EC RFI Responses Resource

In September 2013 Google submitted a new set of proposals to the European Commission and a month later the European Commission announced it would issue formal requests for information (RFIs) on the revised commitments from “complainants in the ongoing proceedings and from all those who responded to the initial market test.” The Commission provided a month long review period to respondents.

ICOMPs response, along with a selection of further responses from ICOMP Members and other interested parties, can be found below.



The Initiative for a Competitive Online Marketplace is of the view that Google’s October 2013 Proposal contains no significant improvements on its previous proposal. In fact, Google’s October 2013 Proposal is based upon similar premises to those underpinning Google’s April 2013 Proposal. Given that those principles did not effectively address the Commission’s concerns Google’s October 2013 Proposal is as flawed as its previous proposal.

The ICOMP response can be found here.


Press Publishers

The Press Publishers position is that Google’s revised remedy package of 21 October does not exclude any of the fundamental flaws of the initial package and even adds new proposals that further reduce competition. Were the Commission to accept these proposals, it would be helping Google advance its business strategy to transition free organic search into paid search.

The Press Publishers’ response can be found here.



Foundem holds that Google’s revised proposals remain fundamentally unchanged and suffer from all of the same fatal flaws that rendered its previous proposals considerably more harmful than helpful. Foundem also states that Far from being a remedy, the adoption of Paid Rival Links would inflict additional grave and irreparable harm to competition, innovation and consumer choice.

The Foundem response can be found here.


Hot Maps and Euro-Cities

As in the  market test of spring  2013, Hot Maps and Euro-Cities find Google’s  proposals to be completely inadequate to restore  competition, deal with Google’s  abuse of its dominance or remedy the wrongful conduct  that Google has undertaken for many years. Their response presents new research, about Google’s favouring of its own services, such as Google Maps.

Hot Maps and Euro-Cities response can be found here.


The Centre of the Picture Industry (CEPIC)

The Centre of the Picture Industry (CEPIC) participated in the first market test with an answer on 27 May 2013. With regard to the present RFI , CEPIC has said that, given that Google’s offer of remedies of 21 October 2013 is based on the same principles which underpin Google’s offer from 3rd April 2013, and that these principles were flawed –  Google’s offer of remedies of 21 October 2013 is equally flawed.

The CEPIC Response can be found here.


Consumer Watchdog

Consumer Watchdog, a U.S.-based public interest group opposes the proposed settlement to the European Commission’s antitrust investigation of Google because the proposed deal “will not restore a competitive search marketplace that will serve the interests of consumers.

The Consumer Watchdog response can be found here.


ProSiebenSat.1 Media AG

P7S1 is deeply disappointed by Google’s revised proposal. After the Commission had refused the original proposal, we would have expected Google to really try and make a serious effort to materially improve the substance of its proposal. However, Google has nothing to offer but cosmetic changes. It is our strong feeling that Google is not serious about addressing the competition concerns. It seems that Google is rather trying to play “hide and seek” in order to wear out any opposition against it.

The ProSiebenSat.1 executive summary can be found here.



We look back at 17 years of experience in the field of search engines. With our objections, ideas and proposals based on our long-term
experience, we hope to contribute to a re-establishment of competition in this fundamental area of the Internet economy. If Google’s new commitments would be accepted as they stand, the European Internet businesses will be deprived of the opportunity to bounce back from the enduring current enourmous digital lag.

The SUMA-EV executive summary can be found here.


One News Page

One News Page considers Google’s revised commitments package of 21 October 2013 as “insufficient and unacceptable” and that it “could be seen as making matters worse.” In its RFI response, One News Page states that the “proposed rival links, almost by definition, lack the essential approach of ‘equal treatment’,” which in its view is “absolutely essential to restore fair competition” and calls for an imposed solution which “puts an end to the unfair practices by Google
treating and displaying competitor’s vertical services in the same way as it treats and displays its own”.

The One News Page response can be found here.