory\u201d) and Google\nLLC (\u201cGoogle\u201d) (collectively, \u201cParties\u201d). The effective date of this Agreement shall be the date\non which Signatory executes this Agreement (the \u201cEffective Date\u201d).\n\n RECITALS\n\nA. WHEREAS, the United States District Court for the District of Columbia (the \u201cCourt\u201d),\nJudge Amit P. Mehta, has entered a Final Judgment (ECF No. 1462, \u201cFinal Judgment\u201d) in\nUnited States of America et al. v. Google LLC (Civil Action No. 20-3010 (APM)) and State of\nColorado et al. v. Google LLC (Civil Action No. 20-3715 (APM)) (collectively, \u201cUnderlying\nConsolidated Cases\u201d), which, among other things, requires Defendant Google to take or refrain\nfrom taking certain actions and further provides for the appointment of five members of a\nTechnical Committee (\u201cTC\u201d) to assist the Plaintiffs in the Underlying Consolidated Cases\n(collectively, \u201cPlaintiffs\u201d) in the enforcement of Google\u2019s compliance with the Final Judgment;\n\nB. WHEREAS, Section IX.V of the Final Judgment provides for the certification of\nQualified Competitors, as defined below;\n\nC. WHEREAS, Signatory has been certified as a Qualified Competitor pursuant to Section\nIX.V of the Final Judgment for the period [CERTIFICATION EFFECTIVE DATE] through\n[CERTIFICATION EXPIRATION DATE], subject to periodic recertification;\n\nD. WHEREAS, Sections V.A\u2013B of the Final Judgment require that Google shall make\navailable to Qualified Competitors certain information and data related to its web and mobile\nsearch services via syndication through real-time APIs and subject to a license governing the\nterms of syndication;\n\nE. WHEREAS, Section VI.B of the Final Judgment requires that Google shall make\navailable to Qualified Competitors its syndication services for Search Text Ads\u2014as defined in\nthe Final Judgment\u2014subject to a license governing the terms of syndication; and\n\nF. WHEREAS, the Parties to this Qualified Competitor Syndication License Agreement\nintend to be legally bound.\n\nNOW, THEREFORE, in consideration of the mutual promises contained herein and pursuant to\nthe Court\u2019s Final Judgment, the sufficiency of which is hereby acknowledged, the Parties agree\nas follows:\n\n\n 1\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 3 of 55\n\n\n\n\n AGREEMENT\n\n\n1. Definitions. As used in this Agreement, the following terms shall have the following\nmeanings:\n\n 1.1. \u201cAd Revenues\u201d means, for any period during the Agreement Term, revenues\ngeneratedthat are recognized by Google in connection with theSignatory\u2019s or its Affiliate(s)\u2019 use\nof anythe Search Text Advertising Service(s) by Signatory or its Affiliate(s) which are and\nattributed to Search Text Ads provided through such in that period. For avoidance of doubt, this\nDefinition extends to all revenues generated in connection with Signatory\u2019s or its Affiliate(s)\u2019 use\nof the Search Text Advertising Service(s) in that period. Notwithstanding the foregoing, if\nadvertisers buyand attributed to Search Text Ads atfor a fixed or aggregated price, thengiven\nperiod, except that Google may withhold or claw back Ad Revenues for those Search Text\nAdsgenerated from spam, bot traffic, or other fraudulent activity, and only if Google first (a)\nnotifies Plaintiffs and the TC of its intent to withhold or claw back such Ad Revenues at least\nthirty (30) days in advance of taking such action and (b) provides Plaintiffs with an opportunity\nto audit and object to Google\u2019s withholding or clawing back of Ad Revenues. In the event\nGoogle receives an objection from Plaintiffs under this Definition, Google will be calculatednot\nwithhold or claw back any Ad Revenues subject to objection until such objection is resolved\nbetween Google and Plaintiffs or as if such advertisers had paid the final price for the provision\nof otherwise ordered by the Search Text Ad in accordance with the definition aboveCourt.\n\n 1.2. \u201cAffiliate\u201d means, as applied to Signatory, any entity, other than Signatory, that\nhas been expressly included within the scope of Signatory\u2019s certification or recertification as a\nQualified Competitor pursuant to Section IX.V of the Final Judgment; provided, however, that\nthe Parties to this Agreement will include or exclude any entity from the scope of this definition\nif the TC so instructs after receiving Signatory\u2019s change of control notice under Section 15. As\napplied to Google, this Definition means any entity that directly or indirectly controls, is\ncontrolled by, or is under common control with, Google.\n\n 1.3. \u201cClick Tracking\u201d means click tracking or other click monitoring of Search Text\nAds or Search Text Ad Sets on the Sites and Client Applications by Signatory or its Affiliate(s).\n\n 1.3.1.4. \u201cClient Application\u201d means any application, plug-in, helper, Search\nAccess Point, component, or other executable code that runs on an End User\u2019s desktop computer,\nmobile device, or other device incorporating a Search Access Point (or any subsequent version of\nsuch application) listed in Exhibit A of this Agreement.\n\n\n\n\n 2\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 4 of 55\n\n\n\n\n 1.4.1.5. \u201cCovered Query\u201d means a Query that originated from an End User in the\nUnited States and was submitted through a Site or Client Application.\n\n 1.5.1.6. \u201cDisclosed Remedies Information\u201d means any information or data listed\nin Exhibit B or provided pursuant to a Service listed in Exhibit B that must be provided to\nSignatory and its Affiliate(s) by Google pursuant to this Agreement, and over which Signatory or\nits Affiliate(s) have possession, custody, or control.\n\n 1.6.1.7. \u201cEnd User\u201d means an individual human end user whom Signatory or its\nAffiliate(s) (as appropriate) permit to use the Services,of a Site, or a Client Application.\n\n 1.8. \u201cGenAI\u201d or \u201cGenerative AI\u201d shall have the meaning assigned to it in Section\nIX.I of the Final Judgment.\n\n 1.7.1.9. \u201cGenAI Product\u201d shall have the meaning assigned to it in Section IX.J of\nthe Final Judgment.\n\n 1.10. \u201cGoogle Program Guidelines\u201d means the policy and implementation guidelines\napplicable to the Services and as located at the following URL(s):\nhttps://support.google.com/adsense/answer/6068943 (or any different URL(s) or additional\nURL(s) Google may provide to Signatory and its Affiliate(s) from time to time, provided that\nGoogly also notify Plaintiffs and TC of any different URL(s) or additional URL(s) under this\ndefinition prior to providing such URL(s) to Signatory or its Affiliate(s)).\u201cGeneral Search\nEngine\u201d or \u201cGSE\u201d shall have the meaning assigned to it in Section IX.K of the Final Judgment.\n 1.8.\n\n 1.9.1.11. \u201cInclude\u201d and \u201cincluding\u201d shall be read as \u201cincluding but not limited to,\u201d\nand any use of either word is not limited in any way to any examples provided.\n\n 1.12. \u201cMonthly Forecast\u201d means the projected volume of Covered Queries that\nSignatory, together with its Affiliate(s), expects to send to Google through Requests each month.\n\n 1.13. \u201cPeak QPS\u201d means the maximum number of Requests a system handles during\nits busiest single second of traffic during a month.\n\n 1.10.1.14. \u201cQualified Competitor\u201d shall have the meaning assigned to it in Section\nIX.V of the Final Judgment.\n\n 1.11.1.15. \u201cQuery\u201d means (a) a text query or prompt entered and submitted by an\nEnd User (whether by typing or voice input) into a Search Access Point on any Site, Client\n\n\n 3\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 5 of 55\n\n\n\n\nApplication, Syndicated Site, or Syndicated Application, including, without limitation, a browser\naddress bar that is configured with a Site as its default search engine (so long as such\nconfiguration is in compliance with this Agreement).), or (b) if applicable, a text query from\nGoogle\u2019s query rewriting features (e.g., \u201cdid you mean,\u201d \u201cpeople also ask,\u201d and autocomplete)\nthat the End User selects.\n\n 1.12.1.16. \u201cRequest\u201d means a request originating from Signatory, an Affiliate of\nSignatory, or an End User (as applicable) and sent to Google for a Search Results Set and/or a\nSearch Text Ad Set (as applicable) under any Service(s) described in Exhibit B.\n\n 1.13.1.17. \u201cSearch Access Point\u201d shall have the meaning assigned to it in Section\nIX.W of the Final Judgment.\n\n 1.14.1.18. \u201cSearch Feature\u201d shall have the meaning assigned to it in Section IX.X of\nthe Final Judgment.\n\n 1.15.1.19. \u201cSearch Result\u201d means an individual search result provided by Google\nthrough any Search Service(s) described in Exhibit B in response to a Query or Request.\n\n 1.16.1.20. \u201cSearch Results Set\u201d means a set of one or more Search Results.\n\n 1.17.1.21. \u201cSearch Service(s)\u201d means the information, data, and Search Features that\nGoogle must make available to Qualified Competitors via syndication through real-time API(s)\nunder Section V.A of the Final Judgment, as further described in Exhibit B.\n\n 1.18.1.22. \u201cSearch Text Ad\u201d shall have the meaning assigned to it in Section IX.Y of\nthe Final Judgment.\n\n 1.19.1.23. \u201cSearch Text Ad Platform\u201d means any product, service, or platform that\ndisplays, serves, issues, syndicates, or otherwise provides Search Text Ads to a General Search\nEngine or a GenAI Product.\n\n 1.20.1.24. \u201cSearch Text Ad Set\u201d means a set of one or more Search Text Ads\nprovided through any Search Text Advertising Service described in Exhibit B.\n\n 1.21.1.25. \u201cSearch Text Advertising Service(s)\u201d means the Search Text Ads\nsyndication and related services, including any assets, extensions, or similar Search Text Ad\nvariations, that Google must make available to Qualified Competitors under Section VI.B of the\nFinal Judgment, as further described in Exhibit B.\n\n\n\n\n 4\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 6 of 55\n\n\n\n\n 1.22.1.26. \u201cSERP\u201d or \u201cSearch Engine Results Page\u201d shall have the meaning\nassigned to it in Section IX.Z of the Final Judgmentmeans any Site page or Client Application\nscreen that contains any Search Results.\n\n 1.23.1.27. \u201cService(s)\u201d means the Search Service(s) and/or Search Text Advertising\nService(s) (as applicable) that Google shall provide to Signatory and its Affiliate(s) under this\nAgreement, as further described in Exhibit B.\n\n 1.28. \u201cSignatory Content\u201d means any content served to End Users that is not provided\nby Google.\n\n 1.24.1.29. \u201cSite(s)\u201d means the website(s) located at the URL(s) listed in Exhibit A of\nthis Agreement, together with any additional URL(s) added under Exhibit A Section 3 (which\nshall be deemed to be included in Exhibit A as of such addition).\n\n 1.25.1.30. \u201cSubsyndicate\u201d means any entity besides Google, Signatory, or an\nAffiliate of Signatory that owns or operates any website, application, plug-in, helper, Search\nAccess Point, component, or other executable code that runs on an End User\u2019s desktop computer,\nmobile device, or other device incorporating a Search Access Point (or any subsequent version of\nsuch application). For clarity, any sub-syndication provided to Subsyndicate under this\nAgreement will be limited to the Subsyndicate\u2019s Syndicated Site(s) and Syndicated\nApplication(s).\n\n 1.26.1.31. \u201cSuspend\u201d or \u201csuspension\u201d means disabling or limiting access to or use\nof the Services or components of the Services.\n\n 1.27.1.32. \u201cSyndicated Site(s)\u201d means any website(s) not owned or operated by\nSignatory or its Affiliate(s) for which Signatory or its Affiliate(s) may provide sub-syndication\nunder this Agreement, as listed in Exhibit A. For the avoidance of doubt, Sites and Client\nApplications are not Syndicated Sites.\n\n 1.28.1.33. \u201cSyndicated Application(s)\u201d means any application, plug-in, helper,\ncomponent, or other executable code that runs on an End User\u2019s desktop computer or mobile\ndevice (or any subsequent version of such application) that is not owned or operated by\nSignatory or its Affiliate(s), but for which Signatory or its Affiliate(s) may provide sub-\nsyndication under this Agreement, as listed in Exhibit A. For the avoidance of doubt, Sites and\nClient Applications are not Syndicated Applications.\n\n 1.29.1.34. \u201cTC Members\u201d means the members of the TC who have been appointed\nto the TC by the Court pursuant to Sections VII.A.1\u20133 of the Final Judgment.\n\n\n 5\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 7 of 55\n\n\n\n\n 1.35. \u201cUnacceptable Content\u201d means content on a Site, Client Application, Syndicated\nSite, or Syndicated Application, besides content provided by Google, that violates or encourages\nconduct that would violate the Google Guidelines and Protocols permitted under Exhibit C\nSection 5.4.\n\n 1.30.1.36. \u201cURL\u201d means a uniform resource locator address to a site on the internet.\n\n2. Agreement Term. The term of this Agreement is five (5) years, starting on the Effective\nDate, unless terminated earlier in accordance with the terms of this License or extended by Court\norder (\u201cAgreement Term\u201d). For avoidance of doubt, the Agreement Term will not be shortened\nby the expiration or termination of the Final Judgment unless otherwise ordered by the Court.\n\n3. Syndication to be Provided, Schedule, and Method. Exhibit B describes the Search\nService(s) and/or Search Text Advertising Service(s) that Google shall provide to Signatory and\nits Affiliate(s) under this Agreement, as well as the method, means, and financial terms by which\nGoogle shall provide these Services. For the avoidance of doubt, any Search Service(s) made\navailable to Signatory under this Agreement must provide, via real-time API(s), the information\nand data described in Section V.A of the Final Judgment.\n\n4. Search Services Launch, Implementation, and Maintenance. For any Search Service(s)\nthat Google shall provide to Signatory and its Affiliate(s) under this Agreement, the Parties agree\nas follows:\n\n 4.1. Launch. The Parties to this Agreement will launch the Search Service(s) into live\nuse within thirty (30) days from the Effective Date., except that this timeline may be extended (a)\nas needed to accommodate the Implementation Review Period permitted under Exhibit A Section\n3.2, (b) due to reasonable delays caused by Signatory or its Affiliate(s), or (c) as otherwise\npermitted by Plaintiffs, in consultation with the TC, or by the Court. Google shall provide all\nSearch Service(s) to Signatory and its Affiliate(s) for implementation across all Sites and Client\nApplications, and Signatory\u2019s payment obligations for such implementations described in Exhibit\nB shall not run until all such Search Service(s) have been implemented across all such Sites and\nClient Applications. Signatory and its Affiliate(s) will not launch, use, or implement any Search\nService(s) provided under this Agreement anywhere other than on a Site or Client Application.\n\n 4.2. Implementation.\n\n a. Choice of Requests to Syndicate. Except as otherwise stated in Sections\n4.6 and 4.7, Signatory may elect, in its sole discretion, the Queries for which it will issue\n\n\n\n\n 6\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 8 of 55\n\n\n\n\nRequests to Google for Search Results or Search Results Sets under this Agreement., so long as\nthe Requests comply with the terms of this Agreement.\n\n b. Latency; Reliability. Google will provide the Search Service(s) to\nSignatory and its Affiliates on a non-discriminatory basis, with required latency and reliability\naccording to the terms set forth in Exhibit C Section 2.1; provided, however, that Google\u2019s\nobligations under this Section 4.2.b do not extend to variations in Search Service latency and\nreliability that result from differences in Service implementation, users, or other such factors\noutside of Google\u2019s control.\n\n c. Required Information Disclosures. Signatory and its Affiliate(s) may\ndetermine, in their sole discretion, what and how much information to share with Google\nregarding their End Users when using any Search Service(s); provided, however, that Google\nmay impose certain disclosure requirements, as set forth in Exhibit C Sections 8 and 9, only as\nnecessary for the purposes of ensuring basic functionality of any Search Service(s), detecting\nspam and abuse, or as otherwise required for legal or regulatory compliance. For avoidance of\ndoubt, nothing in this Section 4.2.c is intended to limit the availability or implementation of the\n or Non Personalized Ads described in Exhibit B Section 3.\n\n 4.3. Search Service Maintenance.\n\n a. For the remainder of the Agreement Term, Google will make available and\nSignatory and its Affiliate(s) (as appropriate) will implement and maintain each of the Search\nServices on each of the applicable Sites and Client Applications in Exhibit A. For clarity,\nSignatory and its Affiliate(s) may not implement the Services on a property that is not a Site or\nClient Application. For technical support from Google, Signatory and its Affiliate(s) may contact\nGoogle at\n or such other email address or URL as Google may providemake available\nto Signatory from time to time,and its Affiliate(s), provided that Google notifies Plaintiffs and\nthe TC in parallel of any alternative email address or URL provided under this Section 4.3.a.\n\n b. Signatory will ensure that, with respect to every Site and Client\nApplication, Signatory or its Affiliate(s) (as appropriate):\n\n i. is the technical and editorial decision maker in relation to each\npage, including SERPs and each Client Application on which the Search Services are\nimplemented; and\n\n ii. has control over the way in which the Search Services are\nimplemented on each of those SERPs and Client Applications.\n\n\n 7\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 9 of 55\n\n\n\n\n c. Signatory will ensure that the Search Services are implemented and\nmaintained by Signatory and its Affiliate(s) in accordance with the applicable Google Program\nGuidelines, Google technical protocols (if any), and any other technical requirements Google\nmay require; provided, however, that Google shall not impose any requirements under the\nGoogle Program Guidelines, Google technical protocols, or any other technical requirements\nexcept as permitted under Section VI.B.11 of the Final Judgment. In the event of a conflict\nbetween the Google Program Guidelines or Google technical protocols and the terms of this\nAgreement, the terms of this Agreement will controlGoogle Guidelines and Protocols permitted\nunder Exhibit C Section 5.4.\n\n d. Signatory will ensure that, at all times during the Agreement Term,\nSignatory and its Affiliate(s):\n\n i. Have a clearly labeled and easily accessible privacy policy in place\nrelating to the Site(s) and Approved Client Application(s); and\n\n ii. Provide the End User with clear and comprehensive information\nabout cookies and otherany information stored or accessed on the End User\u2019s device in\nconnection with the Search Services, including information about End Users\u2019 options for cookie\nmanagement.\n\n e. Signatory and its Affiliate(s) (as appropriate) will use commercially\nreasonable efforts to ensure that an End User gives consent to the storing and accessing of\ncookies and other information on the End User\u2019s device in connection with the Search Services\nwhere such consent is required by law.\n\n 4.4. Display and Use Restrictions.\n\n a. Restrictions Generally. Except as otherwise set forth in Exhibit C Sections\n2.2 and 2.3, Google will not impose any restrictions or conditions on how Signatory or its\nAffiliate(s) use, display, or otherwise integrate the Search Service(s), including any information\nor data made available under such Services. For clarity, except as set forth in Exhibit C Sections\n2.2 and 2.3, Signatory and its Affiliate(s) may elect, in their sole discretion, which Search\nService components, assets, information, and data to display or use in their own products or\nservices, and they may do so in any manner they choose, including, without limitation,\nreordering Search Results or Search Service components, assets, information, or data.\n\n b. Display and Use in GenAI Products. Notwithstanding Section 4.4.a,\nSignatory and its Affiliate(s) may display and use the Search Services to groundResults received\n\n\n 8\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 10 of 55\n\n\n\n\nunder this Agreement within their responses to Covered Queries issued by End Users to GenAI\nProducts owned and operated by Signatory or its Affiliate(s).\n\n c. GenAI Product Training Prohibited. Notwithstanding Section 4.4.b,\nSignatory and its Affiliate(s) shall not use syndicated Search Results to (i) pre-train, train, fine-\ntune, or otherwise develop the weights of any large language model or other machine learning\nmodel such that syndicated content becomes permanently embedded in model parameters\n(\u201cLLM Training\u201d), or (ii) conduct bulk re-indexing or re-syndication of Search Results as a\nsubstitute for independent web crawling or web index development. For avoidance of doubt,\nsingle-use retrieval and incorporation of Search Results into a specific response generated by a\nGenAI Product owned and operated by Signatory or its Affiliate(s) in response to a Covered\nQuery or other actions permitted in Exhibit C Section 2.3 will not constitute LLM Training and\nare permitted under this Agreement.\n\n 4.5. Crawling Restrictions. Pursuant to terms set forth in Exhibit C Section 5 and\nexcept as otherwise stated in Section 4.4 and Exhibit C Section 2.3, Google may, at its discretion,\nplace ordinary commercial restrictions on the ability of Signatory and its Affiliate(s) to scrape,\nindex, or crawl any Search Results, Search Results Sets, or other information or data made\navailable as part of the Search Service(s).\n\n 4.6. No Sub-Syndication. Signatory and its Affiliate(s) will not sell, license, or\notherwise make available to any Subsyndicate any Search Service(s) provided by Google under\nthis Agreement. For clarity, no Affiliate of Signatory will be deemed to be a Subsyndicate under\nthis Agreement.\n\n 4.7. Covered Queries. Google shall only be required to provide Search Services in\nresponse to Request(s) sent in response to a Covered Query except as otherwise provided herein.\n\n 4.8. Signatory Monitoring and Audit Obligations; Tapering Schedule.\n\n a. Monitoring Obligations. For the Agreement Term, Signatory agrees to\nmonitor the frequency and scope of Requests issued by Signatory or its Affiliate(s) to Google for\nSearch Results or Search Results Sets under this Agreement, including (a) the number of total\nannual Covered Queries, and (b) the number of such Covered Queries for which Signatory or its\nAffiliate(s) issues a Request or Requests to Google for Search Results or Search Results Sets\nunder this Agreement. On reasonable written notice from the TC pursuant to Section 4.8.b below,\nSignatory and its Affiliate(s) (as appropriate) will permit the TC to access any information or\ndata collected or monitored under this Section 4.8.a and to independently track, monitor, assess,\nor evaluate the frequency and scope of Requests issued by Signatory or its Affiliate(s) to Google\n\n\n\n\n 9\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 11 of 55\n\n\n\n\nunder this Agreement. For avoidance of doubt, nothing in this Section 4.8.a is intended to limit or\nsupersede the information sharing obligations set forth in Section 6.54.\n\n b. Audit Obligations. For the Agreement Term, Signatory and its Affiliate(s)\n(as appropriate) agree to undergo periodic audits by the TC of the frequency and scope of\nRequests described in Section 4.8.a, which may include audits of, without limitation, the\nfrequency and volume of Requests submitted to Google, the total annual Covered Queries\nreceived by Signatory and its Affiliate(s), and the percentage of Requests for Search Results or\nSearch Results Sets sent to Google in response to Covered Queries. On reasonable written notice\nfrom the TC, Signatory, its Affiliate(s) (as appropriate), and Google will promptly comply with\nany and all requests made by the TC in relation to such audits, including requests for documents,\ndata, information, or interviews.\n\n c. Tapering Schedule. For a one (1)-year term beginning on the Effective\nDate, Signatory and its Affiliate(s) will only issue Requests to Google for Search Results or\nSearch Results Sets under this Section 4 in response to a maximum of forty percent (40%) of\ntotal annual Covered Queries (\u201cInitial Tapering Rate\u201d). For the remainder of the Agreement\nTerm, Signatory and Google agree that the scope and frequency of Requests that Signatory and\nits Affiliate(s) may issue to Google under this Section 4 will be set according to a schedule to be\ndetermined by the Court, Plaintiffs, and the TC in the Underlying Consolidated Cases pursuant to\nSection V.B.4 of the Final Judgment (\u201cTapering Schedule\u201d); provided, however, that if such\nTapering Schedule has not been determined by the end of the one (1)-year term beginning on the\nEffective Date, Signatory and its Affiliate(s) may continue to issue Requests to Google under this\nSection 4 in response to a maximum of forty percent (40%) of total annual Covered Queries until\nsuch Tapering Schedule is in place or as otherwise ordered by the Court.\n\n d. Incorporation of Tapering Schedule. The Parties to this Agreement agree\nto incorporate by reference the Tapering Schedule in its entirety. Within five (5) business days of\nthe date on which the Tapering Schedule is approved by the Court in the Underlying\nConsolidated Cases, Google shall deliver a copy of such Tapering Schedule to Signatory\naccording to the notice procedures set forth in Section 25. Upon receipt by Signatory, the\nTapering Schedule shall automatically become a binding part of this Agreement as if fully set\nforth herein. For clarity, in the event of a conflict between the terms of this Agreement and the\nTapering Schedule, once incorporated, the terms of the Tapering Schedule will control.\n\n5. Search Text Advertising Services Launch, Implementation, and Maintenance. For any\nSearch Text Advertising Service(s) that Google shall provide to Signatory and its Affiliate(s)\nunder this Agreement, the parties agree as follows:\n\n\n\n\n 10\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 12 of 55\n\n HIGHLY CONFIDENTIAL\n SUBJECT TO PROTECTIVE ORDER AND ECF NOS. 1520-1 AND 1521\n\n 5.1. Launch. The parties to this Agreement will launch the Search Text Advertising\nService(s) into live use within thirty (30) days from the Effective Date, except that this timeline\nmay be extended (a) as needed to accommodate the Implementation Review Period permitted\nunder Exhibit A Section 3.2, (b) due to reasonable delays caused by Signatory or its Affiliate(s),\nor (c) as otherwise permitted by Plaintiffs, in consultation with the TC, or by the Court. Google\nshall provide all Search Text Advertising Service(s) to Signatory and its Affiliate(s) for\nimplementation across all Sites and Client Applications, and Signatory\u2019s payment obligations for\nsuch implementations described in Exhibit B shall not run until all such Search Text Advertising\nService(s) have been implemented across all such Sites and Client Applications. Signatory and\nits Affiliate(s) will not launch, use, or implement any Search Text Advertising Service(s)\nprovided under this Agreement anywhere other than on a Site or Client Application.\n\n 5.2. Implementation.\n\n a. Choice of Requests to Syndicate. Except as otherwise stated in Sections\n5.7 and 5.8, Signatory and its Affiliate(s) may elect, in their sole discretion, which Requests to\nissue to Google for Search Text Ads or Search Text Ad Sets under this Agreement., so long as the\nRequests comply with the terms of this Agreement.\n\n b. Latency; Reliability; Performance. Google will provide the Search Text\nAdvertising Service(s) to Signatory and its Affiliate(s) on a non-discriminatory basis, with\nrequired latency, reliability, and performance according to the terms set forth in Exhibit C\nSection 3; provided, however, that Google\u2019s obligations under this Section 5.2.b do not extend to\nvariations in Search Text Advertising Service latency, reliability, or performance that result from\ndifferences in Service implementation, users, or other such factors outside of Google\u2019s control.\n\n c. Required Information Disclosures. Except as set forth in Exhibit C\nSections 8 and 9, Signatory and its Affiliate(s) may determine, in their sole discretion, what and\nhow much information to share with Google regarding their End Users when using any Search\nText Advertising Service(s), including what information about an End User to provide when\nsubmitting a Request to Google for Search Text Ads or Search Text Ad Sets. For avoidance of\ndoubt, nothing in this Section 5.2.c is intended to limit the availability or implementation of the\n or Non Personalized Ads described in Exhibit B Section 3.\n\n 5.3. Search Text Advertising Service Maintenance.\n\n a. For the remainder of the Agreement Term, Google will make available and\nSignatory and its Affiliate(s) (as appropriate) will implement and maintain each of the Search\nText Advertising Services on each of the applicable Sites and Client Applications in Exhibit A.\nFor clarity, Signatory and its Affiliate(s) may not implement the Search Text Advertising\n\n\n 11\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 13 of 55\n\n\n\n\nServices on a property that is not a Site or Client Application. For technical support from Google,\nSignatory and its Affiliate(s) may contact Google at\n\nor such other email address or URL as Google may may providemake available to Signatory\nfrom time to time,and its Affiliate(s), provided that Google notifies Plaintiffs and TC in parallel\nof any alternative email address or URL provided under this Section 5.3.a).\n\n b. Signatory will ensure that, with respect to every Site and Client\nApplication, Signatory or its Affiliate(s) (as appropriate):\n\n i. is the technical and editorial decision maker in relation to each\npage, including SERPs and each Client Application on which the Search Text Advertising\nServices are implemented; and\n\n ii. has control over the way in which the Search Text Advertising\nServices are implemented on each of those SERPs and Client Applications.\n\n c. Signatory will ensure that the Search Text Advertising Services are\nimplemented and maintained by Signatory and its Affiliate(s) in accordance with the applicable\nGoogle Program Guidelines, Google technical protocols (if any), and any other technical\nrequirements Google may require; provided, however, that Google shall not impose any\nrequirements under the Google Program Guidelines, Google technical protocols, or any other\ntechnical requirements except as permitted under Section VI.B.11 of the Final Judgment. In the\nevent of a conflict between the Google Program Guidelines or Google technical protocols and\nthe terms of this Agreement, the terms of this Agreement will controlGoogle Guidelines and\nProtocols permitted under Exhibit C Section 5.4.\n\n d. Signatory will ensure that, at all times during the Agreement Term,\nSignatory and its Affiliate(s):\n\n i. Have a clearly labeled and easily accessible privacy policy in place\nrelating to the Site(s) and Approved Client Application(s); and\n\n ii. Provide the End User with clear and comprehensive information\nabout cookies and other information stored or accessed on the End User\u2019s device in connection\nwith the Search Text Advertising Services, including information about End Users\u2019 options for\ncookie management.\n\n e. Signatory and its Affiliate(s) (as appropriate) will use commercially\nreasonable efforts to ensure that an End User gives consent to the storing and accessing of\n\n\n 12\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 14 of 55\n\n\n\n\ncookies and other information on the End User\u2019s device in connection with the Search Text\nAdvertising Services where such consent is required by law.\n\n 5.4. Display and Use Restrictions. Except as set forth in Section 5.7 and Exhibit C\nSection 3.2, Signatory and its Affiliate(s) may only use Search Text Ads and related information\nprovided as part of the Search Text Advertising Service(s) for the purpose of displaying Search\nText Ads or Search Text Ad Sets to an End User in response to a Query; provided, however, that\nGoogle will not impose any restrictions or conditions on how Signatory or its Affiliate(s) use,\ndisplay, format, or otherwise integrate the Search Text Advertising Service(s), including any\nSearch Text Ads made available under such Services, except as set forth in Exhibit C, as further\ndescribed in the Google Guidelines and Protocols permitted under Exhibit C Section 5.4.\n\n 5.5. Crawling Restrictions. Pursuant to terms set forth in Exhibit C Section 5 and\nexcept as otherwise stated in Section 45.4 and Exhibit C Section 2.3, Google may, at its\ndiscretion, restrict the ability of Signatory and its Affiliate(s) to scrape, index, or crawl any\nSearch Text Ads or Search Text Ad Sets made available as part of the Search Text Advertising\nService(s).\n\n 5.6. No Preferential Placement. Google will not require, as a condition of providing\nany Service(s) or otherwise, that Signatory provide any preferential placement or similar\ntreatment to any Search Text Ad or Search Text Ad Set made available under this Agreement as\ncompared to Search Text Ads or Search Text Ad Sets provided by Signatory, its Affiliate(s), or\nany third party.\n\n 5.7. Sub-Syndication. Signatory and its Affiliate(s) may not sell, license, or otherwise\nmake available any Search Text Advertising Service(s) provided by Google under this\nAgreement to any Subsyndicate unless and until Signatory has been specifically certified as a\nQualified Competitor to a Google Search Text Ad Platform under the Final Judgment. The\nparties will launch any such sub-syndication into live use according the same procedures set\nforth in Section 5.1; provided, however, that if Signatory is certified as a Qualified Competitor to\na Google Search Text Ad Platform after the Effective Date, the time period for launching any\nsub-syndication into live use will run from the date on which Google receives notice of\nSignatory\u2019s certification as a Qualified Competitor to a Google Search Text Ad Platform. For\nclarity, no Affiliate of Signatory will be deemed to be a Subsyndicate under this Agreement.\n\n 5.8. Covered Queries. Google shall only be required to provide Search Text\nAdvertising Services in response to Requests sent in response to a Covered Query except as\notherwise provided herein.\n\n\n\n\n 13\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 15 of 55\n\n\n\n\n 5.9. Advertiser Availability. As of the Effective Date and continuing for the Agreement\n Term, Google will make the purchase of Search Text Ads syndicated under this Agreement\n available to advertisers on a non-discriminatory basis comparable to, and no more burdensome\n than, the availability of any other Google Search Text Ad, including, without limitation, Google\n Search Text Ads incorporated into AI Overviews and GenAI Products. For avoidance of doubt,\n Google shall not take any action during the Agreement Term that is intended to decrease the\n availability of Search Text Ads syndicated under this Agreement to advertisers compared to the\n availability of any other Google Search Text Ad, including opting advertisers out of the Search\n Text Advertising Services by default.\n\n 5.10. Search Partner Network. As of the Effective Date and continuing for the\n Agreement Term, Google will promptly include Signatory and any Affiliate of Signatory (as\n appropriate) in Google\u2019s Search Partner Network. Google shall not condition the inclusion of\n Signatory or any Affiliate of Signatory (as appropriate) in Google\u2019s Search Partner Network on\n any prior, contemporaneous, or future payments, promises, or other such consideration or terms\n beyond those included in this Agreement.\n\n 6. Additional Provisions.\n\n 6.1. No Exclusivity. The Parties to this Agreement acknowledge that this Agreement is\nnon-exclusive and that either Party and its Affiliate(s) will be free, during and after the Agreement\nTerm, to engage or contract with third parties for the provision of services similar to the Services.\n\n 6.2. Competitive Products and Services Permitted. Except as set forth in Section 4,\nSection 5, and Exhibit C Sections 2.2, 3.2, 5, 6, and 8, nothing in this Agreement shall be\ninterpreted to prevent, preclude, or otherwise restrict Signatory or its Affiliates from developing,\ndistributing, marketing, displaying, using, licensing, or selling a product or service that competes\nwith any Services. For clarity, Signatory and/or its Affiliates shall be free to use and/or display\ntheir own Search Results, Search Result Sets, Search Text Ads, and Search Text Ad Sets, or those\nof a third party, without limitation, throughout the Agreement Term.\n\n 6.3. Multiple Requests per Covered Query Permitted. Except as set forth in Exhibit C,\nSignatory, an Affiliate of Signatory, or an End User (as applicable) may send multiple Requests to\nGoogle for any given Covered Query for the purposes of Covered Query refinement, correction,\nor progressive Search Result or Search Text Ad enhancement.\n\n 6.4.6.3. Search Text Ads Auction Change Notice. For any public disclosure of a\nSearch Text Ads auction change that Google makes under Section VI.A of the Final Judgment in\nthe Underlying Consolidated Cases, Google shall, within five (5) business days of the date on\nwhich such disclosure is made, deliver a copy of such disclosure to Signatory.\n\n\n 14\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 16 of 55\n\n\n\n\n 6.5.6.4. Service Information Logs. Throughout the Agreement Term, Signatory\nwill maintain and log information relevant to the use and implementation of Services by\nSignatory and its Affiliate(s) in a reasonably accessible format (\u201cService Information Logs\u201d),\nwhich Signatory will provide to the TC at least monthly following the launch of the Service(s)\nunder this Agreement. These Service Information Logs must include, at minimum, (a)\nmeasurements of Service availability and latency (including measurements collected pursuant to\nExhibit C Sections 2.1 and 3.1; (b) logs of Requests sent to Google and Search Results and/or\nSearch Text Ads received in response (including, if applicable, Publisher IDs, Client IDs, Channel\nIDs, event-level Request IDs, and any response or error code(s) received); and (c) measurements\nof the Service(s) performance (including, if applicable, network traffic logs, cost-per-click,\nnumber of clicks, and conversion metrics). Notwithstanding the foregoing, in the event Signatory\nreceives a request from Plaintiffs or the TC to provide information not included within its Service\nInformation Logs, Signatory will use commercially reasonable efforts to promptly provide such\ninformation to Plaintiffs and the TC.\n\n 6.5. Syndication Forecasting.\n\n a. Baseline Query Volume Threshold. On or promptly after the Effective\nDate, Google will notify Signatory of the maximum monthly query volume and Peak QPS that\nGoogle can accommodate during the Agreement Term without Signatory providing any Monthly\nForecasts or projected Peak QPS under this Section 6.5 (\u201cBaseline Query Volume Threshold\u201d);\nprovided, however, that such Baseline Query Volume Threshold must be determined by Google in\nagreement with Plaintiffs and the TC, or as otherwise ordered by the Court. Google may update or\nmodify the Baseline Query Volume Threshold only in agreement with Plaintiffs, in consultation\nwith the TC, or as otherwise ordered by the Court. If Google updates or modifies the Baseline\nQuery Volume Threshold, Google will notify Signatory in writing of such updated or modified\nBaseline Query Volume Threshold at least three (3) months in advance of such update or\nmodification taking effect.\n\n b. Forecasting Required. Within the first forty-five (45) days when Google\nand Signatory, together with its Affiliate(s), are preparing to launch the Services, Signatory will\nprovide Google and the TC with twelve (12) months of Monthly Forecasts and Peak QPS, for\nreview; provided, however, that Signatory is only required to provide Monthly Forecasts and Peak\nQPS above the Baseline Query Volume Threshold. Signatory warrants that the Monthly Forecasts\nand Peak QPS provided to Google and the TC are reasonably accurate estimates made in good\nfaith. If the TC approves Signatory\u2019s Monthly Forecasts and Peak QPS, Google will use them to\naccommodate Peak QPS for the Services. Thereafter, on the last business day of each month, and\nfor as long as Signatory receives the Services, Signatory will provide an updated set of twelve\n(12) months of Monthly Forecasts and Peak QPS (except where such information falls below the\n\n\n 15\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 17 of 55\n\n\n\n\nBaseline Query Volume Threshold) for the TC to review and approve. Google will work with\nPlaintiffs and the TC to develop reasonable protocols that safeguard any commercially sensitive\ninformation within the Monthly Forecasts or Peak QPS provided by Signatory, and Google will\ncertify its compliance with any such protocols to Signatory by providing written notice of such\ncertification.\n\n c. Signatory Requests to Update Forecasts. Any increase to Signatory\u2019s\nMonthly Forecasts or Peak QPS provided to Google must be approved by the TC. Google requires\nSignatory to provide at least three (3) months notice, via the process set forth in Section 6.5.b,\nshould Signatory seek to increase any Monthly Forecast by 10% or less of its forecasted Peak\nQPS. Google requires Signatory to provide at least six (6) months notice should Signatory seek to\nincrease any Monthly Forecast by more than 10% of its forecasted Peak QPS.\n\n d. No Service Degradation For Exceeding Peak QPS. Signatory's Monthly\nForecasts and Peak QPS are provided for capacity planning purposes only. Google's obligations\nunder this Agreement, including its latency and availability obligations under Exhibit C Sections\n2.1 and 3.1, shall not be diminished, excused, or otherwise affected by Signatory's or its\nAffiliate(s)' actual query volume exceeding the Monthly Forecasts or Peak QPS provided under\nthis Section 6.5. Nothing in this Section 6.5 shall be deemed to create any penalty, liability, or\nadverse consequence for Signatory or its Affiliate(s) in connection with the exceedance of any\nMonthly Forecast or Peak QPS.