Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 1 of 23

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA, et al.,

Plaintiffs,
Case No. 1:20-cv-03010-APM
v.
HON. AMIT P. MEHTA
GOOGLE LLC,

Defendant.

STATE OF COLORADO, et al.,

Plaintiffs,
Case No. 1:20-cv-03715-APM
v.
HON. AMIT P. MEHTA
GOOGLE LLC,

Defendant.

EXECUTIVE SUMMARY OF PLAINTIFFS’ PROPOSED FINAL JUDGMENT

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I. Introduction

For more than a decade, Google has unlawfully maintained its monopolies in general

search services and search text advertising through a web of anticompetitive practices. As this

Court found after a lengthy trial, “Google is a monopolist, and it has acted as one to maintain its

monopoly” over both the general search services and search text advertising markets. See Mem.

Op., United States et al. v. Google LLC, 20-cv-3010 (APM), ECF No. 1032 (“Op.”), at 4. Google

has manipulated its control of Chrome and Android to benefit itself, while sharing monopoly

profits under conditions to induce third parties across the ecosystem to help Google maintain its

monopolies. Google’s exclusionary conduct has, among other things, made Google the near-

universal default for search and ensured that virtually all search access points route users’

valuable queries and interaction data to Google. Google’s unlawful behavior has deprived rivals

not only of critical distribution channels but also distribution partners who could otherwise

enable entry into these markets by competitors in new and innovative ways. Google’s conduct

has resulted in significant anticompetitive effects—causing “market foreclosure,” “preventing

rivals from achieving scale,” and “diminishing the incentives of rivals to invest and innovate.”

Op. at 216.

The Court’s opinion describes the decade-long harm Google inflicted on the markets for

general search and search text advertising and the depths of that harm. At the same time, it also

provides a roadmap to the components necessary to restore competition to these markets that

have “revolutionized how we live” and how search advertisers reach potential customers. Id. at

1. While following that map requires a comprehensive remedy, making those changes would

unleash a significant opportunity for existing competitors and innovative technologies to offer

consumers who use general search services and the advertisers who sell to them meaningful

choices and competitive rates for the first time in over a decade. Plaintiffs’ proposed remedy is

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grounded in longstanding precedent demanding robust remedies for monopolization. Having

found a violation of the law, courts are empowered to “prevent future violations and eradicate

existing evils.” United States v. Microsoft Corp., 253 F.3d 34, 101 (D.C. Cir. 2001) (quoting

United States v. Ward Baking Co., 376 U.S. 327, 330–31 (1964)). Any remedy requires a

“comprehensive” and “unitary framework” to restore competition with provisions “intended to

complement and reinforce each other.” See New York v. Microsoft Corp., 531 F. Supp. 2d 141,

170 (D.D.C. 2008). And a remedy for Google’s unlawful monopolization must simultaneously

(1) unfetter these markets from Google’s exclusionary conduct, (2) pry them open to

competition, (3) deny Google the fruits of its statutory violations, and (4) prevent Google from

monopolizing these and related markets in the future. See Microsoft, 253 F.3d at 103 (quoting

Ford Motor Co. v. United States, 405 U.S. 562, 577 (1972) and United States v. United Shoe

Mach. Corp., 391 U.S. 244, 250–51 (1968)); see also Zenith Radio Corp. v. Hazeltine Rsch.,

Inc., 395 U.S. 100, 132–33 (1969) (antitrust remedies can extend to related markets); Int’l

Boxing Club of N.Y., Inc. v. United States, 358 U.S. 242, 262 (1959) (same). The Proposed Final

Judgment serves all of these ends.

Plaintiffs’ proposed remedy is also grounded in the market realities of general search

services and search text advertising as we find them today. As the Court found, Google’s illegal

conduct contributes to a significant (and growing) scale gap that continues to exacerbate the

harms found by the Court. Op. at 34. Search engines rely on user data to improve search

quality—an outcome that drives more users to a search engine. Id. at 35. Users attract

advertisers, and advertising dollars fund general search engines, creating a perpetual feedback

loop that further entrenches Google. Id. at 230–31. Thus, Google’s exclusionary conduct has

ensured not only that rivals are denied distribution but also that rivals are unlawfully

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disadvantaged with respect to quality. Id. The playing field is not level because of Google’s

conduct, and Google’s quality reflects the ill-gotten gains of an advantage illegally acquired. The

remedy must close this gap and deprive Google of these advantages.

Restoring competition to the markets for general search and search text advertising as

they exist today will require reactivating the competitive process that Google has long stifled:

The remedy must enable and encourage the development of an unfettered search ecosystem that

induces entry, competition, and innovation as rivals vie to win the business of consumers and

advertisers. To reach this goal, the remedy must address each of the ingredients necessary to

create opportunities for competition to emerge. The promise of new technologies, including

advances in artificial intelligence (“AI”), may present an opportunity for fresh competition. But

only a comprehensive set of remedies can thaw the ecosystem and finally reverse years of

anticompetitive effects. A successful remedy requires that Google: stop third-party payments that

exclude rivals by advantaging Google and discouraging procompetitive partnerships that would

offer entrants access to efficient and effective distribution; disclose data sufficient to level the

scale-based playing field it has illegally slanted, including, at the outset, licensing syndicated

search results that provide potential competitors a chance to offer greater innovation and more

effective competition; and reduce Google’s ability to control incentives across the broader

ecosystem via ownership and control of products and data complementary to search.

