European Commission Market Testing Resource

On April 25th, 2013 as part of its investigation in Google’s anti-trust business practices, the European Commission announced that it was to invite comments from market players and complainants on commitments offered by Google in relation to online search and search advertising. More information about the market test can be found on the ICOMP blog.

A selection of those responses members and other interested parties have kindly let us make public are below, as well as our own.


ICOMP Response

ICOMP’s position is that they are inappropriate, inadequate, do not address the fundamental concerns raised in the complaints submitted by ICOMP and others, possibly make things worse and do not address the future.  They do not restore effective competition and are not future proof. The proposed remedies in this case are not only unsuitable to address the concerns raised by the Commission, but are also alarmingly unclear, as they simultaneously (i) oversimplify complex procedures, making the proposals extremely vague; (ii) introduce an arbitrary and discriminatory segmentation between products which is arguably irrelevant today and will certainly not stand the test of time; and (iii) introduce many technicalities and loopholes, whether in the text of the remedies proposal, or through the illustrations annexed thereto.

The ICOMP response can be found here. 

Whilst the addendum can be downloaded from here.



The Center of the Picture Industry (CEPIC) is a European interests group representing the picture industry on a global scale. Their response outlines Google’s extensive unauthorized use of third parties’ content in the area of images and explain why the proposals do nothing to bring this identified abuse of dominance to an end.

The CEPIC response can be found here.



Foundem, the price comparison site, has responded that the fundamental flaw in Google’s proposal is that it ignores the natural search results and AdWords listings that Google is being charged with manipulating. Instead, Google’s proposals focus exclusively on minor alterations to its self-serving Universal Search inserts.

The Foundem response can be found here.


Hot Maps and Euro Cities

Hot Maps and Euro-Cities are both providers of maps and map related vertical search services in the European Economic Area EEA. They have provided joint views on Google’s proposed commitments, stating that they entrench Google’s dominant market position and enhance the network effect of its products, services and partnerships.

The combined Hot Maps and Euro Cities response can be found here.

 The Hot Map Press Release can be found here.


Prof. Benjamin Edelman and Zhenyu Lai

Benjamin Edelman, Associate Professor, Harvard Business School, and Zhenyu Lai, Doctoral Candidate, Department of Economics, Harvard University, comment on how Google’s proposed commitments do not address the underlying practices that favor Google’s own specialized search services and distort the competitive process by examining that first, Google reserves prominent display for its own specialized search services, excluding competing specialized search services from a key supply of algorithmic search traffic. Secondly, by reserving prominent display for its own specialized search services, Google pushes more traffic to paid advertisements, which increases advertising costs for competing specialized search services and further strengthens Google’s advantage in specialized search.

Professor Edelman’s analysis can be viewed here.


Links to other Responses


Hotrec, The Association of Hotels, Restaurants and Cafes in Europe


BEUC, The European Consumers’ Organisation

Consumer Watchdog

European Press Publishers joint release and their detailed joint response