\n\n 6.6. Query Rewriting Features Permitted. Subject to Exhibit C Section 2.2 and the\n Google Guidelines and Protocols, Signatory and its Affiliate(s) may implement their own query\n rewriting features, including features that enable query correction, modification, or expansion,\n instead of or in addition to using any query rewriting features provided by Google under this\n Agreement. For avoidance of doubt, Signatory and its Affiliate(s) may implement any query\n rewriting features permitted under this Agreement within their GSE(s) and/or GenAI Products,\n and any Requests issued by Signatory or its Affiliate(s) following use of such query rewriting\n features shall not be deemed to be synthetic queries under this Agreement.\n\n 7. Retention of Information and Data by Google.\n\n 7.1. Retention for Search Services. Except as set forth in Exhibit C Sections 3.2, 7.1,\nand 8.3, Google may not, in any way, retain or use for its own products and/or services any\nQueries, Requests, or other information it obtains from Signatory or Signatory\u2019s Affiliate(s) in\nconnection with the Search Service(s). For clarity, nothing in this Section 7.1 shall be interpreted\nto limit the provision of any Search Service(s) to Signatory or its Affiliate(s) as otherwise set forth\nherein.\n\n\n\n\n 16\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 18 of 55\n\n\n\n\n 7.2. Retention for Search Text Advertising Services. Google may only retain or use\ndata collected from Signatory or its Affiliate(s) in connection with the Search Text Advertising\nService(s) for the purpose of building, improving, and maintaining its Search Text Ad\ninfrastructure and shared ad systems, as further set forth in Exhibit C. 3.2, 7.1, and 8.3. For clarity,\nnothing in this Section 7.2 shall be interpreted to limit the provision of any Search Text\nAdvertising Service(s) to Signatory or its Affiliate(s) as otherwise set forth herein.\n\n 8. Effect of Requests by Plaintiffs, TC Members, or Court Upon Google. Google shall\n promptly stop providing the Service(s) (as applicable) to Signatory and its Affiliate(s) upon a\n request from the Plaintiffs, TC Members, or the Court. Google shall, within ten (10) business\n days, resume providing the Service(s) upon a request from the Plaintiffs, TC Members, or the\n Court to resume providing such Services.\n\n 9. Effect of Requests by Plaintiffs, TC Members, or Court Upon Signatory. Signatory shall\n use best efforts to return or destroy Disclosed Remedies Information within fifteen (15) business\n days as directed by the Plaintiffs, TC Members, or the Court upon request.\n\n 10. Incorporation of Final Judgment. The Parties to this Agreement agree to incorporate by\n reference the Final Judgment in its entirety. If the Final Judgment is modified, amended, or\n otherwise altered by the Court or as a result of any appeal of the Underlying Consolidated Cases,\n Google shall, within five (5) business days of the date on which such modification, amendment,\n or other alteration occurs, deliver a copy of such modified, amended, or altered Final Judgment\n to Signatory according to the notice procedures set forth in Section 25. Upon receipt by\n Signatory, any modifications, amendments, or alterations of the Final Judgment shall\n automatically become a binding part of this Agreement as if fully set forth herein. For clarity, in\n the event of a conflict between the terms of this Agreement and the Final Judgment, including\n any modification, amendment, or other alteration to the Final Judgment, the terms of the Final\n Judgment will control.\n\n 11. Assignment. Neither Party to this Agreement may assign any part of this Agreement\n without prior written authorization of the Plaintiffs.\n\n 12. Capitalized Terms. Capitalized terms used in this Agreement and not specifically defined\n herein shall have the respective definitions given to them in the Final Judgment.\n\n 13. Computing Time. When computing any time period specified in this Agreement:\n (a) exclude the day of the event that triggers the period; (b) count every day, including\n intermediate Saturdays, Sundays, and legal holidays; and (c) include the last day of the period,\n but if the last day is a Saturday, Sunday, or legal holiday, the period continues to run until the end\n of the next day that is not a Saturday, Sunday, or legal holiday; provided, however, that (1) when\n\n\n 17\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 19 of 55\n\n\n\n\ncomputing any time period listed in terms of business days, exclude intermediate Saturdays,\nSundays, and legal holidays; and (2) in the event of a conflict in deadlines between this\nAgreement and the Final Judgment or related Court order, the deadline in the Final Judgment or\nrelated Court order controls.\n\n14. Affiliate Liability. Signatory will be liable for the acts and omissions of each of its\nAffiliates in connection with any Services provided under this Agreement to the extent any such\nacts or omissions, if performed by Signatory, would constitute a material breach of, or otherwise\ngive rise to liability under, this Agreement.\n\n15. Change of Control. If Signatory experiences a change of control (including through a\nstock purchase or sale, merger, or other form of corporate transaction), then the following\nprovisions shall apply:\n\n a. Signatory shall provide written notice of the change of control to the TC,\nincluding any changes to Signatory\u2019s list of Affiliates, within ten (10) business days after the\nchange of control takes effect. In the event that, following receipt of such notice, the TC so\ninstructs, Signatory and Google shall terminate this Agreement.\n\n b. Signatory and its Affiliate(s) shall immediately cease accepting any Services that\nare provided by Google under this Agreement, unless the TC expressly authorizes otherwise in\nwriting.\n\n c. Upon receiving notice of Signatory\u2019s change of control, Google may request\npermission from the TC to terminate this Agreement. If the TC grants Google\u2019s request, Google\nmay, at its discretion, terminate this Agreement by providing ten (10) business days\u2019 notice, in\nwriting, to the TC and Signatory.\n\n16. Termination of this Agreement.\n\n 16.1. Signatory Right of Termination. Signatory may terminate this Agreement for any\nreason by providing fifteen (15) business days\u2019 written notice to the TC and Google.\n\n 16.2. Google Right of Termination. If Google, in good faith, believes Signatory or its\nAffiliate(s) have materially breached this Agreement, Google may terminate this Agreement\npursuant to the following:\n\n a. Notice Required. At least fifteen (15) business days prior to exercising its\nrights under this Section 16.2, Google must provide written notice to Signatory, Plaintiffs, and\n\n\n\n\n 18\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 20 of 55\n\n\n\n\nthe TC detailing (i) the provisions of this Agreement that Google believes Signatory and/or its\nAffiliate(s) have materially breached, and (ii) the actions Google intends to take in response.\n\n b. Effect of Notice. After providing the notice required under Section 16.2.a,\nGoogle will not exercise any termination rights or take any related action under this Agreement\nuntil the earlier of (i) the date on which Google receives written notice from Plaintiffs that\nPlaintiffs do not object to termination, or (ii) fifteen (15) business days following Google\u2019s\nprovision of notice under Section 16.2.a; provided, however, that if, within fifteen (15) business\ndays of Google providing the notice required under Section 16.2.a, Google receives written\nnotice from Plaintiffs that Plaintiffs intend to object to Google\u2019s termination, Google will not\nexercise any termination rights or take any related action under this Agreement until the later of\n(i) fourteen (14) days after Plaintiffs seek Court intervention concerning Google\u2019s intent to\nterminate this Agreement, if the Court does not act; or (ii) until further order by the Court, if the\nCourt intervenes.\n\n 16.3. Pre-Termination Remediation Permitted. Before either Party exercises its\ntermination rights under this Section 16, such Party may notify the other Party of its intent to\nexercise its termination rights and request remediation of any alleged breach or noncompliance\nserving as the basis for terminating this Agreement. Upon receiving such notice, the receiving\nParty will, within fifteen (15) business days, use commercially reasonable efforts to respond to\nsuch notice and either (a) attempt to remedy any alleged breach or noncompliance or (b) reject\nremediation under this Section 16.3. For avoidance of doubt, nothing in this Agreement,\nincluding Section 16.3, is intended to limit or prevent the ability of Signatory or its Affiliate(s) to\nsubmit complaints to Plaintiffs and the TC under the Final Judgment.\n\n 16.4. Effect of Termination. Upon termination of this Agreement, Google shall\npromptly cease providing any ServicesUpon expiration or termination of this Agreement, (a)\nGoogle shall promptly cease providing any Services, (b) all rights and licenses granted by each\nParty will cease immediately, (c) if requested, and except as otherwise expressly permitted\nelsewhere herein, each Party will use commercially reasonable efforts to promptly return to the\nother Party, or destroy and certify destruction of, all Disclosed Remedies Information; and (d)\nGoogle will have no further obligation to provide the Services (including Search Results) to\nSignatory or its Affiliate(s) or to make any payments with respect to any continued use of the\nServices by Signatory or its Affiliate(s) following expiration or termination.\n\n 16.5. Survival. Upon termination of this Agreement for any reason, including any\ntermination pursuant to a Court order, Sections 1 (Definitions), 9 (Effect of Requests by\nPlaintiffs, TC Members, or Court Upon Signatory), 11 (Assignment), 12 (Capitalized Terms), 13\n(Computing Time), 17 (No Waiver), 18 (No Agency), 19 (No Third-Party Beneficiaries), 23\n(Severability), 24 (Governing Law and Forum), 26 (Intellectual Property), 27 (Confidentiality;\n\n\n 19\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 21 of 55\n\n\n\n\nPublicity), 28 (Warranties; Disclaimers); 29 (Limitation of Liability), and 3031 (Indemnification)\nwill survive unless otherwise specifically ordered by Court order.\n\n17. No Waiver. Neither party to this Agreement will be treated as having waived any rights\nby not exercising (or delaying the exercise of) any rights under this Agreement.\n\n18. No Agency. This Agreement does not create any agency, partnership, or joint venture\nbetween the parties.\n\n19. No Third-Party Beneficiaries. This Agreement does not confer any benefits on any third\nparty unless this Agreement expressly states that it does.\n\n20. Amendment. This Agreement may not be amended absent written permission from\nPlaintiffs, in consultation with the TC, or from the Court, with such permission identifying with\nspecificity the manner in which this Agreement may be amended. Such permission is valid only\nwith respect to this specific Agreement between Signatory and Google. Any amendment must be\nin writing, be signed by both partiesParties, and expressly state that it is amending this\nAgreement. Any amendment shall be null and void to the extent it exceeds the scope of the\nwritten permission provided by Plaintiffs pursuant to this Section 20.\n\n21. Entire Agreement. This Agreement (together with the Exhibits hereto) constitutes the\nentire agreement and understanding between the parties hereto with respect to its subject matter\nand supersedes any and all other prior or contemporaneous agreements, written or oral, between\nthe parties relating to the subject matter herein.\n\n22. Suspension of the Agreement for Decertification.\n\n 22.1. Notice Required. Signatory will notify Google, in writing, within five (5) business\ndays of Signatory losing its certification as a Qualified Competitor pursuant to Section IX.V. of\nthe Final Judgment; provided, however, that this notice period will not run until Signatory\nreceives a specific determination, in writing, from the Court, Plaintiffs, or the TC that it is no\nlonger certified as a Qualified Competitor under the Final Judgment.\n\n 22.2. Effect of Notice. Thirty (30) days from the date on which Google receives the\nnotice required under Section 22.1, or thirty (30) days from the date on which Google otherwise\nlearns of Signatory losing certification as a Qualified Competitor under the Final Judgment and\nproviding written notice to Signatory of such fact, Signatory and Google agree to suspend all\nbenefits and obligations imposed on either Party relating to the Service(s) provided under this\nAgreement, subject to Reinstatement under Section 22.3 herein, unless otherwise ordered by the\nCourt. For clarity, and subject to agreement by Signatory and Google, Google may continue to\n\n\n 20\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 22 of 55\n\n\n\n\nprovide the Services to Signatory or its Affiliate(s) during a period of Suspension under this\nSection 22, subject to Google\u2019s then standard terms and conditions; provided, however, that\nGoogle will not be obligated to provide the Services (including Search Results and Search Text\nAds) to Signatory or its Affiliate(s) or make any payments with respect to the continued use of\nthe Services by Signatory or its Affiliate(s) during a period of Suspension.\n\n 22.3. Reinstatement. If Signatory is recertified as a Qualified Competitor pursuant to\nSection IX.V of the Final Judgment following a period of suspension, the parties agree to\nreinstate this Agreement in its entirety within ten (10) business days of Google learning of such\nrecertification or Google receiving written notice by Signatory of such recertification, whichever\ncomes earlier. For clarity, Google will reinstate provision of the Services under this Section 22.3\nusing the most recent Monthly Forecasts and Peak QPS provided by Signatory and approved by\nthe TC under Section 6.5.b.\n\n23. Severability. If any part of this Agreement is found to be illegal or unenforceable, the\nAgreement may be terminated upon notice from Plaintiffs or TC Members to the Parties. Absent\na notice of termination from Plaintiffs or TC Members, the rest of the Agreement (i.e., any part\nnot found to be illegal or unenforceable), will remain in full effect.\n\n24. Governing Law and Forum. This Agreement is governed in all respects by the federal\ncommon law of the United States of America or, to the extent that the Court deems it necessary\nto resort to the laws of another jurisdiction, the law of the District of Columbia. Pursuant to\nSection XI.A of the Final Judgment, all disputes arising under this Agreement shall be brought in\nthe Court, which shall have exclusive jurisdiction over disputes under this Agreement. As to all\nsuch disputes, the Parties to this Agreement consent to the personal jurisdiction of such Court.\n\n25. Notices. Any notices or other communications required to be given under this Agreement\nwill be deemed to have been properly given if sent by mail andor email to the applicable party or\nentity at its addresses below (or to such other address as to which such party or entity shall\nhereafter notify the other party or parties):), provided that such notice references this\nAgreement\u2019s title and Effective Date:\n\n If to Google, to:\n\n [Name]\n [Address]\n [City, ST ZIP]\n [Phone]\n [Email]\n\n\n\n\n 21\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 23 of 55\n\n\n\n\n If to Signatory or its Affiliate(s), to:\n\n [Name]\n [Address]\n [City, ST ZIP]\n [Phone]\n [Email]\n\n If to the TC, to:\n\n [Name]\n [Address]\n [City, ST ZIP]\n [Phone]\n [Email]\n\n If to Plaintiffs, collectively to:\n\n Danielle Hauck\n Travis Chapman\n Claire M. Maddox\n Grant Fergusson\n Emma Waitzman\n Ryan Karr\n U.S. Department of Justice\n Antitrust Division\n Technology & Digital Platforms Section\n 450 5th St NW\n Washington, D.C. 20530\n (202) 307-3954\n Danielle.Hauck@usdoj.gov\n Travis.Chapman@usdoj.gov\n Claire.Maddox@usdoj.gov\n Grant.Fergusson@usdoj.gov\n Emma.Waitzman@usdoj.gov\n Ryan.Karr@usdoj.gov\n\n Jonathan B. Sallet\n Colorado Office of the Attorney General\n 1300 Broadway, 7th Floor\n\n\n 22\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 24 of 55\n\n\n\n\n Denver, CO 80203\n Telephone: (720) 508-6000\n E-Mail: Jon.Sallet@coag.gov\n\n Jayme Weber\n Arizona Office of the Attorney General\n 400 West Congress, Ste. S-215\n Tucson, Arizona 85701\n Telephone: (520) 628-6609\n E-Mail: Jayme.Weber@azag.gov\n\n Sarah Mader\n Office of the Attorney General of Ohio\n 30 E Broad Street, 26th Floor\n Columbus, OH 43215\n Telephone: (614) 466-4328\n E-Mail: Sarah.Mader@ohioago.gov\n\n Tyler Corcoran\n Office of the Attorney General and Reporter\n P.O. Box 20207\n Nashville, TN 37202\n Telephone: (615) 741-8722\n E-Mail: Tyler.Corcoran@ag.tn.gov\n\n26. Intellectual Property.\n\n\n\n\n 23\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 25 of 55\n\n\n\n\n27. Confidentiality; Publicity.\n\n 27.1. Confidentiality. Except with the prior written consent of the disclosing Party, the\nrecipient of any information pursuant to this Agreement that is marked as confidential or would\nreasonably be considered confidential information under the circumstances (\u201cConfidential\nInformation\u201d) will not disclose that Confidential Information, except to Affiliates, employees,\nagents, or professional advisors who need to know it and who have agreed in writing (or in the\ncase of professional advisors are otherwise bound) to keep it confidential. The recipient will\nensure that those people and entities use Confidential Information only to exercise rights and\nfulfill obligations under this Agreement, while using reasonable care to keep the Confidential\nInformation confidential. The recipient may also disclose Confidential Information when\nrequired by law or Court order after giving reasonable notice to the discloser, if permitted by law.\nFor avoidance of doubt,\n\n 27.2. Exceptions.\n\n a. Notwithstanding Section 27.1, Google may (i) inform advertisers of the\nparticipation of Signatory and its Affiliate(s) (as applicable) in the Services; and (ii) share with\nadvertisers Site-specific and Client Application-specific statistics, the Site URL(s), the name(s)\nand platform(s) of the Client Application(s), and related information collected by Google through\nits provision of the Search Text Advertising Services to Signatory and its Affiliate(s). Disclosure\nof information by Google under this Section 27.2.a will also be subject to the terms of the\nGoogle Privacy Policy located at the following URL: http://www.google.com/privacypolicy.html\n(or a different URL Google may provide to Signatory from time to time), unless otherwise\nordered by the Court. Google shall notify Plaintiffs and the TC upon changing the URL of the\nGoogle Privacy Policy described herein.\n\n b. Each Party agrees that the terms of this Agreement, once fully executed,\nshall be deemed Confidential Information of the other Party; provided that, in addition to the\npermitted disclosures under Section 27.1, the Parties must disclose the terms of this Agreement\nto Plaintiffs and the TC, and either Party may disclose the terms of this Agreement (i) if required\nto do so by law, Court order, or generally accepted accounting principles, (ii) as required to assert\nits rights hereunder, and (iii) to its own directors, employees, attorneys, accountants, and other\nadvisors on a \u201cneed to know\u201d basis and under an obligation of confidentiality no less stringent\nthan set forth herein. Each Party agrees that the disclosing Party will be given prompt notice of\nany disclosure made pursuant to clause (i) or (ii) above, and that any such disclosure shall be\nlimited to the extent reasonably possible and as permitted by applicable law and/or Court order.\nNotwithstanding the foregoing, in the event that Signatory or its Affiliate(s) is required to file a\ncopy of this Agreement or a summary of this Agreement with the Securities and Exchange\nCommission, Signatory will seek confidential treatment for any such filing, will give Google\n\n\n 24\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 26 of 55\n\n\n\n\n reasonable prior notice and opportunity to review any such filing so that Google may provide\n Signatory with specific redaction requests, and will use its reasonable efforts to redact he\n Agreement (including as to all Google redaction requests) or alternatively provide an agreement\n summary, in each case if and to the extent permitted by applicable laws and regulations.\n\n 27.3. Publicity. Neither Party may issue any press release or make any public statement\n regarding this Agreement without the other\u2019s written approval, except that either Party may make\n public disclosure as required by applicable law and/or Court order. For avoidance of doubt,\n statements or disclosures of information to Plaintiffs or the TC shall not be deemed to be public\n statements under this Section 27.3.\n\n 27.4. Subsyndicate Disclosures. Notwithstanding Section 27.1, Signatory may provide\n Subsyndicate(s) with the following information about their Syndicated Site(s) and Syndicated\n Application(s): (a) total number of impressions; (b) total number of clicks; (c) revenue share\n payment made to such Syndicated Site(s) or Syndicated Application(s); and (d) such other\n information and metrics specific to the Syndicated Site(s) or Syndicated Application(s) as\n Signatory reasonably believes is necessary for Signatory to comply with its obligations\n hereunder and Google approves in writing, such approval not to be unreasonably withheld or\n delayed.\n\n 28. Warranties; Disclaimers.\n\n 28.1. Warranties Generally. Each Party warrants that (a) it has full power and authority\n to enter into this Agreement; and (b) entering into or performing under this Agreement will not\n violate any agreement it has with a third party.\n\n 28.2. Signatory Warranties. Signatory warrants that:\n\n a. Signatory, together with its Affiliate(s), will meet all requirements set by\nthe Court or Plaintiffs, in consultation with the TC, to access the Services at all times during the\nAgreement Term and will promptly inform Google, Plaintiffs, and the TC of any changes to its\nbusiness that may affect its eligibility to access the Services; and\n\n b. all information provided by or on behalf of Signatory or its Affiliate(s) to\nGoogle, Plaintiffs, or the TC in connection with this Agreement, including information Signatory\nor its Affiliate(s) provide to gain or maintain access to the Service, is complete, correct, and\ncurrent.\n\n 28.2.28.3. Disclaimers. Except as expressly provided for in this Agreement and to the\n maximum extent permitted by applicable law, neither Party makes any warranty of any kind,\n\n\n 25\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 27 of 55\n\n\n\n\nwhether implied, statutory, or otherwise, and disclaims, without limitation, warranties of\nmerchantability, fitness for a particular use, and noninfringement.\n\n29. Limitation of Liability.\n\n 29.1. Limitations.\n\n a.\n\n\n\n\n b.\n\n\n\n\n 29.2. Exceptions to Limitations.\n\n\n\n\n30. Force Majeure. Neither Party to this Agreement will be liable for failure or delay in\nperformance to the extent caused by circumstances beyond its reasonable control.\n\n30.31. Indemnification.\n\n 30.1. By Signatory.\n\n a.\n\n\n\n\n 26\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 28 of 55\n\n\n\n\n 30.2. By Google.\n\n a.\n\n\n\n\n b.\n\n\n\n\n 27\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 29 of 55\n\n\n\n\n 30.3. General.\n\n\n\n\n31.32. Counterparts. The Parties to this Agreement may execute this Agreement in counterparts,\nincluding facsimile, PDF, and other electronic copies, which taken together will constitute one\ninstrument. The Parties may also sign this Agreement electronically if permitted by applicable\nlaw.\n\n\n\n\n 28\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 30 of 55\n\n\n\n\nSigned by the Parties\u2019 authorized representatives on the dates below.\n\nGOOGLE LLC\n\nBy:\n\nPrint Name:\n\nTitle:\n\nDate:\n\nSIGNATORY\n\nBy:\n\nPrint Name:\n\nTitle:\n\nDate:\n\n\n\n\n 29\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 31 of 55\n\n\n\n\n EXHIBIT A: SITES AND CLIENT APPLICATIONS\n\n The parties to this Agreement hereby acknowledge and agree to the following:\n\n 1. Sites and Client Applications. For the Agreement Term, Google will make\navailable, and Signatory and its Affiliate(s), as appropriate, will implement and maintain, each of\nthe Service(s) listed in Exhibit B on each of the Site(s) and Client Application(s) listed below:\n\nREMEDIAL WEB SEARCH SERVICE SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\n\nREMEDIAL IMAGE SEARCH SERVICE SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\n\n 30\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 32 of 55\n\n\n\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\n\nREMEDIAL ADSENSE FOR SEARCH SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n\n\n2. Syndicated Sites and Syndicated Applications. For the Agreement Term and pursuant to\nSection 5.7 of this Agreement, Signatory and its Affiliate(s), as appropriate, may make available\nthe Search Text Advertising Service(s) listed in Exhibit B on each of the Syndicated Site(s) and\nSyndicated Application(s) listed below:\n\n\nREMEDIAL ADSENSE FOR SEARCH SYNDICATED SITES & APPLICATIONS\n\n\nSyndicated Sites\n\n[List of Syndicated Sites]\n\n\n\n 31\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 33 of 55\n\n\n\n\nSyndicated Applications\n\n[List of Client Applications]\n\n\n\n3. Implementation Review; Modifications Permitted. Signatory may, at its discretion, add or\nremove\n\n 3.1. Implementation Review Criteria. Prior to any implementation of the Services on a\nSite(s),, Client Application(s),, Syndicated Site(s),, or Syndicated Application(s) listed in going\ninto live use, Google is permitted to review such implementation for purposes of ensuring (a)\nbasic search syndication functionality; (b) maintaining the quality of Search Text Ads; (c) spam\nand abuse detection, including prevention of spam, bot traffic, or other fraudulent activity; or (d)\nlegal or regulatory compliance; provided, however, that prior to the Effective Date, Google will\nnotify Plaintiffs and the TC of all criteria it intends to use to review implementations under this\nExhibit A by C Section 3.a (\u201cImplementation Review Criteria\u201d). If Google wishes to modify\nthe Implementation Review Criteria during the Agreement Term, Google will notify Plaintiffs\nand the TC at least thirty (30) days prior to the date on which Google wishes the modification to\nbecome effective (such notice setting out the proposed modification and the basis for\nmodification in reasonable detail). If, within thirty (30) days of Google notifying Plaintiffs and\nthe TC of its proposed modification(s) to the Implementation Review Criteria, Google receives\nnotice from Plaintiffs that Plaintiffs object to such modification(s), Google agrees not to\nimplement the proposed modification(s) unless and until Plaintiffs confirm the objections have\nbeen addressed, or as otherwise ordered by the Court.\n\n 3.2. Implementation Review Period. Upon receiving notice under Exhibit A Section\n3.3 of an implementation of the Services going into live use, Google will have thirty (30) days to\nreview and, if appropriate, object to any such implementation of the Services on a Site, Client\nApplication, Syndicated Site, or Syndicated Application going into live use (\u201cImplementation\nReview Period\u201d), and Signatory, together with its Affiliate(s), will not bring any implementation\ninto live use during the Implementation Review Period. To exercise its objection rights under this\nExhibit A Section 3.2, Google must simultaneously notify Signatory, Plaintiffs, and the TC of its\nintent to object, the basis for its objection, and what steps Google believes would be required\nbefore such implementation goes into live use. If Google objects to an implementation under this\nExhibit A Section 3.2, the implementation shall not go into live until (i) Signatory, together with\nits Affiliate(s), resolves any noncompliance with the Implementation Review Criteria, (ii) Google\nagrees to withdraw its objection(s), or (iii) as otherwise instructed by the Court, whichever\noccurs sooner. During any Implementation Review Period or objection period under this Exhibit\nA Section 3.2, Google shall provide such reasonable assistance and cooperation to Signatory and\n\n\n 32\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 34 of 55\n\n\n\n\nits Affiliate(s) (without being required to disclose any sensitive or proprietary information) as\nSignatory may request to aid in remedying any noncompliance with the Implementation Review\nCriteria. For avoidance of doubt, Google will not object to any such implementation except on\nreasonable belief that such implementation violates the Implementation Review Criteria, and if\nGoogle does not object to an implementation during the Implementation Review Period,\nSignatory and its Affiliate(s) (as appropriate) may bring such implementation into live use.\nNothing in this Exhibit A Section 3.b is intended to limit or supersede the ability of Signatory or\nits Affiliate(s) to issue complaints under the Final Judgment.\n\n 3.3. Notice of Implementations and Modifications. Signatory may, from time to time,\nsimultaneously notify Google, Plaintiffs, and the TC that it wishes to add or remove URL(s) to\nthe Site(s) or Syndicated Site(s), or add or remove Client Applications or Syndicated\nApplications, from Exhibit A Section 1; provided, however, that Signatory notifies Google, in\nwriting, of such modification at least thirty (30) days before Signatory wishes the addition or\ndeletion to take effect. Any such modification to the list of Site(s), Client Application(s),\nSyndicated Site(s), and Syndicated Application(s) in this Exhibit A shall not be treated as an\nAmendment to this Agreement under Section 20. Google may not rejectobject to any\nmodification to the list of Site(s), Client Application(s), Syndicated Site(s), and Syndicated\nApplication(s) in this Exhibit A Section 1, except as permitted under Exhibit A Sections 3.2 and\n3.3.\n\n 3.4. Confidentiality Screening for Syndicated Sites and Syndicated Applications.\nGoogle agrees to treat any information about Syndicated Sites or Syndicated Applications\nreceived under this Agreement as Highly Confidential under the extentProtective Order in the\nUnderlying Consolidated Cases, except that Google employees may be provided access to such\nmodification would otherwise violate the termsinformation on a need-to-know basis for the sole\npurpose and use of this Agreement. At least ten (10) days prior to issuing any such rejection,\nGoogle shall provide written noticecomplying with this Agreement, including reviewing and, if\nappropriate, objecting to implementations under this Exhibit A Section 3. Prior to receiving any\ninformation about Syndicated Sites or Syndicated Applications under this Agreement, Google\nwill certify to Signatory, Plaintiffs, and the TC detailing the basis for in writing that it has\nimplemented appropriate confidentiality procedures or mechanisms under this Exhibit A Section\n3.4, with such certification including a description of the procedure(s) or mechanism(s)\nimplemented. Google will undertake such rejection.reasonable additional steps to comply with\nthis Exhibit A Section 3.4 as may be agreed upon by the Parties or as instructed by Plaintiffs, the\nTC, or the Court. For avoidance of doubt, Google is not required to disclose any sensitive or\nproprietary information to Signatory or its Affiliate(s) under this Exhibit A Section 3.4.\n\n\n\n\n 33\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 35 of 55\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 36 of 55\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 37 of 55\n\n\n\n\nof the date of invoice. For avoidance of doubt, in each invoice or statement of financial activity\nissued under this Exhibit B Section 2.1.c, Google will list all Search Fees payable to Signatory\nand its Affiliate(s) (as appropriate), all payments owed by Google to Signatory and its Affiliate(s)\n(as appropriate), and any offsets calculated for such Search Fees and payment obligations.\n\n d. Invoice Disputes. Signatory and its Affiliate(s) (as appropriate) may\ndispute invoiced Search Fees if Signatory and its Affiliate(s) (as appropriate) believe in good\nfaith that such Search Fees were inaccurately invoiced (an \u201cInvoice Dispute\u201d). Invoice Disputes\nmust be submitted to and identify all disputed amounts and the reason\nfor dispute. Google will review in good faith all Invoice Disputes and will provide Signatory and\nits Affiliate(s) (as appropriate) an explanation of Search Fees due following such review (an\n\u201cInvoice Dispute Report\u201d). If an Invoice Dispute is submitted within thirty (30) days of\nSignatory and its Affiliate(s) (as appropriate) receiving an invoice under this Agreement (the\n\u201cPayment Due Date\u201d), then (i) Signatory and its Affiliate(s) (as appropriate) must only pay the\namounts not subject to the Invoice Dispute by the Payment Due Date, and (ii) unpaid Search\nFees stated in an Invoice Dispute Report to be accurately invoiced are due within thirty (30) days\nafter delivery of such report to Signatory and its Affiliate(s) (as appropriate). If an Invoice\nDispute is submitted after the Payment Due Date and the Invoice Dispute Report states that\nSearch Fees paid were incorrectly invoiced, then Google will issue a credit equal to the agreed\namount. For avoidance of doubt, nothing in this Exhibit B Section 2.1.d is intended to limit or\nsupersede the ability of Signatory and its Affiliate(s) (as appropriate) to submit complaints to\nPlaintiffs, the TC, or Google under the Final Judgment.\n\n 2.2. Google Payments.\n\n a. For each applicable Search Text Advertising Service, Google will pay\nSignatory and its Affiliate(s) (as appropriate) an amount equal to the Revenue Share Percentage\nof Ad Revenues attributable to a calendar month. This payment will be made in the month\nfollowing the calendar month in which the applicable Search Text Ads were displayed.\n\n b. Google\u2019s payments for Search Text Advertising Services under this\nAgreement will be based on Google\u2019s accounting, which may be filtered to exclude invalid\nqueries, impressions, conversions, or clicks in each case provided Google does not receive and\nretain payment from the applicable advertiser for such activity. On reasonable written notice\nfrom Signatory, Plaintiffs, or the TC, Google will promptly produce to Signatory, Plaintiffs, or\nthe TC (as appropriate) its accounting for payments under this Agreement, including any filters\nor exclusions applied.\n\n\n\n\n 36\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 38 of 55\n\n\n\n\n 2.3. All Payments.\n\n a. As between Google and Signatory and its Affiliate(s), Google is\nresponsible for all taxes (if any) associated with the transactions between Google and advertisers\nin connection with Search Text Ads displayed on the Sites, Client Applications, Syndicated Sites,\nand Syndicated Applications. Signatory and its Affiliate(s) (as appropriate) are responsible for all\ntaxes (if any) associated with the Services, other than taxes based on Google\u2019s net income, net\nworth, asset value, property value, or employment. All payments to Signatory and its Affiliate(s)\n(as appropriate) from Google in relation to the Services will be treated as inclusive of tax (if\napplicable) and will not be adjusted. If Google is obligated to withhold any taxes from its\npayments to Signatory and its Affiliate(s), Google will notify Signatory of this and will make the\npayments net of the withheld amounts. Google will provide Signatory with original or certified\ncopies of tax payments (or other sufficient evidence of tax payments) if any of these payments\nare made by Google.\n\n b. All payments due to Google or to Signatory and its Affiliate(s) (as\nappropriate) will be in the currency described in the associated invoice, such currency to be\ndetermined upon mutual agreement by the Parties. and made by electronic transfer to the\naccount notified to the paying Party by the other Party for that purpose, and the Party receiving\npayment will be responsible for any bank charges assessed by the recipient\u2019s bank. Any charges\nfor converting foreign currency shall be the responsibility of Signatory and its Affiliate(s) (as\nappropriate) and will be invoiced accordingly. In accordance with applicable laws and\nregulations, Google operates multiple local Google-affiliated entities to process transactions, and\npayments from Signatory or its Affiliate(s) to Google may be made to one or more of these\nGoogle-affiliated entities as specified by Google, which will satisfy the payment obligations of\nSignatory and its Affiliate(s) (as appropriate) under this Agreement.\n\n c. In addition to other rights and remedies Google may have, Google may\noffset any payment obligations to Signatory and its Affiliate(s) (as appropriate) that Google may\nincur under this Agreement against any undisputed, past due product or service fees owed to\nGoogle by Signatory and its Affiliate(s) (as appropriate) under this Agreement. Google may also\nwithhold and offset against its payment obligations under this Agreement, or require Signatory\nand its Affiliate(s) (as appropriate) to pay Google within thirty (30) days of any invoice, any\namounts Google may have overpaid to Signatory and its Affiliate(s) in prior periods.\n\n 2.4. SOC 1 Report. Upon written request by Signatory or its Affiliate(s) (as\nappropriate), and no more than once per calendar year during the Agreement Term, Google will\nmake available to Company a SOC 1, Type 2 report (or similar report with comparable data)\nfrom a reputable, independent certified public accounting firm covering the key controls and\nvalidation mechanisms in place to meet the revenue reporting obligations under this Agreement.\n\n\n 37\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 39 of 55\n\n\n\n\nSuch report will be considered Confidential Information of Google under this Agreement, except\nthat Google will, upon reasonable, written notice from Plaintiffs or the TC, provide a copy of any\nsuch report made available under this Exhibit B Section 2.4 to Plaintiffs and the TC.\n\n3. Privacy-Preserving Alternative Implementation.\n\n\n\n\n 3.2. Non Personalized Ads Permitted. In addition to the methods of implementing the\nSearch Text Advertising Service(s) described in Exhibit B Sections 1 and 3.1, Google shall make\navailable to Signatory and its Affiliate(s), at Signatory\u2019s sole discretion, the option of receiving\nnon personalized Search Text Ads under the Search Text Advertising Services (\u201cNon\nPersonalized Ads\u201d or \u201cNPAs\u201d). Non Personalized Ads provided under this Agreement shall\nconform to the NPA specifications at https://support.google.com/adsense/answer/7670312 (or\nsuch URL as Google may may provide to Signatory from time to time, provided that Google\nnotifies Plaintiffs and TC in parallel of any alternative URL provided under this Exhibit B\nSection 3.2).\n\n4. Related Products, Services, and Integrated Features. Within five (5) business days of\nlaunching a new, commercially available product, service, or integrated feature that alters,\naugments, replaces, or otherwise relates to any Service(s) provided under this Agreement,\nGoogle shall provide written notice of such new product(s), service(s), or integrated feature(s) to\nPlaintiffs and the TC. In the event that, following receipt of such notice, Plaintiffs so instruct,\nSignatory and Google will amend this Agreement according to Section 20 solely to make such\n\n\n\n\n 38\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 40 of 55\n\n HIGHLY CONFIDENTIAL\n SUBJECT TO PROTECTIVE ORDER AND ECF NOS. 1520-1 AND 1521\n\nnew product(s), service(s), or integrated feature(s) available to Signatory and its Affiliate(s)\npursuant to the terms set forth in Sections V and VI of the Final Judgment.\n\n\n\n\n 39\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 41 of 55\n\n\n\n\n EXHIBIT C: ADDITIONAL CLAUSES FOR SERVICES TO BE PROVIDED\n\n The Parties to this Agreement hereby acknowledge and agree to the following additional\nprovisions, which are intended to supplement, and not replace or conflict with, Sections 4, 5, 6,\nand 7 of this Agreement:\n\n1. Additional Definitions. For the purposes of this Exhibit C, the following terms shall have\nthe following meanings:\n\n 1.1. \u201cDuplicate Advertisements\u201d means URLs (and not advertisers, categories or\nkeywords) that promote Search Text Ads that include the same website, display URL, or\nadvertiser that is promoted in an advertisement displayed or sold by or on behalf of Signatory or\nits Affiliate(s) as permitted under this Agreement.\n\n 1.2. \u201cNetwork Issues\u201d means any outage(s) or latency caused by any third party\nnetwork connectivity or software that is outside of Google\u2019s control.\n\n 1.3. \u201cSearch Service Availability\u201d means the percentage of Requests for Search\nResults or Search Results Sets sent to Google in response to a Covered Query that are processed\nby Google under this Agreement.\n\n 1.4. \u201cSearch Service Network Latency\u201d means the round-trip time of a TCP/IP ping\npacket between a peering address owned or operated by Signatory or its Affiliate(s) and Google\u2019s\npeering address.\n\n 1.5. \u201cSearch Text Advertising Service Availability\u201d means the percentage of\nRequests for Search Text Ads or Search Text Ad Sets sent to Google under this Agreement that\nare processed by Google\u2019s system within one (1) second.\n\n 1.6. \u201cServer Latency\u201d means the time period between when Google's system receives\na Request for Search Text Ads or Search Text Ad Sets under this Agreement and when Google's\nsystem has processed such Request. For clarity, Server Latency does not include any time\nassociated with transmission of the Request for Search Text Ads or Search Text Ad Sets from\nSignatory or its Affiliate(s) to Google's system or transmission of the applicable Search Text Ads\nor Search Text Ad Sets from Google's system to Signatory or its Affiliate(s).\n\n\n\n\n 40\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 42 of 55\n\n\n\n\n2. Additional Clauses for Search Services.\n\n 2.1. Required Search Service Latency and Reliability.\n\n a. Required Search Service Availability. For all selected Search Service(s) in\nExhibit B, Google will provide Signatory and its Affiliate(s) with\n Search Service Availability over a rolling thirty (30) day period (excluding any\nNetwork Issues), as measured and monitored from Google\u2019s facilities in the United States.