Google’s ownership and control of Chrome and Android—key methods for the

distribution of search engines to consumers—poses a significant challenge to effectuate a remedy

that aims to “unfetter [these] market[s] from anticompetitive conduct” and “ensure that there

remain no practices likely to result in monopolization in the future.” Microsoft, 253 F.3d at 103.

To address these challenges, Google must divest Chrome, which has “fortified [Google’s]

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dominance,” Op. at 33, so that rivals may pursue distribution partnerships that this “realit[y] of

control,” id. at 159 (citations omitted), today prevents.

As to Android—a critical platform on which search competitors rely and for which

Google has myriad obvious and not-so-obvious ways to favor its own search products—there are

two options: one that swiftly, efficiently, and decisively strikes at the locus of some

anticompetitive conduct at issue here, and a second option that invites Court and Plaintiff

oversight into longer-term behavioral remedies that may be more protracted and less certain due

to Google’s conduct. The most straightforward solution—the first option—would be to divest

Android, which would prevent Google from using Android to exclude rival search providers. But

Plaintiffs recognize that such divestiture may draw significant objections from Google or other

market participants. As an alternative to the divestiture of Android, Plaintiffs have presented

behavioral remedies that would blunt Google’s ability to use its control of the Android

ecosystem to favor its general search services and search text ad monopolies as well as limit

Google’s ability to discriminate in favor of its own search and ads businesses. This alternative

option would require vigilance and oversight by the Court and Plaintiffs; if such efforts

ultimately fail to achieve the high standards for meaningful relief in these critical markets, the

Court could require return to the first option. Google is further prohibited from owning or

acquiring any interests in search rivals, potential entrants, and rival search or search ads-related

AI products, and it must immediately divest any such interests it owns.

Plaintiffs’ remedy proposal also ensures efficacy, efficiency, and administrability by

deploying a Technical Committee to investigate and examine the issues that will invariably arise

relating to Google’s implementation of the remedies, similar to the approach approved by the

D.C. Circuit in United States v. Microsoft. See Massachusetts v. Microsoft Corp., 373 F.3d 1199,

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1243–44 (D.C. Cir. 2004) (“[T]he Government’s ability to enforce the decree is clearly

strengthened, not diminished, by the existence and composition of the Technical Committee”).

Plaintiffs’ proposal also provides a streamlined path for the regular evaluation and modification

often required of monopolization remedies, including the eventual divestiture of Android if

Google chooses to retain ownership but persists in exploiting its control to the detriment of

competition. United Shoe, 391 U.S. at 250–51.

Moreover, the remedy must restore incentives for innovation and disruptive entry that

Google’s conduct has—for over a decade—diminished. For example, in recent years “[t]he

integration of generative AI is perhaps the clearest example of competition advancing search

quality.” Op. at 41. AI has the ability to affect market dynamics in these industries today as well

as tomorrow. The remedy must prevent Google from frustrating or circumventing the Court’s

Final Judgment by manipulating the development and deployment of new technologies like

query-based AI solutions that provide the most likely long-term path for a new generation of

search competitors, who will depend on the absence of anticompetitive constraints to evolve into

full-fledged competitors and competitive threats.

II. The Proposed Final Judgment

Guided by governing case law, and with these market realities and dynamics in mind,

Plaintiffs respectfully submit the Initial Proposed Final Judgment (“PFJ”), which provides the

Court with a comprehensive and unitary remedy to address the harms in the general search

services and search text advertising markets, ensure that Google cannot further cement its

monopolies by engaging in anticompetitive conduct, and prevent Google from circumventing the

Court’s judgment. To that end, Plaintiffs propose a variety of interconnected and self-reinforcing

remedies to: (1) stop and prevent exclusionary agreements with third parties; (2) prevent Google

from self-preferencing through its ownership and control of search-related products; (3) prevent

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Google from stifling or eliminating emerging competitive threats through acquisitions, minority

investments, or partnerships; (4) disclose data critical to restoring competition; (5) increase

transparency and control for advertisers; (6) end Google’s unlawful distribution; and (7) allow

for the enforcement of the PFJ while preventing circumvention. Those remedies are summarized

below for the Court’s convenience. Further, and to correct for the fact that Google’s unchecked

monopolies have frozen the general search ecosystem for more than a decade, Plaintiffs’

proposed remedies run for a period of 10 years, with some exceptions as detailed below and in

the PFJ.

A. Stopping and Preventing Exclusionary Agreements with Third Parties

An effective remedy must prevent Google from entering into contracts that foreclose or

otherwise exclude competing general search engines and potential entrants, including by raising

their costs, discouraging their distribution, or depriving them of competitive access to inputs. As

detailed in Section IV, the PFJ prohibits Google from providing third parties something of value

(including financial payments) in order to make Google the default general search engine or

otherwise discouraging those third parties from offering competing search products. See Op. at

216 (finding “Google’s distribution agreements are exclusionary contracts that violate Section 2”

and “clearly have a significant effect in preserving [Google’s] monopoly.”) (citations omitted).

