Streetmap.EU Ltd v Google Inc. & Ors

Streetmap.EU Ltd v Google Inc. & Ors

The introduction of the new-style Maps OneBox by Google in June 2007, which displayed a thumbnail map from Google Maps at the top of search results, was not reasonably likely appreciably to affect competition in the market for online maps. Even if it was, the conduct was objectively justified as a technical improvement, and the alternatives proposed by Streetmap were either ineffective or disproportionate. No abuse of dominance was established.

Parties
Claimant: Streetmap.EU Limited; Defendant: Google Inc.; Defendant: Google Ireland Limited; Defendant: Google UK Limited
Jurisdiction
England and Wales
Judgment Date
12 February 2016
Procedural Posture
Civil (competition Law) / Judgment After Trial of Preliminary Issue
Outcome
Claim dismissed; no abuse of dominance found.
Legal Topics
Abuse of Dominant Position, Discrimination, Objective Justification, Foreclosure, Online Search Engines, Online Maps
Competition Law European Union Law Abuse of Dominant Position Discrimination Objective Justification Foreclosure Online Search Engines Online Maps

Case Brief

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Parties

Streetmap.EU Limited

Claimant

Google Inc.

Defendant

Google Ireland Limited

Defendant

Google UK Limited

Defendant

Procedural Posture

Civil (competition Law) / Judgment After Trial of Preliminary Issue

Legal Issues

  1. 1 Whether Google abused a dominant position by displaying a thumbnail map from Google Maps at the top of its search results, to the detriment of competing online mapping providers such as Streetmap, contrary to UK and EU competition law.

Ratio Decidendi

The introduction of the new-style Maps OneBox by Google in June 2007, which displayed a thumbnail map from Google Maps at the top of search results, was not reasonably likely appreciably to affect competition in the market for online maps. Even if it was, the conduct was objectively justified as a technical improvement, and the alternatives proposed by Streetmap were either ineffective or disproportionate. No abuse of dominance was established.

Court Disposition

Claim dismissed; no abuse of dominance found.

Orders

  • Claim against all defendants dismissed.
  • No finding of abuse of dominant position by Google.