Wow, this is very poorly written. Even ignoring the fact that they appear to have just sourced all their info from the CMA(note below), they really need to tigh

Wow, this is very poorly written. Even ignoring the fact that they appear to have just sourced all their info from the CMA(note below), they really need to tighten this up considerably. In particular, you cannot mix conclusions and introduction/background into the same section (when this happens, it is usually because someone is writing to a conclusion). Also, the overuse of lawerly adjectives (i.e. hyperbolic) and catch phrases really shouldn't fly. Either way, I don't think the case is made particularly well. Anytime you talk about prices, you are on very shaky ground indeed. If advertisers can't make money at a certain price, they don't buy it. Equally, Google's marginal cost is zero so they have every incentive to move inventory. Equally, publishers make money when Google does so the gross price is roughly correct (in other words, focus on fees...that is where the issues are). There is conspiracy theory stuff here - Google are fiddling attribution measurement to favour search ads, they are hiding prices (no, publishers say this but advertisers are very aware of what they are paying...it is leaving their account), arbitrage...clutch pearls. There is inaccurate stuff here - imposing rigid market definitions (for example, the difference between exchange and Adsense is the publisher...most small publishers want a simple product like Adsense). There is directly contradictory stuff here - Google uses data to steal from publishers...but taking away third-party cookies will lower prices and publishers won't be able to bid efficiently...okay, which is it? I think there is quite a clear case, it isn't made here. It needs to be far more concise. Google shouldn't operate exchanges and publish, it shouldn't operate exchanges and advertise, the exchange should be transparent. The core business here isn't complicated: I have something to sell, I need a venue to create a clearing price, there are other people who need to buy it. There is a long history of people creating venues that aren't fair, the solution is: create a fair venue. All the stuff about trying to prove harm and say that Google is a bad actor who is doing all these secret, ultra illegal things (that no-one has any proof for) is, quite frankly, nonsense. It doesn't matter if Google is doing bad things or not. The point is that their market position gives them that opportunity, and most humans are greedy. Watching a lawyer try to moralise is an unedifying sight (this paper comes from a billionaire's think tank, watching someone try to moralise about other people's behaviour with their pockets weighed down with gold is...really not a great sight, particularly as this content is just copied from the work done by the govt in another country...a charmed life indeed). CMA Note - I am from the UK and the CMA are terrible...mainly very well-connected Brits who either worked in business and ran their company into the ground or people who can't get a job in business at all. In particular, relying on CMA's market definition is perilous. Their logic is usually: what definition do we need to get the right decision? It is bafflingly inconsistent.