The PFJ also prohibits Google from entering exclusive agreements with content

publishers; bundling, tying, or comingling its general search engine or search access points with

any other Google product; entering revenue share agreements related to the distribution of

general search services; or participating in investments in, collaborations with, or acquisitions of

its competitors or potential competitors in the general search services or search text ads markets

without prior approval of the United States. The proposed remedies are designed to end Google’s

unlawful practices and open up the market for rivals and new entrants to emerge.

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B. Prohibited Ownership And Control That Enables Self-Preferencing

In order to safeguard against the possibility of further foreclosure and exclusion of rivals

and potential entrants including via self-preferencing, the PFJ requires Google to divest Chrome.

As the Court recognized, “Google’s near-complete control of the most efficient search

distribution channels is a major barrier to entry,” and the Chrome default is “a market reality that

significantly narrows the available channels of distribution and thus disincentivizes the

emergence of new competition.” Op. at 159. Plaintiffs’ PFJ addresses this “realit[y] of control,”

id., and will restore incentives to rivals and potential entrants to compete.

Plaintiffs’ PFJ further provides that Google is prohibited from owning not only a

browser—following its divestiture of Chrome it may not reenter the browser market for five

years—but also from owning or acquiring any investment or interest in any search or search text

ad rival, search distributor, or rival query-based AI product or ads technology. Google’s financial

entanglements with current or future rivals risk compromising the proposed remedy. Investments

in or acquisitions of potential rivals would stifle emerging competition or reduce their incentives

to challenge Google. Such arrangements frustrate the PFJ’s remedial goals of fostering

innovation and transforming the general search and search text ads markets over the next decade.

Google must disclose any such investments it owns, immediately refrain from using these

interests to discourage or disincentivize competing products, and must divest these holdings

within six months.

Plaintiffs’ PFJ also provides for further contingent structural relief—the divestiture of

Android—if Plaintiffs’ proposed conduct remedies are not effective in preventing Google from

improperly leveraging its control of the Android ecosystem to its advantage, or if Google

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attempts to circumvent the remedy package. See, e.g., United Shoe, 391 U.S. at 249–51.1 Similar

to United Shoe, Plaintiffs propose with respect to Android “that relatively mild remedies should

be tried as a first resort, and that the possibility of more drastic measures should be held in

abeyance.” Id. at 249. Indeed, in United Shoe, when the initially imposed behavioral remedies

failed to establish the decree’s goal of “workable competition,” the Supreme Court ordered the

district court to consider the government’s subsequent request to break the defendant into “two

fully competing companies.” Id. at 247, 251–52 (“the time has come to prescribe other, and if

necessary more definitive, means to achieve the result”). Alternatively, Google may also choose

to divest Android at the outset in lieu of adhering to the requirements of Section V as they relate

to Android.

C. Conduct Remedies That Prevent Self-Preferencing

An effective remedy must also ensure that Google cannot circumvent the Court’s remedy

by providing its search products preferential access to related products or services that it owns or

controls, including mobile operating systems (e.g., Android), apps (e.g., YouTube), or AI

products (e.g. Gemini) or related data. As noted in Section V, the PFJ prohibits, among other

things, Google from using any owned or operated asset to preference its general search engine or

search text ad products. The PFJ further prohibits Google from engaging in conduct that

undermines, frustrates, interferes with, or in any way lessens the ability of a user to discover a

rival general search engine, limits the competitive capabilities of rivals, or otherwise impedes

user discovery of products or services that are competitive threats to Google in the general search

services or search text ads markets. Op. at 119–21, 210 (finding that Google’s contractual

1
As the Court in Microsoft recognized, “conduct remedies may be unavailing” in cases such as
this, where “years have passed since [Google] engaged in the first conduct.” Microsoft, 253
F.3d at 49.

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requirements that Chrome be preinstalled and the Google Search widget be placed on the home

screen of all Android devices was an unlawful exclusive agreement).

D. Restoring Competition Through Syndication And Data Access

Data at scale is the “essential raw material” for “building, improving and sustaining” a

competitive general search engine. Op. at 226 (finding that “Google’s exclusive

agreements…deny rivals access to use queries, or scale, needed to effectively compete.”).

Through its unlawful behavior, Google has accumulated a staggering amount of data over many

years, at the expense of its rivals. Id. Plaintiffs’ PFJ aims to remedy this anticompetitively

acquired advantage. As set forth in Section VI, the PFJ requires Google, among other things, to

make its search index available at marginal cost, and on an ongoing basis, to rivals and potential

rivals; and also requires Google to provide rivals and potential rivals both user-side and ads data

for a period of ten years, at no cost, on a non-discriminatory basis, and with proper privacy

safeguards in place. Section VI further requires that Google provide publishers, websites, and

content creators with data crawling rights (such as the ability to opt out of having their content

crawled for the index or training of large language models or displayed as AI-generated content).

To remove barriers to entry and erode Google’s unlawfully gained scale advantages,

Section VII requires Google to syndicate (subject to certain restrictions) its search results,

ranking signals, and query understanding information for ten years. The PFJ only requires

Google to syndicate queries that originate in the United States. Section VII also requires Google

to syndicate its search text ads for terms of one year subject to certain restrictions.