\n\n b. Search Service Network Latency Threshold. Throughout the Agreement\nTerm, Search Service Network Latency will not exceed an average of milliseconds over any\n10-hour period (excluding any Network Issues) (\u201cSearch Service Network Latency\nThreshold\u201d). To measure Search Service Network Latency, Signatory willmay either (i) install\nprivate interconnects at Google\u2019s United States-based network meeting places as mutually agreed\nby the Parties., or (ii) implement such other processes and mechanisms agreed upon by the\nParties. Upon reasonable notice by the TC, Signatory and Google agree to submit information or\ndata concerning measurements of the Search Service Network Latency, or to grant the TC access\nto the private interconnects installed under this Exhibit C Section 2.1, and will, if the TC so\ninstructs, modify, update, or otherwise change the method(s) for measuring Search Service\nNetwork Latency under this Agreement. Throughout the Agreement Term, Google shall not take\nany actions that have the effect of slowing Search Service Network Latency, including, without\nlimitation, in circumstances where Search Service Network Latency is below the Search Service\nNetwork Latency Threshold, with the intent of approaching or reaching the Search Service\nNetwork Latency Threshold, even if doing so would decrease costs for Google.\n\n 2.2. Display or Use Restrictions for Search Services. Signatory and its Affiliate(s) (as\nappropriate),) may\n\n Except as expressly approved by Google or the Court in writing, Signatory and\nits Affiliate(s) will not make more than one (1) Request for Search Results or Search Results Set\nper Covered Query. Notwithstanding the foregoing,\n\n\n\n\n 41\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 43 of 55\n\n\n\n\n 2.3. Additional Terms Permitting Use Within GenAI Product GroundingProducts.\nNotwithstanding Sections 4.4, 4.5, 5.4, and 5.5, as well as the terms of this Exhibit C, Google\nshall not:\n\n a. prohibit Signatory andor its Affiliate(s) from temporarily caching Search\nResults solely for the purpose of grounding any single displaying or using those Search Results\nas part of a response to a Covered Query generatedissued by an End User of a GenAI Product\nowned and operated by Signatory and its Affiliate(s), provided that any such cached content is\nnot stored beyond the duration necessary to complete such response; or\n\n b. treat single-call API retrieval under this Agreement for use inwithin GenAI\nProduct groundingProducts described in Exhibit C Section 2.3.a as bulk scraping, indexing, or\ncrawling prohibited under this Agreement.\n\n3. Additional Clauses for Search Text Advertising Services.\n\n 3.1. Required Search Text Advertising Service Latency, Reliability, and Performance.\n\n a. Search Text Advertising Service Availability. For all selected Search Text\nAdvertising Service(s) in Exhibit B, Google will provide Signatory and its Affiliate(s) with\n Search Text Advertising Availability over a\nrolling thirty (30) day period (excluding any Network Issues), as measured and monitored from\nGoogle\u2019s facilities in the United States.\n\n b. Search Text Ad Server Latency Threshold. For all selected Search Text\nAdvertising Service(s) in Exhibit B, Server Latency will not exceed an average of\nmilliseconds over any 1024-hour period (\u201cServer Latency Threshold\u201d). Google will work in\ngood faith to find ways to continuously improve Server Latency during the Agreement Term. For\navoidance of doubt, Google shall not take any actions throughout the Agreement Term that have\nthe effect of slowing Server Latency, including, without limitation, in circumstances where\nServer Latency is below the Server Latency Threshold, with the intent of approaching or\nreaching the Server Latency Threshold, even if doing so would decrease costs for Google.\n\n 3.2. Search Text Ads Display or Use Restrictions.\n\n\n\n\n 42\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 44 of 55\n\n\n\n\n 3.3. No Dedicated Search Text Ads Software Development Kit (SDK) for Client\nApplications and Syndicated Applications. Notwithstanding any other terms in this Agreement,\nGoogle and Signatory acknowledge and agree that Google does not offer a dedicated mobile\napplication software development kit for the provision of Search Text Ads. Unless otherwise\nordered by the Court, Google will not be required to make Search Text Ads available on any\nClient Applications or Syndicated Applications through any dedicated mobile application\nsoftware development kit during the Agreement Term. The Parties to this Agreement will\ncollaborate in good faith to implement the Search Text Advertising Service(s) on the Client\nApplication(s) and Syndication Application(s) without the use of a dedicated mobile application\nsoftware development kit. Google shall provide Signatory and its Affiliate(s) with commercially\nreasonable technical support and cooperation necessary to enable such implementation, subject\nto any Google Guidelines and Protocols implemented pursuant to Exhibit C Section 5.4.\n\n4. Escalation of Service Availability and Latency Noncompliance.\n\n 4.1. Severity Classifications. For the purposes of this Exhibit C Section 4, the Parties\nagree to classify any Google noncompliance with Exhibit C Sections 2.1.a, 2.1.b, 3.1.a, or 3.1.b\nby severity (together, \u201cSeverity Errors\u201d) as follows:\n\n a. A \u201cSeverity 2 Error\u201d shall mean (i) any Search Service Availability or\nSearch Text Advertising Availability provided by Google under this Agreement that is more than\nninety-nine and five-tenths percent (99.5%) but less than the required ninety-nine and nine-tenths\npercent (99.9%) over a rolling thirty (30) day period (excluding any Network Issues), as\n\n\n 43\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 45 of 55\n\n\n\n\nmeasured and monitored from Google\u2019s facilities in the United States, and (ii) any Search\nService Network Latency or Server Latency that exceeds an average of 75 milliseconds over any\n10-hour period but is less than 99 milliseconds over any 10-hour period.\n\n b. A \u201cSeverity 1 Error\u201d shall mean (i) any Search Service Availability or\nSearch Text Advertising Availability provided by Google under this Agreement that is ninety-\nnine and five-tenths percent (99.5%) or less over a rolling thirty (30) day period (excluding any\nNetwork Issues), as measured and monitored from Google\u2019s facilities in the United States, and\n(ii) any Search Service Network Latency or Server Latency that exceeds 99 milliseconds over\nany 10-hour period.\n\n 4.2. Responding to Severity Errors. If either Party becomes aware of a suspected\nSeverity 2 Error or Severity 1 Error under this Agreement, such Party will promptly notify the\nother Party of such Severity Error(s). Upon becoming aware of such Severity Error(s), Google\nwill use commercially reasonable efforts to (a) respond to any such notice provided by Signatory\nor its Affiliate(s) within thirty (30) minutes (for Severity 2 Errors) or fifteen (15) minutes (for\nSevery 1 Errors), and (b) resolve such Severity Error within one (1) day (for Severity 2 Errors) or\nthirty (30) minutes (for Severity 1 Errors).\n\n 4.3. Remedy for Noncompliance.\n\n a. If Google fails to resolve a Severity Error within the applicable time\nperiod set forth in Exhibit C Section 4.2 such that, during any given thirty (30) day period,\nSearch Text Ads or Search Text Ad Sets are not sent back to Signatory or its Affiliate(s) in\nresponse to a Request for Search Text Ads or Search Text Ad Set under this Agreement, then\n\n\n\n\n 44\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 46 of 55\n\n\n\n\n b.\n\n\n\n\n5. Policy and Compliance Obligations.\n\n 5.1. Policy Obligations. Except as otherwise permitted by this Agreement, including\nactions permitted under Section 4.4, Section 5.4, Section 6.6, and Exhibit C Section 2.3,\nSignatory and its Affiliate(s) will not, and will use commercially reasonable efforts to not permit\nany third party to:\n\n a. modify, obscure, or prevent the display of all, or any part of, any Search\nResults or Search Text Ads;\n\n b. edit, filter, truncate, append terms to, or otherwise modify any Covered\nQuery;\n\n c. implement any click tracking or other click monitoring of Search Results\nor Search Text AdsClick Tracking, except as provided in Exhibit C Section 6 below;\n\n d. display any Search Results or Search Text Ads in pop-ups, pop-unders,\nexit windows, expanding buttons, animation, or other similar methods;\n\n\n 45\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 47 of 55\n\n\n\n\n e. enter into any type of arrangement with a third party where either party\nreceives a financial benefit in connection with (i) the Search Results or Search Text Ads provided\nunder this Agreement or (ii) any Ad Revenues (including any co-branding, white labeling or sub-\nsyndication arrangement). For the avoidance of doubt, nothing in this Exhibit C Section 5.1.e is\nintended to prevent Signatory or its Affiliate(s) from displaying, using, or sub-syndicating Search\nText Ads under Section 5Sections 5.4, 5.6, 5.7, and Exhibit C Section 3 of this Agreement;\n\n f. directly or indirectly, (i) offer incentives to End Users to generate\nimpressions, Requests, or clicks on Search Results and/or Search Text Ads; (ii) fraudulently\ngenerate impressions, Requests, or clicks on Search Results and/or Search Text Ads; or (iii)\nmodify impressions, Requests, or clicks on Search Results and/or Search Text Ads;\n\n g. \u201ccrawl,\u201d \u201cspider,\u201d index or in any non-transitory manner store or cache\ninformation obtained from the Services (including Search Results and Search Text Ads), beyond\nwhat is necessary to present Search Results and/or Search Text Ads in response to a Query;\n\n h. except for content provided by Google, display on any Site or Client\nApplication any content that violates or encourages conduct that would violate the Google\nProgram Guidelines, Google technical protocols, or any other technical requirements; provided,\nhowever, that Google shall not impose any requirements under the Google Program Guidelines,\nGoogle technical protocols, or any other technical requirements except as permitted under\nSection VI.B.11 of the Final Judgment. In the event of a conflict between the Google Program\nGuidelines, Google\u2019s technical protocols, or any other technical requirements and this\nAgreement, the terms of this Agreement will controlGuidelines and Protocols permitted under\nExhibit C Section 5.4;\n\n i. enter into any type of arrangement where a third party other than\nSubsyndicate receives a payment in connection with Search Text Ads provided under this\nAgreement (for example, a Subsyndicate\u2019s partner). For the avoidance of doubt, Affiliates are not\ntreated as third parties for the purposes of this Exhibit C Section 5.1.i;\n\n j. use the Services to directly or indirectly monetize error pages, unless\nexpressly permitted by Google or as otherwise ordered by the Court.. Indirect monetization of\nerror pages includes, but is not limited to, having a search box or text links on error pages that\nresolve to pages containing Search Text Ads. Errors include, but are not limited to, DNS errors or\nHTTP response codes of types 3xx, 4xx, or 5xx; or\n\n\n\n\n 46\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 48 of 55\n\n\n\n\n k. serve or display advertisements on or in connection with, or otherwise\nmonetize, SERPs that have Search Results from the Remedial Image Search Service listed in\nExhibit B.\n\n 5.2. Compliance Obligations. Signatory and its Affiliate(s) will not knowingly or\nnegligently allow any use of or access to the Services through any Site or Client Application that\nis not in compliance with the terms of this Agreement. Signatory and its Affiliate(s) (as\nappropriate) will use commercially reasonable efforts to monitor for any such access or use and\nwill, if any such access or use is detected, take all reasonable steps requested by Google to\ndisable this access or use. If Signatory and its Affiliate(s) are not in compliance with this\nAgreement at any time, Google may with notice to Signatory (such notice setting forth such\nnoncompliance in reasonable detail) suspend provision of all (or any part of) the applicable\nServices (in as targeted and narrow a fashion as is commercially reasonable to eliminate the\nproblem) until Signatory and its Affiliate(s) (as appropriate) implement adequate corrective\nmodifications as reasonably required and determined by Google or as otherwise ordered by the\nCourt; provided, however, that at least fifteen (15) business days prior to exercising its\nrightsduring any suspension period, Google shall provide such reasonable assistance and\ncooperation to Signatory and its Affiliate(s) (without being required to disclose any sensitive or\nproprietary information) as Signatory may request to aid in remedying the noncompliance. For\nany notice Google provides to Signatory under this Exhibit C Section 5.2, Google mustshall also\nprovide simultaneous written notice to Signatory, Plaintiffs, and the TC detailing (i) the alleged\nnoncompliance by Signatory and/or its Affiliate(s) and, (ii) the actions Google intends to takeis\ntaking in response. After providing this notice, Google will not exercise any suspension rights,\nand (iii) the anticipated length of the suspension period. For avoidance of doubt, once Signatory\nand its Affiliate(s) (as appropriate) implement adequate corrective modifications under this\nExhibit C Section 5.2, Google agrees to reinstate any Services suspended under this Exhibit C\nSection 5.2 or take any related action under this Agreement until the earlier of (i) the date on\nwhich Google receives written notice from Plaintiffs that Plaintiffs do not object to suspension,\nor (ii) fifteen (15) business days following Google\u2019s provision of notice under this Exhibit C\nSection 5.2; provided, however, that if, within fifteen (15) business days of Google providing the\nnotice required under this Exhibit C Section 5.2, Google receives written notice from Plaintiffs\nthat Plaintiffs intend to object to Google\u2019s termination, Google will not exercise any termination\nrights or take any related action under this Agreement until the as soon as possible and no later of\n(i) fourteen (14)than ten (10) business days after Plaintiffs seek Court intervention concerning\nGoogle\u2019s intent to suspend this Agreement, if the Court does not act; or (ii) until further order by\nthe Court, if the Court intervenes.such corrective modifications are implemented.\n\n 5.3. Signatory Content. For Site, Client Application, Syndicated Site, or Syndicated\nApplication content not controlled by Signatory or its Affiliate(s), Signatory and its Affiliate(s)\n(as appropriate) will use commercially reasonable efforts to ensure that such content is not\n\n\n 47\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 49 of 55\n\n\n\n\nUnacceptable Content. If Signatory or its Affiliate(s) becomes aware that any Site, Client\nApplication, Syndicated Site, or Syndicated Application contains Unacceptable Content,\nSignatory will have such Unacceptable Content removed as soon as reasonably practicable (not\nto exceed five (5) days). If Signatory, together with its Affiliate(s), fails to remove Unacceptable\nContent not controlled by Signatory or its Affiliate(s) within five (5) days of becoming aware of\nsuch Unacceptable Content, Google may, with notice to Signatory (such notice setting forth the\nnoncompliance with this Exhibit C Section 5.3 in reasonable detail) suspend provision of all (or\nany part of) the Services (in as targeted and narrow a fashion as is commercially reasonable to\neliminate the problem) until Signatory or its Affiliate(s) (as appropriate) removes the\nUnacceptable Content; provided, that, during any suspension period, Google shall provide such\nreasonable assistance and cooperation to Signatory and its Affiliate(s) (without being required to\ndisclose any sensitive or proprietary information) as Signatory shall request to aid in remedying\nthe noncompliance. For avoidance of doubt, once Signatory and its Affiliate(s) (as appropriate)\nremoves the Unacceptable Content, Google agrees to reinstate any Services suspended under this\nExhibit C Section 5.2 as soon as possible and no later than ten (10) business days after such\nUnacceptable Content is removed. Google will not exercise any suspension rights under this\nExhibit C Section 5.3 without first notifying Plaintiffs and the TC of Google\u2019s intent to exercise\nsuch rights (such notice setting forth the noncompliance with this Exhibit C Section 5.3 in\nreasonable detail) at least three (3) business days in advance.\n\n 5.4. Additional Obligations Permitted by Amendment. During the Agreement Term\nand only pursuant to the Amendment procedures set forth in Section 20 of this Agreement,\nGoogle may, at its discretion, propose additional terms to this Agreement for the purposes of (a)\nbasic search syndication functionality; (b) maintaining the quality of Search Text Ads; (c) spam\nand abuse detection, including reasonable terms to prevent or eliminate spam, bot traffic, or other\nfraudulent activity; or (d) legal or regulatory compliance (\u201cGoogle Guidelines and Protocols\u201d).\nFor avoidance of doubt, Google shall not propose additional terms to this Agreement that conflict\nwith the Final Judgment.\n\n 5.5. Compliance with Laws. Each Party to this Agreement will comply with all\napplicable laws, rules, ordinances, judicial and administrative orders, and regulations in\nexercising its rights and fulfilling its obligations under this Agreement.\n\n6. Click Tracking. Signatory and its Affiliate(s) (as appropriate) may implement click\ntrackingClick Tracking in accordance with Google\u2019s applicable Google technical protocols, the\nGoogle Program Guidelines, and this Agreementpolicies, or guidelines; provided, however, that\nthat Google shall not impose any terms or requirements under the Google Program Guidelines,\nGoogle technical protocols, or any other technical requirementsthis Exhibit C Section 6 except as\npermitted under Section VI.B.11 of the Final Judgment. In the event of a conflict between\nGoogle\u2019s technical protocols or the Google Program Guidelines and this Agreement, the terms of\n\n\n 48\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 50 of 55\n\n\n\n\nthis Agreement will controlExhibit C Section 5.4 herein. Signatory and its Affiliate(s) (as\nappropriate) are responsible for the implementation and operation of any click trackingClick\nTracking.\n\n7.\n\n 7.1.\n\n\n\n\n 7.2.\n\n\n\n .\n\n 7.3.\n\n\n\n\n 49\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 51 of 55\n\n\n\n\n 7.4.\n\n\n\n\n8. Permitted and Prohibited Uses of Data.\n\n 8.1. Definition of Signatory Data.\n\n\n\n\n 8.2. Definitions of Google Data.\n\n\n\n\n 8.3. Permitted and Prohibited Uses.\n\n a. Signatory Data.\n\n\n\n\n 50\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 52 of 55\n\n\n\n\n b. Google Data.\n\n\n\n\n c. Signatory Click Data.\n\n\n\n d. Data Shared with Advertisers.\n\n\n\n\n e. Legally Required Uses. Notwithstanding the foregoing or anything to the\ncontrary within this Agreement, Google may use Google Data, and either Party may use\nSignatory Data and Signatory Click Data to the extent required by law, in order to comply with\nlegal process, preventing fraud or imminent harm, and ensuring the security of its network and\nservices.\n\n f. Exceptions for Privacy-Preserving Alternatives. Nothing in this Exhibit C\nSection 8 shall limit or supersede any rights that Signatory and its Affiliate(s) may have to\n\n\n\n\n 51\n\f Case 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 53 of 55\n\n\n\n\nwithhold, anonymize, alter, or otherwise protect the privacy of End User data under Exhibit B\nSection 3.\n\n9.\n\n\n\n\n 52\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 54 of 55\n\n\n\n\n 53\n\fCase 1:20-cv-03010-APM Document 1567-4 Filed 10/23/26 Page 55 of 55\n\n\n\n\n 54\n\f","ocr_status":1,"date_upload":"2026-10-23T19:16:08.987306-07:00","document_number":"1567","attachment_number":4,"pacer_doc_id":"045012431084","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487566/","id":498487566,"tags":[],"absolute_url":"/docket/18552824/1567/5/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.264155-07:00","date_modified":"2026-10-26T18:01:10.224088-07:00","sha1":"c781a71066527f12a3ce5c73f8436f5a900981b6","page_count":15,"file_size":248218,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.5.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.5.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487566.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 1 of 15\n\n\n\n\n Exhibit 5\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 2 of 15\n\n\nFrom: Fergusson, Grant (ATR)\nTo: Connor, Colette; Keung, Tiffany; Maddox, Claire (ATR); Waitzman, Emma (ATR); Karr, Ryan (ATR); \"Jon Sallet\";\n \"Weber, Jayme\"; \"Sarah Mader\"\nCc: Schmidtlein, John; Safty, Graham; Greenblum, Benjamin; Ryan, Thomas; Clay, Jesse\nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\nDate: Friday, October 9, 2026 6:00:57 PM\n\n\n\nColette,\n\nPlaintiffs object to the formulation of your emailed questions as overly ambiguous, particularly\ngiven the highly technical nature of the syndication remedies. Nevertheless, Plaintiffs believe the\nposition provided in our previous email answers Google's questions on this point. On Monday's\nmeet and confer, Plaintiffs also confirmed that the recommended syndication template does not\npermit a Qualified Competitor to train AI models on syndicated content or otherwise use\nsyndicated content to independently develop search capabilities.\n\nTo confirm, Plaintiffs and the TC do not believe our position on this issue requires a modification\nto the recommended syndication template provided to Google.\n\nBest,\nGrant\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Connor, Colette \nSent: Friday, October 9, 2026 1:57 PM\nTo: Fergusson, Grant (ATR) ; Keung, Tiffany ;\nMaddox, Claire (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; 'Jon Sallet'\n; 'Weber, Jayme' ; 'Sarah Mader'\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nGrant,\nThank you for your response. It does not, however, directly answer the two questions we\nposed at our Monday meet and confer, which I also repeated in my email below: (1) is a\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 3 of 15\n\n\nQC allowed under Plaintiffs\u2019 template to take Google\u2019s syndicated search results and feed\nthem into an LLM?; and (2) if any form of grounding is intended to be prohibited by\nPlaintiffs\u2019 template, how is that form of grounding defined? Please respond to these\nquestions by Monday. If the Technical Committee requires more information or a further\ndiscussion with Google, please let us know and we will get that on calendar for early next\nweek.\n I don\u2019t understand your position to be modifying the template such that we need to include\na new objection and counter-proposal, but if I am mistaken on that please let me know. As\nyou know, Google objects to terms that depart from Google\u2019s MFN use and display terms\nand Google\u2019s ordinary-course IP protections.\n Best,\nColette\nColette Connor\nWilliams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n(P) 202-434-5170 | (F) 202-480-8236\ncconnor@wc.com | www.wc.com/cconnor\n\n\n\nFrom: Fergusson, Grant (ATR) \nSent: Thursday, October 8, 2026 7:48 PM\nTo: Connor, Colette ; Keung, Tiffany ; Maddox, Claire (ATR)\n; Waitzman, Emma (ATR) ; Karr, Ryan\n(ATR) ; 'Jon Sallet' ; 'Weber, Jayme'\n; 'Sarah Mader' \nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nColette,\n\nOn the Parties\u2019 meet and confer dated October 5, 2026, Google requested additional information\nregarding the Plaintiffs\u2019 position on how Qualified Competitors offering GenAI Products may\ndisplay and use syndicated search results.\n\nTo confirm, the Plaintiffs\u2019 position, in consultation with the TC, is that Qualified Competitors,\nincluding those offering GenAI Products, may display and use syndicated search results flexibly\nso long as such display and use comports with the Final Judgment and the Court\u2019s instructions.\nSpecifically, Qualified Competitors offering GenAI Products are not limited to displaying\nsyndicated search results in Google\u2019s \u201cten blue links\u201d format and may temporarily cache the\ncontent of syndicated search results received in response to a Covered Query for the purpose of\nresponding to such Covered Query in a different way, including in text responses akin to AI\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 4 of 15\n\n\nOverviews.\n\nIf Google intends to raise an objection related to this position, please provide Google\u2019s\nobjection(s), the bases for such objection(s), and any proposed resolution(s) by Google as part of\nGoogle\u2019s submission of objections tomorrow (10/9).\n\nSeparately, we noted on Monday\u2019s meet and confer that the TC was still finalizing its notice\naddress box for Section 25 of Plaintiffs\u2019 recommended syndication template. The TC has\nprovided the following address box, which we plan to include in tomorrow\u2019s filing:\n\n\n Chair, Remedies Technical Committee, Inc.\n\n\n\n\nBest,\nGrant\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Connor, Colette \nSent: Thursday, October 8, 2026 4:30 PM\nTo: Fergusson, Grant (ATR) ; Keung, Tiffany ;\nMaddox, Claire (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; 'Jon Sallet'\n; 'Weber, Jayme' ; 'Sarah Mader'\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 5 of 15\n\n\nGrant,\n\nThank you for your letter. We will review. To make sure we are on the same page, we\ncontinue to await an answer to our questions regarding grounding: (1) is a QC allowed\nunder Plaintiffs\u2019 template to take Google\u2019s syndicated search results and feed them into an\nLLM?; and (2) if any form of grounding is intended to be prohibited by Plaintiffs\u2019 template,\nplease define that form of grounding.\n\nWith respect your last paragraph, we cannot agree to that process as that does not provide\nGoogle adequate time to evaluate your responses.\n\nBest,\nColette\n\nColette Connor\nWilliams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n(P) 202-434-5170 | (F) 202-480-8236\ncconnor@wc.com | www.wc.com/cconnor\n\n\n\nFrom: Fergusson, Grant (ATR) \nSent: Thursday, October 8, 2026 4:19 PM\nTo: Keung, Tiffany ; Maddox, Claire (ATR) ; Connor,\nColette ; Waitzman, Emma (ATR) ; Karr, Ryan\n(ATR) ; 'Jon Sallet' ; 'Weber, Jayme'\n; 'Sarah Mader' \nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel:\n\nPlease see the attached letter relating to the Parties\u2019 meet and confer on October 5, 2026.\n\nBest,\nGrant\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 6 of 15\n\n\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Fergusson, Grant (ATR)\nSent: Sunday, October 4, 2026 5:12 PM\nTo: 'Keung, Tiffany' ; Maddox, Claire (ATR) ; Connor,\nColette ; Waitzman, Emma (ATR) ; Karr, Ryan\n(ATR) ; 'Jon Sallet' ; 'Weber, Jayme'\n; 'Sarah Mader' \nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel,\n\nAs discussed during our September 30, 2026, meet and confer, Plaintiffs hereby attach:\n\n 1. An updated syndication license agreement template intended to address certain Google\n objections, and\n 2. A redline comparing Plaintiffs' updated syndication license agreement template with the\n original template provided on August 31, 2026.\n\nBest,\nGrant\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Keung, Tiffany \nSent: Tuesday, September 29, 2026 6:24 PM\nTo: Fergusson, Grant (ATR) ; Maddox, Claire (ATR)\n; Connor, Colette ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; 'Jon Sallet'\n; 'Weber, Jayme' ; 'Sarah Mader'\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 7 of 15\n\n\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel: please find attached the presentation from the meeting with Dave Graham, Matt\nKlainer, and Jesse Adkins earlier today.\n\nTiffany Keung\nAssociate | Williams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n202-434-5806 | tkeung@wc.com | www.wc.com\n\nFrom: Keung, Tiffany \nSent: Friday, September 25, 2026 12:36 PM\nTo: Fergusson, Grant (ATR) ; Maddox, Claire (ATR)\n; Connor, Colette ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; 'Jon Sallet'\n; 'Weber, Jayme' ; 'Sarah Mader'\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nThank you Grant. As Colette mentioned on our call, Jesse Adkins ( @google.com) will\nbe joining the Tuesday meeting as well\u2014can you please add him to the invitation? I am also\nattaching the presentation from our meeting with the TC this morning.\n\nThanks,\nTiffany Keung\nAssociate | Williams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n202-434-5806 | tkeung@wc.com | www.wc.com\n\nFrom: Fergusson, Grant (ATR) \nSent: Thursday, September 24, 2026 4:28 PM\nTo: Keung, Tiffany ; Maddox, Claire (ATR) ; Connor,\nColette ; Waitzman, Emma (ATR) ; Karr, Ryan\n(ATR) ; 'Jon Sallet' ; 'Weber, Jayme'\n; 'Sarah Mader' \nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nTiffany,\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 8 of 15\n\n\n\n\nMeeting invites will be circulated shortly to the individuals listed in your email from yesterday. If\nyou have trouble accessing the relevant meeting links, please let us know.\n\nThanks,\nGrant\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Keung, Tiffany \nSent: Thursday, September 24, 2026 3:58 PM\nTo: Maddox, Claire (ATR) ; Connor, Colette ;\nFergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; 'Jon Sallet'\n; 'Weber, Jayme' ; 'Sarah Mader'\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nClaire, please send the invitations for tomorrow\u2019s meetings when you\u2019re able, thanks.\n\nTiffany Keung\nAssociate | Williams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n202-434-5806 | tkeung@wc.com | www.wc.com\n\nFrom: Keung, Tiffany\nSent: Wednesday, September 23, 2026 7:02 PM\nTo: Maddox, Claire (ATR) ; Connor, Colette ;\nFergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; Jon Sallet\n; 'Weber, Jayme' ; Sarah Mader\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 9 of 15\n\n\n\n\nThank you Claire, please see below for the attendees and email addresses for the meetings:\n\nWSS/AFS Technical Topics \u2013 Friday 9/25, 11 AM-12 PM ET\nMatt Klainer - @google.com\nJesse Adkins - @google.com\nColette Connor - cconnor@wc.com\nTiffany Keung \u2013 tkeung@wc.com\nJack Mellyn - @google.com\n\nLocal/Maps \u2013 Friday 9/25, 1:30-2:30 PM ET\nYael Maguire - @google.com\nJesse Adkins - @google.com\nColette Connor - cconnor@wc.com\nTiffany Keung \u2013 tkeung@wc.com\nJack Mellyn - @google.com\n\nWSS/AFS Topics \u2013 Tuesday 9/29, 1:30-2:30 PM ET\nMatt Klainer - @google.com\nDave Graham - @google.com\nColette Connor - cconnor@wc.com\nTiffany Keung \u2013 tkeung@wc.com\nJack Mellyn - @google.com\n\nTiffany Keung\nAssociate | Williams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n202-434-5806 | tkeung@wc.com | www.wc.com\n\nFrom: Maddox, Claire (ATR) \nSent: Wednesday, September 23, 2026 5:09 PM\nTo: Connor, Colette ; Keung, Tiffany ; Fergusson, Grant\n(ATR) ; Waitzman, Emma (ATR) ; Karr,\nRyan (ATR) ; Jon Sallet ; 'Weber, Jayme'\n; Sarah Mader \nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\nThank you, Colette. The TC can do Tuesday, 1:30-2:30p ET, for the first set of AFS/WSS topics. We\nwill block these times on our calendars and send invites once we hear from you on attendees.\n\nClaire M. Maddox\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 10 of 15\n\n\n202.549.7155\nclaire.maddox@usdoj.gov\n\n\nFrom: Connor, Colette \nSent: Wednesday, September 23, 2026 4:31 PM\nTo: Maddox, Claire (ATR) ; Keung, Tiffany ;\nFergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; Jon Sallet\n; 'Weber, Jayme' ; Sarah Mader\n\nCc: Schmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nClaire,\n\nYes \u2013 we have been rounding schedules and I was just emailing you. Let\u2019s set 11-12 ET on\nFriday for the WSS/AFS Technical Topics call and 1:30 \u2013 2:30 ET on Friday for the\nLocal/Maps call. For third call (re: the first set of AFS/WSS topics listed in our letter), one of\nthe lead executives we want to connect the TC with is traveling on Thursday and Friday.\nGiven the TC is not available on Monday, we propose to set that call for Tuesday, and we\nare available 1:30-4:00 pm ET. Can you confirm that works for the TC?\n\nI\u2019ll circulate the names for invitations shortly but wanted to fire this off in the meantime for\nyour scheduling purposes.\n\nBest,\nColette\n\nColette Connor\nWilliams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n(P) 202-434-5170 | (F) 202-480-8236\ncconnor@wc.com | www.wc.com/cconnor\n\n\n\nFrom: Maddox, Claire (ATR) \nSent: Wednesday, September 23, 2026 4:07 PM\nTo: Keung, Tiffany ; Fergusson, Grant (ATR) ;\nWaitzman, Emma (ATR) ; Karr, Ryan (ATR) ;\nJon Sallet ; 'Weber, Jayme' ; Sarah Mader\n\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 11 of 15\n\n\nCc: Schmidtlein, John ; Connor, Colette ; Safty, Graham\n; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\nCounsel,\n\nFollowing up on my email below, please let us know which days/times work on your end and for\nwhich topics, so we know what times to lock in on our calendars and what times we can free up.\n\nThank you,\nClaire\n\nClaire M. Maddox\n202.549.7155\nclaire.maddox@usdoj.gov\n\n\nFrom: Maddox, Claire (ATR)\nSent: Tuesday, September 22, 2026 6:42 PM\nTo: 'Keung, Tiffany' ; Fergusson, Grant (ATR) ;\nWaitzman, Emma (ATR) ; Karr, Ryan (ATR) ;\nJon Sallet ; 'Weber, Jayme' ; Sarah Mader\n\nCc: Schmidtlein, John ; Connor, Colette ; Safty, Graham\n; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\nCounsel,\n\nThank you for your letter sent below this morning.\n\nAs noted in Grant\u2019s letter of September 15, Plaintiffs and the TC are amenable to having live\ndiscussions with Google employees to the extent Google seeks information that is necessary to\nexercise its right to object under the Final Judgment. Regarding the calls requested in your\nSeptember 22 letter, Plaintiffs and the TC are unable to do a call on Monday but are available as\nfollows:\n\n Thursday\u20141:30 - 3 PT / 4:30 - 6 ET\n\n Friday\u2014 8-9 AM PT / 11-12 ET or 10:30 - 1PM PT / 1:30 - 4:00 ET\n\nPlease confirm which days/times work on your end and for which topics, as well as the name of\nGoogle employees who will attend, and we can circulate invites.\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 12 of 15\n\n\n\nThank you,\nClaire\n\nClaire M. Maddox\n202.549.7155\nclaire.maddox@usdoj.gov\n\n\nFrom: Keung, Tiffany \nSent: Tuesday, September 22, 2026 9:02 AM\nTo: Maddox, Claire (ATR) ; Fergusson, Grant (ATR)\n; Waitzman, Emma (ATR) ; Karr, Ryan\n(ATR) ; Jon Sallet ; 'Weber, Jayme'\n; Sarah Mader \nCc: Schmidtlein, John ; Connor, Colette ; Safty, Graham\n; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel, please see the attached correspondence.\n\nTiffany Keung\nAssociate | Williams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n202-434-5806 | tkeung@wc.com | www.wc.com\n\n\nFrom: Fergusson, Grant (ATR) \nSent: Tuesday, September 15, 2026 2:58 PM\nTo: Connor, Colette ; Maddox, Claire (ATR) ;\nSchmidtlein, John ; Safty, Graham ; Greenblum,\nBenjamin ; Ryan, Thomas ; Clay, Jesse \nCc: Waitzman, Emma (ATR) ; Karr, Ryan (ATR)\n; Jon Sallet ; 'Weber, Jayme'\n; Sarah Mader \nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel,\n\nPlease see the attached responses and attachments, consistent with the Orders described\nbelow.\n\nBest,\nGrant\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 13 of 15\n\n\n\n\n---\nGrant M. Fergusson\nTrial Attorney, Antitrust Division\nU.S. Department of Justice\n450 Fifth Street, NW\nWashington, DC 20001\ngrant.fergusson@usdoj.gov\n\nFrom: Connor, Colette \nSent: Tuesday, September 8, 2026 3:04 PM\nTo: Maddox, Claire (ATR) ; Schmidtlein, John ;\nSafty, Graham ; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nCc: Fergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; Jon Sallet\n; 'Weber, Jayme' ; Sarah Mader\n\nSubject: [EXTERNAL] RE: US v Google -- Template Search and Search Text Ads Syndication License\n\n\nCounsel, with apologies, here is the accompanying Attachment A.\n\nBest,\nColette\n\nColette Connor\nWilliams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n(P) 202-434-5170 | (F) 202-480-8236\ncconnor@wc.com | www.wc.com/cconnor\n\n\n\nFrom: Connor, Colette\nSent: Tuesday, September 8, 2026 3:01 PM\nTo: 'Maddox, Claire (ATR)' ; Schmidtlein, John ;\nSafty, Graham ; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nCc: Fergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; Jon Sallet\n; 'Weber, Jayme' ; Sarah Mader\n\nSubject: RE: US v Google -- Template Search and Search Text Ads Syndication License\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 14 of 15\n\n\nCounsel,\n\nPlease see the attached in response, consistent with the Orders you identify. We will send\nto the TC email address now as well.\n\nBest,\nColette\n\nColette Connor\nWilliams & Connolly LLP\n680 Maine Avenue, S.W., Washington, DC 20024\n(P) 202-434-5170 | (F) 202-480-8236\ncconnor@wc.com | www.wc.com/cconnor\n\n\n\nFrom: Maddox, Claire (ATR) \nSent: Monday, August 31, 2026 2:58 PM\nTo: Schmidtlein, John ; Safty, Graham ; Connor, Colette\n; Greenblum, Benjamin ; Ryan, Thomas\n; Clay, Jesse \nCc: Fergusson, Grant (ATR) ; Waitzman, Emma (ATR)\n; Karr, Ryan (ATR) ; Jon Sallet\n; 'Weber, Jayme' ; Sarah Mader\n\nSubject: US v Google -- Template Search and Search Text Ads Syndication License\n\nCounsel,\n\nPursuant to Sections V and VI.B of the Final Judgment, as well as to the terms adopted by the Court\nfor Recommendations as set forth in Appendix A to the Parties\u2019 Joint Status Report filed on May 20,\n2026, ECF Nos. 1520-1, 1521, and to the order of operations and timing for Category 2\nRecommendations, ECF Nos. 1528-2, 1529, Plaintiffs together with the TC hereby submit this\nRecommendation and Template Search and Search Text Ads Syndication License.\n\nSpecifically, attached are:\n Syndication Cover Recommendation and Basis - Counsel-Only Copy\n Syndication Cover Recommendation and Basis - Employee Copy\n Syndication License Agreement Template with accompanying Exhibit A-C (both in Word and\n PDF)\n Three documents referenced in the Recommendation:\n USDOJ-GOOG-FJ-000001\n USDOJ-GOOG-FJ-000008\n\f Case 1:20-cv-03010-APM Document 1567-5 Filed 10/23/26 Page 15 of 15\n\n\n USDOJ-GOOG-FJ-000020\n\nRegards,\nClaire\n\nClaire M. Maddox\nTrial Attorney\nTechnology and Digital Platforms Section\nAntitrust Division | U.S. Department of Justice\n450 5th St NW, Washington, D.C. 20530\n202.549.7155 | claire.maddox@usdoj.gov\n\n\n\n\nThis message and any attachments are intended only for the addressee and may contain information that is\nprivileged and confidential. If you have received this message in error, please do not read, use, copy, distribute, or\ndisclose the contents of the message and any attachments. Instead, please delete the message and any attachments\nand notify the sender immediately. Thank you.\n\f","ocr_status":2,"date_upload":"2026-10-23T19:16:11.313972-07:00","document_number":"1567","attachment_number":5,"pacer_doc_id":"045012431085","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487567/","id":498487567,"tags":[],"absolute_url":"/docket/18552824/1567/6/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.283424-07:00","date_modified":"2026-10-26T18:01:01.848083-07:00","sha1":"6bf9ec4358c555c1d77cfacab361dac98fdfd091","page_count":48,"file_size":5650250,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.6.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.6.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487567.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 1 of 48\n\nExhibit 6\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 2 of 48\n\n[TEMPLATE] QUALIFIED COMPETITOR SYNDICATION LICENSE AGREEMENT\n\nThis Qualified Competitor Syndication License Agreement (\u201cAgreement\u201d) is entered\nintothis _dayof__, [2026] by and between (\u201cSignatory\u201d) and Google\nLLC (\u201cGoogle\u201d) (collectively, \u201cParties\u201d). The effective date of this Agreement shall be the date\non which Signatory executes this Agreement (the \u201cEffective Date\u2019).\n\nRECITALS\n\nA. WHEREAS, the United States District Court for the District of Columbia (the \u201cCourt\u2019\u2019),\nJudge Amit P. Mehta, has entered a Final Judgment (ECF No. 1462, \u201cFinal Judgment\u201d) in\nUnited States of America et al. v. Google LLC (Civil Action No. 20-3010 (APM)) and State of\nColorado et al. v. Google LLC (Civil Action No. 20-3715 (APM)) (collectively, \u201cUnderlying\nConsolidated Cases\u201d), which, among other things, requires Defendant Google to take or refrain\nfrom taking certain actions and further provides for the appointment of five members of a\nTechnical Committee (\u201c\u201cTC\u2019\u2019) to assist the Plaintiffs in the Underlying Consolidated Cases\n(collectively, \u201cPlaintiffs\u201d) in the enforcement of Google\u2019s compliance with the Final Judgment;\n\nB. WHEREAS, Section IX.V of the Final Judgment provides for the certification of\nQualified Competitors, as defined below;\n\nC. WHEREAS, Signatory has been certified as a Qualified Competitor pursuant to Section\nIX.V of the Final Judgment for the period [CERTIFICATION EFFECTIVE DATE] through\n[CERTIFICATION EXPIRATION DATE], subject to periodic recertification;\n\nD. WHEREAS, Sections V.A\u2014B of the Final Judgment require that Google shall make\navailable to Qualified Competitors certain information and data related to its web and mobile\nsearch services via syndication through real-time APIs and subject to a license governing the\nterms of syndication;\n\nE. WHEREAS, Section VI.B of the Final Judgment requires that Google shall make\navailable to Qualified Competitors its syndication services for Search Text Ads\u2014as defined in\nthe Final Judgment\u2014subject to a license governing the terms of syndication; and\n\nF. WHEREAS, the Parties to this Qualified Competitor Syndication License Agreement\nintend to be legally bound.\n\nNOW, THEREFORE, in consideration of the mutual promises contained herein and pursuant to\nthe Court\u2019s Final Judgment, the sufficiency of which is hereby acknowledged, the Parties agree\nas follows:\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 3 of 48\n\nAGREEMENT\n1. Definitions. As used in this Agreement, the following terms shall have the following\nmeanings:\n1.1. \u201cAd Revenues\u201d means, for any period during the Agreement Term, revenues\n\ngenerated in connection with the use of any Search Text Advertising Service(s) by Signatory or\nits Affiliate(s) which are attributed to Search Text Ads provided through such Search Text\nAdvertising Service(s) in that period. Notwithstanding the foregoing, if advertisers buy Search\nText Ads at a fixed or aggregated price, then Ad Revenues for those Search Text Ads will be\ncalculated as if such advertisers had paid the final price for the provision of the Search Text Ad\nin accordance with the definition above.\n\n1.2. \u201cAffiliate\u201d means any entity, other than Signatory, that has been expressly\nincluded within the scope of Signatory\u2019s certification or recertification as a Qualified Competitor\npursuant to Section IX.V of the Final Judgment; provided, however, that the Parties to this\nAgreement will include or exclude any entity from the scope of this definition if the TC so\ninstructs after receiving Signatory\u2019s change of control notice under Section 15.\n\n1.3. \u201cClient Application\u201d means any application, plug-in, helper, Search Access\nPoint, component, or other executable code that runs on an End User\u2019s desktop computer, mobile\ndevice, or other device incorporating a Search Access Point (or any subsequent version of such\napplication) listed in Exhibit A of this Agreement.