Alphabet Inc. is U.S.-based multinational conglomerate company headquartered in California. And Google Search is its most profitable product.
With an estimated 9 out of 10 searches in the world is done with Google, the company is one of the few internet businesses that has billions of users.
With its ppwer and influence, Google can be somehow monopolistic, and capable of controlling the flow of information through its products and services that are interconnected.
These are the reasons why Google is a target for many antitrust regulations.
Google is no stranger to lawsuits and dealing with regulators. But this time, the company is dealing with at least four major investigations on two continents.
And Google's parent company Alphabet, has been preparing for this moment for years. And it comes prepared.
Knowing that antitrust regulators need to first establish that Google has a dominant market share, before it can ever take action, Alphabet has been telling its 100,000+ employees across the massive enterprise that certain language is off limits in all written communications, no matter how casual.
The words Alphabet is urging employees to not use, include “market,” “barriers to entry,” and “network effects”.
“Words matter. Especially in antitrust law,” reads one document titled Five Rules of Thumb for Written Communications.
For that reason, employees need to do the following "to help ensure that what we write accurately reflects our intent":
- We’re out to help users, not hurt competitors.
- Our users should always be free to switch, and we don’t lock anyone in.
- We’ve got lots of competitors, so don’t assume we control or dominate any market.
- Don’t try and define a market or estimate our market share.
- Assume every document you generate, including email, will be seen by regulators.
"We are not out to 'crush', 'kill', 'hurt', 'block' or do anything else that might be perceived as evil or unfair," the document reads, referencing to how Microsoft famously got into trouble when one of its employees threatened to “cut off Netscape’s air supply” during the First Browser war.
In another document titled Communicating Safely, the company advises employees on which terms are “Bad” and “Good.”
For example, instead of using the word "market", employees may say “industry,” “space,” “area,” or simply cite a region; instead of using “network effects,” the presentation suggests employees to use “valuable to users”; and instead of using “barriers to entry”, employees can substitute the term with “challenges.”
“We use the term ‘User Preference for Google Search’ and never the term market share," reads another document titled External Communication.
As a parent company of many popular products, Alphabet gets sued a lot.
And these internal documents appear to be part of the company employees' self-guided training. From the company's engineers to salespeople, the documents read that they also apply to interns, temporary workers, vendors, and even contractors.
The words are chosen, based on the basics of antitrust laws, in order to caution anything that is related to Alphabet and its subsidiaries, against loose talks that could have implications for government regulators or lawsuits.
The documents that appear to be written by the company's legal team, not also advised employees to carefully choose their words, but to only use third-party data when referencing Google's "position in search" in sales pitches. Employees are also cautioned to never print or hand out their slides.
“These are completely standard competition law compliance trainings that most large companies provide to their employees,” explained Julie Tarallo McAlister, a Google spokesperson. “We instruct employees to compete fairly and build great products, rather than focus or opine on competitors. We’ve had these trainings in place for well over a decade.”
Just recently, Alphabet CEO Sundar Pichai faced 61 questions from lawmakers referencing the company’s dominance in online video, advertising, search, and other areas at a hearing before the House Judiciary antitrust subcommittee.
At that time, Pichai did not say “network effects” or “dominant” for even once to stay clear of defining any particular market.
“Google operates in highly competitive and dynamic global markets, in which prices are free or falling, and products are constantly improving,” he said.