E. Restoring Competition By Improving Transparency And Reduction Of

Switching Costs

Google’s unlawful maintenance of its search text advertising monopoly has undermined

advertisers’ choice of search providers, as well as rivals’ ability to monetize search advertising,

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and has enabled “Google to profitably charge supracompetitive prices for search text

advertisements” while “degrad[ing] the quality of its text advertisements” and the related

services and reporting. Op. at 258–65 (finding “Google’s text ads products has degraded” and

“advertisers receive less information in search query reports.”). As set forth in Section VIII,

Plaintiffs’ PFJ will remedy these harms by providing advertisers with the information, options,

and visibility into the performance and cost of Google Text Ads necessary to optimize their

advertising across Google and its rivals. In particular, the PFJ requires Google to include fulsome

and necessary real-time performance information about ad performance and costs in its search

query reports to advertisers, and further requires Google to increase advertiser control by

improving keyword matching options to advertisers. Op. at 263–64 (finding Google degraded

SQR content and reduced control over keyword matching).

The PFJ also prohibits Google from limiting the ability of advertisers to export search

text ad data and information for which the advertiser bids on keywords, and further requires that

Google provide to the Technical Committee and Plaintiffs a monthly report outlining any

changes to its search text ads auction and its public disclosure of those changes.

F. Limitations On Distribution And User Notifications To Restore Competition

A comprehensive and unitary remedy in this case must also undo the effects on search

distribution. See Op. at 3 (“[M]ost devices in the United States come preloaded exclusively with

Google. These distribution deals have forced Google’s rivals to find other ways to reach users.”).

To remedy these harms, the PFJ requires Google to divest Chrome, which will

permanently stop Google’s control of this critical search access point and allow rival search

engines the ability to access the browser that for many users is a gateway to the internet. In

addition, the PFJ contains multiple provisions that will limit Google’s distribution of general

search services by contract with third-party devices and search access points (e.g., Samsung

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devices, Safari, Firefox) and via self-distribution on Google devices and search access points

(e.g., Pixel) which will facilitate competition in the markets for general search services and

search text advertising. These provisions are designed to end Google’s unlawful distribution

agreements, ensure that Google cannot approximate its unlawful practices with updated

contracts, and eliminate anticompetitive payments to distributors, including Apple. As set forth

in Section IV, the PFJ prohibits Google from offering Apple anything of value for any form of

default, placement, or preinstallation distribution (including choice screens) related to general

search or a search access point. See Op. at 238, 240–44 (“Apple, a fierce potential competitor,

remains on the sidelines due to the large revenue share payments it receives from Google”). As

set forth in Section IX, for non-Apple distributors and third-party devices, the PFJ similarly

prohibits—with limited exceptions—Google from offering anything of value for any form of

default, placement, or preinstallation distribution (including choice screens) related to general

search or a search access point.

The PFJ further prohibits Google from preinstalling any search access point on any new

Google device, and requires it to display a choice screen on every new and existing instance of a

Google browser where the user has not previously affirmatively selected a default general search

engine. The choice screens must be designed not to preference Google and to be accessible, easy

to use, and minimize choice friction, based on empirical evidence of consumer behavior, among

other requirements.

User choice will be improved when consumers better understand the benefits that

Google’s rivals can provide. For that reason, Colorado Plaintiff States have included a provision

requiring Google to fund a nationwide advertising and education program. The fund’s purpose is

to enhance the effectiveness of distribution remedies by informing users of the outcome of this

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litigation and the remedies in the Final Judgment designed to increase user choice. The program

may include short-term incentive payments to individual users as a further incentive to choosing

a non-Google default on a choice screen.

G. Administration, Anti-circumvention, and Anti-retaliation

A remedy that prevents and restrains monopoly maintenance will require administration

as well as protections against circumvention and retaliation, including through novel paths to

preserving dominance in the monopolized markets. This is especially important in the types of

markets implicated here. As set forth in Section X, Plaintiffs’ PFJ requires Google to appoint an

internal Compliance Officer and establishes a Technical Committee to assist Plaintiffs and the

Court in monitoring Google’s compliance. See United States v. Microsoft Corp., Civ. No. 98-

1232 (CKK), 2002 U.S. Dist. LEXIS 22864, at *22 (D.D.C. Nov. 12, 2002) (establishing a

Technical Committee “to assist in enforcement of and compliance with this Final Judgment.”).

This section of the PFJ provides Plaintiffs tools to investigate complaints about Google’s

compliance and prohibits Google from taking retaliatory or circumventing actions.

⁕ ⁕ ⁕

Plaintiffs’ PFJ reflects extensive efforts to engage with market participants, utilize formal

discovery, and collaborate with experts. Given that third-party outreach and discovery on Google

are ongoing, Plaintiffs will continue to investigate and evaluate the remedies necessary to restore

competition to the affected markets. Plaintiffs reserve the right to add, remove, or modify

provisions of the PFJ as needed following further engagement with market participants and

additional remedies discovery. Consistent with the Court’s scheduling order governing remedy

proceedings, Plaintiffs will file a Revised PFJ on March 7, 2025. See ECF 1043 at 2.