\n\n1.4. \u201cCovered Query\u201d means a Query that originated from an End User in the United\nStates and was submitted through a Site or Client Application.\n\n1.5. \u201cDisclosed Remedies Information\u201d means any information or data listed in\nExhibit B or provided pursuant to a Service listed in Exhibit B that must be provided to\nSignatory and its Affiliate(s) by Google pursuant to this Agreement, and over which Signatory or\nits Affiliate(s) have possession, custody, or control.\n\n1.6. \u201cEnd User\u201d means an individual human end user whom Signatory or its\nAffiliate(s) (as appropriate) permit to use the Services, a Site, or a Client Application.\n\n1.7. \u201cGenAI Product\u201d shall have the meaning assigned to it in Section IX.J of the\nFinal Judgment.\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 4 of 48\n\n1.8. \u201cGoogle Program Guidelines\u201d means the policy and implementation guidelines\napplicable to the Services and as located at the following URL(s):\n(or any different URL(s) or additional\nURL(s) Google may provide to Signatory and its Affiliate(s) from time to time, provided that\nGoogly also notify Plaintiffs and TC of any different URL(s) or additional URL(s) under this\ndefinition prior to providing such URL(s) to Signatory or its Affiliate(s)).\n\n1.9. \u201cInclude\u201d and \u201cincluding\u201d shall be read as \u201cincluding but not limited to,\u201d and\nany use of either word is not limited in any way to any examples provided.\n\n1.10. \u201cQualified Competitor\u201d shall have the meaning assigned to it in Section IX.V of\nthe Final Judgment.\n\n1.11. \u201cQuery\u201d means a text query or prompt entered and submitted by an End User\n(whether by typing or voice input) into a Search Access Point on any Site, Client Application,\nSyndicated Site, or Syndicated Application, including, without limitation, a browser address bar\nthat is configured with a Site as its default search engine (so long as such configuration is in\ncompliance with this Agreement).\n\n1.12. \u201cRequest\u201d means a request originating from Signatory, an Affiliate of Signatory,\nor an End User (as applicable) and sent to Google for a Search Results Set and/or a Search Text\nAd Set (as applicable) under any Service(s) described in Exhibit B.\n\n1.13. \u201cSearch Access Point\u201d shall have the meaning assigned to it in Section IX.W of\nthe Final Judgment.\n\n1.14. \u201cSearch Feature\u201d shall have the meaning assigned to it in Section IX.X of the\nFinal Judgment.\n\n1.15. \u201cSearch Result\u201d means an individual search result provided by Google through\nany Search Service(s) described in Exhibit B in response to a Query or Request.\n\n1.16. \u201cSearch Results Set\u201d means a set of one or more Search Results.\n1.17. \u201cSearch Service(s)\u201d means the information, data, and Search Features that\nGoogle must make available to Qualified Competitors via syndication through real-time API(s)\n\nunder Section V.A of the Final Judgment, as further described in Exhibit B.\n\n1.18. \u201cSearch Text Ad\u201d shall have the meaning assigned to it in Section IX.Y of the\nFinal Judgment.\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 5 of 48\n\n1.19. \u201cSearch Text Ad Platform\u201d means any product, service, or platform that\ndisplays, serves, issues, syndicates, or otherwise provides Search Text Ads.\n\n1.20. \u201cSearch Text Ad Set\u201d means a set of one or more Search Text Ads provided\nthrough any Search Text Advertising Service described in Exhibit B.\n\n1.21. \u201cSearch Text Advertising Service(s)\u201d means the Search Text Ads syndication\nand related services, including any assets, extensions, or similar Search Text Ad variations, that\nGoogle must make available to Qualified Competitors under Section VI.B of the Final Judgment,\nas further described in Exhibit B.\n\n1.22. \u201cSERP\u201d or \u201cSearch Engine Results Page\u201d shall have the meaning assigned to it\nin Section IX.Z of the Final Judgment.\n\n1.23. \u201cService(s)\u201d means the Search Service(s) and/or Search Text Advertising\nService(s) (as applicable) that Google shall provide to Signatory and its Affiliate(s) under this\nAgreement, as further described in Exhibit B.\n\n1.24. \u201cSite(s)\u201d means the website(s) located at the URL(s) listed in Exhibit A of this\nAgreement, together with any additional URL(s) added under Exhibit A Section 3 (which shall\nbe deemed to be included in Exhibit A as of such addition).\n\n1.25. \u201cSubsyndicate\u201d means any entity besides Google, Signatory, or an Affiliate of\nSignatory that owns or operates any website, application, plug-in, helper, Search Access Point,\ncomponent, or other executable code that runs on an End User\u2019s desktop computer, mobile\ndevice, or other device incorporating a Search Access Point (or any subsequent version of such\napplication). For clarity, any sub-syndication provided to Subsyndicate under this Agreement\nwill be limited to the Subsyndicate\u2019s Syndicated Site(s) and Syndicated Application(s).\n\n1.26. \u201cSuspend\u201d or \u201csuspension\u201d means disabling or limiting access to or use of the\nServices or components of the Services.\n\n1.27. \u201cSyndicated Site(s)\u201d means any website(s) not owned or operated by Signatory\nor its Affiliate(s) for which Signatory or its Affiliate(s) may provide sub-syndication under this\nAgreement, as listed in Exhibit A. For the avoidance of doubt, Sites and Client Applications are\nnot Syndicated Sites.\n\n1.28. \u201cSyndicated Application(s)\u201d means any application, plug-in, helper, component,\nor other executable code that runs on an End User\u2019s desktop computer or mobile device (or any\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 6 of 48\n\nsubsequent version of such application) that is not owned or operated by Signatory or its\nAffiliate(s), but for which Signatory or its Affiliate(s) may provide sub-syndication under this\nAgreement, as listed in Exhibit A. For the avoidance of doubt, Sites and Client Applications are\nnot Syndicated Applications.\n\n1.29. \u201cTC Members\u201d means the members of the TC who have been appointed to the\nTC by the Court pursuant to Sections VI.A.1\u20143 of the Final Judgment.\n\n1.30. \u201cURL\u201d means a uniform resource locator address to a site on the internet.\n\n2. Agreement Term. The term of this Agreement is five (5) years, starting on the Effective\nDate, unless terminated earlier in accordance with the terms of this License or extended by Court\norder (\u201cAgreement Term\u2019).\n\n3. Syndication to be Provided, Schedule, and Method. Exhibit B describes the Search\nService(s) and/or Search Text Advertising Service(s) that Google shall provide to Signatory and\nits Affiliate(s) under this Agreement, as well as the method, means, and financial terms by which\n\nGoogle shall provide these Services. For the avoidance of doubt, any Search Service(s) made\navailable to Signatory under this Agreement must provide, via real-time API(s), the information\nand data described in Section V.A of the Final Judgment.\n\n4. Search Services Launch, Implementation, and Maintenance. For any Search Service(s)\nthat Google shall provide to Signatory and its Affiliate(s) under this Agreement, the Parties agree\n\nas follows:\n\n4.1. Launch. The Parties to this Agreement will launch the Search Service(s) into live\nuse within thirty (30) days from the Effective Date. Google shall provide all Search Service(s) to\nSignatory and its Affiliate(s) for implementation across all Sites and Client Applications, and\nSignatory\u2019s payment obligations for such implementations described in Exhibit B shall not run\nuntil all such Search Service(s) have been implemented across all such Sites and Client\nApplications. Signatory and its Affiliate(s) will not launch, use, or implement any Search\nService(s) provided under this Agreement anywhere other than on a Site or Client Application.\n\n4.2. Implementation.\n\na. Choice of Requests to Syndicate. Except as otherwise stated in Sections\n\n4.6 and 4.7, Signatory may elect, in its sole discretion, the Queries for which it will issue\nRequests to Google for Search Results or Search Results Sets under this Agreement.\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 7 of 48\n\nb. Latency: Reliability. Google will provide the Search Service(s) to\nSignatory and its Affiliates on a non-discriminatory basis, with required latency and reliability\naccording to the terms set forth in Exhibit C; provided, however, that Google\u2019s obligations under\n\nthis Section 4.2.b do not extend to variations in Search Service latency and reliability that result\nfrom differences in Service implementation, users, or other such factors outside of Google\u2019s\ncontrol.\n\nc. Required Information Disclosures. Signatory and its Affiliate(s) may\ndetermine, in their sole discretion, what and how much information to share with Google\nregarding their End Users when using any Search Service(s); provided, however, that Google\nmay impose certain disclosure requirements, as set forth in Exhibit C, only as necessary for the\npurposes of ensuring basic functionality of any Search Service(s), detecting spam and abuse, or\nas otherwise required for legal or regulatory compliance. For avoidance of doubt, nothing in this\nSection 4.2.c is intended to limit the availability or implementation of the ii\na. Non-Personalized Ads described in Exhibit B Section 3.\n\n4.3. Search Service Maintenance.\n\na. For the remainder of the Agreement Term, Google will make available and\nSignatory and its Affiliate(s) (as appropriate) will implement and maintain each of the Search\nServices on each of the applicable Sites and Client Applications in Exhibit A. For clarity,\nSignatory and its Affiliate(s) may not implement the Services on a property that is not a Site or\nClient Application. For technical support from Google, Signatory and its Affiliate(s) may contact\nGoogle or such URL as Google\nmay provide to Signatory from time to time, provided that Google notifies Plaintiffs and the TC\nin parallel of any alternative URL provided under this Section 4.3.a.\n\nb. Signatory will ensure that, with respect to every Site and Client\nApplication, Signatory or its Affiliate(s) (as appropriate):\n\n1. is the technical and editorial decision maker in relation to each\npage, including SERPs and each Client Application on which the Search Services are\nimplemented; and\n\nil. has control over the way in which the Search Services are\nimplemented on each of those SERPs and Client Applications.\n\nc. Signatory will ensure that the Search Services are implemented and\nmaintained by Signatory and its Affiliate(s) in accordance with the applicable Google Program\nGuidelines, Google technical protocols (if any), and any other technical requirements Google\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 8 of 48\n\nmay require; provided, however, that Google shall not impose any requirements under the\nGoogle Program Guidelines, Google technical protocols, or any other technical requirements\nexcept as permitted under Section VI.B.11 of the Final Judgment. In the event of a conflict\nbetween the Google Program Guidelines or Google technical protocols and the terms of this\nAgreement, the terms of this Agreement will control.\n\nd. Signatory will ensure that, at all times during the Agreement Term,\nSignatory and its Affiliate(s):\n\n1. Have a clearly labeled and easily accessible privacy policy in place\nrelating to the Site(s) and Approved Client Application(s); and\n\nil. Provide the End User with clear and comprehensive information\nabout cookies and other information stored or accessed on the End User\u2019s device in connection\nwith the Search Services, including information about End Users\u2019 options for cookie\nmanagement.\n\ne. Signatory and its Affiliate(s) (as appropriate) will use commercially\nreasonable efforts to ensure that an End User gives consent to the storing and accessing of\ncookies and other information on the End User\u2019s device in connection with the Search Services\nwhere such consent is required by law.\n\n44. Display and Use Restrictions.\n\na. Restrictions Generally. Except as otherwise set forth in Exhibit C, Google\nwill not impose any restrictions or conditions on how Signatory or its Affiliate(s) use, display, or\notherwise integrate the Search Service(s), including any information or data made available\nunder such Services. For clarity, except as set forth in Exhibit C, Signatory and its Affiliate(s)\nmay elect, in their sole discretion, which Search Service components, assets, information, and\ndata to display or use in their own products or services, and they may do so in any manner they\nchoose, including, without limitation, reordering Search Results or Search Service components,\nassets, information, or data.\n\nb. Display and Use in GenAI Products. Notwithstanding Section 4.4.a,\nSignatory and its Affiliate(s) may use the Search Services to ground their responses to Covered\nQueries issued to GenAI Products owned and operated by Signatory or its Affiliate(s).\n\nCc. GenAI Product Training Prohibited. Notwithstanding Section 4.4.b,\nSignatory and its Affiliate(s) shall not use syndicated Search Results to (1) pre-train, train, fine-\ntune, or otherwise develop the weights of any large language model or other machine learning\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 9 of 48\n\nmodel such that syndicated content becomes permanently embedded in model parameters\n(\u201cLLM Training\u201d), or (11) conduct bulk re-indexing or re-syndication of Search Results as a\nsubstitute for independent web crawling or web index development. For avoidance of doubt,\nsingle-use retrieval and incorporation of Search Results into a specific response generated by a\nGenAI Product owned and operated by Signatory or its Affiliate(s) in response to a Covered\nQuery or other actions permitted in Exhibit C Section 2.3 will not constitute LLM Training and\nare permitted under this Agreement.\n\n4.5. Crawling Restrictions. Pursuant to terms set forth in Exhibit C and except as\notherwise stated in Section 4.4 and Exhibit C Section 2.3, Google may, at its discretion, place\nordinary commercial restrictions on the ability of Signatory and its Affiliate(s) to scrape, index,\nor crawl any Search Results, Search Results Sets, or other information or data made available as\npart of the Search Service(s).\n\n4.6. No Sub-Syndication. Signatory and its Affiliate(s) will not sell, license, or\notherwise make available to any Subsyndicate any Search Service(s) provided by Google under\nthis Agreement. For clarity, no Affiliate of Signatory will be deemed to be a Subsyndicate under\n\nthis Agreement.\n\n4.7. Covered Queries. Google shall only be required to provide Search Services in\n\nresponse to Request(s) sent in response to a Covered Query except as otherwise provided herein.\n\n4.8. Signatory Monitoring and Audit Obligations: Tapering Schedule.\n\na. Monitoring Obligations. For the Agreement Term, Signatory agrees to\nmonitor the frequency and scope of Requests issued by Signatory or its Affiliate(s) to Google for\nSearch Results or Search Results Sets under this Agreement, including (a) the number of total\nannual Covered Queries, and (b) the number of such Covered Queries for which Signatory or its\nAffiliate(s) issues a Request or Requests to Google for Search Results or Search Results Sets\nunder this Agreement. On reasonable written notice from the TC pursuant to Section 4.8.b below,\nSignatory and its Affiliate(s) (as appropriate) will permit the TC to access any information or\ndata collected or monitored under this Section 4.8.a and to independently track, monitor, assess,\nor evaluate the frequency and scope of Requests issued by Signatory or its Affiliate(s) to Google\nunder this Agreement. For avoidance of doubt, nothing in this Section 4.8.a is intended to limit or\nsupersede the information sharing obligations set forth in Section 6.5.\n\nb. Audit Obligations. For the Agreement Term, Signatory and its Affiliate(s)\n\n(as appropriate) agree to undergo periodic audits by the TC of the frequency and scope of\nRequests described in Section 4.8.a, which may include audits of, without limitation, the\nfrequency and volume of Requests submitted to Google, the total annual Covered Queries\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 10 of 48\n\nreceived by Signatory and its Affiliate(s), and the percentage of Requests for Search Results or\nSearch Results Sets sent to Google in response to Covered Queries. On reasonable written notice\nfrom the TC, Signatory, its Affiliate(s) (as appropriate), and Google will promptly comply with\nany and all requests made by the TC in relation to such audits, including requests for documents,\ndata, information, or interviews.\n\nc. Tapering Schedule. For a one (1)-year term beginning on the Effective\nDate, Signatory and its Affiliate(s) will only issue Requests to Google for Search Results or\nSearch Results Sets under this Section 4 in response to a maximum of forty percent (40%) of\n\ntotal annual Covered Queries (\u201cInitial Tapering Rate\u2019). For the remainder of the Agreement\nTerm, Signatory and Google agree that the scope and frequency of Requests that Signatory and\nits Affiliate(s) may issue to Google under this Section 4 will be set according to a schedule to be\ndetermined by the Court, Plaintiffs, and the TC in the Underlying Consolidated Cases pursuant to\nSection V.B.4 of the Final Judgment (\u201cTapering Schedule\u201d); provided, however, that if such\nTapering Schedule has not been determined by the end of the one (1)-year term beginning on the\nEffective Date, Signatory and its Affiliate(s) may continue to issue Requests to Google under this\nSection 4 in response to a maximum of forty percent (40%) of total annual Covered Queries until\nsuch Tapering Schedule is in place or as otherwise ordered by the Court.\n\nd. Incorporation of Tapering Schedule. The Parties to this Agreement agree\nto incorporate by reference the Tapering Schedule in its entirety. Within five (5) business days of\nthe date on which the Tapering Schedule is approved by the Court in the Underlying\nConsolidated Cases, Google shall deliver a copy of such Tapering Schedule to Signatory\naccording to the notice procedures set forth in Section 25. Upon receipt by Signatory, the\nTapering Schedule shall automatically become a binding part of this Agreement as :f fully set\nforth herein. For clarity, in the event of a conflict between the terms of this Agreement and the\nTapering Schedule, once incorporated, the terms of the Tapering Schedule will control.\n\n5. Search Text Advertising Services Launch, Implementation, and Maintenance. For any\nSearch Text Advertising Service(s) that Google shall provide to Signatory and its Affiliate(s)\nunder this Agreement, the parties agree as follows:\n\n5.1. Launch. The parties to this Agreement will launch the Search Text Advertising\nService(s) into live use within thirty (30) days from the Effective Date. Google shall provide all\nSearch Text Advertising Service(s) to Signatory and its Affiliate(s) for implementation across all\nSites and Client Applications, and Signatory\u2019s payment obligations for such implementations\ndescribed in Exhibit B shall not run until all such Search Text Advertising Service(s) have been\nimplemented across all such Sites and Client Applications. Signatory and its Affiliate(s) will not\nlaunch, use, or implement any Search Text Advertising Service(s) provided under this Agreement\nanywhere other than on a Site or Client Application.\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 11 of 48\n\n5.2. Implementation.\n\na. Choice of Requests to Syndicate. Except as otherwise stated in Sections\n5.7 and 5.8, Signatory and its Affiliate(s) may elect, in their sole discretion, which Requests to\nissue to Google for Search Text Ads or Search Text Ad Sets under this Agreement.\n\nb. Latency: Reliability: Performance. Google will provide the Search Text\nAdvertising Service(s) to Signatory and its Affiliate(s) on a non-discriminatory basis, with\nrequired latency, reliability, and performance according to the terms set forth in Exhibit C;\nprovided, however, that Google\u2019s obligations under this Section 5.2.b do not extend to variations\nin Search Text Advertising Service latency, reliability, or performance that result from\ndifferences in Service implementation, users, or other such factors outside of Google\u2019s control.\n\nCc. Required Information Disclosures. Except as set forth in Exhibit C,\nSignatory and its Affiliate(s) may determine, in their sole discretion, what and how much\n\ninformation to share with Google regarding their End Users when using any Search Text\nAdvertising Service(s), including what information about an End User to provide when\nsubmitting a Request to Google for Search Text Ads or Search Text Ad Sets. For avoidance of\ndoubt, nothing in this Section 5.2.c is intended to limit the availability or implementation of the\n\nee or Non-Personalized Ads described in Exhibit B Section 3.\n\n5.3. Search Text Advertising Service Maintenance.\n\na. For the remainder of the Agreement Term, Google will make available and\nSignatory and its Affiliate(s) (as appropriate) will implement and maintain each of the Search\nText Advertising Services on each of the applicable Sites and Client Applications in Exhibit A.\nFor clarity, Signatory and its Affiliate(s) may not implement the Search Text Advertising\nServices on a property that is not a Site or Client Application. For technical support from Google,\nSignatory and its Affiliate(s) may contact Google at\n\n(or such URL as Google may may\n\nprovide to Signatory from time to time, provided that Google notifies Plaintiffs and TC in\nparallel of any alternative URL provided under this Section 5.3.a).\n\nb. Signatory will ensure that, with respect to every Site and Client\nApplication, Signatory or its Affiliate(s) (as appropriate):\n\n1. is the technical and editorial decision maker in relation to each\n\npage, including SERPs and each Client Application on which the Search Text Advertising\nServices are implemented; and\n\n10\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 12 of 48\n\nil. has control over the way in which the Search Text Advertising\nServices are unplemented on each of those SERPs and Client Applications.\n\nc. Signatory will ensure that the Search Text Advertising Services are\nimplemented and maintained by Signatory and its Affiliate(s) in accordance with the applicable\nGoogle Program Guidelines, Google technical protocols (if any), and any other technical\nrequirements Google may require; provided, however, that Google shall not impose any\nrequirements under the Google Program Guidelines, Google technical protocols, or any other\ntechnical requirements except as permitted under Section VI.B.11 of the Final Judgment. In the\nevent of a conflict between the Google Program Guidelines or Google technical protocols and\nthe terms of this Agreement, the terms of this Agreement will control.\n\nd. Signatory will ensure that, at all tumes during the Agreement Term,\nSignatory and its A ffiliate(s):\n\n1. Have a clearly labeled and easily accessible privacy policy in place\nrelating to the Site(s) and Approved Client Application(s); and\n\nil. Provide the End User with clear and comprehensive information\nabout cookies and other information stored or accessed on the End User\u2019s device in connection\nwith the Search Text Advertising Services, including information about End Users\u2019 options for\ncookie management.\n\ne. Signatory and its Affiliate(s) (as appropriate) will use commercially\nreasonable efforts to ensure that an End User gives consent to the storing and accessing of\ncookies and other information on the End User\u2019s device in connection with the Search Text\nAdvertising Services where such consent is required by law.\n\n5.4. Display and Use Restrictions. Except as set forth in Section 5.7 and Exhibit C,\nSignatory and its Affiliate(s) may only use Search Text Ads and related information provided as\npart of the Search Text Advertising Service(s) for the purpose of displaying Search Text Ads or\nSearch Text Ad Sets to an End User in response to a Query; provided, however, that Google will\nnot impose any restrictions or conditions on how Signatory or its Affiliate(s) use, display, format,\nor otherwise integrate the Search Text Advertising Service(s), including any Search Text Ads\nmade available under such Services, except as set forth in Exhibit C.\n\n5.5. Crawling Restrictions. Pursuant to terms set forth in Exhibit C and except as\notherwise stated in Section 4.4 and Exhibit C Section 2.3, Google may, at its discretion, restrict\n\n11\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 13 of 48\n\nthe ability of Signatory and its Affiliate(s) to scrape, index, or crawl any Search Text Ads or\nSearch Text Ad Sets made available as part of the Search Text Advertising Service(s).\n\n5.6. No Preferential Placement. Google will not require, as a condition of providing\n\nany Service(s) or otherwise, that Signatory provide any preferential placement or similar\ntreatment to any Search Text Ad or Search Text Ad Set made available under this Agreement as\ncompared to Search Text Ads or Search Text Ad Sets provided by Signatory, its Affiliate(s), or\nany third party.\n\n5.7. Sub-Syndication. Signatory and its Affiliate(s) may not sell, license, or otherwise\nmake available any Search Text Advertising Service(s) provided by Google under this\nAgreement to any Subsyndicate unless and until Signatory has been specifically certified as a\nQualified Competitor to a Google Search Text Ad Platform under the Final Judgment. The\nparties will launch any such sub-syndication into live use according the same procedures set\nforth in Section 5.1; provided, however, that if Signatory is certified as a Qualified Competitor to\na Google Search Text Ad Platform after the Effective Date, the time period for launching any\nsub-syndication into live use will run from the date on which Google receives notice of\n\nSignatory\u2019s certification as a Qualified Competitor to a Google Search Text Ad Platform. For\nclarity, no Affiliate of Signatory will be deemed to be a Subsyndicate under this Agreement.\n\n5.8. | Covered Queries. Google shall only be required to provide Search Text\nAdvertising Services in response to Requests sent in response to a Covered Query except as\notherwise provided herein.\n\n5.9. Advertiser Availability. As of the Effective Date and continuing for the Agreement\nTerm, Google will make the purchase of Search Text Ads syndicated under this Agreement\navailable to advertisers on a non-discriminatory basis comparable to, and no more burdensome\nthan, the availability of any other Google Search Text Ad, including, without limitation, Google\nSearch Text Ads incorporated into AI Overviews and GenAI Products. For avoidance of doubt,\nGoogle shall not take any action during the Agreement Term that is intended to decrease the\navailability of Search Text Ads syndicated under this Agreement to advertisers compared to the\navailability of any other Google Search Text Ad, including opting advertisers out of the Search\nText Advertising Services by default.\n\n5.10. Search Partner Network. As of the Effective Date and continuing for the\nAgreement Term, Google will promptly include Signatory and any Affiliate of Signatory (as\nappropriate) in Google\u2019s Search Partner Network. Google shall not condition the inclusion of\n\nSignatory or any Affiliate of Signatory (as appropriate) in Google\u2019s Search Partner Network on\nany prior, contemporaneous, or future payments, promises, or other such consideration or terms\nbeyond those included in this Agreement.\n\n12\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 14 of 48\n\n6. Additional Provisions.\n\n6.1. No Exclusivity. The Parties to this Agreement acknowledge that this Agreement is\nnon-exclusive and that either Party and its Affiliate(s) will be free, during and after the Agreement\nTerm, to engage or contract with third parties for the provision of services similar to the Services.\n\n6.2. Competitive Products and Services Permitted. Except as set forth in Section 4,\nSection 5, and Exhibit C, nothing in this Agreement shall be interpreted to prevent, preclude, or\notherwise restrict Signatory or its Affiliates from developing, distributing, marketing, displaying,\nusing, licensing, or selling a product or service that competes with any Services. For clarity,\nSignatory and/or its Affiliates shall be free to use and/or display their own Search Results, Search\nResult Sets, Search Text Ads, and Search Text Ad Sets, or those of a third party, without\nlimitation, throughout the Agreement Term.\n\n6.3. Multiple Requests per Covered Query Permitted. Except as set forth in Exhibit C,\nSignatory, an Affiliate of Signatory, or an End User (as applicable) may send multiple Requests to\n\nGoogle for any given Covered Query for the purposes of Covered Query refinement, correction,\nor progressive Search Result or Search Text Ad enhancement.\n\n6.4. Search Text Ads Auction Change Notice. For any public disclosure of a Search\nText Ads auction change that Google makes under Section VI.A of the Final Judgment in the\nUnderlying Consolidated Cases, Google shall, within five (5) business days of the date on which\nsuch disclosure is made, deliver a copy of such disclosure to Signatory.\n\n6.5. Service Information Logs. Throughout the Agreement Term, Signatory will\nmaintain and log information relevant to the use and implementation of Services by Signatory and\nits Affiliate(s) in a reasonably accessible format (\u201cService Information Logs\u201d), which Signatory\nwill provide to the TC at least monthly following the launch of the Service(s) under this\nAgreement. These Service Information Logs must include, at minimum, (a) measurements of\nService availability and latency (including measurements collected pursuant to Exhibit C Sections\n2.1 and 3.1; (b) logs of Requests sent to Google and Search Results and/or Search Text Ads\nreceived in response (including, if applicable, Publisher IDs, Client IDs, Channel IDs, event-level\nRequest IDs, and any response or error code(s) received); and (c) measurements of the Service(s)\nperformance (including, if applicable, network traffic logs, cost-per-click, number of clicks, and\nconversion metrics). Notwithstanding the foregoing, in the event Signatory receives a request\nfrom Plaintiffs or the TC to provide information not included within its Service Information Logs,\nSignatory will use commercially reasonable efforts to promptly provide such information to\nPlaintiffs and the TC.\n\n13\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 15 of 48\n\n7. Retention of Information and Data by Google.\n\n7.1. Retention for Search Services. Except as set forth in Exhibit C, Google may not,\n\nin any way, retain or use for its own products and/or services any Queries, Requests, or other\ninformation it obtains from Signatory or Signatory\u2019s Affiliate(s) in connection with the Search\nService(s). For clarity, nothing in this Section 7.1 shall be interpreted to limit the provision of any\nSearch Service(s) to Signatory or its Affiliate(s) as otherwise set forth herein.\n\n7.2. Retention for Search Text Advertising Services. Google may only retain or use\n\ndata collected from Signatory or its Affiliate(s) in connection with the Search Text Advertising\nService(s) for the purpose of building, improving, and maintaining its Search Text Ad\ninfrastructure and shared ad systems, as further set forth in Exhibit C. For clarity, nothing in this\nSection 7.2 shall be interpreted to limit the provision of any Search Text Advertising Service(s) to\nSignatory or its Affiliate(s) as otherwise set forth herein.\n\n8. Effect of Requests by Plaintiffs, TC Members, or Court Upon Google. Google shall\npromptly stop providing the Service(s) (as applicable) to Signatory and its Affiliate(s) upon a\nrequest from the Plaintiffs, TC Members, or the Court. Google shall, within ten (10) business\ndays, resume providing the Service(s) upon a request from the Plaintiffs, TC Members, or the\nCourt to resume providing such Services.\n\n9. Effect of Requests by Plaintiffs, TC Members, or Court Upon Signatory. Signatory shall\nuse best efforts to return or destroy Disclosed Remedies Information within fifteen (15) business\n\ndays as directed by the Plaintiffs, TC Members, or the Court upon request.\n\n10. Incorporation of Final Judgment. The Parties to this Agreement agree to incorporate by\nreference the Final Judgment in its entirety. If the Final Judgment is modified, amended, or\notherwise altered by the Court or as a result of any appeal of the Underlying Consolidated Cases,\nGoogle shall, within five (5) business days of the date on which such modification, amendment,\nor other alteration occurs, deliver a copy of such modified, amended, or altered Final Judgment\nto Signatory according to the notice procedures set forth in Section 25. Upon receipt by\nSignatory, any modifications, amendments, or alterations of the Final Judgment shall\nautomatically become a binding part of this Agreement as if fully set forth herein. For clarity, in\nthe event of a conflict between the terms of this Agreement and the Final Judgment, including\nany modification, amendment, or other alteration to the Final Judgment, the terms of the Final\nJudgment will control.\n\n11. Assignment. Neither Party to this Agreement may assign any part of this Agreement\nwithout prior written authorization of the Plaintiffs.\n\n14\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 16 of 48\n\n12. Capitalized Terms. Capitalized terms used in this Agreement and not specifically defined\nherein shall have the respective definitions given to them in the Final Judgment.\n\n13. Computing Time. When computing any time period specified in this Agreement:\n(a) exclude the day of the event that triggers the period; (b) count every day, including\nintermediate Saturdays, Sundays, and legal holidays; and (c) include the last day of the period,\n\nbut if the last day is a Saturday, Sunday, or legal holiday, the period continues to run until the end\nof the next day that is not a Saturday, Sunday, or legal holiday; provided, however, that (1) when\ncomputing any time period listed in terms of business days, exclude intermediate Saturdays,\nSundays, and legal holidays; and (2) in the event of a conflict in deadlines between this\nAgreement and the Final Judgment or related Court order, the deadline in the Final Judgment or\nrelated Court order controls.\n\n14. _\u2014 Affiliate Liability. Signatory will be liable for the acts and omissions of each of its\nAffiliates in connection with any Services provided under this Agreement to the extent any such\nacts or omissions, if performed by Signatory, would constitute a material breach of, or otherwise\ngive rise to liability under, this Agreement.\n\n15. Change of Control. If Signatory experiences a change of control (including through a\nstock purchase or sale, merger, or other form of corporate transaction), then the following\nprovisions shall apply:\n\na. Signatory shall provide written notice of the change of control to the TC,\nincluding any changes to Signatory\u2019s list of Affiliates, within ten (10) business days after the\nchange of control takes effect. In the event that, following receipt of such notice, the TC so\ninstructs, Signatory and Google shall terminate this Agreement.\n\nb. Signatory and its Affiliate(s) shall immediately cease accepting any Services that\nare provided by Google under this Agreement, unless the TC expressly authorizes otherwise in\nwriting.\n\nc. Upon receiving notice of Signatory\u2019s change of control, Google may request\n\npermission from the TC to terminate this Agreement. If the TC grants Google\u2019s request, Google\nmay, at its discretion, terminate this Agreement by providing ten (10) business days\u2019 notice, in\nwriting, to the TC and Signatory.\n\n16. Termination of this Agreement.\n\n16.1. Signatory Right of Termination. Signatory may terminate this Agreement for any\nreason by providing fifteen (15) business days\u2019 written notice to the TC and Google.\n\n15\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 17 of 48\n\n16.2. Google Right of Termination. If Google, in good faith, believes Signatory or its\nAffiliate(s) have materially breached this Agreement, Google may terminate this Agreement\npursuant to the following:\n\na. Notice Required. At least fifteen (15) business days prior to exercising its\n\nrights under this Section 16.2, Google must provide written notice to Signatory, Plaintiffs, and\nthe TC detailing (i) the provisions of this Agreement that Google believes Signatory and/or its\nAffiliate(s) have materially breached, and (11) the actions Google intends to take in response.\n\nb. Effect of Notice. After providing the notice required under Section 16.2.a,\nGoogle will not exercise any termination rights or take any related action under this Agreement\nuntil the earlier of (i) the date on which Google receives written notice from Plaintiffs that\nPlaintiffs do not object to termination, or (11) fifteen (15) business days following Google\u2019s\nprovision of notice under Section 16.2.a; provided, however, that if, within fifteen (15) business\ndays of Google providing the notice required under Section 16.2.a, Google receives written\nnotice from Plaintiffs that Plaintiffs intend to object to Google\u2019s termination, Google will not\nexercise any termination rights or take any related action under this Agreement until the later of\n(i) fourteen (14) days after Plaintiffs seek Court intervention concerning Google\u2019s intent to\nterminate this Agreement, if the Court does not act; or (11) until further order by the Court, if the\nCourt intervenes.\n\n16.3. Pre-Termination Remediation Permitted. Before either Party exercises its\ntermination rights under this Section 16, such Party may notify the other Party of its intent to\nexercise its termination rights and request remediation of any alleged breach or noncompliance\nserving as the basis for terminating this Agreement. Upon receiving such notice, the receiving\nParty will, within fifteen (15) business days, use commercially reasonable efforts to respond to\nsuch notice and either (a) attempt to remedy any alleged breach or noncompliance or (b) reject\nremediation under this Section 16.3. For avoidance of doubt, nothing in this Agreement,\nincluding Section 16.3, is intended to limit or prevent the ability of Signatory or its Affiliate(s) to\nsubmit complaints to Plaintiffs and the TC under the Final Judgment.\n\n16.4. Effect of Termination. Upon termination of this Agreement, Google shall\npromptly cease providing any Services.\n\n16.5. Survival. Upon termination of this Agreement for any reason, including any\ntermination pursuant to a Court order, Sections 1 (Definitions), 9 (Effect of Requests by\nPlaintiffs, TC Members, or Court Upon Signatory), 11 (Assignment), 12 (Capitalized Terms), 13\n(Computing Time), 17 (No Waiver), 18 (No Agency), 19 (No Third-Party Beneficiaries), 23\n(Severability), 24 (Governing Law and Forum), 26 (Intellectual Property), 27 (Confidentiality;\n\n16\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 18 of 48\n\nPublicity), 28 (Warranties; Disclaimers); 29 (Limitation of Liability), and 30 (Indemnification)\nwill survive unless otherwise specifically ordered by Court order.\n\n17. | No Waiver. Neither party to this Agreement will be treated as having waived any rights\nby not exercising (or delaying the exercise of) any rights under this Agreement.\n\n18. | NoAgency. This Agreement does not create any agency, partnership, or joint venture\nbetween the parties.\n\n19. No Third-Party Beneficiaries. This Agreement does not confer any benefits on any third\nparty unless this Agreement expressly states that it does.\n\n20. Amendment. This Agreement may not be amended absent written permission from\nPlaintiffs identifying with specificity the manner in which this Agreement may be amended.\nSuch permission is valid only with respect to this specific Agreement between Signatory and\nGoogle. Any amendment must be in writing, be signed by both parties, and expressly state that it\nis amending this Agreement. Any amendment shall be null and void to the extent it exceeds the\nscope of the written permission provided by Plaintiffs pursuant to this Section 20.\n\n21. Entire Agreement. This Agreement (together with the Exhibits hereto) constitutes the\nentire agreement and understanding between the parties hereto with respect to its subject matter\nand supersedes any and all other prior or contemporaneous agreements, written or oral, between\nthe parties relating to the subject matter herein.\n\n22. Suspension of the Agreement for Decertification.\n\n22.1. Notice Required. Signatory will notify Google, in writing, within five (5) business\ndays of Signatory losing its certification as a Qualified Competitor pursuant to Section IX.V. of\nthe Final Judgment; provided, however, that this notice period will not run until Signatory\n\nreceives a specific determination, in writing, from the Court, Plaintiffs, or the TC that it is no\nlonger certified as a Qualified Competitor under the Final Judgment.\n\n22.2. Effect of Notice. Thirty (30) days from the date on which Google receives the\nnotice required under Section 22.1, or thirty (30) days from the date on which Google otherwise\n\nlearns of Signatory losing certification as a Qualified Competitor under the Final Judgment and\nproviding written notice to Signatory of such fact, Signatory and Google agree to suspend all\nbenefits and obligations imposed on either Party relating to the Service(s) provided under this\nAgreement, subject to Reinstatement under Section 22.3 herein, unless otherwise ordered by the\nCourt. For clarity, and subject to agreement by Signatory and Google, Google may continue to\nprovide the Services to Signatory or its Affiliate(s) during a period of Suspension under this\n\n17\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 19 of 48\n\nSection 22, subject to Google\u2019s then standard terms and conditions; provided, however, that\nGoogle will not be obligated to provide the Services (including Search Results and Search Text\nAds) to Signatory or its Affiliate(s) or make any payments with respect to the continued use of\nthe Services by Signatory or its Affiliate(s) during a period of Suspension.\n\n22.3. Remstatement. If Signatory is recertified as a Qualified Competitor pursuant to\nSection IX.V of the Final Judgment following a period of suspension, the parties agree to\nreinstate this Agreement in its entirety within ten (10) business days of Google learning of such\nrecertification or Google receiving written notice by Signatory of such recertification, whichever\ncomes earlier.\n\n23. Severability. If any part of this Agreement is found to be illegal or unenforceable, the\nAgreement may be terminated upon notice from Plaintiffs or TC Members to the Parties. Absent\na notice of termination from Plaintiffs or TC Members, the rest of the Agreement (1.e., any part\nnot found to be illegal or unenforceable), will remain in full effect.