Streetmap.eu Ltd v Google Inc
[2016] EWHC 253 (Ch)
Ratio Decidendi
A dominant undertaking displaying its own mapping product prominently in search results does not necessarily constitute an abuse of dominant position where there is an objective justification related to improving the quality of search results for users.
Ffeithiau
Streetmap, a UK online mapping company, alleged that Google abused its dominant position in online search by displaying a Google Maps thumbnail prominently at the top of search results for location-related queries, thereby diverting traffic from Streetmap's competing mapping service.
Crynodeb o'r dyfarniad
Roth J dismissed the claim, holding that while Google held a dominant position in online search, displaying the Maps thumbnail was objectively justified as an improvement to search quality. The inclusion of a clickable map in search results was a genuine product improvement that benefited consumers.
Dyfyniadau allweddol
"Competition on the merits may lead a dominant firm to offer a better product. Article 102 is not designed to protect competitors from vigorous competition, but to protect the competitive process."
— Roth J
Triniaeth ddilynol
Cited in subsequent UK abuse of dominance cases involving digital platforms.
Contrasted with the European Commission's Google Shopping decision (2017), which reached a different conclusion on self-preferencing.