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Dated: November 20, 2024 Respectfully submitted,

/s/ Karl E. Herrmann

David E. Dahlquist
Adam T. Severt
Veronica N. Onyema (D.C. Bar #979040)
Diana A. Aguilar Aldape
Sarah M. Bartels (D.C. Bar #1029505)
Travis R. Chapman
Grant M. Fergusson (D.C. Bar #90004882)
Meagan M. Glynn (D.C. Bar #1738267)
R. Cameron Gower
Karl E. Herrmann (D.C. Bar #1022464)
Ian D. Hoffman
Elizabeth S. Jensen
Ryan T. Karr
Claire M. Maddox (D.C. Bar #498356)
Michael G. McLellan (D.C. Bar #489217)
Ryan S. Struve (D.C. Bar #495406)
Sara Trent
Jennifer A. Wamsley (D.C. Bar #486540)
Catharine S. Wright (D.C. Bar #1019454)

U.S. Department of Justice

Antitrust Division
Technology & Digital Platforms Section
450 Fifth Street NW, Suite 7100
Washington, DC 20530
Telephone: (202) 805-8563
David.Dahlquist@usdoj.gov
Adam.Severt@usdoj.gov

Counsel for Plaintiff

United States of America
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 15 of 23

By: /s/ Christoper A. Knight Brian Wang, Deputy Attorney General

Ashley Moody, Attorney General Carolyn D. Jeffries, Deputy Attorney
R. Scott Palmer, Special Counsel, Complex General (DC Bar No. 1600843)
Enforcement Chief, Antitrust Division Office of the Attorney General
Lee Istrail, Assistant Attorney General California Department of Justice
Christopher A. Knight, Assistant Attorney 455 Golden Gate Avenue, Suite 11000
General San Francisco, California 94102
Office of the Attorney General, State of Cari.Jeffries@doj.ca.gov
Florida
PL-01 The Capitol Counsel for Plaintiff State of California
Tallahassee, Florida 32399
Lee.Istrail@myfloridalegal.com Matthew M. Ford
Scott.Palmer@myfloridalegal.com Arkansas Bar No. 2013180
Christopher.Knight@myfloridalegal.com Senior Assistant Attorney General
Office of the Arkansas Attorney General
Counsel for Plaintiff State of Florida Tim Griffin
323 Center Street, Suite 200
By: /s/ Diamante Smith Little Rock, AR 72201
Ken Paxton, Attorney General Matthew.Ford@arkansasag.gov
Brent Webster, First Assistant Attorney
General Counsel for Plaintiff State of Arkansas
Ralph Molina, Deputy First Assistant
Attorney General Christopher Carr, Attorney General
James Lloyd, Deputy Attorney General for Logan B. Winkles, Deputy Attorney General
Civil Litigation Ronald J. Stay, Jr., Senior Assistant Attorney
Ryan Baasch, Associate Deputy Attorney General
General for Civil Litigation Charles Thimmesch, Senior Assistant
Trevor Young, Deputy Chief, Antitrust Attorney General
Division Office of the Attorney General, State of
Diamante Smith, Assistant Attorney Georgia
General, Antitrust Division 40 Capitol Square, SW
Office of the Attorney General, State of Atlanta, Georgia 30334-1300
Texas cthimmesch@law.georgia.gov
300 West 15th Street
Austin, Texas 78701 Counsel for Plaintiff State of Georgia
Diamante.Smith@oag.texas.gov
Theodore Edward Rokita, Attorney General
Counsel for Plaintiff State of Texas Scott L. Barnhart, Chief Counsel and
Director, Consumer Protection Division
By: /s/ Carolyn D. Jeffries Jesse Moore, Deputy Attorney General
Rob Bonta, Attorney General Christi Foust, Deputy Attorney General
Paula Blizzard, Senior Assistant Attorney Office of the Attorney General, State of
General Indiana
Michael Jorgenson, Supervising Deputy Indiana Government Center South, Fifth
Attorney General Floor
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 16 of 23

302 West Washington Street Consumer Protection Section

Indianapolis, Indiana 46204 Missouri Attorney General's Office
Jesse.Moore@atg.in.gov 815 Olive Street | Suite 200
Saint Louis, Missouri 63101
Counsel for Plaintiff State of Indiana michael.schwalbert@ago.mo.gov
Phone: 314-340-7888
Russell Coleman, Attorney General Fax: 314-340-7981
J. Christian Lewis, Commissioner of the
Office of Consumer Protection Counsel for Plaintiff State of Missouri
Philip R. Heleringer, Executive Director of
the Office of Consumer Protection Lynn Fitch, Attorney General
Jonathan E. Farmer, Deputy Executive Crystal Utley Secoy, Assistant Attorney
Director of the Office of Consumer General
Protection Office of the Attorney General, State of
Office of the Attorney General, Mississippi
Commonwealth of Kentucky P.O. Box 220
1024 Capital Center Drive, Suite 200 Jackson, Mississippi 39205
Frankfort, Kentucky 40601 Crystal.Utley@ago.ms.gov
Philip.Heleringer@ky.gov
Counsel for Plaintiff State of Mississippi
Counsel for Plaintiff Commonwealth of
Kentucky Anna Schneider
Bureau Chief
Liz Murrill, Attorney General Montana Office of Consumer Protection
Patrick Voelker, Assistant Attorney General P.O. Box 200151
Office of the Attorney General, State of Helena, MT. 59602-0150
Louisiana Phone: (406) 444-4500
Public Protection Division Fax: 406-442-1894
1885 North Third St. Anna.schneider@mt.gov
Baton Rouge, Louisiana 70802
voelkerp@ag.louisiana.gov Counsel for Plaintiff State of Montana