\n\n24. Governing Law and Forum. This Agreement is governed in all respects by the federal\ncommon law of the United States of America or, to the extent that the Court deems it necessary\nto resort to the laws of another jurisdiction, the law of the District of Columbia. Pursuant to\nSection XI.A of the Final Judgment, all disputes arising under this Agreement shall be brought in\nthe Court, which shall have exclusive jurisdiction over disputes under this Agreement. As to all\nsuch disputes, the Parties to this Agreement consent to the personal jurisdiction of such Court.\n\n25. Notices. Any notices or other communications required to be given under this Agreement\nwill be deemed to have been properly given if sent by mail and email to the applicable party or\nentity at its addresses below (or to such other address as to which such party or entity shall\nhereafter notify the other party or parties):\n\nIf to Google, to:\n\n[Name]\n[Address]\n[City, ST ZIP]\n[Phone]\n[Email]\n\nIf to Signatory or its Affiliate(s), to:\n[Name]\n\n[Address]\n[City, ST ZIP]\n\n18\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 20 of 48\n\n[Phone]\n[Email]\n\nIf to the TC, to:\n\n[Name]\n[Address]\n[City, ST ZIP]\n[Phone]\n[Email]\n\nIf to Plaintiffs, collectively to:\n\nDanielle Hauck\n\nTravis Chapman\n\nClaire M. Maddox\n\nGrant Fergusson\n\nEmma Waitzman\n\nRyan Karr\n\nU.S. Department of Justice\nAntitrust Division\nTechnology & Digital Platforms Section\n450 Sth St NW\n\nWashington, D.C. 20530\n(202) 307-3954\n\nDanielle. Hauck@usdoj.gov\nTravis. Chapman@usdoj.gov\nClaire. Maddox@usdoj.gov\nGrant.Fergusson@usdoj.gov\nEmma. Waitzman@usdoj.gov\nRyan.Karr@usdoj.gov\n\nJonathan B. Sallet\n\nColorado Office of the Attorney General\n1300 Broadway, 7th Floor\n\nDenver, CO 80203\n\nTelephone: (720) 508-6000\n\nE-Mail: Jon.Sallet@coag.gov\n\n19\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 21 of 48\n\nJayme Weber\n\nArizona Office of the Attorney General\n400 West Congress, Ste. S-215\n\nTucson, Arizona 85701\n\nTelephone: (520) 628-6609\n\nE-Mail: Jayme. Weber@azag.gov\n\nSarah Mader\n\nOffice of the Attorney General of Ohio\n30 E Broad Street, 26\" Floor\nColumbus, OH 43215\n\nTelephone: (614) 466-4328\n\nE-Mail: Sarah.Mader@ohioago.gov\n\nTyler Corcoran\n\nOffice of the Attorney General and Reporter\nP.O. Box 20207\n\nNashville, TN 37202\n\nTelephone: (615) 741-8722\n\nE-Mail: Tyler.Corcoran@ag.tn.gov\n\n26. Intellectual Property.\n\n27. Confidentiality: Publicity.\n\n27.1. Confidentiality. Except with the prior written consent of the disclosing Party, the\nrecipient of any information pursuant to this Agreement that is marked as confidential or would\nreasonably be considered confidential information under the circumstances (\u201cConfidential\nInformation\u2019) will not disclose that Confidential Information, except to Affiliates, employees,\n\n20\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 22 of 48\n\nagents, or professional advisors who need to know it and who have agreed in writing (or in the\ncase of professional advisors are otherwise bound) to keep it confidential. The recipient will\nensure that those people and entities use Confidential Information only to exercise rights and\nfulfill obligations under this Agreement, while using reasonable care to keep the Confidential\nInformation confidential. The recipient may also disclose Confidential Information when\nrequired by law or Court order after giving reasonable notice to the discloser, if permitted by law.\nFor avoidance of doubt,\n\n27.2. Exceptions.\n\na. Notwithstanding Section 27.1, Google may (i) inform advertisers of the\nparticipation of Signatory and its Affiliate(s) (as applicable) in the Services; and (ii) share with\nadvertisers Site-specific and Client Application-specific statistics, the Site URL(s), the name(s)\nand platform(s) of the Client Application(s), and related information collected by Google through\nits provision of the Search Text Advertising Services to Signatory and its Affiliate(s). Disclosure\nof information by Google under this Section 27.2.a will also be subject to the terms of the\nGoogle Privacy Policy located at the following URL: http://www.google.com/privacypolicy.html\n(or a different URL Google may provide to Signatory from time to time), unless otherwise\nordered by the Court. Google shall notify Plaintiffs and the TC upon changing the URL of the\nGoogle Privacy Policy described herein.\n\nb. Each Party agrees that the terms of this Agreement, once fully executed,\nshall be deemed Confidential Information of the other Party; provided that, in addition to the\npermitted disclosures under Section 27.1, the Parties must disclose the terms of this Agreement\nto Plaintiffs and the TC, and either Party may disclose the terms of this Agreement (1) if required\nto do so by law, Court order, or generally accepted accounting principles, (ii) as required to assert\nits rights hereunder, and (111) to its own directors, employees, attorneys, accountants, and other\nadvisors on a \u201cneed to know\u201d basis and under an obligation of confidentiality no less stringent\nthan set forth herein. Each Party agrees that the disclosing Party will be given prompt notice of\nany disclosure made pursuant to clause (i) or (11) above, and that any such disclosure shall be\nlimited to the extent reasonably possible and as permitted by applicable law and/or Court order.\nNotwithstanding the foregoing, in the event that Signatory or its Affiliate(s) is required to file a\ncopy of this Agreement or a summary of this Agreement with the Securities and Exchange\nCommission, Signatory will seek confidential treatment for any such filing, will give Google\nreasonable prior notice and opportunity to review any such filing so that Google may provide\nSignatory with specific redaction requests, and will use its reasonable efforts to redact he\nAgreement (including as to all Google redaction requests) or alternatively provide an agreement\nsummary, in each case if and to the extent permitted by applicable laws and regulations.\n\n21\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 23 of 48\n\n27.3. Publicity. Neither Party may issue any press release or make any public statement\nregarding this Agreement without the other\u2019s written approval, except that either Party may make\npublic disclosure as required by applicable law and/or Court order. For avoidance of doubt,\nstatements or disclosures of information to Plaintiffs or the TC shall not be deemed to be public\nstatements under this Section 27.3.\n\n28. Warranties: Disclaimers.\n\n28.1. Warranties. Each Party warrants that (a) it has full power and authority to enter\ninto this Agreement; and (b) entering into or performing under this Agreement will not violate\nany agreement it has with a third party.\n\n28.2. Disclaimers. Except as expressly provided for in this Agreement and to the\nmaximum extent permitted by applicable law, neither Party makes any warranty of any kind,\nwhether implied, statutory, or otherwise disclaims, without limitation, warranties of\nmerchantability, fitness for a particular use, and noninfringement.\n\n29. Limitation of Liability.\n\n29.1. Limitations.\n\n29.2. Exceptions to Limitations.\n\n22\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 24 of 48\n\n30. Indemnification.\n\n30.1. By Signatory.\n\neee\na\n\n30.2. By Google.\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 25 of 48\n\nGeneral.\n\n31. Counterparts. The Parties to this Agreement may execute this Agreement in counterparts,\nincluding facsimile, PDF, and other electronic copies, which taken together will constitute one\ninstrument.\n\n24\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 26 of 48\n\nSigned by the Parties\u2019 authorized representatives on the dates below.\nGOOGLE LLC\n\nBy:\n\nPrint Name:\n\nTitle:\n\nDate:\n\nSIGNATORY\n\nBy:\n\nPrint Name:\n\nTitle:\n\nDate:\n\n25\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 27 of 48\n\nEXHIBIT A: SITES AND CLIENT APPLICATIONS\nThe parties to this Agreement hereby acknowledge and agree to the following:\n\n1. Sites and Client Applications. For the Agreement Term, Google will make\n\navailable, and Signatory and its Affiliate(s), as appropriate, will implement and maintain, each of\nthe Service(s) listed in Exhibit B on each of the Site(s) and Client Application(s) listed below:\n\nREMEDIAL WEB SEARCH SERVICE SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\nREMEDIAL IMAGE SEARCH SERVICE SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n26\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 28 of 48\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\nREMEDIAL ADSENSE FOR SEARCH SITES & CLIENT APPLICATIONS\n\n[Signatory] Properties\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\nProperties of [Signatory]\u2019s Affiliate(s)\n\nSites:\n[List of Sites]\n\nClient Applications:\n[List of Client Applications]\n\n2. Syndicated Sites and Syndicated Applications. For the Agreement Term and pursuant to\nSection 5.7 of this Agreement, Signatory and its Affiliate(s), as appropriate, may make available\nthe Search Text Advertising Service(s) listed in Exhibit B on each of the Syndicated Site(s) and\nSyndicated Application(s) listed below:\n\nREMEDIAL ADSENSE FOR SEARCH SYNDICATED SITES & APPLICATIONS\n\nSyndicated Sites\n\n[List of Syndicated Sites]\n\n27\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 29 of 48\n\nSyndicated Applications\n\n[List of Client Applications]\n\n3. Modifications Permitted. Signatory may, at its discretion, add or remove any Site(s),\nClient Application(s), Syndicated Site(s), or Syndicated Application(s) listed in this Exhibit A by\nnotifying Google, in writing, of such modification at least thirty (30) days before Signatory\nwishes the addition or deletion to take effect. Any such modification to the list of Site(s), Client\nApplication(s), Syndicated Site(s), and Syndicated Application(s) in this Exhibit A shall not be\ntreated as an Amendment to this Agreement under Section 20. Google may not reject any\nmodification to the list of Site(s), Client Application(s), Syndicated Site(s), and Syndicated\nApplication(s) in this Exhibit A, except to the extent that such modification would otherwise\nviolate the terms of this Agreement. At least ten (10) days prior to issuing any such rejection,\nGoogle shall provide written notice to Signatory, Plaintiffs, and the TC detailing the basis for\nsuch rejection.\n\n28\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 30 of 48\n\nEXHIBIT B: SERVICES TO BE PROVIDED\n\nThe Parties to this Agreement hereby acknowledge and agree to the following:\n\n1. Selected Service(s). Signatory may elect, in its sole discretion, which Service(s) listed\n\nbelow to receive under this Agreement, and Google will provide such selected Service(s) to\nSignatory and its Affiliate(s) according to the methods and financial terms listed below:\n\nNS) OFLU CO) 5 Bo) 08 (OI De)\n\nC1) Remedial Web Search (\u201cWS\u201d) Service\n\nSearch Fees\n\nAll syndicated web search results and related\ninformation, data, and Search Feature content\nrequired under Section V.A of the Final\nJudgment, including user-facing query-rewriting\nfeatures and Local, Maps, Video, and Knowledge\nPanel Search Feature content (whether provided\nvia content flags, contextual features, or\notherwise).\n\nThe Remedial WS Service will be made\navailable on all Sites and Client Applications via\none or more real-time APIs.\n\n7 per 1,000 Requests for WS Search\nResults Sets\n\n1) Remedial Image Search (\u201cIS\u201d) Service\n\nSearch Fees\n\nAll syndicated information, data, and Search\nFeature content relating to Google\u2019s provision of\nits Images Search Feature(s) under Section V.A\nof the Final Judgment.\n\nThe Remedial IS Service will be made available\non all Sites and Client Applications via one or\nmore real-time APIs.\n\n7 per 1,000 Requests for IS Search\nResults Sets.\n\n29\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 31 of 48\n\nHIGHLY CONFIDENTIAL\nSUBJECT TO PROTECTIVE ORDER AND ECF NOS. 1520-1 AND 1521\n\nNS OW CO) 5 OS BPS WUD Ow td LO) A Ol re\n\nC1 Remedial AdSense for Search (\u201c\u201cAFS\u201d) | Revenue Share Percentage\n\nAll Search Text Ads and related information, For Sites and Client Applications: a. of\ndata, or content, including assets, extensions, or | AFS Ad Revenues in a given month.\n\nSearch Text Ad variations, made available\n\nthrough Google\u2019s commercial ads syndication For Syndicated Sites and Syndicated\nproduct(s). Applications: a of AFS Ad Revenues in\n\na given month.\nThe Remedial AFS Service will be made\navailable to Signatory and its Affiliate(s)\naccording to Google\u2019s standard method(s) for\nproviding ads syndication; provided, however,\nthat at Signatory\u2019s sole discretion, Google will\nalternatively make the Remedial AFS Service\navailable to Signatory and its Affiliate(s)\naccording to the\n\ndescribed in Exhibit B Section 3.\n\n2. Payment Terms.\n\n2.1. Company Payments.\n\na. Search Services. The Search Fees owed to Google under this Agreement\nwill be calculated using the number of Requests for Search Results Sets as reported by Google.\n\nb. Offset. Google may offset the Search Fees payable to Signatory and its\nAffiliate(s) (as appropriate) under this Agreement against Google\u2019s payment obligations to\nSignatory and its Affiliate(s) (as appropriate) under this Agreement.\n\nc. Invoices. Even if the Search Fees are offset under Exhibit B Section 2.1.b,\nGoogle will invoice (or send a statement of financial activity to) Signatory or its Affiliate(s) (as\nappropriate) for Search Fees in the month after the Search Fees are incurred. Signatory or its\nAffiliate(s) (as appropriate) will pay the invoice amount, if any, to Google within thirty (30) days\nof the date of invoice. For avoidance of doubt, in each invoice or statement of financial activity\n\n30\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 32 of 48\n\nissued under this Exhibit B Section 2.1.c, Google will list all Search Fees payable to Signatory\nand its Affiliate(s) (as appropriate), all payments owed by Google to Signatory and its Affiliate(s)\n(as appropriate), and any offsets calculated for such Search Fees and payment obligations.\n\nd. Invoice Disputes. Signatory and its Affiliate(s) (as appropriate) may\ndispute invoiced Search Fees if Signatory and its Affiliate(s) (as appropriate) believe in good\nfaith that such Search Fees were inaccurately invoiced (an \u201cInvoice Dispute\u201d). Invoice Disputes\nmust be submitted and identify all disputed amounts and the reason\nfor dispute. Google will review in good faith all Invoice Disputes and will provide Signatory and\nits Affiliate(s) (as appropriate) an explanation of Search Fees due following such review (an\n\u201cInvoice Dispute Report\u2019). If an Invoice Dispute is submitted within thirty (30) days of\nSignatory and its Affiliate(s) (as appropriate) receiving an invoice under this Agreement (the\n\u201cPayment Due Date\u2019\u2019), then (1) Signatory and its Affiliate(s) (as appropriate) must only pay the\namounts not subject to the Invoice Dispute by the Payment Due Date, and (ii) unpaid Search\nFees stated in an Invoice Dispute Report to be accurately invoiced are due within thirty (30) days\nafter delivery of such report to Signatory and its Affiliate(s) (as appropriate). If an Invoice\nDispute is submitted after the Payment Due Date and the Invoice Dispute Report states that\nSearch Fees paid were incorrectly invoiced, then Google will issue a credit equal to the agreed\namount. For avoidance of doubt, nothing in this Exhibit B Section 2.1.d is intended to limit or\nsupersede the ability of Signatory and its Affiliate(s) (as appropriate) to submit complaints to\nPlaintiffs, the TC, or Google under the Final Judgment.\n\n2.2. Google Payments.\n\na. For each applicable Search Text Advertising Service, Google will pay\nSignatory and its Affiliate(s) (as appropriate) an amount equal to the Revenue Share Percentage\nof Ad Revenues attributable to a calendar month. This payment will be made in the month\nfollowing the calendar month in which the applicable Search Text Ads were displayed.\n\nb. Google\u2019s payments for Search Text Advertising Services under this\nAgreement will be based on Google\u2019s accounting, which may be filtered to exclude invalid\nqueries, impressions, conversions, or clicks in each case provided Google does not receive and\nretain payment from the applicable advertiser for such activity. On reasonable written notice\nfrom Signatory, Plaintiffs, or the TC, Google will promptly produce to Signatory, Plaintiffs, or\nthe TC (as appropriate) its accounting for payments under this Agreement, including any filters\nor exclusions applied.\n\n31\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 33 of 48\n\n2.3. All Payments.\n\na. As between Google and Signatory and its Affiliate(s), Google is\nresponsible for all taxes (if any) associated with the transactions between Google and advertisers\nin connection with Search Text Ads displayed on the Sites, Client Applications, Syndicated Sites,\nand Syndicated Applications. Signatory and its Affiliate(s) (as appropriate) are responsible for all\ntaxes (if any) associated with the Services, other than taxes based on Google\u2019s net income, net\nworth, asset value, property value, or employment. All payments to Signatory and its Affiliate(s)\n(as appropriate) from Google in relation to the Services will be treated as inclusive of tax (if\napplicable) and will not be adjusted. If Google is obligated to withhold any taxes from its\npayments to Signatory and its Affiliate(s), Google will notify Signatory of this and will make the\npayments net of the withheld amounts. Google will provide Signatory with original or certified\ncopies of tax payments (or other sufficient evidence of tax payments) if any of these payments\nare made by Google.\n\nb. All payments due to Google or to Signatory and its Affiliate(s) (as\nappropriate) will be in the currency described in the associated invoice, such currency to be\ndetermined upon mutual agreement by the Parties. and made by electronic transfer to the\naccount notified to the paying Party by the other Party for that purpose, and the Party receiving\npayment will be responsible for any bank charges assessed by the recipient\u2019s bank. Any charges\nfor converting foreign currency shall be the responsibility of Signatory and its Affiliate(s) (as\nappropriate) and will be invoiced accordingly. In accordance with applicable laws and\nregulations, Google operates multiple local Google-affiliated entities to process transactions, and\npayments from Signatory or its Affiliate(s) to Google may be made to one or more of these\nGoogle-affiliated entities as specified by Google, which will satisfy the payment obligations of\nSignatory and its Affiliate(s) (as appropriate) under this Agreement.\n\nc. In addition to other rights and remedies Google may have, Google may\noffset any payment obligations to Signatory and its Affiliate(s) (as appropriate) that Google may\nincur under this Agreement against any undisputed, past due product or service fees owed to\nGoogle by Signatory and its Affiliate(s) (as appropriate) under this Agreement. Google may also\nwithhold and offset against its payment obligations under this Agreement, or require Signatory\nand its Affiliate(s) (as appropriate) to pay Google within thirty (30) days of any invoice, any\namounts Google may have overpaid to Signatory and its Affiliate(s) in prior periods.\n\n2.4. SOC 1 Report. Upon written request by Signatory or its Affiliate(s) (as\nappropriate), and no more than once per calendar year during the Agreement Term, Google will\nmake available to Company a SOC 1, Type 2 report (or similar report with comparable data)\nfrom a reputable, independent certified public accounting firm covering the key controls and\nvalidation mechanisms in place to meet the revenue reporting obligations under this Agreement.\n\n32\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 34 of 48\n\nSuch report will be considered Confidential Information of Google under this Agreement, except\nthat Google will, upon reasonable, written notice from Plaintiffs or the TC, provide a copy of any\nsuch report made available under this Exhibit B Section 2.4 to Plaintiffs and the TC.\n\n3. Privacy-Preserving Alternative Implementation.\n\n3.2. Non-Personalized Ads Permitted. In addition to the methods of implementing the\n\nSearch Text Advertising Service(s) described in Exhibit B Sections 1 and 3.1, Google shall make\navailable to Signatory and its Affiliate(s), at Signatory\u2019s sole discretion, the option of receiving\nnon-personalized Search Text Ads under the Search Text Advertising Services (\u201cNon-\nPersonalized Ads\u201d or \u201cNPAs\u201d). Non-Personalized Ads provided under this Agreement shall\nconform to the NPA specifications at https://support.google.com/adsense/answer/7670312 (or\nsuch URL as Google may may provide to Signatory from time to time, provided that Google\nnotifies Plaintiffs and TC in parallel of any alternative URL provided under this Exhibit B\nSection 3.2).\n\n4. Related Products, Services, and Integrated Features. Within five (5) business days of\nlaunching a new, commercially available product, service, or integrated feature that alters,\n\naugments, replaces, or otherwise relates to any Service(s) provided under this Agreement,\nGoogle shall provide written notice of such new product(s), service(s), or integrated feature(s) to\nPlaintiffs and the TC. In the event that, following receipt of such notice, Plaintiffs so instruct,\nSignatory and Google will amend this Agreement according to Section 20 solely to make such\n\nWw\nWw\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 35 of 48\n\nnew product(s), service(s), or integrated feature(s) available to Signatory and its Affiliate(s)\npursuant to the terms set forth in Sections V and VI of the Final Judgment.\n\n34\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 36 of 48\n\nEXHIBIT C: ADDITIONAL CLAUSES FOR SERVICES TO BE PROVIDED\n\nThe Parties to this Agreement hereby acknowledge and agree to the following additional\nprovisions, which are intended to supplement, and not replace or conflict with, Sections 4, 5, 6,\nand 7 of this Agreement:\n\n1. Additional Definitions. For the purposes of this Exhibit C, the following terms shall have\nthe following meanings:\n\n1.1. \u201cDuplicate Advertisements\u201d means URLs (and not advertisers, categories or\nkeywords) that promote Search Text Ads that include the same website, display URL, or\nadvertiser that is promoted in an advertisement displayed or sold by or on behalf of Signatory or\nits Affiliate(s) as permitted under this Agreement.\n\n1.2. \u201cNetwork Issues\u201d means any outage(s) or latency caused by any third party\nnetwork connectivity or software that is outside of Google\u2019s control.\n\n1.3. \u201cSearch Service Availability\u201d means the percentage of Requests for Search\nResults or Search Results Sets sent to Google in response to a Covered Query that are processed\nby Google under this Agreement.\n\n1.4. \u201cSearch Service Network Latency\u201d means the round-trip time of a TCP/IP ping\npacket between a peering address owned or operated by Signatory or its Affiliate(s) and Google\u2019s\npeering address.\n\n1.5. \u201cSearch Text Advertising Service Availability\u201d means the percentage of\nRequests for Search Text Ads or Search Text Ad Sets sent to Google under this Agreement that\nare processed by Google\u2019s system within one (1) second.\n\n1.6. \u201cServer Latency\u201d means the time period between when Google's system receives\na Request for Search Text Ads or Search Text Ad Sets under this Agreement and when Google's\nsystem has processed such Request. For clarity, Server Latency does not include any time\nassociated with transmission of the Request for Search Text Ads or Search Text Ad Sets from\nSignatory or its Affiliate(s) to Google's system or transmission of the applicable Search Text Ads\nor Search Text Ad Sets from Google's system to Signatory or its Affiliate(s).\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 37 of 48\n\n2. Additional Clauses for Search Services.\n\n2.1. Required Search Service Latency and Reliability.\n\na. Required Search Service Availability. For all selected Search Service(s) in\nExhibit B, Google will provide Signatory and its Affiliate(s) with\na Search Service Availability over a rolling thirty (30) day period (excluding any\nNetwork Issues), as measured and monitored from Google\u2019s facilities in the United States.\n\nb. Search Service Network Latency Threshold. Throughout the Agreement\nTerm, Search Service Network Latency will not exceed an average of| a milliseconds over any\n10-hour period (excluding any Network Issues) (\u201cSearch Service Network Latency\nThreshold\u201d). To measure Search Service Network Latency, Signatory will install private\ninterconnects at Google\u2019s United States-based network meeting places as mutually agreed by the\nParties. Upon reasonable notice by the TC, Signatory and Google agree to submit information or\ndata concerning measurements of the Search Service Network Latency, or to grant the TC access\nto the private interconnects installed under this Exhibit C Section 2.1, and will, if the TC so\ninstructs, modify, update, or otherwise change the method(s) for measuring Search Service\nNetwork Latency under this Agreement. Throughout the Agreement Term, Google shall not take\nany actions that have the effect of slowing Search Service Network Latency, including, without\n\nlimitation, in circumstances where Search Service Network Latency is below the Search Service\nNetwork Latency Threshold, with the intent of approaching or reaching the Search Service\nNetwork Latency Threshold, even if doing so would decrease costs for Google.\n\n2.2. Display or Use Restrictions for Search Services. Signatory and its Affiliate(s) (as\nappropriate), may\n\nExcept as expressly approved by Google or the Court in writing, Signatory and\nits Affiliate(s) will not make more than one (1) Request for Search Results or Search Results Set\n\nper Covered Query. Notwithstanding the foregoing,\n\n2.3. Additional Terms Permitting GenAI Product Grounding. Notwithstanding\nSections 4.4, 4.5, 5.4, and 5.5, as well as the terms of this Exhibit C, Google shall not:\n\n36\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 38 of 48\n\na. prohibit Signatory and its Affiliate(s) from temporarily caching Search\nResults solely for the purpose of grounding any single response to a Covered Query generated by\na GenAI Product owned and operated by Signatory and its Affiliate(s), provided that any such\ncached content is not stored beyond the duration necessary to complete such response; or\n\nb. treat single-call API retrieval under this Agreement for use in GenAI\nProduct grounding described in Exhibit C Section 2.3.a as bulk scraping, indexing, or crawling\n\nprohibited under this Agreement.\n\n3. Additional Clauses for Search Text Advertising Services.\n\n3.1. Required Search Text Advertising Service Latency, Reliability, and Performance.\n\na. Search Text Advertising Service Availability. For all selected Search Text\nAdvertising Service(s) in Exhibit B, Google will provide Signatory and its Affiliate(s) with\n\nee Search Text Advertising Availability over a rolling\n\nthirty (30) day period (excluding any Network Issues), as measured and monitored from\n\nGoogle\u2019s facilities in the United States.\n\nb. Search Text Ad Server Latency Threshold. For all selected Search Text\n\nAdvertising Service(s) in Exhibit B, Server Latency will not exceed an average of| a\nmilliseconds over any 10-hour period (\u201cServer Latency Threshold\u201d). Google will work in good\nfaith to find ways to continuously improve Server Latency during the Agreement Term. For\navoidance of doubt, Google shall not take any actions throughout the Agreement Term that have\nthe effect of slowing Server Latency, including, without limitation, in circumstances where\nServer Latency is below the Server Latency Threshold, with the intent of approaching or\nreaching the Server Latency Threshold, even if doing so would decrease costs for Google.\n\n3.2. Search Text Ads Display or Use Restrictions.\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 39 of 48\n\n4. Escalation of Service Availability and Latency Noncompliance.\n\n4.1. Severity Classifications. For the purposes of this Exhibit C Section 4, the Parties\n\nagree to classify any Google noncompliance with Exhibit C Sections 2.1.a, 2.1.b, 3.1.a, or 3.1.b\nby severity (together, \u201cSeverity Errors\u201d) as follows:\n\na. A \u201cSeverity 2 Error\u201d shall mean (i) any Search Service Availability or\nSearch Text Advertising Availability provided by Google under this Agreement that is more than\nninety-nine and five-tenths percent (99.5%) but less than the required ninety-nine and nine-tenths\npercent (99.9%) over a rolling thirty (30) day period (excluding any Network Issues), as\nmeasured and monitored from Google\u2019s facilities in the United States, and (i1) any Search\nService Network Latency or Server Latency that exceeds an average of 75 milliseconds over any\n10-hour period but is less than 99 milliseconds over any 10-hour period.\n\nb. A \u201cSeverity 1 Error\u201d shall mean (i) any Search Service Availability or\nSearch Text Advertising Availability provided by Google under this Agreement that is ninety-\nnine and five-tenths percent (99.5%) or less over a rolling thirty (30) day period (excluding any\nNetwork Issues), as measured and monitored from Google\u2019s facilities in the United States, and\n(11) any Search Service Network Latency or Server Latency that exceeds 99 milliseconds over\nany 10-hour period.\n\n4.2. Responding to Severity Errors. If either Party becomes aware of a suspected\nSeverity 2 Error or Severity 1 Error under this Agreement, such Party will promptly notify the\nother Party of such Severity Error(s). Upon becoming aware of such Severity Error(s), Google\nwill use commercially reasonable efforts to (a) respond to any such notice provided by Signatory\nor its Affiliate(s) within thirty (30) minutes (for Severity 2 Errors) or fifteen (15) minutes (for\nSevery 1 Errors), and (b) resolve such Severity Error within one (1) day (for Severity 2 Errors) or\nthirty (30) minutes (for Severity 1 Errors).\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 40 of 48\n\n4.3. Remedy for Noncompliance.\n\na. If Google fails to resolve a Severity Error within the applicable time\nperiod set forth in Exhibit C Section 4.2 such that, during any given thirty (30) day period,\nSearch Text Ads or Search Text Ad Sets are not sent back to Signatory or its Affiliate(s) in\nresponse to a Request for Search Text Ads or Search Text Ad Set under this Agreement, then\n\ni\n\n39\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 41 of 48\n\nes\na\n\n5. Policy and Compliance Obligations.\n\n5.1. Policy Obligations. Except as otherwise permitted by this Agreement, including\nactions permitted under Section 4.4, Section 5.4, and Exhibit C Section 2.3, Signatory and its\nAffiliate(s) will not, and will use commercially reasonable efforts to not permit any third party\nto:\n\na. modify, obscure, or prevent the display of all, or any part of, any Search\nResults or Search Text Ads;\n\nb. edit, filter, truncate, append terms to, or otherwise modify any Covered\nQuery;\n\nc. implement any click tracking or other click monitoring of Search Results\nor Search Text Ads, except as provided in Exhibit C Section 6 below;\n\nd. display any Search Results or Search Text Ads in pop-ups, pop-unders,\nexit windows, expanding buttons, animation, or other similar methods;\n\ne. enter into any type of arrangement with a third party where either party\nreceives a financial benefit in connection with (i) the Search Results or Search Text Ads provided\nunder this Agreement or (11) any Ad Revenues (including any co-branding, white labeling or sub-\nsyndication arrangement). For the avoidance of doubt, nothing in this Exhibit C Section 5.1. is\nintended to prevent Signatory or its Affiliate(s) from displaying, using, or sub-syndicating Search\nText Ads under Section 5 and Exhibit C Section 3 of this Agreement;\n\nf. directly or indirectly, (i) offer incentives to End Users to generate\nimpressions, Requests, or clicks on Search Results and/or Search Text Ads; (11) fraudulently\ngenerate impressions, Requests, or clicks on Search Results and/or Search Text Ads; or (111)\nmodify impressions, Requests, or clicks on Search Results and/or Search Text Ads;\n\ng. \u201ccrawl,\u201d \u201cspider,\u201d index or in any non-transitory manner store or cache\ninformation obtained from the Services (including Search Results and Search Text Ads), beyond\n\nwhat is necessary to present Search Results and/or Search Text Ads in response to a Query;\n\nh. except for content provided by Google, display on any Site or Client\nApplication any content that violates or encourages conduct that would violate the Google\n\n40\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 42 of 48\n\nProgram Guidelines, Google technical protocols, or any other technical requirements; provided,\nhowever, that Google shall not impose any requirements under the Google Program Guidelines,\nGoogle technical protocols, or any other technical requirements except as permitted under\nSection VI.B.11 of the Final Judgment. In the event of a conflict between the Google Program\nGuidelines, Google\u2019s technical protocols, or any other technical requirements and this\nAgreement, the terms of this Agreement will control;\n\ni. enter into any type of arrangement where a third party other than\nSubsyndicate receives a payment in connection with Search Text Ads provided under this\nAgreement (for example, a Subsyndicate\u2019s partner). For the avoidance of doubt, Affiliates are not\ntreated as third parties for the purposes of this Exhibit C Section 5.1.1;\n\nj- use the Services to directly or indirectly monetize error pages, unless\nexpressly permitted by Google or as otherwise ordered by the Court. Indirect monetization of\nerror pages includes, but is not limited to, having a search box or text links on error pages that\nresolve to pages containing Search Text Ads. Errors include, but are not limited to, DNS errors or\nHTTP response codes of types 3xx, 4xx, or 5xx; or\n\nk. serve or display advertisements on or in connection with, or otherwise\n\nmonetize, SERPs that have Search Results from the Remedial Image Search Service listed in\nExhibit B.\n\n5.2. Compliance Obligations. Signatory and its Affiliate(s) will not knowingly or\nnegligently allow any use of or access to the Services through any Site or Client Application that\nis not in compliance with the terms of this Agreement. Signatory and its Affiliate(s) (as\nappropriate) will use commercially reasonable efforts to monitor for any such access or use and\nwill, if any such access or use is detected, take all reasonable steps requested by Google to\ndisable this access or use. If Signatory and its Affiliate(s) are not in compliance with this\nAgreement at any time, Google may suspend provision of all (or any part of) the applicable\nServices until Signatory and its Affiliate(s) (as appropriate) implement adequate corrective\nmodifications as reasonably required and determined by Google or as otherwise ordered by the\nCourt; provided, however, that at least fifteen (15) business days prior to exercising its rights\nunder this Exhibit C Section 5.2, Google must provide written notice to Signatory, Plaintiffs, and\nthe TC detailing (1) the alleged noncompliance by Signatory and/or its Affiliate(s) and (11) the\nactions Google intends to take in response. After providing this notice, Google will not exercise\nany suspension rights under this Exhibit C Section 5.2 or take any related action under this\nAgreement until the earlier of (i) the date on which Google receives written notice from Plaintiffs\nthat Plaintiffs do not object to suspension, or (11) fifteen (15) business days following Google\u2019s\nprovision of notice under this Exhibit C Section 5.2; provided, however, that if, within fifteen\n(15) business days of Google providing the notice required under this Exhibit C Section 5.2,\n\n4]\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 43 of 48\n\nGoogle receives written notice from Plaintiffs that Plaintiffs intend to object to Google\u2019s\ntermination, Google will not exercise any termination rights or take any related action under this\nAgreement until the later of (1) fourteen (14) days after Plaintiffs seek Court intervention\nconcerning Google\u2019s intent to suspend this Agreement, if the Court does not act; or (ii) until\nfurther order by the Court, if the Court intervenes.\n\n6. Click Tracking. Signatory and its Affiliate(s) (as appropriate) may implement click\ntracking in accordance with Google\u2019s technical protocols, the Google Program Guidelines, and\n\nthis Agreement; provided, however, that that Google shall not impose any requirements under the\nGoogle Program Guidelines, Google technical protocols, or any other technical requirements\nexcept as permitted under Section VI.B.11 of the Final Judgment. In the event of a conflict\nbetween Google\u2019s technical protocols or the Google Program Guidelines and this Agreement, the\nterms of this Agreement will control. Signatory and its Affiliate(s) (as appropriate) are\nresponsible for the implementation and operation of any click tracking.\n\n. az\n7.1.\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 44 of 48\n\n8. Permitted and Prohibited Uses of Data.\n\n8.1. Definition of Signatory Data.\n\n8.2. Definitions of Google Data.\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 45 of 48\n\n8.3. Permitted and Prohibited Uses.\n\nSignatory Data.\n\nGoogle Data.\n\nCc. Signatory Click Data. a\n\nData Shared with Advertisers.\n\nAd\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 46 of 48\n\ne. Legally Required Uses. Notwithstanding the foregoing or anything to the\ncontrary within this Agreement, either Party may use Signatory Data and Signatory Click Data to\nthe extent required by law, in order to comply with legal process, preventing fraud or imminent\n\nharm, and ensuring the security of its network and services.\n\nf. Exceptions for Privacy-Preserving Alternatives. Nothing in this Exhibit C\nSection 8 shall limit or supersede any rights that Signatory and its Affiliate(s) may have to\nwithhold, anonymize, alter, or otherwise protect the privacy of End User data under Exhibit B\nSection 3.\n\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 47 of 48\n\n46\n\fCase 1:20-cv-03010-APM Document 1567-6 Filed 10/23/26 Page 48 of 48\n\n","ocr_status":1,"date_upload":"2026-10-23T19:16:18.664553-07:00","document_number":"1567","attachment_number":6,"pacer_doc_id":"045012431086","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487568/","id":498487568,"tags":[],"absolute_url":"/docket/18552824/1567/7/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.300443-07:00","date_modified":"2026-10-26T17:44:51.588326-07:00","sha1":"3cf5d012796830132cf9efaa1741ebfcf59f03e2","page_count":29,"file_size":914877,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.7.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.7.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487568.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 1 of 29\n\n\n\n\n Exhibit 7\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002 \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 2 of 29\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF COLUMBIA\n\n\n\n United States of America, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03010-APM\n\n v. HON. AMIT P. MEHTA\n\n Google LLC,\n\n Defendant.\n\n\n\n\n State of Colorado, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03715-APM\n\n v. HON. AMIT P. MEHTA\n\n Google LLC,\n\n Defendant.\n\n\n\n DECLARATION OF JESSE ADKINS\n\n I, Jesse Adkins, declare as follows:\n\n 1. I am currently employed by Google LLC (\u201cGoogle\u201d) as a Director of Product\n\n Management for Search Ads. I served as the Director of Product Management for Search\n\n Syndication and Search Ads Syndication from 2013 until September 2026. I submit this\n\n declaration in support of Google\u2019s objections to Plaintiffs\u2019 Proposed Syndication Template. The\n\n facts set forth herein are within my personal knowledge and if called as a witness, I could and\n\n would competently testify to them.\n\n\n\n 1\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 3 of 29\n\n\n\n\n 2. As Director of Product Management for Search Syndication and Search Ads\n\n Syndication, my responsibilities included overseeing the product areas in which Google\n\n syndicates its web search results and search ads to partners for display on their sites. In\n\n particular, my responsibilities included overseeing Google\u2019s search and ads syndication products.\n\n I have served as one of the product approvers for Google\u2019s search and search ads syndication\n\n contracts, and I am familiar with Google\u2019s existing commercial terms for Google\u2019s search and\n\n search ads syndication agreements.\n\n 3. I testified in the remedies evidentiary hearing on May 1 and May 2, 2025. I also\n\n submitted a declaration in support of Google\u2019s Motion to Stay on January 16, 2026. ECF No.\n\n 1471-3.\n\n 4. I have reviewed the Court\u2019s Final Judgment (\u201cFJ\u201d) issued on December 5, 2025,\n\n and, in particular, Section V titled \u201cRequired Syndication of Search Results\u201d and Section VI\n\n titled \u201cSearch Text Ad Auction Changes and Search Text Ads Syndication.\u201d I have also\n\n reviewed the syndication license agreement template proposed by the Technical Committee\n\n (\u201cTC\u201d) and Plaintiffs, as revised on October 4, 2026 (\u201cPlaintiffs\u2019 Proposed Template\u201d), and the\n\n two template syndication agreements that Google submitted to the TC on August 10, 2026: a\n\n search syndication license (\u201cGoogle\u2019s Proposed Search Template\u201d) and an AdSense for Search\n\n license (\u201cGoogle\u2019s Proposed Ads Template\u201d). On September 25, 2026 and September 29, 2026,\n\n I met with the TC and Plaintiffs to discuss the Proposed Template.\n\n Google\u2019s Search and Search Ads Syndication Products\n\n 5. Search syndication is when Google\u2019s web search results are syndicated for display\n\n to users on a third-party website. Google offers two search syndication products: Programmable\n\n\n\n\n 2\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 4 of 29\n\n\n\n\n Search Engine (\u201cProSE\u201d), which is available to anyone who signs up for it, and Web Search\n\n Syndication (\u201cWSS\u201d), which is available to directly negotiated partners.\n\n 6. Search ad syndication is when a partner requests Google\u2019s search text ads for its\n\n search results page and Google displays those ads on the partner\u2019s site. This service is called\n\n AdSense for Search (\u201cAFS\u201d): AFS Online is the off-the-shelf product governed by click-to-\n\n accept terms; AFS Direct is only available to directly negotiated partners.