In the Common Pleas Court Delaware County, Ohio Civil Division
IN THE COMMON PLEAS COURT DELAWARE COUNTY, OHIO CIVIL DIVISION STATE OF OHIO ex rel. DAVE YOST, OHIO ATTORNEY GENERAL, Case No. 21 CV H________________ 30 East Broad St. Columbus, OH 43215 Plaintiff, JUDGE ___________________ v. GOOGLE LLC 1600 Amphitheatre Parkway COMPLAINT FOR Mountain View, CA 94043 DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF Also Serve: Google LLC c/o Corporation Service Co. 50 W. Broad St., Ste. 1330 Columbus OH 43215 Defendant. Plaintiff, the State of Ohio, by and through its Attorney General, Dave Yost, (hereinafter “Ohio” or “the State”), upon personal knowledge as to its own acts and beliefs, and upon information and belief as to all matters based upon the investigation by counsel, brings this action seeking declaratory and injunctive relief against Google LLC (“Google” or “Defendant”), alleges as follows: I. INTRODUCTION The vast majority of Ohioans use the internet. And nearly all of those who do use Google Search. Google is so ubiquitous that its name has become a verb. A person does not have to sign a contract, buy a specific device, or pay a fee to use Good Search. Google provides its CLERK OF COURTS - DELAWARE COUNTY, OH - COMMON PLEAS COURT 21 CV H 06 0274 - SCHUCK, JAMES P. FILED: 06/08/2021 09:05 AM search services indiscriminately to the public. To use Google Search, all you have to do is type, click and wait. Primarily, users seek “organic search results”, which, per Google’s website, “[a] free listing in Google Search that appears because it's relevant to someone’s search terms.” In lieu of charging a fee, Google collects user data, which it monetizes in various ways—primarily via selling targeted advertisements.
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