Counsel for Plaintiff State of Louisiana Alan Wilson, Attorney General

W. Jeffrey Young, Chief Deputy Attorney
Dana Nessel, Attorney General General
Scott Mertens, Assistant Attorney General C. Havird Jones, Jr., Senior Assistant Deputy
Michigan Department of Attorney General Attorney General
P.O. Box 30736 Mary Frances Jowers, Assistant Deputy
Lansing, Michigan 48909 Attorney General
MertensS@michigan.gov Office of the Attorney General, State of
South Carolina
Counsel for Plaintiff State of Michigan 1000 Assembly Street
Rembert C. Dennis Building
Michael Schwalbert P.O. Box 11549
Missouri Bar No. 63229 Columbia, South Carolina 29211-1549
Assistant Attorney General mfjowers@scag.gov
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 17 of 23

Counsel for Plaintiff State of South Carolina

Joshua L. Kaul, Attorney General
Laura E. McFarlane, Assistant Attorney
General
Wisconsin Department of Justice
17 W. Main St.
Madison, Wisconsin 53701
mcfarlanele@doj.state.wi.us
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 18 of 23

PHILIP WEISER
Attorney General of Colorado Counsel for Plaintiff State of Nebraska

/s/ Jonathan B. Sallet KRISTIN K. MAYES

Jonathan B. Sallet, DC Bar No. 336198 Attorney General of Arizona
Steven M. Kaufmann
Elizabeth W. Hereford Robert A. Bernheim, Unit Chief Counsel
Conor J. May Jayme Weber, Senior Litigation Counsel
Colorado Office of the Attorney General Arizona Office of the Attorney General
1300 Broadway, 7th Floor 400 West Congress, Ste. S-215
Denver, CO 80203 Tucson, Arizona 85701
Telephone: (720) 508-6000 Telephone: (520) 628-6507
E-Mail: Jon.Sallet@coag.gov E-Mail: Robert.bernheim@azag.gov
Steve.Kaufmann@coag.gov Jayme.Weber@azag.gov
Elizabeth.Hereford@coag.gov
Conor.May@coag.gov Counsel for Plaintiff State of Arizona

William F. Cavanaugh, Jr. BRENNA BIRD

PATTERSON BELKNAP WEBB & Attorney General of Iowa
TYLER LLP
1133 Avenue of the Americas Noah Goerlitz, Assistant Attorney General
New York, NY 10036 Office of the Attorney General of Iowa
Telephone: (212) 336-2793 1305 E. Walnut St., 2nd Floor
E-Mail: wfcavanaugh@pbwt.com Des Moines, IA 50319
Telephone: (515) 725-1018
Counsel for Plaintiff State of Colorado E-Mail: Noah.goerlitz@ag.iowa.gov

MIKE HILGERS Counsel for Plaintiff State of Iowa

Attorney General of Nebraska
LETITIA JAMES
Colin P. Snider, Assistant Attorney Attorney General of New York
General
Nebraska Department of Justice Elinor R. Hoffmann
Office of the Attorney General Morgan J. Feder
2115 State Capitol Michael D. Schwartz
Lincoln, NE 68509 Office of the Attorney General of New
Telephone: (402) 471-3840 York
E-Mail: Colin.Snider@nebraska.gov 28 Liberty Street
New York, NY 10005
William F. Cavanaugh, Jr. Telephone: (212) 416-8513
PATTERSON BELKNAP WEBB & E-Mail: Elinor.hoffmann@ag.ny.gov
TYLER LLP Morgan.feder@ag.ny.gov
1133 Avenue of the Americas Michael.schwartz@ag.ny.gov
New York, NY 10036
Telephone: (212) 336-2793 Counsel for Plaintiff State of New York
E-Mail: wfcavanaugh@pbwt.com
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 19 of 23

JOSHUA STEIN
Attorney General of North Carolina Counsel for Plaintiff State of Utah

Kunal Janak Choksi TREGARRICK TAYLOR

Joshua Daniel Abram Attorney General of Alaska
Jessica Vance Sutton
North Carolina Department of Justice Jeff Pickett
114 W. Edenton St. State of Alaska, Department of Law
Raleigh, NC 27603 Office of the Attorney General
Telephone: (919) 716-6000 1031 W. Fourth Avenue, Suite 200
E-Mail: kchoksi@ncdoj.gov Anchorage, Alaska 99501
jabram@ncdoj.gov Telephone: (907) 269-5100
jsutton2@ncdoj.gov E-Mail: Jeff.pickett@alaska.gov

Counsel for Plaintiff State of North Counsel for Plaintiff State of Alaska
Carolina
WILLIAM TONG
JONATHAN SKRMETTI Attorney General of Connecticut
Attorney General of Tennessee
Nicole Demers
J. David McDowell Office of the Attorney General of
Austin Ostiguy Connecticut
Tyler Corcoran 165 Capitol Avenue, Suite 5000
Office of the Attorney General and Hartford, CT 06106
Reporter Telephone: (860) 808-5202
P.O. Box 20207 E-Mail: Nicole.demers@ct.gov
Nashville, TN 37202
Telephone: (615) 741-8722 Counsel for Plaintiff State of Connecticut
E-Mail: David.McDowell@ag.tn.gov
austin.ostiguy@ag.tn.gov KATHLEEN JENNINGS
Tyler.Corcoran@ag.tn.gov Attorney General of Delaware