\n\n 7. When an AFS search text ad receives a click, the advertiser pays Google, and\n\n Google pays a revenue share to the syndication partner. Google, not the partner, has the\n\n relationship with the advertiser. If an advertiser has a problem with the traffic it receives from a\n\n syndication partner, the advertiser comes to Google for support, and Google may offer the\n\n advertiser a refund.\n\n 8. Google\u2019s syndicated ads are shown on what Google calls its Search Partner\n\n Network. The Search Partner Network is selected by default when an advertiser purchases\n\n search ads on Google, although advertisers may opt out of the network or exclude individual\n\n sites. Because the network operates as a single opt-out, poor-quality traffic on one partner\u2019s site\n\n can lead advertisers to opt out of the network as a whole, which reduces revenue for every\n\n partner in the network, including any Qualified Competitor who syndicates Google\u2019s ads. For\n\n this reason, Google devotes substantial time and effort to maintaining the quality of the Search\n\n Partner Network.\n\n 9. Providing Google\u2019s search and ads syndication services requires coordination\n\n among at least six different teams, including Product Management, Engineering, Trust and\n\n Safety, Policy and Enforcement, Tech Support, and Finance. However, the Plaintiffs\u2019 Proposed\n\n Template makes a number of changes to Google\u2019s MFN contractual terms that would upend the\n\n\n\n 3\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 5 of 29\n\n\n\n\n systems and processes that these teams rely on today, which would not only burden Google but\n\n also delay provision of services to the Qualified Competitors.\n\n Web Search Syndication Services Versus Grounding Services\n\n 10. Google offers grounding services separately from search syndication, and the two\n\n products differ significantly in a number of respects. At a baseline level the products serve\n\n different purposes\u2014while search syndication provides Google\u2019s organic search results for\n\n display on third-party websites, grounding uses organic search data to provide a machine\n\n learning model with additional information used to improve the model\u2019s output. Grounding with\n\n Google Search (\u201cGwGS\u201d), which is available on Google Cloud\u2019s Vertex AI platform, does not\n\n provide customers with ranked raw search results\u2014instead, it provides a grounded large\n\n language model response accompanied by unranked corroborating sources.\n\n 11. The products also use different methods to protect their intellectual property.\n\n Because the search syndication product only provides for the display of search results, Google\n\n relies on contractual restrictions to protect its intellectual property, rather than technological\n\n constraints. For instance, Google\u2019s syndication agreements include terms that prohibit\n\n syndication partners from crawling, spidering, indexing or in any non-transitory manner storing\n\n or caching Google\u2019s results, as well as prohibitions on modifying individual results and\n\n modifying the user queries. By contrast, Section 4.4(a)-(b) of the Plaintiffs\u2019 Proposed Template\n\n would permit Qualified Competitors to use Google\u2019s search results within their GenAI products,\n\n and Exhibit C, Section 2.3 would bar Google from prohibiting temporary caching of results for\n\n that purpose. Google has been offering search syndication for decades, and the product was\n\n designed long before the proliferation of GenAI products.\n\n\n\n\n 4\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 6 of 29\n\n\n\n\n 12. By contrast, Google\u2019s grounding product employs both contractual restrictions\n\n and product design choices to protect Google\u2019s IP. To prevent scraping, traffic is typically\n\n routed through a temporary \u201credirect\u201d via Google\u2019s search attribution layer instead of navigating\n\n directly to the web link, enabling Google to track potential service misuse. The temporary nature\n\n of these redirect links\u2014in contrast to standard, static web links\u2014creates technical barriers to\n\n scraping and caching the underlying source content. Additionally, the data flows for the\n\n grounding product run on Google\u2019s platform, allowing Google to monitor compliance and\n\n immediately suspend customers that violate its terms.\n\n 13. Google provides publishers with distinct controls over how their content is used in\n\n Google\u2019s search and grounding products. Under Google\u2019s publisher controls, website owners\n\n and publishers can permit Google\u2019s primary web crawler (Googlebot) to index their pages for\n\n display in Google\u2019s search results\u2014which also governs whether their content appears in\n\n Google\u2019s syndicated search results. A separate management tool, Google-Extended, allows\n\n publishers to opt out of having their content processed by Google\u2019s AI grounding services,\n\n including Grounding with Google Search, and for training future generations of Gemini models\n\n that power Gemini Apps and Vertex AI API for Gemini.1 Google also offers a separate Search\n\n Generative AI Control that allows publishers to appear in traditional search results without\n\n having their content used for Google\u2019s Gen-AI features, such as AI Overviews and AI Mode.2\n\n\n\n 1\n See List of Google\u2019s Common Crawlers, Google,\n https://developers.google.com/crawling/docs/crawlers-fetchers/google-common-\n crawlers#google-extended (last visited Oct. 13, 2026).\n 2\n See, e.g., Search Generative AI Control, Google Search Console Help, Google,\n https://support.google.com/webmasters/answer/16908024?hl=en (last visited Oct. 13, 2026);\n New Opportunities, control and insights for website owners, Google,\n https://blog.google/products-and-platforms/products/search/new-controls-website-owners/ (last\n visited Oct. 13, 2026).\n 5\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 7 of 29\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 8 of 29\n\n\n\n\n whether through Google-Extended or through robots.txt instructions directed at the Qualified\n\n Competitors\u2019 own crawlers.\n\n Pricing of the Syndicated Search Services\n\n 16. Google\u2019s off-the-shelf online search syndication service, ProSE, includes an ads-\n\n free version, which was offered as of the date of entry of the Final Judgment for $5 per 1,000\n\n requests. That product reflects Google\u2019s only stand-alone web search syndication pricing.\n\n ProSE is ordinarily subject to a cap of 10,000 queries per day.\n\n .\n\n 17. Unlike ProSE, Google\u2019s directly negotiated WSS partners all have combined\n\n WSS and AFS agreements. WSS and AFS terms are negotiated together and evaluated as a\n\n whole.\n\n 18. Because the ads portion of a bundled syndication deal is often worth a multiple of\n\n the search syndication fees, Google has historically accepted lower per-query fees for search\n\n syndication in the context of a bundled search and ads syndication relationship, in which AFS\n\n revenue offsets the lower search fees. Google would not agree to those search syndication fees\n\n on a stand-alone basis.\n\n 19. I understand that the price of $ per 1,000 requests for the Remedial Web\n\n Search Service in Exhibit B, Section 1 of the Proposed Template is drawn from Google\u2019s\n\n agreement with . Pls\u2019 9/15 Letter, Response 30; GOOG-DOJ-FJ-00000142. That pricing\n\n term expired in . GOOG-DOJ-FJ-00000240. As of December 5, 2025, the date of\n\n entry of the Final Judgment, paid $ per 1,000 queries for web search results. Id. For all\n\n relevant time periods, the contract bundled syndicated web search results together with\n\n AFS. Google charged an AFS\n\n\n\n 7\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 9 of 29\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 10 of 29\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 11 of 29\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 12 of 29\n\n\n\n\n 28. Exhibit B, Section 1 of Plaintiffs\u2019 Proposed Template would apply the same\n\n revenue share percentage to desktop and mobile ad revenues. No current AFS direct agreement\n\n uses a flat rate across desktop and mobile.\n\n 29. The Plaintiffs\u2019 Proposed Template also does not apply the that\n\n Google applies to account for Google\u2019s operating costs and other baseline technical expenses. In\n\n Google\u2019s agreements that\n\n . In failing to apply the ,\n\n Plaintiffs propose a revenue share that is a more favorable effective rate than what Google\n\n provides to any customer.\n\n 30. Plaintiffs\u2019 Proposed Template would also provide a revenue share of % for all\n\n AFS ad revenues for desktop and mobile ads in a given month for a Qualified Competitor\u2019s own\n\n sites and client applications, and % for syndicated sites and applications. First, no Google\n\n agreement has provided a % revenue share on both desktop and mobile. Second, in the\n\n agreement, the % rate applied only to the top tier of a progressive desktop schedule\u2014\n\n the portion of monthly AFS revenue above $ \u2014and was subject to the ,\n\n resulting in an effective rate of % on that portion of revenue. Effective , the\n\n agreement incorporated a tiered step-down structure for desktop revenue share rates.\n\n Under this schedule, the top tier rate was set at %( ) through\n\n , decreasing to %( ) through , and ultimately stepping\n\n down to %( ) for the remainder of the term ending . As a\n\n result, the initial % rate had already lapsed prior to the entry of the Final Judgment.\n\n 31. Currently is receiving a desktop revenue share between % and %,\n\n (or, an effective rate of % to %).\n\n\n\n 11\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 13 of 29\n\n\n\n\n 32. Exhibit C, Section 10 of Plaintiffs\u2019 Proposed Template would further require\n\n Google to provide each Qualified Competitor with within\n\n thirty days of the agreement\u2019s effective date, , and\n\n \u2014to be spent on\n\n advertising on Google.com. This was taken from a one-off term with that dates to .\n\n Google has not provided in syndication agreements since , years before the\n\n effective date of the Final Judgment. Because the regardless of\n\n whether a Qualified Competitor implements the syndication services, they would also create a\n\n perverse incentive for entities to seek Qualified Competitor status in order to obtain .\n\n Technical Constraints Implicated by Plaintiffs\u2019 Proposed Template\n\n Ad Revenue Accounting\n\n 33. Google\u2019s syndication agreements define ad revenues as revenues that are\n\n . See Google Ads Template \u00a7 1.3.\n\n\n\n Google\u2019s agreements also provide that\n\n Google\u2019s payments are based on\n\n\n\n See id. \u00a7 14.1(b). These are\n\n important terms that are present in all of Google\u2019s syndication agreements\u2014without them, a\n\n syndication partner\u2019s noncompliance could cause an ad to appear alongside illegal content, and\n\n Google could not recover that ad revenue from the partner even if Google refunded the amount\n\n to the advertiser.\n\n\n\n\n 12\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 14 of 29\n\n\n\n\n 34. When Google confirms that ad clicks were invalid, Google fully refunds\n\n advertisers and then debits the invalid or unrecognized revenue from syndication partners.\n\n However, Section 1.1 of Plaintiffs\u2019 Proposed Template, which defines \u201cAd Revenues,\u201d would\n\n permit Google to withhold or claw back ad revenues generated from spam, bot traffic, or other\n\n fraudulent activity only if Google first notifies Plaintiffs and the TC at least thirty days in\n\n advance and provides Plaintiffs with an opportunity to audit and object, and would bar Google\n\n from withholding or clawing back any amount subject to an objection until the objection is\n\n resolved. As I explained in my January 16, 2026 declaration, my team encountered a scheme\n\n that resulted in tens of millions of dollars in click fraud over the course of only two months.\n\n ECF No. 1471-3 \u00b6 20. Requiring Google to delay its typical debit processes would be harmful to\n\n Google\u2019s advertisers and create significant administrative burden.\n\n 35. Google\u2019s payment pipelines run on automated, shared infrastructure that does not\n\n support treating Qualified Competitors differently from other partners. All AFS customers flow\n\n through the same payment pipelines and processes, and there is no way to segregate Qualified\n\n Competitors so that they are subject to different accounting practices. Accommodating\n\n Plaintiffs' Proposed Template\u2019s process would require Google to engineer new systems,\n\n requiring work across three to four different teams and affecting multiple workflows in the\n\n payment process. Forcing a 30-day pause or pre-approval before executing debits is technically\n\n unfeasible and disruptive to Google\u2019s financial workflows.\n\n 36. Section 5.1 of Plaintiffs\u2019 Proposed Template (and, for search services, Section\n\n 4.1) would also provide that a Qualified Competitor\u2019s payment obligations do not run until\n\n Google\u2019s services have been implemented across all of the Qualified Competitor\u2019s sites and\n\n client applications. This term is not included in any of Google\u2019s syndication agreements. For\n\n\n\n 13\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 15 of 29\n\n\n\n\n ads syndication, Google collects payment from advertisers and then pays the partner a revenue\n\n share. Withholding Google\u2019s payment rights until all Qualified Competitor properties are live\n\n penalizes Google for delays caused by the Qualified Competitor. Section 2.1 of Google\u2019s Ads\n\n Template instead provides that implementations are not launched, and are not payable, until\n\n Google has approved them in writing, with approval not to be unreasonably withheld or\n\n delayed\u2014these are the MFN terms in Google\u2019s syndication agreements.\n\n Ads on Mobile Applications\n\n 37. In December 2024, Google stopped allowing for the display of its search ads\n\n integrated into mobile applications and Google no longer offers a mobile software development\n\n kit for syndicated ads. The current allowance for ads on mobile is limited to ads displayed on\n\n mobile sites. Google\u2019s contracts and policies state that customers may not access AFS through,\n\n or as a result of, any application, plug-in, or other executable code running on a mobile device.\n\n See, e.g., Syndication Agreement, GOOG-DOJ-FJ-00000142 \u00a7 2.7; Syndication\n\n Agreement GOOG-DOJ-FJ-00000348 \u00a7 2.3.\n\n 38. Google\u2019s ad spam teams can monitor sites on desktop and mobile web sites by\n\n navigating to them, but it is far more difficult to monitor whether mobile applications comply\n\n with Google\u2019s policies. Inspecting compiled software for malicious behavior requires\n\n substantially more effort and specialized skills compared to inspecting websites, which have all\n\n of their code open to the public. When users download mobile applications, an application can\n\n make covert changes to the user\u2019s device or download malware. Google\u2019s experience with\n\n downloadable desktop applications included deceptive user acquisition, deceptive installation\n\n tactics, and deceptive settings changes, and Google lacks effective tools to monitor and enforce\n\n against similar conduct in mobile applications at scale. Google no longer monetizes mobile\n\n\n\n 14\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 16 of 29\n\n\n\n\n applications through syndicated search ads because of these enforcement difficulties, and\n\n offering such monetization would make these deceptive schemes more profitable.\n\n 39. I understand the Plaintiffs\u2019 Proposed Template does not require Google to offer a\n\n mobile application software development kit to Qualified Competitors, though Exhibit C Section\n\n 3.3 does require that Google will \u201ccollaborate in good faith to implement the Search Text\n\n Advertising Service(s) on the Client Application(s) and Syndication Application(s),\u201d including\n\n \u201cproviding commercially reasonable technical support and cooperation necessary to enable such\n\n implementation.\u201d This provision would force Google to enable a mobile app implementation\n\n that is forbidden by its contractual terms.\n\n 40. And whether implemented via a mobile application software development kit, or\n\n through some other method, allowing mobile app developers to integrate AFS ads onto their apps\n\n will weaken Google\u2019s spam protections and potentially expose the contents of Google\u2019s iframe,\n\n exposing Google\u2019s intellectual property. When ads show on websites, the browser provides a\n\n layer of security such that a website owner could not effectively scrape the contents of Google\u2019s\n\n iframe. But in a mobile application, the app will have additional operating system privileges that\n\n would allow it to inspect the content of Google\u2019s ads without the ability for Google to detect this\n\n behavior.\n\n Subsyndication\n\n 41. Exhibit A, Section 3.4 of Plaintiffs\u2019 Proposed Template would require Google to\n\n treat any information about a Qualified Competitor\u2019s syndicated sites and applications as\n\n \u201cHighly Confidential\u201d under the Protective Order, to restrict access to that information on a\n\n need-to-know basis, and to certify to the Qualified Competitor, Plaintiffs, and the TC that it has\n\n implemented confidentiality procedures before receiving any such information.\n\n\n\n 15\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 17 of 29\n\n\n\n\n 42. Google\u2019s data stack cannot support that requirement. Publisher data for AFS is\n\n maintained horizontally throughout shared infrastructure, not segregated by individual owner.\n\n For that reason, partitioning subsyndicate data into distinct tables and permission tiers would\n\n necessitate the development of parallel logging and database architectures\u2014a major engineering\n\n undertaking that would take years to complete.\n\n 43. Google\u2019s existing policies, which state that employees may access data only as\n\n necessary to perform their roles, are designed to protect commercially sensitive information\n\n regarding subsyndicates. All Google personnel who access AFS data must agree to Google\u2019s\n\n , which prohibits competitive use of business platform data.\n\n Google employees complete annual compliance training on this policy.\n\n 44. At the most fundamental level, Google needs to know the identity of each\n\n subsyndicate in order to provide the services. Section 2.3(c) of Google\u2019s Ads Template requires\n\n the partner to name the subsyndicate that owns and operates each syndicated property, and\n\n Exhibit D of that template passes through Google\u2019s material terms to subsyndicates, requires that\n\n\n\n\n Section 5.7 of Plaintiffs\u2019 Proposed\n\n Template contains none of these protections. To protect advertisers, Google confirms that the\n\n named subsyndicate has editorial control over each site receiving the services, monitors whether\n\n the site is receiving bot traffic, and confirms that the subsyndicate is not an entity previously\n\n terminated from the service for policy violations. Bad actors removed from AFS for ad fraud\n\n sometimes attempt to regain access to the services through subsyndication. Without pass-\n\n through of Google\u2019s terms, a subsyndicate that is suspended for violating Google\u2019s policies could\n\n\n\n 16\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 18 of 29\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 19 of 29\n\n\n\n\n 47. Plaintiffs\u2019 Proposed Template further requires that, \u201cGoogle shall not take any\n\n actions that have the effect of slowing Search Service Network Latency, including, without\n\n limitation, in circumstances where Search Service Network Latency is below the Search Service\n\n Network Latency Threshold, with the intent of approaching or reaching the Search Service\n\n Network Latency Threshold, even if doing so would decrease costs for Google.\u201d Plaintiffs\u2019\n\n Proposed Template, Exhibit C \u00a7 2.1(b). Google has never included any such term in any of its\n\n syndication agreements because it is industry standard to use load shedding, the practice of\n\n dropping requests during extraordinary traffic spikes to prevent system-wide overload.\n\n 48. Google\u2019s syndication services share common servers with Google.com search\n\n services, and these servers will automatically perform load shedding on a system-wide basis,\n\n including on requests to Google.com. But under Plaintiffs\u2019 template, Google would be prevented\n\n from using this ordinary course traffic management practice because it could in some instances\n\n slow the Search Service Network Latency for Qualified Competitors.\n\n 49. To guarantee that Qualified Competitors\u2019 traffic is not impacted by system-wide\n\n load shedding, Google would need to isolate syndication services for the Qualified Competitors\n\n onto isolated servers, which would require significant time and engineering work to accomplish.\n\n 50. And because Exhibit C, Section 2.1(b) is very broad (\u201cGoogle shall not take any\n\n actions that have the effect of slowing Search Service Network Latency\u201d) it could be interpreted\n\n to mean that Google cannot even launch product improvements that have a side effect of slowing\n\n latency, which is fairly common for launches that increase ad candidates to improve relevancy in\n\n the auction.\n\n 51. Furthermore, Plaintiffs\u2019 Proposed Template requires % of AFS ads to be\n\n under 1 second, which is currently not being met. Because Google runs an ad auction each time\n\n\n\n 18\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 20 of 29\n\n\n\n\n a syndicated ad is requested, a portion of requests take longer to process: approximately %\n\n of U.S. AFS ad requests take longer than one second on the server because U.S. traffic has\n\n denser ad auctions on average.\n\n 52. The severity-error classifications and the associated resolution deadlines and\n\n service credits in Exhibit C, Sections 4.2 and 4.3 do not appear in any of Google\u2019s syndication\n\n SLAs, and Google does not guarantee resolution times in any of its syndication agreements\n\n because doing so may not be technically possible during extraordinary events.\n\n 53. The Syndication Forecasting portion of the Plaintiffs\u2019 Proposed Template, which\n\n proposes to use a 10% increase in peak QPS to determine how much advanced notice Google\n\n will receive, presents additional technical and operational issues. There may be significant\n\n variance in the query volumes and peak QPS of the Qualified Competitors. A 10% increase\n\n could encompass an enormous amount of machine capacity,\n\n\n\n\n Proxy Architecture\n\n 54. Exhibit B, Section 3 of the Proposed Template defines a\n\n\n\n\n However, that description does not\n\n reflect how\n\n\n\n 19\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 21 of 29\n\n\n\n\n .11 In a typical AFS implementation, the user\u2019s browser requests the\n\n search results page from the partner\u2019s server, and that page instructs the browser to load Google-\n\n owned AFS JavaScript from a Google server. The AFS JavaScript then sends the ad request\u2014\n\n including the publisher\u2019s identity and the user\u2019s query\u2014to a Google server. Google runs an ad\n\n auction and serves ads relevant to the query. When the user clicks an ad, the browser sends a\n\n request to a Google server reporting the click, and Google directs the browser to the advertiser\u2019s\n\n website. The end user\u2019s IP address is visible to Google at each of these steps.\n\n 55.\n\n\n\n\n 56.\n\n\n\n\n 57.\n\n\n\n\n 11\n Google has never .\n 20\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 22 of 29\n\n\n\n\n As I testified at the\n\n remedies hearing, Google must collect signals directly from the user\u2019s device in order to detect\n\n bots and invalid activity and to verify the integrity of each click.\n\n\n\n\n Query Rewriting and Keyword Match\n\n 58. Section 6.7 of the Proposed Template would allow Qualified Competitors to apply\n\n their own query rewriting technology\u2014including query correction, modification, or expansion\u2014\n\n without limitation, and provides that requests issued after such rewriting will not be deemed\n\n synthetic queries. The provision places no limit on how far a rewritten query may depart from\n\n the query the end user entered.\n\n 59. Google does not permit its current syndication partners to use their own query\n\n correction technology. Google\u2019s agreements require that each query be entered by a human end\n\n user, that each request contain that query, and that partners not edit, truncate, append terms to, or\n\n otherwise modify the query. See Google Ads Template \u00a7\u00a7 2.2, 2.3(f), 3.2(b); Google Search\n\n Template \u00a7 2.3(e).\n\n 60. Third-party query alteration breaks Google\u2019s exact-match keyword guarantees to\n\n advertisers (who bid on specific query terms) and risks serving irrelevant ads that damage\n\n advertiser return on investment. For example, if an advertiser opts into exact match, Google\n\n must ensure that the advertiser\u2019s ads show only on queries that are nearly an exact match to the\n\n\n\n\n 21\n\fCase 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 23 of 29\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 24 of 29\n\n\n\n\n implemented the services, reviews the implementations. Google also reviews subsequent\n\n changes to approved sites, client applications, and implementations to ensure ongoing\n\n compliance with its policies. Google\u2019s templates reflect this process: Section 2.1 of the Google\n\n Ads Template and the Google Search Template requires Google\u2019s written approval before an\n\n implementation goes live; Section 10.3(a) of the Google Ads Template permits Google to\n\n approve or disapprove, in its reasonable discretion, new sites and client applications on days\u2019\n\n notice; and Exhibit A of that template confirms that approved sites remain subject to the\n\n agreement and that Google may cease providing the service to non-compliant sites.\n\n\n\n\n Google\n\n uses these approval rights to monitor for invalid traffic, misleading display of advertisements,\n\n and illegal or objectionable content such as Child Sexual Abuse Material. Google applies these\n\n approvals to Qualified Competitors in the same manner it does for all other syndication partners\n\n and does not intend to use them as a veto over Qualified Competitors.\n\n 64. The timing of enforcement matters to advertisers. Each day that syndication\n\n services remain active on a site engaged in fraud, millions of dollars in fraudulent bot traffic can\n\n be imposed on Google\u2019s advertisers, and advertisers\u2019 ads may continue to show alongside illegal\n\n or objectionable content. However Section 5.3 of Plaintiffs\u2019 Proposed Template gives the\n\n Qualified Competitor and their subsyndicates five days to remove unacceptable content and bars\n\n Google from suspending service for such content without three business days\u2019 advance notice to\n\n Plaintiffs and the TC; and Section 16.2 requires fifteen business days\u2019 notice before Google may\n\n act on a material breach, with further delay if Plaintiffs object. By contrast, Sections 3.2(n) and\n\n\n\n 23\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 25 of 29\n\n\n\n\n 3.3(b) of the Google Ads Template permit Google to suspend service, in as targeted a fashion as\n\n is commercially reasonable, when unacceptable content appears or the partner is out of\n\n compliance. For many content violations, Google must act immediately to remove its ads from\n\n the site, such as when bad actors are trying to use AFS to monetize sites containing Child Sexual\n\n Abuse Material or promoting terrorism.\n\n To accommodate the Proposed\n\n Template\u2019s periods,\n\n , which would be burdensome from\n\n an engineering perspective and would delay provision of the services.\n\n Google\u2019s Policies and the Advertiser Ecosystem\n\n 65. Every AFS and WSS partner is subject to Google\u2019s policies, guidelines, and\n\n technical protocols, including the Google Program Guidelines, the Google Branding Guidelines,\n\n the Client Application Guidelines, the Google Technical Protocols, the Acceptable Use Policy,\n\n and the AdSense for Search Restricted Access Features (\u201cRAF\u201d) Policy. The Proposed Template\n\n omits these policies. Instead, Exhibit C, Section 5.4 provides that Google may propose \u201cGoogle\n\n Guidelines and Protocols\u201d only through the amendment procedures in Section 20, after the\n\n agreement\u2019s effective date and with no defined end date, and Section 1.35 and Exhibit C, Section\n\n 5.1(h) define unacceptable content solely by reference to whatever guidelines are adopted\n\n through that process.\n\n 66. These policies serve to safeguard advertisers, users, and Google\u2019s intellectual\n\n property. For instance, the Google Branding Guidelines do not only apply to results that include\n\n Google\u2019s branding, but also include broader requirements that advertisements must be clearly\n\n labeled and distinguished from organic search results, and alterations to the content of individual\n\n\n\n 24\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 26 of 29\n\n\n\n\n search results are strictly prohibited\u2014a measure that further protects Google\u2019s intellectual\n\n property. To prevent applications from deceiving users or defrauding advertisers, such as\n\n through unwanted software installations, compliance with the Client Application Guidelines is\n\n also required. Additionally, the Acceptable Use Policy prohibits sites from hosting unlawful or\n\n harmful content, including computer viruses or Child Sexual Abuse Material. Prohibited\n\n practices like deceptive ad presentation are governed by the Google Program Guidelines, which\n\n also regulate alternative search mechanisms such as keyword appending and related search units.\n\n Finally, the RAF Policy establishes rules regarding special AFS features, such as click tracking\n\n and alternative search queries, which carry greater risk to advertisers and to Google and requires\n\n additional restrictions\n\n 67. Google must be able to update its policies, guidelines, and technical protocols as\n\n methods of abuse and click fraud evolve. Companies in the ad syndication space are constantly\n\n creating new schemes to increase their revenue at the expense of advertisers, and Google is\n\n engaged in a continual effort to detect and end those practices. As I testified at the remedies\n\n hearing, Google tightened its ad styling restrictions after receiving advertiser escalations about a\n\n partner whose ad display\u2014which used hard-to-read text, a barely visible ad attribution, and an\n\n oversized call-to-action button\u2014generated 20% more revenue than a compliant display while\n\n leaving advertisers with low value clicks.\n\n 68. My understanding is that Exhibit C, Section 5.4 of Plaintiffs\u2019 Proposed Template\n\n would only permit Google to update its policies, guidelines, and technical protocols through a\n\n formal contract amendment that must be approved by Plaintiffs and the Technical Committee.\n\n This would cause a significant bottleneck for Google\u2019s Trust and Safety, Enforcement, and Spam\n\n teams, who together own the network of policies that govern the syndication services. If\n\n\n\n 25\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 27 of 29\n\n\n\n\n Google\u2019s policies cannot keep pace with changing ad fraud schemes, Google will be unable to\n\n maintain the quality of ad clicks on its search partner network, and I expect that advertisers will\n\n opt out of the network, limiting the monetization opportunity available to all partners, including\n\n Qualified Competitors. Google has instead proposed to provide notice to the Technical\n\n Committee and Plaintiffs should it intend to change the syndication policies in a manner that will\n\n impact Qualified Competitors.\n\n 69. Moreover, Google\u2019s policies, guidelines, and technical protocols may link to other\n\n Google policies that affect products other than the syndication services. For instance, Google\u2019s\n\n Program Guidelines may reference unwanted software policies, which also apply to products in\n\n the Chrome Web Store. As written, Exhibit C, Section 5.4 of Plaintiffs\u2019 Proposed Template may\n\n implicate even these policies, slowing down the work of many other Google teams.\n\n 70. And if Qualified Competitors are not bound to Google\u2019s ad policies, it is unclear\n\n whether they will be eligible for the in Exhibit C, Section 7 of\n\n Plaintiffs\u2019 Proposed Template.\n\n\n\n\n .\n\n Additional Concerns Presented by Plaintiffs\u2019 Template\n\n 71. Plaintiffs\u2019 Proposed Template also makes a number of unnecessary changes to\n\n Google\u2019s typical contractual language, which essentially break many of Google\u2019s policies and\n\n would result in various unintended consequences.\n\n 72. For instance, section 2.3(e) of the Google Ads Template requires that ads be\n\n displayed in a single continuous block; because syndicated ads are rendered in an iframe, they\n\n\n\n 26\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 28 of 29\n\n\n\n\n are necessarily displayed in a single continuous block and cannot be interspersed with other\n\n advertisements.13 Sections 3.2(e) and (f) of the Google Ads Template also prohibit partners from\n\n framing or interfering with results pages and from inserting interstitial content between an ad and\n\n the page the user reaches by clicking it. These provisions appear in all of Google\u2019s syndication\n\n agreements, and the Proposed Template omits them from its list of restrictions in Exhibit C,\n\n Section 5.1. As written, it is not technologically possible for Google to comply with Plaintiffs\u2019\n\n provision.\n\n 73. Additionally, Plaintiffs define a SERP as any page or screen containing \u201cSearch\n\n Results,\u201d a term limited to Google's organic results. As a result of this definition, webpages that\n\n only show Google\u2019s ad results are not SERPs, and any obligations tied to SERPs will not apply\n\n to pages that only contain Google\u2019s ads. This creates an improper loophole to the restrictions in\n\n Google\u2019s ordinary course agreements.\n\n 74. Google\u2019s syndication agreements define an \u201cAd\u201d as an individual search text ad\n\n provided through Google\u2019s service, so that the agreements\u2019 restrictions apply only to the ads\n\n Google provides. See Google Ads Template \u00a7 1.1. Section 1.22 of the Plaintiffs\u2019 Proposed\n\n Template omits that definition and instead provides that \u201cSearch Text Ad\u201d has the meaning\n\n assigned to it in Section IX.Y of the Final Judgment\u2014a generic definition that is not limited to\n\n ads provided by Google. The term therefore covers a Qualified Competitor\u2019s own ads and ads\n\n provided by third parties, as other provisions of the Proposed Template confirm: Section 5.6\n\n compares Search Text Ads made available under the agreement to \u201cSearch Text Ads or Search\n\n Text Ad Sets provided by Signatory, its Affiliate(s), or any third party,\u201d and Section 6.2 provides\n\n that a Qualified Competitor is free to use and display \u201ctheir own . . . Search Text Ads . . . or\n\n\n\n 13\n However, third party advertisements can be shown above or below the block of AFS ads.\n 27\n\f\u000f\u0018\u0012\u001b\u001a\u0015\u0014\u0017 \u0010\u0017\u001c\u0013\u0016\u0018\u0019\u0013 \u0011\u000f \u0004\u0004\u0004\u000e\u0006\u0005\u000f \u0002\n \u0003\u0002 \u0004\u000e\u0005\u0002 \u0003 \u0002\b\u000e\u0006\u0006\u0007 \b\u000e\u0006\u0006\u0010\n Case 1:20-cv-03010-APM Document 1567-7 Filed 10/23/26 Page 29 of 29\n\n\n\n\n those of a third party.\u201d Because the Proposed Template uses the generic term throughout, it\n\n produces results that appear unintended. For example, the restrictions in Exhibit C, Section 5.1\u2014\n\n including the prohibitions on modifying or obscuring the display of \u201cany Search Text Ads\u201d and\n\n on caching information obtained from the services, \u201cincluding . . . Search Text Ads\u201d\u2014would by\n\n their terms apply to every search text ad a Qualified Competitor displays, not only to Google\u2019s\n\n ads. The Google Ads Template avoids this problem by limiting its restrictions to the ads Google\n\n provides, consistent with Google\u2019s ordinary-course terms.\n\n * * * *\n\n I declare under penalty of perjury that the foregoing is true and correct.\n\n\n Executed on this 16th day of October 2026, in Pittsburgh, Pennsylvania.\n\n\n __ ___________\n Jesse Adkins\n\n\n\n\n 28\n\f","ocr_status":1,"date_upload":"2026-10-23T19:16:21.405521-07:00","document_number":"1567","attachment_number":7,"pacer_doc_id":"045012431087","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487569/","id":498487569,"tags":[],"absolute_url":"/docket/18552824/1567/8/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.318396-07:00","date_modified":"2026-10-26T17:47:17.595856-07:00","sha1":"51860060329df8ed055f56cad6820527dfe40516","page_count":19,"file_size":305042,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.8.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.8.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487569.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 1 of 19\n\n\n\n\n Exhibit 8\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 2 of 19\n\n\n\n\n Liberty Square Building\n 450 5th Street, N.W.\n Washington, DC 20530\n\n\n September 15, 2026\n\n\n\nColette Connor, Esq.\nWilliams & Connolly LLP\n680 Maine Ave SW\nWashington, DC 20024\n\n Re: United States et al. v. Google LLC, 1:20-cv-03010-APM (D.D.C.)\n\nDear Colette:\n\n Pursuant to the order of operations and timing for Category 2 Recommendations,\nECF Nos. 1528-2, 1529, Plaintiffs together with the Technical Committee (\u201cTC\u201d) hereby\nrespond to your letter and Attachment A thereto of September 8, 2026 (\u201cRequests\u201d),\nseeking additional information regarding the recommended template search syndication\nand Search Text Ads syndication license, provided to Google on August 31, 2026\n(\u201cRecommended Template\u201d).\n\n As stated in the Cover Recommendation, in developing the Recommended\nTemplate, Plaintiffs and the TC affirmatively sought input from Google, reviewed\ndocuments and information provided by Google, engaged with third parties, and brought\nto bear the cumulative experience of Plaintiffs in the underlying litigation and of TC\nMembers and TC Staff as professionals working extensively in the industry for over 20\nyears. Where the Final Judgment sets explicit requirements, those requirements are\nreflected within the main body of the Recommended Template. Where the Final\nJudgment demands terms no less favorable than Google\u2019s commercial agreements\u2014or\nexplicitly pins terms to Google\u2019s commercial agreements\u2014the Recommended Template\nwas supplemented with appropriate language in exhibits derived from the TC\u2019s analysis\nof Google\u2019s commercial syndication agreements.\n\n Pursuant to the order of operations and timing for Category 2 Recommendations,\nECF Nos. 1582-2, 1529, Google had the opportunity to request additional information\nregarding the Recommended Template if it had a good faith belief that such information\nwas necessary to comply with or exercise its right to object under the Final Judgment. By\nyour September 8 letter, Google has submitted approximately 100 Requests for additional\ninformation. To facilitate providing responses, Plaintiffs have annotated your September\n8 letter and Attachment A to add numbers to the Requests. Copies of the annotated letter\nand attachment are being provided contemporaneously with these responses. As you will\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 3 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 2\n\nsee below, we have identified by number the Request(s) to which a given response is\nbeing provided.1\n\n Plaintiffs have in good faith considered each of these Requests and provided any\nappropriate responses thereto. In responding to any given Request, Plaintiffs and the TC\ndo not concede, nor should any response be construed as conceding, that the Request\nitself is appropriate or that the information sought by the Request is relevant to Google\u2019s\nability to exercise its right to object under the Final Judgment.\n\n Before addressing Google\u2019s specific Requests below, Plaintiffs more broadly note\nthat Google appears to take issue with Plaintiffs and the TC\u2019s treatment of Google\u2019s\nAugust 10, 2026, submission to the TC, which Google describes as \u201cinclud[ing] complete\ntemplate licenses for search syndication and search ads syndication and explain[ing] why\n[those] licenses would be consistent with the Court\u2019s Final Judgment.\u201d Plaintiffs and the\nTC reviewed all of Google\u2019s input, including its August 10 submission. They were not,\nhowever, required to follow or rely on Google\u2019s proposed template licenses in developing\nthe Recommended Template. And indeed, it would make little sense if Google were able\nto dictate the terms of its own syndication remedies.\n\n Google also appears to take issue with various departures from and omissions of\nits \u201cstandard\u201d terms. The Court was clear, however, that remedial syndication licenses\nneed not mirror Google\u2019s standards terms exactly\u2014and in fact, the Court anticipated that\nthere may be variations from Google's \u201cordinary commercial terms\u201d within remedial\nsyndication licenses in order to promote the \u201cinnovation this [syndication] remedy\nattempts to encourage,\u201d and preserve availability of syndication remedies to Qualified\nCompetitors even where they \u201chop[e] to compete by offering unique services or\nfeatures.\u201d Final J. Op. at 37-39. Google itself \u201crecognize[s] there are adjustments needed\nto Google\u2019s standard terms given the procedural circumstances.\u201d Google Req. No. 38.\n\n Subject to the foregoing, Plaintiffs together with the TC further respond to\nGoogle\u2019s Requests as follows:\n\n Re Google Request Nos. 1, 11\u201312: Plaintiffs and the TC drafted the\nRecommended Template to comply with the Court\u2019s instruction that providers of GenAI\nProducts be included within the Final Judgment\u2019s definition of Qualified Competitor to\n\u201cleave no doubt that the remedies extend to [GenAI Product] companies.\u201d Final J.\n\u00a7\u00a7 IX.E, IX.V; Rem. Op. at 103\u201304. Plaintiffs and the TC further took into account that\nthe \u201cpurpose of this [syndication] remedy is to provide a short-term measure for\nQualified Competitors to compete as they improve their own search capabilities, not an\nadditional means to facilitate that development.\u201d Rem. Op. at 178.