Counsel for Plaintiff State of Tennessee Michael Andrew Undorf

Delaware Department of Justice
SEAN REYES Fraud and Consumer Protection Division
Attorney General of Utah 820 N. French St., 5th Floor
Wilmington, DE 19801
Matthew Michaloski Telephone: (302) 683-8816
Marie W.L. Martin E-Mail: Michael.undorf@delaware.gov
Utah Office of Attorney General
160 E 300 S, 5th Floor Counsel for Plaintiff State of Delaware
P.O. Box 140830
Salt Lake City, Utah 84114 BRIAN SCHWALB
Telephone: (801) 440-9825 Attorney General of the District of
E-Mail: mmichaloski@agutah.gov Columbia
mwmartin@agutah.gov
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 20 of 23

Elizabeth Gentry Arthur

Office of the Attorney General for the Counsel for Plaintiff State of Idaho
District of Columbia
400 6th Street NW KWAME RAOUL
Washington, DC 20001 Attorney General of Illinois
Telephone: (202) 724-6514
E-Mail: Elizabeth.arthur@dc.gov Elizabeth Maxeiner
Brian Yost
Counsel for Plaintiff District of Columbia Jennifer Coronel
Office of the Attorney General of Illinois
DOUGLAS MOYLAN 100 W. Randolph St.
Attorney General of Guam Chicago, IL 60601
Telephone: (773) 590-7935
Fred Nishihira E-Mail: Elizabeth.maxeiner@ilag.gov
Office of the Attorney General of Guam Brian.yost@ilag.gov
590 S. Marine Corps Drive, Suite 901 Jennifer.coronel@ilag.gov
Tamuning, Guam 96913
Telephone: (671) 475-3324 Counsel for Plaintiff State of Illinois
E-Mail: fnishihira@oagguam.org
KRIS W. KOBACH
Counsel for Plaintiff Territory Guam Attorney General of Kansas

ANNE E. LOPEZ Lynette R. Bakker

Attorney General of Hawai‘i Kansas Office of the Attorney General
120 S.W. 10th Avenue, 2nd Floor
Rodney I. Kimura Topeka, KS 66612
Department of the Attorney General, State Telephone: (785) 296-3751
of Hawai‘i E-Mail: Lynette.bakker@ag.ks.gov
425 Queen Street
Honolulu, HI 96813 Counsel for Plaintiff State of Kansas
Telephone (808) 586-1180
E-Mail: Rodney.i.kimura@hawaii.gov AARON M. FREY
Attorney General of Maine
Counsel for Plaintiff State of Hawai‘i
Christina M. Moylan
RAÚL LABRADOR Office of the Attorney General of Maine
Attorney General of Idaho 6 State House Station
August, ME 04333
John K. Olson Telephone: (207) 626-8800
Office of the Idaho Attorney General E-Mail: Christina.moylan@maine.gov
Consumer Protection Division
954 W. State St., 2nd Floor Counsel for Plaintiff State of Maine
P.O. Box 83720
Boise, ID 83720 ANTHONY G. BROWN
Telephone: (208) 332-3549 Attorney General of Maryland
E-Mail: John.olson@ag.idaho.gov
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 21 of 23

Schonette J. Walker Nevada Office of the Attorney General

Gary Honick 100 N. Carson Street
Office of the Attorney General of Carson City, NV 89701
Maryland Telephone: (775) 684-1164
200 St. Paul Place, 19th Floor E-Mail: mbadorine@ag.nv.gov
Baltimore, MD 21202 ltucker@ag.nv.gov
Telephone: (410) 576-6480
E-Mail: swalker@oag.state.md.us Counsel for Plaintiff State of Nevada
ghonick@oag.state.md.us
JOHN FORMELLA
Counsel for Plaintiff State of Maryland Attorney General of New Hampshire

ANDREA CAMPBELL Brandon Garod

Attorney General of Massachusetts Office of Attorney General of New
Hampshire
William T. Matlack 33 Capitol Street
Office of the Attorney General of Concord, NH 03301
Massachusetts Telephone: (603) 271-1217
One Ashburton Place, 18th Floor E-Mail: Brandon.h.garod@doj.nh.gov
Boston, MA 02108
Telephone: (617) 727-2200 Counsel for Plaintiff State of New
E-Mail: William.matlack@mass.gov Hampshire

Counsel for Plaintiff Commonwealth of MATTHEW PLATKIN

Massachusetts Attorney General of New Jersey

KEITH ELLISON Isabella R. Pitt

Attorney General of Minnesota Deputy Attorney General
New Jersey Attorney General’s Office
Zach Biesanz 124 Halsey Street, 5th Floor
Senior Enforcement Counsel Newark, NJ 07102
Office of the Minnesota Attorney General Telephone: (973) 648-7819
Antitrust Division E-Mail: Isabella.Pitt@law.njoag.gov
445 Minnesota Street, Suite 600
St. Paul, MN 55101 Counsel for Plaintiff State of New Jersey
Telephone: (651) 757-1257
E-Mail: Zach.biesanz@ag.state.mn.us RAÚL TORREZ
Attorney General of New Mexico
Counsel for Plaintiff State
of Minnesota Judith E. Paquin Cholla Khoury
Assistant Attorney General
AARON D. FORD New Mexico Office of the Attorney
Attorney General of Nevada General
408 Galisteo St.
Michelle C. Badorine Santa Fe, NM 87504
Lucas J. Tucker Telephone: (505) 490-4885
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 22 of 23

E-Mail: jpaquin@nmag.gov Telephone: (405) 522-1014

ckhoury@nmag.gov E-Mail: Robert.carlson@oag.ok.gov

Counsel for Plaintiff State of New Mexico Counsel for Plaintiff State of Oklahoma

DREW WRIGLEY ELLEN ROSENBLUM

Attorney General of North Dakota Attorney General of Oregon

Elin S. Alm Cheryl Hiemstra

Assistant Attorney General Oregon Department of Justice
Consumer Protection and Antitrust 1162 Court St. NE
Division Salem, OR 97301
Office of the Attorney General of North Telephone: (503) 934-4400
Dakota E-Mail: Cheryl.hiemstra@doj.state.or.us
1720 Burlington Drive, Suite C
Bismarck, ND 58504 Counsel for Plaintiff State of Oregon
Telephone: (701) 328-5570
E-Mail: ealm@nd.gov MICHELLE HENRY
Attorney General of Pennsylvania
Counsel for Plaintiff State of North
Dakota Tracy W. Wertz
Joseph S. Betsko
DAVID YOST Pennsylvania Office of Attorney General
Attorney General of Ohio Strawberry Square
Harrisburg, PA 17120
Jennifer Pratt Telephone: (717) 787-4530
Beth Ann Finnerty E-Mail: jbetsko@attorneygeneral.gov
Mark Kittel twertz@attorneygeneral.gov
Office of the Attorney General of Ohio
30 E Broad Street, 26th Floor Counsel for Plaintiff Commonwealth of
Columbus, OH 43215 Pennsylvania
Telephone: (614) 466-4328
E-Mail: DOMINGO EMANUELLI
Jennifer.pratt@ohioattorneygeneral.gov HERNANDEZ
Beth.finnerty@ohioattorneygeneral.gov Attorney General of Puerto Rico
Mark.kittel@ohioattorneygeneral.gov Guarionex Diaz Martinez
Assistant Attorney General Antitrust
Counsel for Plaintiff State of Ohio Division
Puerto Rico Department of Justice
GENTNER DRUMMOND P.O. Box 9020192
Attorney General of Oklahoma San Juan, Puerto Rico 00902
Telephone: (787) 721-2900, Ext. 1201
Robert J. Carlson E-Mail: gdiaz@justicia.pr.gov
Office of the Oklahoma Attorney General
313 NE 21st Street Counsel for Plaintiff Territory Puerto
Oklahoma City, OK 73105 Rico
 Case 1:20-cv-03010-APM Document 1062 Filed 11/20/24 Page 23 of 23

Richmond, VA 23219
PETER NERONHA Telephone: (804) 692-0485
Attorney General of Rhode Island E-Mail: thenry@oag.state.va.us

Stephen Provazza Counsel for Plaintiff State of Virginia

Rhode Island Office of the Attorney
General ROBERT FERGUSON
150 South Main Street Attorney General of Washington
Providence, RI 02903
Telephone: (401) 274-4400 Amy Hanson
E-Mail: SProvazza@riag.ri.gov Senior Assistant Attorney General
800 Fifth Avenue, Suite 2000
Counsel for Plaintiff State of Rhode Island Seattle, WA 98104
Telephone: (206) 464-5419
MARTIN J. JACKLEY E-Mail: Amy.hanson@atg.wa.gov
Attorney General of South Dakota
Counsel for Plaintiff State of Washington
Yvette K. Lafrentz
Office of the Attorney General of South PATRICK MORRISEY
Dakota Attorney General of West Virginia
1302 E. Hwy 14, Suite 1
Pierre, SD 57501 Douglas Lee Davis
Telephone: (605) 773-3215 Office of the Attorney General, State of
E-Mail: Yvette.lafrentz@state.sd.us West Virginia
1900 Kanawha Boulevard
Counsel for Plaintiff State of South East Building 6, Suite 401
Dakota P.O. Box 1789
Charleston, WV 25305
CHARITY R. CLARK Telephone: (304) 558-8986
Attorney General of Vermont E-Mail: Douglas.l.davis@wvago.gov

Christopher J. Curtis, Assistant Attorney Counsel for Plaintiff State of West Virginia
General
Office of the Attorney General of Vermont BRIDGET HILL
109 State St. Attorney General of Wyoming
Montpelier, VT 05609
Telephone: (802) 828-3170 Amy Pauli
E-Mail: christopher.curtis@vermont.gov Wyoming Attorney General’s Office
Counsel for Plaintiff State of Vermont 2320 Capitol Avenue
Kendrick Building
JASON S. MIYARES Cheyenne, WY 82002
Attorney General of Virginia Telephone: (307) 777-6397
E-Mail: amy.pauli@wyo.gov
Tyler T. Henry
Office of the Attorney General of Virginia Counsel for Plaintiff State of
202 N. 9th Street Wyoming