\n\n Further as to Request No. 1, the Court understood that, \u201cas to the data-sharing\nand syndication remedies,\u201d GenAI Products \u201cgrounded in general search perform an\n\n\n1 Please note that the number \u201c94\u201d was inadvertently skipped and therefore is not\n\nreferenced in the responses below.\n 2\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 4 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 3\n\ninformation-retrieval function that is similar to GSEs,\u201d such that GenAI Products are a\n\u201cpotential threat to Google\u2019s dominance in the market for general search services.\u201d Id. at\n99\u2013100. For clarity, Plaintiffs and the TC have drafted the Recommended Template with\nthe intent to ensure that search syndication and Search Text Ads syndication remedies\ncan extend to GenAI Product providers. The Recommended Template does not, however,\nreference Google\u2019s FastSearch results or other services available through Google\u2019s\nVertex platform, nor do we intend for the syndication remedies to encompass these\nservices. See id. at 179.\n\n Further as to Request No. 11, Plaintiffs and the TC also drafted the\nRecommended Template to comply with the Court\u2019s instruction that syndication\nremedies should extend to Qualified Competitors \u201choping to compete by offering unique\nservices or features,\u201d including in circumstances where such a Qualified Competitor\nrequires license terms that are \u201cnot \u2018ordinary\u2019 or typical to Google\u2019s existing syndication\nagreements.\u201d Final J. Op. at 39. Accordingly, Plaintiffs do not interpret the Final\nJudgment or the Recommended Template as prohibiting purely transitory processing of\nsyndicated content by Qualified Competitors with GenAI Products to permissibly\nimplement the syndication remedies or display search results and Search Text Ads to End\nUsers. Plaintiffs do not intend for the Recommended Template to permit Qualified\nCompetitors to use syndicated data to train their GenAI Products. See Final J. Op. at 43\nn.10.\n\n Further as to Request No. 12, Section 4.4.c of the Recommended Template is not\nintended to permit improper use by Qualified Competitors of syndicated content or other\ninformation received from Google under the syndication remedies as a substitute for\nindependent web crawling or web index development, nor is it intended to limit the\nability of Qualified Competitors, including those offering GenAI Products or \u2018unique\nservices or features,\u201d to receive and implement the syndication remedies. See Final J. Op.\nat 39.\n\n Re Google Req. No. 2: Plaintiffs and the TC have drafted this language with the\nintent to preserve a Qualified Competitor\u2019s ability to ensure search results and Search\nText Ads are properly retrieved and displayed for their End Users, including for Qualified\nCompetitors who may need, inter alia, to correct typos or reformat Covered Queries\nreceived through GenAI Products (including as needed to ensure syndicated content is\nproperly displayed in GenAI Products). For clarity, Plaintiffs and the TC do not intend\nfor the Recommended Template to permit the issuance of synthetic queries, as prohibited\nby the Final Judgment. See Final J. \u00a7\u00a7 V.B.10, VI.B.9; Rem. Op. at 170, 178.\n\n Re Google Req. Nos. 3, 95: Plaintiffs and the TC do not intend to permit\nQualified Competitors to issue synthetic queries under the syndication remedies. The\nFinal Judgment is clear on this prohibition. Final J. \u00a7\u00a7 V.B.10, VI.B.9. As the Court\ndescribes them, synthetic queries are \u201cmade-up queries, by a human or machine, that a\nQualified Competitor could ask Google to run to test towards developing its own GSE.\u201d\nRem. Op. at 170. Plaintiffs and the TC have drafted the Recommended Template with\nthis definition and these prohibitions in mind.\n 3\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 5 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 4\n\n Google\u2019s questionining appears to assume that any difference between a Covered\nQuery and a Request issued to Google in response to such Covered Query would\nconstitute a synthetic query under the Final Judgment, but such differences could also\nresult from normal and permissible technical processes undertaken by Qualified\nCompetitors to ensure search results and Search Text Ads are properly retrieved and\ndisplayed for their End Users. For example, query processing by a Qualified\nCompetitor\u2014including, e.g., to correct typos or reformat Covered Queries issued to\nGenAI Products\u2014would facilitate the display of search results and Search Text Ads for\nEnd Users, not create \u201cmade-up queries\u201d issued to Google to \u201ctest towards developing [a\nQualified Competitor\u2019s] GSE.\u201d See id.\n\n Further as to Request No. 95, on the other hand, processing of Covered Queries\nas needed for the purpose of permissibly implementing the syndication remedies and\ndisplaying results and Search Text Ads to the End User is covered, even if it does so\nthrough agentic or non-human mechanisms.\n\n Re Google Req. No. 4: Plaintiffs and the TC drafted Section 6.3 of the\nRecommended Template after evaluating input from Google, including responses to\nTechnical Committee demand letters, commercial agreements, and Google\u2019s own\nsyndication proposals, and in compliance with the Final Judgment. See, e.g., Final J.\n\u00a7\u00a7 V.B.3, V.B.7, VI.B.6. For example, the language of is derived from\nGoogle commercial agreements (e.g., GOOG-DOJ-FJ-00000142) with the intent to\npreserve a Qualified Competitor\u2019s ability on terms \u201cno less\nfavorable than what [Google] provides under any current search syndication agreements\nas of the date of entry of th[e] Final Judgment.\u201d See Final J. \u00a7 V.B.7. The intent of this\nprovision is not to improperly manipulate search results or Search Text Ads, but to ensure\nQualified Competitors, including those intending to compete using GenAI Products, can\nproperly and effectively implement the syndication remedies and display results and\nSearch Text Ads to End Users.\n\n Re Google Req. No. 5: Google\u2019s understanding of the relationship between\nSection 6.3 and Exhibit C Section 2.2 of the Recommended Template is generally\ncorrect. Plaintiffs and the TC drafted these sections after evaluating input from Google\nand with the intent to preserve a Qualified Competitor\u2019s ability\n on terms \u201cno less favorable than what [Google] provides under any current\nsearch syndication agreements as of the date of entry of th[e] Final Judgment.\u201d See Final\nJ. \u00a7 V.B.7. The Exhibit C cross-reference in Section 6.3 is intended to encompass the\nlimiting language in Exhibit C Section 2.2.\n\n Re Google Req. Nos. 6, 8, 10, 21: Plaintiffs and the TC drafted the\nRecommended Template to conform to the Final Judgment\u2019s requirement that Google\nmust make remedial syndication licenses available to Qualified Competitors on terms \u201cno\nless favorable\u201d to those offered to any user of Google\u2019s search syndication products or\nSearch Text Ads syndication products, with certain exceptions where Google may impose\nits ordinary commercial terms (e.g., on scraping, indexing, or crawling syndicated results,\ncontent, and Search Text Ads). Final J. \u00a7\u00a7 V.B, VI.B; Final J. Op. at 37\u201343. As\n 4\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 6 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 5\n\nreitereated supra, where the Final Judgment demands terms no less favorable than\nGoogle\u2019s commercial agreements\u2014or where such terms must align to Google\u2019s ordinary\ncommercial restrictions\u2014the Recommended Template is supplemented with appropriate\nlanguage derived from Google\u2019s commercial syndication agreements, as set forth in\nExhibit C.\n\n Further as to Request No. 6, as to the inclusion of \u201cSearch Results\u201d alongside\n\u201cSearch Results Sets,\u201d Plaintiffs and the TC do not intend for this language to change\nGoogle\u2019s products or the rights of the parties. Rather, this language was included for\nclarity given the Final Judgment\u2019s language and use of \u201cresults\u201d rather than \u201cResults\nSets.\u201d See, e.g., Final J. \u00a7 V.A, V.B.7.\n\n Further as to Request No. 8, Plaintiffs and the TC drafted the quoted language in\nSection 4.4.a of the Recommended Template to reflect language used in the Final\nJudgment to describe the full scope of syndication information and materials covered by\nthe syndication remedies. See Final J. \u00a7\u00a7 V.A, V.B.6\u20137. The quoted language is not\nintended to conflict with language in Exhibit C Section 2.\n\n Further as to Request No. 10, Section 4.4.a was drafted to conform to the Final\nJudgment\u2019s inclusion of explicit language regarding a Qualified Competitor\u2019s display,\nuse, and integration of information or services obtained under a remedial syndication\nlicense. See Final J. \u00a7 V.B.6\u20137. For clarity, Plaintiffs and the TC do not intend for the\nRecommended Template to permit Qualified Competitors to use syndicated content in\nways that conflict with the Final Judgment or the Court\u2019s instructions. See, e.g., Rem. Op.\nat 178.\n\n Further as to Request No. 21, the Court was clear that remedial syndication\nlicenses need not mirror Google\u2019s standard terms exactly. Final J. Op. at 37\u201339. As to\nlatency, reliability, and performance requirements, Plaintiffs and the TC reviewed and,\nwhere appropriate, incorporated language derived from Google\u2019s input based on the Final\nJudgment\u2019s requirement that Google provide Qualified Competitors with latency,\nreliability, and performance \u201cfunctionally equivalent\u201d to what any other user of Google\u2019s\nsyndication services would receive as of the date of entry of the Final Judgment. Final J.\n\u00a7\u00a7 V.B.2, VI.B.1.\n\n Re Google Req. No. 7: Plaintiffs and the TC do not anticipate permitted use cases\nwhere a Qualified Competitor performs individual, result-level modifications to search\nresults received by Google under the syndication remedies.\n\n Re Google Req. No. 9: Plaintiffs and the TC drafted the Recommended Template\nto conform to the Final Judgment\u2019s requirements, including the required scope of\nsyndication and limitations on how Google may restrict a Qualified Competitor\u2019s ability\nto use, display, or integrate information or services obtained under the syndication\nremedies. See Final J. \u00a7\u00a7 V.A, V.B.6\u20137. Accordingly, the Recommended Template\u2019s\ntreatment of the ten blue links is intended to be\nthe same as for any other search results provided under the syndication remedies. If\n\n 5\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 7 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 6\n\nGoogle has concerns around this approach, Plaintiffs invite Google to identify or provide\nlanguage from its commercial syndication agreements relating to this point. Absent such\ncommercial language that Plaintiffs and the TC can independently verify, Plaintiffs and\nthe TC must follow the Final Judgment\u2019s requirements set forth in, e.g., Sections V.B.6\u2013\n7.\n\n Re Google Req. No. 13: The click tracking language included in Exhibit C\nSection 6 is informed by Google\u2019s commercial syndication agreements (e.g., GOOG-\nDOJ-FJ-00000348) and is intended to cover only click tracking for Search Text Ads.\nRegarding the second question, Plaintiffs and the TC do not intend for the Recommend\nTemplate to permit use of syndicated content and other information received from\nGoogle in ways that contradict the Final Judgement and the Court\u2019s instruction. See, e.g.,\nRem. Op. at 178.\n\n Re Google Req. No. 14: Under Section V.A of the Final Judgment, Google is\nrequired to make available to Qualified Competitors a search syndication license under\nwhich Google must provide, \u201cvia real-time API(s),\u201d the following information and data:\n(1) \u201cboth desktop and mobile versions of the ranked organic web search results obtained\nfrom crawling the web\u201d; (2) \u201cthe user-facing query-rewriting features that Google\nprovides under any of its current search syndication agreements as of the date of entry of\nthis Final Judgment, including user-facing Search Features that enable query correction,\nmodification, or expansion\u201d; and (3) \u201cthe Local, Maps, Video, Images, and Knowledge\nPanel Search Feature content that Google provides under any of its current search\nsyndication agreements as of the date of entry of this Final Judgment.\u201d The Final\nJudgment provides these requirements explicitly, rather than pinning the search\nsyndication Google must provide only to what Google ordinarily provides within its Web\nSearch syndication services. Given the Final Judgment\u2019s language and upon\nconsideration of Google\u2019s input, including Google\u2019s commercial syndication agreements,\nPlaintiffs and the TC have drafted the Remedial Web Search Service in Exhibit B to\nencompass Google\u2019s commercial Web Search syndication product and the Search Feature\ncontent required under Section V.A, including Video Search Feature content and any\nrelated beta programs or Product-Integrated Features (PIFs). Image Search syndication is\noffered separately given evidence of such service separation in Google\u2019s commercial\nsyndication agreements.\n\n Re Google Req. No. 15: Plaintiffs and the TC appreciate the added context\nprovided by Google regarding the technical feasibility of terms covering Search Text Ad\nformatting flexibility, display, and use. See Final J. \u00a7 VI.B.6. Without the Source Code\nAgreement in effect, Plaintiffs and the TC remain unable to independently confirm\nGoogle\u2019s assertions regarding this point.\n\n As a general matter, Plaintiffs and the TC drafted the Recommended Template to\nconform to the Court\u2019s view that Google may not reject variations from terms that are\n\u201c\u2018ordinary\u2019 or typical to Google\u2019s existing syndication agreements\u201d where such variations\nwould \u201censur[e] a certain degree of user-data protections\u201d or ensure the syndication\nremedies can extend to \u201cQualified Competitors hoping to compete by offering unique\n 6\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 8 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 7\n\nservices or features.\u201d Final J. Op. at 39. Plaintiffs and the TC understand that Google\u2019s\nimplementation of Search Text Ads via JavaScript and iFrames permits Google to track\nor receive granular data from syndication partners, which could require privacy-focused\nQualified Competitors to forego the Search Text Ads syndication remedies. If this\nunderstanding is incorrect, please let Plaintiffs know.\n\n Re Google Req. No. 16: Google has previously approved Search Text Ads for\ndisplay and revenue share in\n The TC has requested\ninformation related to all protocols for delivering syndication, but Google has not\nprovided it. The Recommended Template has therefore been drafted based on available\ninformation.\n\n In addition, Plaintiffs and the TC drafted the Recommended Template to\nminimize reliance on external Google policies and guidelines, which Google appears to\nbe able to unilaterally change under commercial agreements, to conform the\nRecommended Template to the Court's view that Google should not have an \"effective\nveto\" over remedial syndication terms or over which Qualified Competitors may receive\nsyndication remedies. See Final J. Op. at 37-39.\n\n Re Google Req. No. 17: Plaintiffs and the TC understand that Google\u2019s various\nexternal policies and guidelines, including Google\u2019s Program Guidelines, impose terms\nunilaterally on Google\u2019s syndication partners and may be changed at any time by Google\nwithout prior agreement by Google\u2019s syndication partners. The Final Judgment does not\npermit Google to unilaterally alter the terms of remedial syndication agreements in any\nway; Google is only permitted to propose additional Search Text Ad syndication terms\nunder Section VI.B.11 of the Final Judgment. Moreover, the Final Judgment does not\npermit Google to impose terms on Qualified Competitors that conflict with express\nrequirements of the Final Judgment, so Plaintiffs and the TC have drafted the\nRecommended Template with the intent of incorporating, where approrpiate under the\nFinal Judgment, as many technical implementation requirements and policies as possible\nwithin the Recommended Template itself.\n\n Re Google Req. No. 18: Plaintiffs and the TC drafted the Recommended\nTemplate to conform to the Final Judgment and the Court\u2019s instructions, including the\nCourt\u2019s view that that there may be variations from Google\u2019s \u201cordinary commercial\nterms\u201d within remedial syndication licenses in order to, e.g., increase clarity for Qualified\nCompetitors, promote the \u201cinnovation this [syndication] remedy attempts to encourage,\u201d\nand preserve availability of syndication remedies to Qualified Competitors even where\nthey \u201chop[e] to compete by offering unique services or features.\u201d Final J. Op. at 37\u201339.\nThe Recommended Template\u2019s broad treatment of Client Applications, including the\nadditional reference to Search Access Points, as defined by the Final Judgment, is\nintended to encompass the full set of applications, plug-ins, interfaces, browsers, GenAI\nProducts, etc., through which a Qualified Competitor may display syndicated content and\ncompete under the Final Judgment. This treatment conforms to the Final Judgment and\nthe Court\u2019s interest in (1) promoting innovation through syndication remedies and (2)\n 7\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 9 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 8\n\npreserving the availability of syndication remedies to \u201cQualified Competitors hoping to\ncompete by offering unique services or features.\u201d Final J. Op. at 37\u201339.\n\n Re Google Req. No. 19: In drafting the Recommended Template, Plaintiffs and\nthe TC considered and, where appropriate, incorporated input from Google to comply\nwith and facilitate the efficient implementation of the Final Judgment. The\nRecommended Template\u2019s definition of URL is taken from Google\u2019s Maps license\nproposal and included out of an abundance of caution. If Google has specific concerns\nregarding the language of this definition, please let Plaintiffs know.\n\n Re Google Req. No. 20: Thank you for this context and your offer to discuss\nprovisions requiring forecasts of projected syndication volume from Qualified\nCompetitors. Plaintiffs and the TC drafted the Recommended Template to conform to the\nFinal Judgment, including Sections V.B.6\u20139, and the purpose of the syndication\nremedies, which is to provide a short-term measure for Qualified Competitors to\ncompete. Rem. Op. at 178. For example, Plaintiffs and the TC have some concerns that\nrequiring Qualified Competitors to provide forecasts of syndication volume to Google\nmay inhibit the innovation and competition the syndication remedies were meant to\nencourage. See Final J. Op. at 39. Plaintiffs will confer with the TC regarding Google\u2019s\nrequest to discuss this provision.\n\n Re Google Req. Nos. 22, 46\u201366: As noted supra, where the Final Judgment\ndemands terms no less favorable than Google\u2019s commercial agreements\u2014or where such\nterms must align to Google\u2019s ordinary commercial restrictions\u2014the Recommended\nTemplate is supplemented with appropriate language derived from Google\u2019s commercial\nsyndication agreements. The Court, however, was clear that remedial syndication licenses\nneed not mirror Google\u2019s standards terms exactly; in fact, the Court anticipated that there\nmay be variations from Google\u2019s \u201cordinary commercial terms\u201d within remedial\nsyndication licenses in order to, e.g., increase clarity for Qualified Competitors, promote\nthe \u201cinnovation this [syndication] remedy attempts to encourage,\u201d and preserve\navailability of syndication remedies to Qualified Competitors even where they \u201chop[e] to\ncompete by offering unique services or features.\u201d Final J. Op. at 37\u201339.\n\n In the Recommendation Statement and Basis Statement, Plaintiffs have already\nprovided (1) an explanation of the process Plaintiffs and the TC undertook to evaluate\ninput from Google and third parties, as well as to determine the recommended terms\npresent in the Recommended Template, and (2) an account of the materials relied upon to\ninform the Recommendation, including the Recommended Template. Plaintiffs\nunderstand from Google\u2019s phrasing that at this time, it does not have any specific\nquestions regarding the provisions referenced in the respective Requests, apart from what\nis apparent in the parentheticals at Request Nos. 57 and 62.\n\n Further as to Request No. 22, Exhibit B Section 3 of the Recommended Template\nwas drafted with the understanding that the Court explicitly contemplated extending the\nsyndication remedies to privacy-focused Qualified Competitors and other Qualified\nCompetitors \u201choping to compete by offering unique services or features,\u201d including in\n\n 8\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 10 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 9\n\ncircumstances where such a Qualified Competitor requires license terms that are \u201cnot\n\u2018ordinary\u2019 or typical to Google\u2019s existing syndication agreements.\u201d Id. at 39. In addition,\nRequest No. 22 suggests that\ndiffers from in the Recommended Template. Please provide information\nor documentation on Google\u2019s so that Plaintiffs and the TC\nmay consider it.\n\n Further as to Request Nos. 57 and 66, regarding Google\u2019s Branding Guidelines,\nthe Court was clear in its Memorandum Opinion Supporting the Final Judgment that \u201cthe\nsyndication remedy is meant to give Qualified Competitors a boost in quality while they\ndevelop competitive products, not to pose as Google in the meantime.\u201d Final J. Op. at 42.\nRequiring Qualified Competitors to adopt Google Branding Guidelines is at odds with the\nCourt\u2019s language and the remedial goals of the syndication remedies. More generally,\nPlaintiffs and the TC drafted the Recommended Template to minimize reliance on\nexternal Google policies and guidelines, which Google appears to be able to unilaterally\nchange under commercial agreements, to conform the Recommended Template to the\nCourt\u2019s view that Google should not have an \u201ceffective veto\u201d over remedial syndication\nterms or over which Qualified Competitors may receive syndication remedies. See Final\nJ. Op. at 37\u201339.\n\n Further as to Request No. 62, regarding the parenthetical, the language of Section\n27.1 is derived from a Google syndication agreement (GOOG-DOJ-FJ-00000142) and\ndoes not \u201cremove industry-standard exclusions.\u201d Rather, Plaintiffs and the TC intend for\nreferences to Google to align with the Final Judgment\u2019s definition, which includes\naffiliates. Final J. \u00a7 IX.L.\n\n Further as to Request No. 65, regarding the parenthetical, Plaintiffs and the TC\ndrafted Exhibit C Section 8.3 of the Recommended Template to comply with the Final\nJudgment requirements regarding limitations on what information Google can require\nQualified Competitors to share under the syndication remedies and how Google may\nretain or use that information language, Final J. \u00a7\u00a7 V.B.8\u20139, VI.B.3\u20134, with language\nderived from Google commercial agreements (e.g., GOOG-DOJ-FJ-00000142).\n\n Re Google Req. Nos. 23, 25: Thank you for this context regarding Google\u2019s\nreview of implementations as well as Sites and Client Applications. Plaintiffs and the TC\nhave drafted the Recommended Template with the understanding that Qualified\nCompetitors must abide by the Recommended Template\u2019s requirements for\nimplementations of Sites and Client Applications, such as those set forth in Sections 4.2\nand 5.2 of the Recommended Template. While, as a general matter, Plaintiffs and the TC\ndo not interpret the Final Judgment as granting Google a unilateral approval right over\nthe availability of syndication remedies to Qualified Competitors, Plaintiffs and the TC\nhave drafted Exhibit A Section 3 with the intent to permit Google to reject Sites and\nClient Applications, including implementations thereof, with prior notice to Plaintiffs, the\nTC, and the relevant Qualified Competitor if extending the Services to such Sites, Client\nApplications, Syndicated Sites, or Syndicated Application would violate the terms of the\nRecommended Template.\n 9\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 11 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 10\n\n Re Google Req. No. 24: Plaintiffs and the TC have drafted the Recommended\nTemplate to conform to the Final Judgment\u2019s requirements, which include the explicit\nrequirement that Google include Qualified Competitors in its Search Partner Network.\nFinal J. \u00a7 VI.B.5. This requirement is not paired with any terms permitting Google to\nlimit inclusion based on verification or other procedures, and the Court does not\ncontemplate such limitations in either its Remedies Opinion (ECF No. 1436) or Final\nJudgment Opinion (ECF No. 1461). If Google has specific concerns underlying its\nrequest to impose verification or other requirements on Qualified Competitors before\ncomplying with this Final Judgment provision, please let Plaintiffs know.\n\n Re Google Req. No. 26: The references to \u201ccontent flags\u201d and \u201ccontextual\nfeatures\u201d in Exhibit B Section 1 are intended to capture signals and protocols leveraged to\nsurface Search Feature content within the remedial Web Search Service. Cf. Ltr. from C.\nConnor to Technical Committee (Aug. 14, 2026) (describing\n ). The TC has requested information related\nto how the signals or protocols for such features work and how they are delivered, but\nGoogle has not provided it. The Recommended Template has therefore been drafted\nbased on available information..\n\n Re Google Req. No. 27: As described in Exhibit B Section 1, Plaintiffs and the\nTC have drafted the Recommended Template to include a remedial Search Text Ads\nsyndication service that encompass the full scope of Search Text Ads syndication covered\nby the Final Judgment. This includes \u201call types of Search Text Ads (including any assets,\nextensions, or similar Search Text Ad variations) available through [Google\u2019s]\nsyndication products,\u201d including AdSense for Search and \u201cany other current or future\nproducts offering syndicated Search Text Ads.\u201d Final J. \u00a7 VI.B.1. In drafting the\nRecommended Template, Plaintiffs and the TC reviewed and, where appropriate,\nincorporated input from Google, such as responses to Technical Committee demand\nletters, commercial agreements, and Google\u2019s own syndication proposals. The resulting\nRecommended Template includes language intended to cover not only AdSense for\nSearch but also services and features covered by other Google Search Text Ads\nsyndication products, such as the AdSense Direct Program,\n , and other related beta programs and PIFs. See, e.g., Ltr. from C. Connor to\nTechnical Committee (Aug. 14, 2026). The Recommended Template does not encompass\nthe deprecated AdSense for Domains program or the AdMob Program.\n\n Re Google Req. No. 28: Plaintiffs and the TC drafted the Recommended\nTemplate in conformity with the Final Judgment\u2019s requirement that Google must make\nremedial syndication licenses available to Qualified Competitors on terms \u201cno less\nfavorable\u201d to those offered to any user of Google\u2019s search syndication products or Search\nText Ads syndication products, rather than on Google\u2019s \u201cordinary commercial terms\u201d\u2014\nexcept that Google may impose its ordinary commercial restrictions on scraping,\nindexing, or crawling syndicated results, content, and Search Text Ads. Final J. \u00a7\u00a7 V.B,\nVI.B; Final J. Op. at 37\u201343. Plaintiffs\u2019 and the TC\u2019s treatment of subsyndication within\nthe Recommended Template is intended to reflect the limited scope of subsyndication\npermitted under the Final Judgment: sub-syndication is only permitted for Search Text\n 10\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 12 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 11\n\nAds syndication and only where a Qualified Competitor has been certified as a\nCompetitor to a Google ads platform. Compare Final J. \u00a7 V.B.10 with id. \u00a7 VI.B.9.\nUnder these circumstances, Google\u2019s proposed subsyndication terms may require\nimproper information sharing among Competitors. For example, Google\u2019s proposed\nrequirement that, e.g., Qualified Competitors identify all subsyndicates to Google\namounts to a requirement that Competitors to Google\u2019s ads platform must share their own\nads platform client list\u2014which is competitively sensitive information\u2014with Google in\norder to benefit from the remedy. Such a requirement would undermine the purpose of\nthis syndication remedy. See Final J. Op. at 37\u201339.\n\n Re Google Req. No. 29: To clarify, by \u201cpersonalization is not available for AFS,\u201d\ndoes Google mean that only non-personalized Ads are available through AdSense for\nSearch, or that AdSense for Search does not currently support non-personalized Ads? In\neither case, please confirm whether personalization was ever available for AdSense for\nSearch, and if so, when personalization became unavailable for AdSense for Search.\n\n Re Google Req. Nos. 30\u201332, 43: Plaintiffs and the TC drafted the Recommended\nTemplate to conform to the Final Judgment\u2019s requirement that Google must make\nremedial syndication licenses available to Qualified Competitors on \u201cfinancial terms no\nworse than those offered to any other user\u201d of Google\u2019s search syndication products or\nSearch Text Ads syndication products. Final J. \u00a7\u00a7 V.A, VI.B.2. As described in the\nRecommendation Statement, where the Final Judgment demands terms no less favorable\nthan Google\u2019s commercial agreements, Plaintiffs and the TC included language in the\nRecommended Template derived, where appropriate, from the TC\u2019s analysis of the most\nfavorable financial terms in Google\u2019s commercial syndication agreements (including,\ne.g., GOOG-DOJ-FJ-00000142 and GOOG-DOJ-FJ-00000348).\n\n In its Memorandum Opinion Supporting the Final Judgment (ECF No. 1461), the\nCourt made clear that the remedial syndication licenses need not include pricing terms\nthat exactly mirror Google\u2019s \u201cordinary commercial terms,\u201d nor must they reflect market\nrates without the context of Google\u2019s discounted pricing practices, including discounts\noffered due to the bundled provision of search syndication and Search Text Ads\nsyndication services, \u201csometimes at prices below marginal cost.\u201d Final J. Op. at 37\u201341.\nThe result, per the Court, is that the \u201cFinal Judgment\u2019s pricing provisions may result in\nsyndication agreements that depart from the way Google has historically contracted or\nmade its revenue.\u201d Id. at 41. \u201c[T]hat is an acceptable consequence of remedying Google\u2019s\nillegal conduct.\u201d Id. Pinning remedial pricing terms to Google\u2019s \u201cordinary commercial\nterms\u201d would run counter to the Court\u2019s instructions, improperly \u201cconvey an effective\nveto to Google\u201d over terms if Google does not deem them \u201cordinary,\u201d id. at 38\u201339, and\nimpose remedial terms on Qualified Competitors \u201cwith Google\u2019s profit motive in mind,\u201d\nrather than the remedial goals of the remedies, id. at 41.\n\n Further as to Request No. 43, Plaintiffs understand that, unlike certain other\nrequirements in the Final Judgment, the requirement of \u201cfinancial terms no worse than\nthose offered to any other user\u201d is not pinned to the Final Judgment\u2019s date of entry.\nAccordingly, as described in the Recommendation Statement, where the Final Judgment\n 11\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 13 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 12\n\ndemands terms no less favorable than Google\u2019s commercial agreements, Plaintiffs and\nthe TC included language in the Recommended Template derived, where appropriate,\nfrom the TC\u2019s analysis of the most favorable financial terms in Google\u2019s commercial\nsyndication agreements. This includes the provision added to the\nRecommended Template.\n\n Re Google Req. No. 33: Plaintiffs and the TC drafted the Recommended\nTemplate to conform to the Final Judgment\u2019s requirement that Google provide\nsyndication licenses to Qualified Competitors, encompassing not only providers of or\npotenital entrants in the provision of a General Search Engine or GenAI Product, but also\nproviders of or potential entrants in the provision of Search Text Ads in the United States.\nFinal J. \u00a7\u00a7 V.A, VI.B, IX.E, IX.V. For example, the Final Judgment contemplates the\nprovision of syndication remedies to Qualified Competitors who have been certified as a\nCompetitor to a Google ads platform. Final J. \u00a7 VI.B.9.\n\n The extension of syndication remedies to providers of competing ads platforms\nand Search Access Points aligns with the Final Judgment and the Court\u2019s adoption of \u201cno\nless favorable\u201d language over \u201cordinary commercial terms\u201d language, including to ensure\nthat Google cannot refuse to syndicate search results or Search Text Ads to a Qualified\nCompetitor \u201choping to compete by offering unique services or features\u201d simply because\nthe terms of remedial syndication are not \u201cordinary.\u201d Final J. Op. at 37\u201339.\n\n Re Google Req. No. 34: Plaintiffs view the Final Judgment as clear regarding the\nscope and implementation of the syndication remedies, as well as the rights and\nobligations of Google and Qualified Competitors under the Final Judgment. Where the\nFinal Judgment refers to terms \u201cno less favorable\u201d than what Google offers other users of\nits search syndication or Search Text Ads syndication services\u2014or \u201cordinary commercial\nrestrictions on scraping, indexing, or crawling\u201d the syndicated content\u2014Plaintiffs and the\nTC have drafted the Recommended Template to reflect those requirements. See Final J.\n\u00a7 V.B, VI.B. However, the Court was clear that Qualified Competitors retain the right to\nsubmit complaints based on remedial syndication agreements, Final J. \u00a7 X, and the Court\nretains jurisdiction over the Final Judgment if further orders or directions are needed \u201cfor\nthe construction or carrying out of th[e] Final Judgment, for the modification of any of its\nprovisions, for the enforcement of compliance with this Final Judgment, and for the\npunishment of any violation of th[e] Final Judgment.\u201d Final J. \u00a7 XI.A. Plaintiffs and the\nTC do not believe it is appropriate for Google to use remedial syndication agreements as\na way to delay its compliance with the Final Judgment, including possible modifications\nthereof, and Plaintiffs and the TC believe incorporation of the Final Judgment by\nreference is a proper and effective method to ensure such compliance within the\nRecommended Template. For clarity, Google and Qualified Competitors will remain\nempowered to seek amendment under Recommended Template Section 20 as needed\nfollowing any potential modification to the Final Judgment, and nothing in the\nRecommended Template is intended to suggest that the Court cannot set a schedule for\nimplementing any such modification to the Final Judgment.\n\n\n\n 12\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 14 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 13\n\n Re Google Req. No. 35: Limiting the referenced provision to \u201cmaterial breach\u201d\nas the primary grounds for termination is consistent with standard commercial practice.\nIncorporating a non-material breach standard would introduce broad, unilateral and\nimmediate termination rights. Providing Google with such a unilateral control mechanism\nis not appropriate given the current remedial posture and would further leave Qualified\nCompetitors, the TC, Plaintiffs, and the Court without a reasonable cure period or other\nmeans of intervention.\n\n Re Google Req. No. 36: Plaintiffs oppose the inclusion of Google\u2019s proposed\nCompany Warranties provision in the Recommended Template. The proposed provision\nwould make the warranties mutual as between Google and the TC, effectively expanding\nthe grounds for termination and giving Google greater control over Qualified\nCompetitors. Such a result is not appropriate in this context, given the current remedial\nposture, and Qualified Competitors will be subject to processes and procedures overseen\nand enforced by Plaintiffs and the TC.\n\n Re Google Req. No. 37: Plaintiffs and the TC do not intend for the\nRecommended Template to require Google to provide syndication services to Qualified\nCompetitors whose certification under Section IX.V of the Final Judgment has lapsed.\nInstead, the Suspension provision in the Recommended Template is intended to permit\nGoogle to suspend all remedial syndication services once a Qualified Competitor loses\ncertification under the Final Judgment. In the event that a lapsed Qualified Competitor is\nlater recertified under Section IX.V of the Final Judgement, the Suspension provision is\nintended to expedite the reinstatement of the remedial syndication services to the\nQualified Competitor given that the \u201cpurpose of this [syndication] remedy is to provide a\nshort-term measure for Qualified Competitors to compete as they improve their own\nsearch capabilities.\u201d Rem. Op. at 178.\n\n Re Google Req. No. 38: Plaintiffs and the TC drafted the Amendment and\nTermination provisions in compliance with the Final Judgment, including express\nrequirements governing termination, See Final J. \u00a7\u00a7 V.B.11, VI.B.10, and in alignment\nwith Plaintiffs\u2019 and the TC\u2019s roles regarding the enforcement of and compliance with the\nFinal Judgment. Section 16.3 of the Recommended Template is intended only to provide\na voluntary remediation process for Google and Qualified Competitors available prior to\ninitiating termination proceedings. This process is not mandatory but is intended as a\nvoluntary preliminary step before initiating termination proceedings. If a Qualified\nCompetitor wishes to seek voluntary remediation under a remedial syndication\nagreement, for example, Google would have fifteen (15) business days to respond to the\nQualified Competitor\u2019s notice and either attempt or reject remediation. Upon receipt of\nGoogle\u2019s response, the Qualified Competitor may pursue termination or choose to\ncontinue under the remedial syndication agreement.\n\n Re Google Req. No. 39: As a general matter, Plaintiffs and the TC have drafted\nthe Severability provision of the Recommended Template with the intent of conforming\nto the Final Judgment\u2019s requirement that Google make syndication services available to\nQualified Competitors pursuant to a license whose term will be five (5) years from the\n 13\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 15 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 14\n\ndate the license is signed. Final J. \u00a7\u00a7 V.A, VI.B. While Plaintiffs and the TC do not\nintend for any terms of the Recommended Template to be illegal or unenforceable,\nshould any terms of a remedial syndication agreement entered into between Google and a\nQualified Competitor be found to be illegal or unenforceable, the Severability provision\nis intended to operate as severing the illegal or unenforceable provisions such that the\nrelevant Qualified Competitor may continue to receive syndication remedies as required\nunder the Final Judgment. In such circumstances, Plaintiffs and the TC may review the\nsurviving remedial syndication license to ensure it complies with all Final Judgment\nrequirements.\n\n Re Google Req. No. 40: Plaintiffs and the TC drafted the Assignment provision\nof the Recommended Template with the understanding that neither party to the agreement\nwould be generally permitted to assign the agreement to a different entity. The\npermission structure included in the Assignment section is intended only to capture edge\ncases, such as where a Qualified Competitor pursues internal corporate restructuring\nduring the Agreement Term to better compete, where restructuring does not conflict with\nthe scope of the Qualified Competitor\u2019s certification under Section IX.V of the Final\nJudgment.\n\n Re Google Req. No. 41: Plaintiffs and the TC drafted the Change of Control\nprovision of the Recommended Template with the understanding that only Qualified\nCompetitors would be able to receive search syndication and Search Text Ads\nsyndication services under the Final Judgment. The notice structure included in the\nChange of Control section is intended only to capture edge cases involving Qualified\nCompetitor certification or recertification under Section IX.V of the Final Judgment, such\nas where a a change of control does not conflict with the scope of the Qualified\nCompetitor\u2019s current certification under the Final Judgment.\n\n Re Google Req. Nos. 42, 67\u201389: Plaintiffs and the TC have carried out their\nobligations under the Final Judgment to create and submit to the Court a template for\nsearch syndication and Search Text Ads syndication. Final J. \u00a7\u00a7 V.B, VI.B. In so doing,\nPlaintiffs and the TC reviewed and, where appropriate, incorporated input from Google,\nsuch as responses to Technical Committee demand letters, commercial agreements, and\nGoogle\u2019s own syndication proposals. Id. Google\u2019s role under the Final Judgment is not to\ndictate the terms of its own syndication remedies or demand inclusion of omitted terms,\nbut to comply with the remedies.\n\n Further as to Request No. 42, Plaintiffs and the TC do not understand Google\u2019s\nquestion to relate to the syndication remedies, of which the present Recommendation is a\npart, nor do Plaintiffs believe it is appropriate to incorporate restrictions unrelated to the\nsyndication remedies within the Recommended Template.\n\n Re Google Req. No. 44: Plaintiffs and the TC drafted the Recommended\nTemplate to conform to the Final Judgment\u2019s language, with the Exhibits generally\nhousing language intended to cover terms \u201cno less favorable\u201d than what Google provides\nto other users of its syndication services. See Final J. Op. at 37\u201339. Plaintiffs and the TC\n\n 14\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 16 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 15\n\ndo not intend for any cross-references within the Recommended Template to be\nambiguous or circular. As an example, the cross-references in Exhibit C, Section 5.1.e is\nincluded only to clarify that the prohibition in Exhibit C, Section 5.1.e, covering financial\narrangements with third parties, is not intended to restrict a Qualified Competitor\u2019s ability\nto (1) sub-syndicate Search Text Ads as permitted under the Final Judgment or (2)\ndisplay or use the Search Text Ads syndication remedies as permitted under the Final\nJudgment. As to Google\u2019s reference to Exhibit C, Sections 4.5 and 5.5, because no such\nSections exist, Plaintiffs understand Google\u2019s request to be referring to Sections 4.5 and\n5.5 of the core Recommended Template, rather than Exhibit C. Plaintiffs and the TC have\ndrafted these sections to conform to the Final Judgment\u2019s requirements permitting\nGoogle to impose ordinary commercial restrictions on scraping, indexing, or crawling\nsyndicated search results and Search Text Ads. Final J. \u00a7\u00a7 V.B.7, VI.B.6. The cross-\nreferences in these sections are included only to clarify that permissible display and use\nof the syndication remedies by providers of GenAI Products, which the Court explicitly\nincluded within the Final Judgment\u2019s definition of Qualified Competitor to \u201cleave no\ndoubt that the remedies extend to [GenAI Product] companies,\u201d Final J. \u00a7\u00a7 IX.E, IX.V;\nRem. Op. at 103\u201304, do not consitute scraping, indexing, or crawling prohibited under\nthe Final Judgment.\n\n Re Google Req. No. 45: Plaintiffs and the TC drafted the language in\nRecommended Template Sections 1.5 and 9 with the intent of ensuring that Qualified\nCompetitors do not improperly retain or use syndicated content or information received\nfrom Google under the syndication remedies. This approach aligns with the Court\u2019s view\nthat \u201cthe purpose of this [syndication] remedy is to provide a short-term measure for\nQualified Competitors to compete as they improve their own search capabilities, not an\nadditional means to facilitate that development.\u201d Rem. Op. at 178.\n\n Re Google Request No. 90: Plaintiffs and the TC drafted the Recommended\nTemplate, including the descriptions of remedial syndication services in Exhibit B that\ninclude syndication of Maps Search Feature content, to conform to the Final Judgment.\nUnder Section V.A of the Final Judgment, Google is required to make available to\nQualified Competitors a search syndication license under which Google must provide,\n\u201cvia real-time API(s),\u201d the following information and data: (1) \u201cboth desktop and mobile\nversions of the ranked organic web search results obtained from crawling the web;\u201d (2)\n\u201cthe user-facing query-rewriting features that Google provides under any of its current\nsearch syndication agreements as of the date of entry of this Final Judgment, including\nuser-facing Search Features that enable query correction, modification, or expansion;\u201d\nand (3) \u201cthe Local, Maps, Video, Images, and Knowledge Panel Search Feature content\nthat Google provides under any of its current search syndication agreements as of the date\nof entry of this Final Judgment.\u201d The Final Judgment provides these requirements\nexplicitly, rather than pinning the search syndication Google must provide only to what\nGoogle ordinarily provides within its Web Search syndication services. Given the Final\nJudgment\u2019s language and upon consideration of Google\u2019s input, including Google\u2019s own\nproposed Maps license, Plaintiffs and the TC have drafted the Remedial Web Search\nService in Exhibit B to encompass Google\u2019s commercial Web Search syndication product\n\n 15\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 17 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 16\n\nand the Search Feature content required under Section V.A, including Maps Search\nFeature content and any related beta programs or PIFs.\n\n Moreover, the Court was clear that remedial syndication licenses need not mirror\nGoogle\u2019s standards terms exactly. In fact, the Court anticipated that there may be\nvariations from Google\u2019s \u201cordinary commercial terms\u201d within remedial syndication\nlicenses in order to, e.g., increase clarity for Qualified Competitors, promote the\n\u201cinnovation this [syndication] remedy attempts to encourage,\u201d and preserve availability\nof syndication remedies to Qualified Competitors even where they \u201chop[e] to compete by\noffering unique services or features.\u201d Final J. Op. at 37\u201339.\n\n Re Google Req. Nos. 91, 93, 98\u201399, 104\u201305, 107: Google misunderstands the\nprocess. Plaintiffs and the TC are not required to identify materials relied upon on a\nprovision-by-provision basis. Moreover, requests for additional information must include,\ninter alia, \u201cthe relevance of each piece of information sought to . . . Google\u2019s ability to\n. . . exercise its right to object under the Final Judgment.\u201d May 20 JSR App. \u00b6 6(b)(i).\nGoogle\u2019s blanket request is not sufficient.\n\n In addition, Google turns the process on its head, by broadly asking for additional\ninformation without specifying any particular provision as to which Google is seeking\ninformation and potentially taking issue. Google thus appears to be targeting provisions\nbased on the information relied upon, rather than on the merits of the provisions\nthemselves.\n\n Further as to Request No. 93, Plaintiffs and the TC drafted the Recommended\nTemplate after reviewing a wide range of input from Google, including Google\u2019s\ncommercial syndication agreements, and in conformity with the Final Judgment\u2019s\nrequirement that syndication licenses be offered to Qualified Competitors \u201con financial\nterms no worse than those offered to any other user\u201d of Google\u2019s search syndication\nproducts and Search Text Ads syndication products. Final J. \u00a7\u00a7 V.A, VI.B. The\n AdSense for Domain contract provides only secondary support, after other\nGoogle commercial syndication agreements (e.g., GOOG-DOJ-FJ-00000311), for\nincluding a on AFS revenue share.\n\n Re Google Req. No. 92: In drafting the Recommended Template, Plaintiffs and\nthe TC considered and, where appropriate, incorporated input from Google (including\nlanguage from all commercial syndication agreements Google provided) not only where\nexpressly required by the Final Judgment, but also where incorporating such input could\nfacilitate the efficient implementation of the syndication remedies. As part of this\nprocess, Plaintiffs and the TC reviewed the agreement and other Google\nsyndication agreements for standard contractual terms, such as the definition of\n\u201cRequest,\u201d and implementation provisions, such as the Launch provision in\nRecommended Template Section 4.1.\n\n Re Google Req. No. 96: The proposed pricing set forth in the Recommended\nTemplate is dictated by Section V.A of the Final Judgment, which orders that the search\n\n 16\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 18 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 17\n\nsyndication license be offered \u201con financial terms no worse than those offered to any\nother user of Google\u2019s search syndication products.\u201d Accordingly, Plaintiffs and the TC\nrelied on Google\u2019s own syndication agreements for the pricing terms, and information\nfrom third parties was neither was relied upon nor \u201cis necessary [for Google] to. . .\nexercise its right to object under the Final Judgment.\u201d See May 20 JSR App. \u00b6 6(b).\n\n Re Google Req. No. 97: Section V.B.4 of the Final Judgment provides that \u201c[t]he\npace of this tapering, the methods for measuring and determining the percentage, and the\napplication of the percentage will be determined by the Court upon consultation with\nPlaintiffs and the Technical Committee in a manner that facilitates competition while\nincentivizing Qualified Competitors to move promptly to become independent of\nGoogle.\u201d The template is clear that the tapering schedule is still being determined. If\nGoogle believes that the tapering schedule should be included in the submission to the\nCourt on October 6, 2026, please provide Google\u2019s position and rationale.\n\n Re Google Req. Nos. 100\u2013102: Google misunderstands Plaintiffs\u2019 and the TC\u2019s\nreliance on the TC\u2019s interview with . As reflected by the description of that\ninterview in the Basis Statement, the material information relied upon related to\n\n . When\nconsidering monitoring provisions within the Recommended Template, Plaintiffs and the\nTC relied on Google\u2019s own agreements, including for any values for relevant parameters.\n\n Further as to Request No. 102, Plaintiffs and the TC do not have any\u2014and did not\nrely upon any\u2014contracts or other documentation from related to the\nRecommended Template\u2019s provisions regarding violation severity classification levels.\n\n Re Google Req. Nos. 103, 108: Plaintiffs refer Google to Section II.B of the\nRecommendation, which identifies the material information relied upon to support the\nRecommendation Statement, pursuant to Paragraphs 1 and 2 of the May 20 JSR\nAppendix.\n\n Further as to Request No. 103, the TC\u2019s interview with was not\nrelied upon for Section 4 of the Recommended Template.\n\n Re Google Req. No. 106: As discussed supra, Request No. 22 suggests that the\n Google currently makes commercially available differs from the in\nthe Recommended Template. Such information is relevant for assessing a response to this\nquestion. Please provide information or documentation on Google\u2019s commercially\navailable so that Plaintiffs and the TC may consider it.\n\n *****\n\n Finally, Google has requested a \u201clive discussion between Google and members of\nthe Technical Committee in order to narrow areas of disagreement and improve\n[Google\u2019s] shared factual understanding.\u201d Plaintiffs and the TC are amenable to such a\ncall prior to the deadline for Google\u2019s objections on September 29, 2026, to the extent\n 17\n\fCase 1:20-cv-03010-APM Document 1567-8 Filed 10/23/26 Page 19 of 19\n\nC. Connor\nSeptember 15, 2026\nPage 18\n\nGoogle seeks information that is necessary to exercise its right to object under the Final\nJudgment, and provided that Google identifies, at least 48 hours in advance, the specific\nRequests that it would like to discuss on the call. Once Google has had the opportunity to\nreview the responses above, please send us available dates and times, and we will\npromptly respond to schedule the call.\n\n To the extent Googel has any objections to the Recommended Template, we look\nforward to receiving Google\u2019s submission to Plaintiffs by 3p ET on September 29, 2026.\nECF No. 1528-2 at 3.\n\n Sincerely,\n\n\n /s/ Grant M. Fergusson\n Grant M. Fergusson\n\n\n\n\n 18\n\f","ocr_status":1,"date_upload":"2026-10-23T19:16:23.759116-07:00","document_number":"1567","attachment_number":8,"pacer_doc_id":"045012431088","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487570/","id":498487570,"tags":[],"absolute_url":"/docket/18552824/1567/9/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.335335-07:00","date_modified":"2026-10-26T18:04:09.363617-07:00","sha1":"8bd1ef103726db6eb5cd80bbf4890e4e39fb0d93","page_count":4,"file_size":261835,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.9.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.9.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487570.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 1:20-cv-03010-APM Document 1567-9 Filed 10/23/26 Page 1 of 4\n\n\n\n\n Exhibit 9\n\f Case 1:20-cv-03010-APM Document 1567-9 Filed 10/23/26 Page 2 of 4\n\n\n\n\nCOLETTE T. CONNOR\n (202) 434-5170\n cconnor@wc.com\n\n\n\n\n September 29, 2026\n\n\n Via Email\n\n Claire Maddox\n U.S. Department of Justice\n 450 Fifth Street N.W.\n Washington, D.C. 20530\n claire.maddox@usdoj.gov\n\n Remedies Technical Committee, Inc.\n tc@remediestc.org\n\n Re: United States, et al. v. Google LLC, No. 20-cv-3010-APM (D.D.C.) & State of\n Colorado, et al. v. Google LLC, No. 20-cv-3715-APM (D.D.C.)\n\n Dear Counsel and Technical Committee Members,\n\n Please find attached Google\u2019s list of objections to your proposed search and search ads\n syndication license template. The objections contained in the attached chart specify the terms of\n your proposed license to which Google objects, the basis for the objection, and Google\u2019s\n proposed resolution. As an overarching matter, Google objects to the use of your proposed\n template as a whole because its structure is entirely inconsistent with any of Google\u2019s current\n syndication agreements. Such expansive changes to Google\u2019s syndication agreements were not\n contemplated by the Final Judgment. In addition, the changes create unnecessary ambiguity as\n to the parties\u2019 obligations.1 For the avoidance of doubt, where Google agrees to adopt your\n proposed language in the attached chart, Google is agreeing to incorporate your language into\n Google\u2019s search or search text ad syndication template agreements transmitted to the Technical\n Committee on August 10.\n\n\n\n\n 1\n See ECF No. 1461, Court\u2019s December 5, 2025 Opinion, at 38 (\u201cThe court\u2019s overarching point was that the terms of\n a syndication license should not be unmoored from commercial realities already in place.\u201d).\n\f Case 1:20-cv-03010-APM Document 1567-9 Filed 10/23/26 Page 3 of 4\n\n\n\n\nSeptember 29, 2026\nPage 2\n\n Our objections are grouped into several categories for ease of reading. The categories are\nas follows:\n\n \u25cf Conflicts with MFN Term: This objection indicates that the term is not consistent with\n any of Google\u2019s existing syndication agreements.\n\n \u25cf Contradicts FJ IP Protections: This objection indicates that the term contravenes the Final\n Judgment\u2019s language allowing Google to retain its ordinary course IP protections.\n\n \u25cf Unsupported by Google Technology: This objection indicates that the term would require\n Google to build a new product or substantially re-engineer existing technology to comply\n with the proposed term.\n\n \u25cf Unsupported by Google\u2019s Administrative Processes: This objection indicates that the\n term would require a change to Google\u2019s processes that would affect multiple teams and\n create an administrative burden, delaying services to the Qualified Competitors.\n \u25cf Advertiser Harm: This objection indicates that inclusion of the term would cause\n detrimental harm to Google\u2019s advertisers.\n\n \u25cf Drafting Issue - Substantive: This objection indicates that the term creates an\n unacceptable ambiguity or internal conflict within the agreement.\n\n \u25cf Drafting Issue - Minor: This objection indicates that Google\u2019s suggested change to the\n term is for additional clarity.\n\n \u25cf Unclear Obligation: This objection indicates that the term creates an unacceptable\n ambiguity in what is required of Google to comply.\n\n The attached chart does not include Google\u2019s objections with respect to the local/maps\nsearch features agreement terms. As Google explained during the September 25, 2026 meeting\nwith Jesse Adkins, Yael Maguire, and the Technical Committee, Google\u2019s Websearch\nSyndication (\u201cWSS\u201d) product returns 10 blue links in response to local queries, and does not\nreturn a local unit (beyond limited Knowledge Panel content pertaining to some local entities,\nwhich does not include third-party content) or a map. If Plaintiffs and the TC agree that this\nfeature set satisfies the Final Judgment\u2019s requirement that Google provide the \u201cLocal, Maps, \u2026\nand Knowledge Panel Search Feature content that Google provides under any of its current\nsearch syndication agreements as of the date of entry of this Final Judgment,\u201d we request that\nyou confirm that this is your position. To the extent that Plaintiffs and the TC believe that the\nFinal Judgment requires Google to provide local/maps content beyond the content included in its\nSearch syndication products (e.g., ProSE and WSS), Google proposes providing Qualified\n\f Case 1:20-cv-03010-APM Document 1567-9 Filed 10/23/26 Page 4 of 4\n\n\n\n\nSeptember 29, 2026\nPage 3\n\nCompetitors with the particular Google Maps Platforms (\u201cGMP\u201d) APIs2 in its August 19, 2026\nsubmission to the Technical Committee, and for which Google provided separate template\nagreements, modified to conform with the terms of the Final Judgment (see Exhibits 4, 5, and 6\nto Google\u2019s August 19 correspondence). These GMP APIs are entirely separate from Google\u2019s\nsearch syndication services: they are in separate product portfolios (with the GMP APIs being\noffered through Google Cloud); they use different technology stacks; and they have separate\npricing and commercial terms (including different standards for latency and reliability). As Dr.\nMaguire explained, the terms for the GMP APIs are inseparable from the products because the\nterms define how the products may be used, are based on the products\u2019 unique technical\nfunctionality, and account for the reliance of the GMP products on third-party licensed content.\nTo the extent that your template is intended to govern access to the GMP APIs, Google objects to\nyour template in its entirety because your search syndication license template would impose an\nentirely different contractual structure and does not incorporate any of the existing terms from\nthe GMP API agreements.\n\n We look forward to discussing with you on our meet and confers scheduled for\ntomorrow, September 30 and Monday, October 5. If you have any questions or requests for\nclarification in the meantime, please let us know.\n\n\n\n Sincerely,\n\n /s/ Colette T. Connor\n\n Colette T. Connor\n\n\n\n\n2\n Google proposed the following Google Maps Product APIs: Places UI Kit Query, Places UI Kit Pro, Dynamic\nMaps, and Maps SDK.\n\f","ocr_status":1,"date_upload":"2026-10-23T19:16:25.921184-07:00","document_number":"1567","attachment_number":9,"pacer_doc_id":"045012431089","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487571/","id":498487571,"tags":[],"absolute_url":"/docket/18552824/1567/10/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.353594-07:00","date_modified":"2026-10-26T18:04:06.493597-07:00","sha1":"06008574a11aad529a3dcdf67c36579ff117bb6f","page_count":1,"file_size":48285,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.10.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.10.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487571.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23T19:16:27.868789-07:00","document_number":"1567","attachment_number":10,"pacer_doc_id":"045012431090","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487572/","id":498487572,"tags":[],"absolute_url":"/docket/18552824/1567/11/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.371689-07:00","date_modified":"2026-10-26T17:34:10.354792-07:00","sha1":"519e57969fdf148fa465df52c2cd91b8bad60411","page_count":4,"file_size":480089,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.11.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.11.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487572.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23T19:16:30.214351-07:00","document_number":"1567","attachment_number":11,"pacer_doc_id":"045012431091","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487573/","id":498487573,"tags":[],"absolute_url":"/docket/18552824/1567/12/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.393794-07:00","date_modified":"2026-10-26T18:04:05.800717-07:00","sha1":"d95822823c9e65fd2394ee1c4976dd58b7991cbe","page_count":11,"file_size":256087,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.12.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.12.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487573.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23T19:16:32.648168-07:00","document_number":"1567","attachment_number":12,"pacer_doc_id":"045012431092","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487574/","id":498487574,"tags":[],"absolute_url":"/docket/18552824/1567/13/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.412798-07:00","date_modified":"2026-10-26T17:57:32.766316-07:00","sha1":"0056631fd9dd9a798b027e970975f004fb35c275","page_count":2,"file_size":271355,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.13.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.13.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487574.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23T19:16:35.044010-07:00","document_number":"1567","attachment_number":13,"pacer_doc_id":"045012431093","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":2,"description":"Exhibit","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498487575/","id":498487575,"tags":[],"absolute_url":"/docket/18552824/1567/14/united-states-of-america-v-google-llc/","date_created":"2026-10-23T19:14:58.430691-07:00","date_modified":"2026-10-26T17:36:22.014707-07:00","sha1":"b4f6dfc22e0edff6acf975687004c0ab09de39aa","page_count":13,"file_size":905949,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.14.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1567.14.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498487575.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-10-23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DOCUMENT- Joint Status Report to 1562 Sealed Document, by UNITED STATES OF AMERICA. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit)(Fergusson, Grant) (Entered: 10/23/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/482624627/","id":482624627,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498407161/","id":498407161,"tags":[],"absolute_url":"/docket/18552824/1566/united-states-of-america-v-google-llc/","date_created":"2026-10-23T10:09:19.196609-07:00","date_modified":"2026-10-26T15:54:35.311131-07:00","sha1":"a6632bfa8e5135a3b88e35a836e20f9c286f7bba","page_count":13,"file_size":218492,"filepath_local":"recap/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1566.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.dcd.223205/gov.uscourts.dcd.223205.1566.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.dcd.223205/498407161.thumb.1068.png","thumbnail_status":1,"plain_text":" Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 1 of 13\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE DISTRICT OF COLUMBIA\n\n\n United States of America, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03010-APM\n\n v. HON. AMIT P. MEHTA\n Google LLC,\n\n Defendant.\n\n\n State of Colorado, et al.,\n\n Plaintiffs, Case No. 1:20-cv-03715-APM\n\n v. HON. AMIT P. MEHTA\n Google LLC,\n\n Defendant.\n\n\n\n JOINT STATUS REPORT\n\n Pursuant to the Court\u2019s October 5, 2026 Minute Order, the Parties submit the following\n\nJoint Status Report to further update the Court regarding the status of indemnification of Technical\n\nCommittee Members and Staff. The Parties jointly propose that they file a further status report on\n\nNovember 13, 2026.\n\n I. Indemnification of TC Members and TC Staff\n\n Since the last Joint Status Report on this issue, see ECF No. 1557, the TC\u2019s legal and\n\ninsurance teams have gathered the additional information described in prior Joint Status Reports\n\nregarding possible options relating to indemnification, including insurance quotes. Plaintiffs then\n\nworked with the TC on a proposal to Google presenting that information, which Plaintiffs provided\n\n\n 1\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 2 of 13\n\n\n\n\nto Google today, October 23, 2026. Once Google has the opportunity to review the proposal, the\n\nParties will meet and confer.\n\n\n\nDated: October 23, 2026 Respectfully submitted,\n\n /s/ Grant M. Fergusson\n Claire M. Maddox (D.C. Bar #498356)\n Travis R. Chapman (D.C. Bar #90031151)\n Danielle Hauck\n Grant M. Fergusson (D.C. Bar #90004882)\n Joseph Gordon (D.C. Bar #90027976)\n Emma Waitzman (D.C. Bar #1738427)\n\n U.S. Department of Justice\n Antitrust Division\n Technology & Digital Platforms Section\n 450 Fifth Street NW, Suite 7100\n Washington, DC 20530\n Telephone: (202) 549-7155\n Claire.Maddox@usdoj.gov\n\n Counsel for Plaintiff United States of America\n\n\n\n\n 2\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 3 of 13\n\n\n\n\nBy: /s/ Amanda Wentz By: /s/ Charles Thimmesch\nAmanda J. Wentz Christopher Carr, Attorney General\nAssistant Attorney General Logan B. Winkles, Deputy Attorney\nOffice of the Arkansas Attorney General General\n101 West Capitol Avenue Ronald J. Stay, Jr., Senior Assistant\nLittle Rock, Arkansas 72201 Attorney General\nPhone: (501) 682-1178 Charles Thimmesch, Senior Assistant\nAmanda.Wentz@ArkansasAG.gov Attorney General\n Office of the Attorney General, State of\nCounsel for Plaintiff State of Arkansas Georgia\n 40 Capitol Square, SW\nBy: /s/ Carolyn D. Jeffries Atlanta, Georgia 30334-1300\nRob Bonta, Attorney General cthimmesch@law.georgia.gov\nPaula Blizzard, Senior Assistant Attorney\nGeneral Counsel for Plaintiff State of Georgia\nMichael Jorgenson, Supervising Deputy\nAttorney General By: /s/ Scott L. Barnhart\nBrian Wang, Deputy Attorney Theodore Edward Rokita, Attorney General\nGeneral Scott L. Barnhart, Chief Counsel and\nCarolyn D. Jeffries, Deputy Attorney Director, Consumer Protection Division\nGeneral (DC Bar No. 1600843) Office of the Attorney General, State of\nOffice of the Attorney General Indiana\nCalifornia Department of Justice Indiana Government Center South, Fifth\n455 Golden Gate Avenue, Suite 11000 Floor\nSan Francisco, California 94102 302 West Washington Street\nCari.Jeffries@doj.ca.gov Indianapolis, Indiana 46204\n Scott.Barnhart@atg.in.gov\nCounsel for Plaintiff State of California\n\nBy: /s/ Lee Istrail Counsel for Plaintiff State of Indiana\nJames Uthmeier, Attorney General\nR. Scott Palmer, Special Counsel, Complex\nEnforcement Chief, Antitrust Division\nLee Istrail, Assistant Attorney General\nOffice of the Attorney General, State of\nFlorida\nPL-01 The Capitol\nTallahassee, Florida 32399\nLee.Istrail@myfloridalegal.com\nScott.Palmer@myfloridalegal.com\n\nCounsel for Plaintiff State of Florida\n\n\n\n\n 3\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 4 of 13\n\n\n\n\nBy: /s/ Jonathan E. Farmer By: /s/ Alison Esbeck\nRussell Coleman, Attorney General Alison Esbeck\nJ. Christian Lewis, Commissioner of the Assistant Attorney General\nOffice of Consumer Protection Missouri Attorney General\u2019s Office\nPhilip R. Heleringer, Executive 815 Olive Street | Suite 200\nDirector of the Office of Consumer Saint Louis, Missouri 63101\nProtection Alison.esbeck@ago.mo.gov\nJonathan E. Farmer, Deputy Executive Phone: 314-340-4977\nDirector of the Office of Consumer\nProtection Counsel for Plaintiff State of Missouri\nOffice of the Attorney General,\nCommonwealth of Kentucky By: /s/ Anna Schneider\n1024 Capital Center Drive, Suite 200 Anna Schneider\nFrankfort, Kentucky 40601 Special Assistant Attorney General,\nPhilip.Heleringer@ky.gov Senior Counsel,\n Montana Office of Consumer Protection\nCounsel for Plaintiff P.O. Box 200151\nCommonwealth of Kentucky Helena, MT 59602-0150\n Phone: (406) 444-4500\nBy: /s/ Asyl Nachabe Anna.schneider@mt.gov\nLiz Murrill, Attorney General\nAsyl Nachabe, Assistant Attorney General Counsel for Plaintiff State of Montana\nOffice of the Attorney General, State of\nLouisiana By: /s/ Mary Frances Jowers\nPublic Protection Division Alan Wilson, Attorney General\n909 Poydras St. Suite 1850 W. Jeffrey Young, Chief Deputy\nNew Orleans, LA 70112 Attorney General\n(225) 326-6435 C. Havird Jones, Jr., Senior Assistant\nNachabeA@ag.louisiana.gov Deputy Attorney General\n Mary Frances Jowers, Assistant Deputy\nCounsel for Plaintiff State of Louisiana Attorney General\n Office of the Attorney General\nBy: /s/ Scott Mertens State of South Carolina\nDana Nessel, Attorney General 1000 Assembly Street\nScott Mertens, Assistant Attorney General Rembert C. Dennis\nMichigan Department of Attorney General Building\nP.O. Box 30736 P.O. Box 11549\nLansing, Michigan 48909 Columbia, South Carolina 29211-1549\nMertensS@michigan.gov mfjowers@scag.gov\n\nCounsel for Plaintiff State of Michigan Counsel for Plaintiff State of South Carolina\n\n\n\n\n 4\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 5 of 13\n\n\n\n\nBy: /s/ Diamante Smith\nKen Paxton, Attorney General\nRalph Molina, Deputy First Assistant\nAttorney General\nWilliam D. Wassdorf, Deputy Attorney\nGeneral for Civil Litigation\nThomas York, Division Chief, Antitrust\nDivision\nDiamante Smith, Assistant Attorney\nGeneral, Antitrust Division\nOffice of the Attorney General,\nState of Texas\nP.O. Box 12548\nAustin, Texas 78711-2548\n(512) 936-1162\nDiamante.Smith@oag.texas.gov\n\nCounsel for Plaintiff State of Texas\n\nBy: /s/ Caitlin M. Madden\nJoshua L. Kaul, Attorney General\nCaitlin M. Madden, Assistant\nAttorney General\nWisconsin Department of Justice\n17 W. Main St.\nPost Office Box 7857\nMadison, Wisconsin 53707-7857\ncaitlin.madden@Wisconsin.gov\n\nCounsel for Plaintiff State of Wisconsin\n\n\n\n\n 5\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 6 of 13\n\n\n\n\nPHILIP WEISER\nAttorney General of Colorado BRENNA BIRD\n Attorney General of Iowa\n/s/ Jonathan B. Sallet\nJonathan B. Sallet, DC Bar No. 336198 Noah Goerlitz, Assistant Attorney General\nSteven M. Kaufmann Office of the Attorney General of Iowa\nElizabeth W. Hereford 1305 E. Walnut St., 2nd Floor\nConor J. May Des Moines, IA 50319\nColorado Office of the Attorney General Telephone: (515) 725-1018\n1300 Broadway, 7th Floor E-Mail: Noah.goerlitz@ag.iowa.gov\nDenver, CO 80203\nTelephone: (720) 508-6000 Counsel for Plaintiff State of Iowa\nE-Mail: Jon.Sallet@coag.gov\nSteve.Kaufmann@coag.gov LETITIA JAMES\nElizabeth.Hereford@coag.gov Attorney General of New York\nConor.May@coag.gov\n Elinor R. Hoffmann\nCounsel for Plaintiff State of Colorado Morgan J. Feder\n Michael D. Schwartz\nMIKE HILGERS Office of the New York State Attorney\nAttorney General of Nebraska General\n 28 Liberty Street\nJustin C. McCully, Assistant Attorney New York, NY 10005\nGeneral Telephone: (212) 416-8513\nNebraska Department of Justice E-Mail: Elinor.hoffmann@ag.ny.gov\nOffice of the Attorney General Morgan.feder@ag.ny.gov\n2115 State Capitol Michael.schwartz@ag.ny.gov\nLincoln, NE 68509\nTelephone: (402) 471-9305 Counsel for Plaintiff State of New York\nE-Mail: Justin.mccully@nebraska.gov\n JEFF JACKSON\nCounsel for Plaintiff State of Nebraska Attorney General of North Carolina\n\nKRISTIN K. MAYES Kunal Janak Choksi\nAttorney General of Arizona Joshua Daniel Abram\n North Carolina Department of Justice\nRobert A. Bernheim, Unit Chief Counsel 114 W. Edenton St.\nJayme Weber, Senior Litigation Counsel Raleigh, NC 27603\nArizona Office of the Attorney General Telephone: (919) 716-6000\n400 West Congress, Ste. S-215 E-Mail: kchoksi@ncdoj.gov\nTucson, Arizona 85701 jabram@ncdoj.gov\nTelephone: (520) 628-6507\nE-Mail: Robert.Bernheim@azag.gov Counsel for Plaintiff State of North\nJayme.Weber@azag.gov Carolina\n\nCounsel for Plaintiff State of Arizona\n 6\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 7 of 13\n\n\n\n\nJONATHAN SKRMETTI WILLIAM TONG\nAttorney General of Tennessee Attorney General of Connecticut\n\nJ. David McDowell Nicole Demers\nAustin Ostiguy Office of the Attorney General of\nTyler Corcoran Connecticut\nOffice of the Attorney General and 165 Capitol Avenue, Suite 5000\nReporter Hartford, CT 06106\nP.O. Box 20207 Telephone: (860) 808-5202\nNashville, TN 37202 E-Mail: Nicole.demers@ct.gov\nTelephone: (615) 741-8722\nE-Mail: David.McDowell@ag.tn.gov Counsel for Plaintiff State of Connecticut\naustin.ostiguy@ag.tn.gov\nTyler.Corcoran@ag.tn.gov KATHLEEN JENNINGS\n Attorney General of Delaware\nCounsel for Plaintiff State of Tennessee\n Michael Andrew Undorf\nDEREK E. BROWN Delaware Department of Justice\nAttorney General of Utah Fraud and Consumer Protection Division\n 820 N. French St., 5th Floor\nMarie W.L. Martin, Division Director Wilmington, DE 19801\nUtah Office of Attorney General Telephone: (302) 683-8816\n160 E 300 S, 5th Floor E-Mail: Michael.undorf@delaware.gov\nP.O. Box 140811\nSalt Lake City, Utah 84114 Counsel for Plaintiff State of Delaware\nTelephone: (801) 440-9825\nE-Mail: BRIAN SCHWALB\nmwmartin@agutah.gov Attorney General of the District of\n Columbia\nCounsel for Plaintiff State of Utah\n Elizabeth Gentry Arthur\nSTEPHEN J. COX Office of the Attorney General for the\nAttorney General of Alaska District of Columbia\n 400 6th Street NW\nJeff Pickett Washington, DC 20001\nSenior Assistant Attorney General Telephone: (202) 724-6514\nState of Alaska, Department of Law E-Mail: Elizabeth.arthur@dc.gov\nOffice of the Attorney General\n1031 W. Fourth Avenue, Suite 200 Counsel for Plaintiff District of Columbia\nAnchorage, Alaska 99501\nTelephone: (907) 269-5275\nE-Mail: Jeff.pickett@alaska.gov\n\nCounsel for Plaintiff State of Alaska\n\n\n\n 7\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 8 of 13\n\n\n\n\nDOUGLAS MOYLAN KWAME RAOUL\nAttorney General of Guam Attorney General of Illinois\n\nNorman Lee Miller, Jr. Elizabeth Maxeiner\nOffice of the Attorney General of Guam Brian Yost\n590 S. Marine Corps Drive, Suite 901 Jennifer Coronel\nTamuning, Guam 96913 Office of the Attorney General of Illinois\nTelephone: (671) 475-2710 115 S. LaSalle St.\nE-Mail: nmillerjr@oagguam.org Chicago, IL 60603\n Telephone: (773) 590-7935\nCounsel for Plaintiff Territory Guam E-Mail: Elizabeth.maxeiner@ilag.gov\n Brian.yost@ilag.gov\nANNE E. LOPEZ Jennifer.coronel@ilag.gov\nAttorney General of Hawai\u2018i\n Counsel for Plaintiff State of Illinois\nRodney I. Kimura\nDepartment of the Attorney General, State KRIS W. KOBACH\nof Hawai\u2018i Attorney General of Kansas\n425 Queen Street\nHonolulu, HI 96813 Christopher Teters\nTelephone (808) 586-1180 Kansas Office of the Attorney General\nE-Mail: Rodney.i.kimura@hawaii.gov 120 S.W. 10th Avenue, 2nd Floor\n Topeka, KS 66612\nCounsel for Plaintiff State of Hawai\u2018i Telephone: (785) 296-3751\n E-Mail: chris.teters@ag.ks.gov\nRA\u00daL LABRADOR\nAttorney General of Idaho Counsel for Plaintiff State of Kansas\n\nJohn K. Olson AARON M. FREY\nOffice of the Idaho Attorney General Attorney General of Maine\nConsumer Protection Division\n954 W. Jefferson St., 2nd Floor Christina M. Moylan\nP.O. Box 83720 Office of the Attorney General of Maine\nBoise, ID 83720 6 State House Station\nTelephone: (208) 332-3549 August, ME 04333\nE-Mail: John.olson@ag.idaho.gov Telephone: (207) 626-8800\n E-Mail: Christina.moylan@maine.gov\nCounsel for Plaintiff State of Idaho\n Counsel for Plaintiff State of Maine\n\n\n\n\n 8\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 9 of 13\n\n\n\n\nANTHONY G. BROWN AARON D. FORD\nAttorney General of Maryland Attorney General of Nevada\n\nSchonette J. Walker Michelle C. Badorine\nMelissa English Lucas J. Tucker\nOffice of the Attorney General of Nevada Office of the Attorney General\nMaryland 100 N. Carson Street\n200 St. Paul Place, 19th Floor Carson City, NV 89701\nBaltimore, MD 21202 Telephone: (775) 684-1164\nTelephone: (410) 576-6480 E-Mail: mbadorine@ag.nv.gov\nE-Mail: swalker@oag.state.md.us ltucker@ag.nv.gov\nmenglish@oag.state.md.us\n Counsel for Plaintiff State of Nevada\nCounsel for Plaintiff State of Maryland\n JOHN FORMELLA\nANDREA CAMPBELL Attorney General of New Hampshire\nAttorney General of Massachusetts\n Brandon Garod\nJennifer E. Greaney Office of Attorney General of New\nOffice of the Attorney General of Hampshire\nMassachusetts 1 Granite Place South\nOne Ashburton Place, 18th Floor Concord, NH 03301\nBoston, MA 02108 Telephone: (603) 271-1217\nTelephone: (617) 963-2981 E-Mail: Brandon.h.garod@doj.nh.gov\nE-Mail: Jennifer, greaney@mass.gov\n Counsel for Plaintiff State of New\nCounsel for Plaintiff Commonwealth of Hampshire\nMassachusetts\n JENNIFER DAVENPORT\nKEITH ELLISON Acting Attorney General of New Jersey\nAttorney General of Minnesota\n Yale A. Leber\nZach Biesanz Abiola G. Miles\nSenior Enforcement Counsel Deputy Attorneys General\nOffice of the Minnesota Attorney General New Jersey Attorney General\u2019s Office\nAntitrust Division 25 Market Street, P.O. Box 106\n445 Minnesota Street, Suite 600 Trenton, NJ 08625\nSt. Paul, MN 55101 Telephone: (609) 376-2383\nTelephone: (651) 757-1257 E-Mail: Yale.Leber@law.njoag.gov\nE-Mail: Zach.biesanz@ag.state.mn.us Abiola.Miles@law.njoag.gov\n\nCounsel for Plaintiff State of Minnesota Counsel for Plaintiff State of New Jersey\n\n\n\n\n 9\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 10 of 13\n\n\n\n\nRA\u00daL TORREZ Counsel for Plaintiff State of Ohio\nAttorney General of New Mexico\n GENTNER DRUMMOND\nJudith E. Paquin Cholla Khoury Attorney General of Oklahoma\nAssistant Attorney General\nNew Mexico Office of the Attorney Cameron R. Capps\nGeneral Office of the Oklahoma Attorney General\n408 Galisteo St. 313 NE 21st Street\nSanta Fe, NM 87504 Oklahoma City, OK 73105\nTelephone: (505) 490-4885 Telephone: (405) 522-0858\nE-Mail: jpaquin@nmag.gov E-Mail: Cameron.capps@oag.ok.gov\nckhoury@nmag.gov\n Counsel for Plaintiff State of Oklahoma\nCounsel for Plaintiff State of New Mexico\n DAN RAYFIELD\nDREW WRIGLEY Attorney General of Oregon\nAttorney General of North Dakota\n Gina Ko, Assistant Attorney General\nElin S. Alm Oregon Department of Justice\nAssistant Attorney General 100 SW Market Street\nConsumer Protection and Antitrust Portland, OR 97201\nDivision Telephone: (503) 934-4400\nOffice of the Attorney General of North E-Mail: Gina.Ko@doj.oregon.gov\nDakota\n1720 Burlington Drive, Suite C Counsel for Plaintiff State of Oregon\nBismarck, ND 58504\nTelephone: (701) 328-5570 DAVID W. SUNDAY, JR.\nE-Mail: ealm@nd.gov Attorney General of Pennsylvania\n\nCounsel for Plaintiff State of North Tracy W. Wertz\nDakota Joseph S. Betsko\n Pennsylvania Office of Attorney General\nD. ANDREW WILSON Strawberry Square\nAttorney General of Ohio Harrisburg, PA 17120\n Telephone: (717) 787-4530\nBeth Ann Finnerty, Section Chief, E-Mail: jbetsko@attorneygeneral.gov\nAntitrust twertz@attorneygeneral.gov\nSarah Mader, Assistant Attorney General,\nAntitrust Counsel for Plaintiff Commonwealth of\nOffice of the Attorney General of Ohio Pennsylvania\n30 E Broad Street, 26 th Floor\nColumbus, OH 43215\nTelephone: (614) 466-4328\nE-Mail: Beth.Finnerty@ohioago.gov\nSarah.Mader@ohioago.gov\n\n 10\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 11 of 13\n\n\n\n\nLOURDES L. G\u00d3MEZ TORRES Dakota\nSecretary of Justice\n CHARITY R. CLARK\nTANIA L. FERN\u00c1NDEZ-MEDERO Attorney General of Vermont\nAssistant Secretary of Justice\n Christopher J. Curtis, Assistant Attorney\nSAMUEL WISCOVITCH-CORALI General\nDeputy Undersecretary Office of the Attorney General of\n Vermont\nPablo Tufi\u00f1o-Soto 109 State St.\nSenior Attorney Montpelier, VT 05609\nAntitrust Division Telephone: (802) 828-3170\nPuerto Rico Department of Justice E-Mail: christopher.curtis@vermont.gov\nP.O. Box 9020192 Counsel for Plaintiff State of Vermont\nSan Juan, Puerto Rico 00902-0192\nTelephone: (787) 721-2900, Ext. 1205 JAY JONES\nE-Mail: ptufino@justicia.pr.gov Attorney General of Virginia\n\nCounsel for Plaintiff Territory Puerto Tyler T. Henry\nRico Senior Assistant Attorney General\n Antitrust Unit\nPETER NERONHA Office of the Attorney General of Virginia\nAttorney General of Rhode Island 202 N. 9th Street\n Richmond, VA 23219\nStephen Provazza Telephone: (804) 692-0485\nRhode Island Office of the Attorney E-Mail: thenry@oag.state.va.us\nGeneral\n150 South Main Street Counsel for Plaintiff State of Virginia\nProvidence, RI 02903\nTelephone: (401) 274-4400 NICHOLAS W. BROWN\nE-Mail: SProvazza@riag.ri.gov Attorney General of Washington\n\nCounsel for Plaintiff State of Rhode Island Amy N.L. Hanson\n Senior Managing Assistant Attorney\nMARTIN J. JACKLEY General\nAttorney General of South Dakota 800 Fifth Avenue, Suite 2000\n Seattle, WA 98104\nYvette K. Lafrentz Telephone: (206) 464-5419\nOffice of the Attorney General of South E-Mail: Amy.hanson@atg.wa.gov\nDakota\n1302 E. Hwy 14, Suite 1 Counsel for Plaintiff State of Washington\nPierre, SD 57501\nTelephone: (605) 773-3215\nE-Mail: Yvette.lafrentz@state.sd.us\n\nCounsel for Plaintiff State of South\n 11\n\f Case 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 12 of 13\n\n\n\n\nJOHN B. McCUSKEY\nAttorney General of West Virginia\n\nDouglas Lee Davis\nOffice of the Attorney General, State of\nWest Virginia\n1900 Kanawha Boulevard East\nBuilding 6, Suite 401\nP.O. Box 1789\nCharleston, WV 25305\nTelephone: (304) 558-8986\nE-Mail: Douglas.l.davis@wvago.gov\n\nCounsel for Plaintiff State of West\nVirginia\n\nKEITH KAUTZ\nAttorney General of Wyoming\n\nWilliam T. Young\nWyoming Attorney General\u2019s Office\n2320 Capitol Avenue\nKendrick Building\nCheyenne, WY 82002\nTelephone: (307) 777-7847\nE-Mail: William.young@wyo.gov\n\nCounsel for Plaintiff State of Wyoming\n\n\n\n\n 12\n\fCase 1:20-cv-03010-APM Document 1566 Filed 10/23/26 Page 13 of 13\n\n\n\n\n WILLIAMS & CONNOLLY LLP\n\n By: /s/ John E. Schmidtlein\n John E. Schmidtlein (D.C. Bar No. 441261)\n Benjamin M. Greenblum (D.C. Bar No. 979786)\n Colette T. Connor (D.C. Bar No. 991533)\n 680 Maine Avenue, SW\n Washington, DC 20024\n Tel: 202-434-5000\n jschmidtlein@wc.com\n bgreenblum@wc.com\n cconnor@wc.com\n\n WILSON SONSINI GOODRICH & ROSATI P.C.\n Michael Sommer (admitted pro hac vice)\n Franklin M. Rubinstein (D.C. Bar No. 476674)\n 1700 K Street, NW\n Washington, DC 20006\n Tel: 202-973-880\n msommer@wsgr.com\n frubinstein@wsgr.com\n\n ROPES & GRAY LLP\n Mark S. Popofsky (D.C. Bar No. 454213)\n 2099 Pennsylvania Avenue, NW\n Washington, DC 20006\n Tel: 202-508-4624\n Mark.Popofsky@ropesgray.com\n\n Matthew McGinnis (admitted pro hac vice)\n Prudential Tower\n 800 Boylston Street\n Boston, MA 02199\n Tel: 617-951-7703\n Matthew.McGinnis@ropesgray.com\n\n Counsel for Defendant Google LLC\n\n\n\n\n 13\n\f","ocr_status":2,"date_upload":"2026-10-23T10:57:54.327282-07:00","document_number":"1566","attachment_number":null,"pacer_doc_id":"045012429164","is_available":true,"is_free_on_pacer":null,"is_sealed":false,"document_type":1,"description":"Status Report","acms_document_guid":""}],"date_created":"2026-10-23T10:09:19.118985-07:00","date_modified":"2026-10-26T09:42:01.608252-07:00","date_filed":"2026-10-23","time_filed":"12:38:33","entry_number":1566,"recap_sequence_number":"2026-10-23.001","pacer_sequence_number":5188,"description":"Joint STATUS REPORT by UNITED STATES OF AMERICA. (Fergusson, Grant) (Entered: 10/23/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/482489394/","id":482489394,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/18552824/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/498266286/","id":498266286,"tags":[],"absolute_url":"/docket/18552824/1565/united-states-of-america-v-google-llc/","date_created":"2026-10-22T10:49:26.843714-07:00","date_modified":"2026-10-22T10:51:22.508651-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1565","attachment_number":null,"pacer_doc_id":"045012426660","is_available":false,"is_free_on_pacer":null,"is_sealed":true,"document_type":1,"description":"Transcript","acms_document_guid":""}],"date_created":"2026-10-22T10:49:26.796953-07:00","date_modified":"2026-10-22T11:47:35.533148-07:00","date_filed":"2026-10-22","time_filed":"13:47:07","entry_number":1565,"recap_sequence_number":"2026-10-22.001","pacer_sequence_number":5186,"description":"TRANSCRIPT OF REMEDIES HEARING PROCEEDINGS - DAY 10, before Judge Amit P. Mehta, held on May 2, 2025. Page Numbers: 3253-3423. Date of Issuance: October 22, 2026. Court Reporter: Lorraine Herman. Email: Lorraine_herman@dcd.uscourts.gov. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 11/12/2026. Redacted Transcript Deadline set for 11/22/2026. 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