By: Sean Sung
Volume IX – Issue I – Fall 2023
I. Introduction and the Background on Google’s Recent Antitrust Case
On January 24th, 2023, The United States Department of Justice (DOJ) brought a federal antitrust lawsuit against Google LLC, accusing Google of monopolizing three markets: the website ranking market, the search advertising market, and the search engine market. Corresponding states like New York, California, Connecticut, Virginia, Tennessee, Texas, and others are suing along with the DOJ. [1] Such lawsuits have also brought private plaintiffs to sue Google for roughly the same topic. The European Commission has already ruled that Google illegally maintained its monopoly, and the General Court of the European Union backed the Commission’s decision. The DOJ cites that Google holds around 85% of the search engine market as the impact of these anti-competitive practices. [2] The DOJ cites Section 2 of the Sherman Antitrust Act of 1890. In the United States, it is not illegal to have a monopoly, and it is not illegal to raise prices because of a monopoly because innovation and actions that benefit the market and consumers can lead to monopolistic tendencies. The government does not want to limit such innovation. In other words, it is not illegal to be dominant if the company is better than its competitors. However, Section 2 of the Sherman Antitrust Act prohibits maintaining monopolies through exclusionary conduct and anti-competitive practice. The DOJ claims that Google’s contracts with original equipment manufacturers, like Apple, LG, Samsung, and Motorola, with Internet Service Providers, like AT&T, T-Mobile, and Verizon, and browser developers, like Mozilla, Opera, and UCWeb, to keep Google as the primary search engine on all products is anti-competitive in nature and is illegal. [3] This Google antitrust case is most similar to Microsoft’s antitrust case in 2001, since Microsoft was sued by the DOJ for also maintaining an illegal monopoly through restrictive deals with original equipment manufacturers to install Windows as the primary operating system on newly produced equipment. [4] In this article, we will cover market and legal definitions, the Microsoft antitrust case, its relation and detail with the Google antitrust case, and the weakness of the Sherman Antitrust Act of 1890.
II. Definition of Network Effects
Network effects, also known as barriers to entry, refers to a product being more valuable as more people use the product, which drives exponential growth. This is more prevalent in technology companies and platform companies. For example, as more people use Facebook, the value of having a Facebook account increases because it offers the opportunity to connect with more people. Because the value of having a Facebook account increases, more people get an account, which fuels the cycle over again, leading to exponential growth of the platform. [5] Google’s network effect is quite extensive because it is also a two-sided market. Two-sided markets are platforms that provide a platform to two or more distinct consumer groups that offer services to each other, which would create network effects. Google is a two-sided market as it caters to advertisers, content creators and internet searchers. Advertisers and content creators go onto the internet to get the attention and views of the content consumers. Content consumers go on the internet to look at advertisements and content created. As more consumers use Google, more advertisers and content creators post their content on Google as that is where their content would get the most attention. As more content creators use Google, more consumers are incentivized to join Google, as that is where the most content is. As more people use Google, more content is being put onto Google, which then increases its value. A similar effect also works with Google’s Youtube. With Microsoft, consumers would want to buy operating systems that a lot of other people use already, so systems are more compatible. Additionally, as more people use Windows, more developers want to use Windows to write programs as Windows already has a massive user base. As more developers use Windows, more users would want to use Windows as well because that is where all the programs are being made. That drives exponential growth. This works specifically for tech companies because technology and platform companies like Google, Microsoft, and Facebook have low marginal costs. It does not cost a lot to add one additional user to these platforms. However, the entry costs are extraordinarily high. The initial investment in hardware, software, talent, etc is higher than a non tech company. Additionally, the network effect adds additional barriers to entering the market. A new social media platform could not hope to compete with well established social media platforms because no one uses the new one, and therefore no one has any incentive to get the new social media platform. In the case of Google and Microsoft, it would be quite easy to maintain a monopoly through the network effect. It raises entry costs even higher and pushes out competition. [6] It would be hard to regulate on the government’s side as well because by breaking up such monopolies, the value of these services is decreased significantly. Markets with high fixed costs and high barriers to entry but low marginal costs are also known as economies of scale. The Sherman Antitrust Act of 1890 was not ready to deal with such business plans, especially since in 1890, the government was more concerned with trusts selling physical products with physical manufacturing lines.
III. Definition of Zero Price Markets
Zero price markets are markets that give away a product or service for free. Tech and platform companies like Google are zero price firms. [7] Google allows users to use many of its services, like internet search, without cost. Instead, it generates profit from advertisements and other indirect revenue streams. Because of this, the Department of Justice realistically never tried setting the existence of the browser market. The regulation and the point of the zero price market become elusive and difficult to manage. Under the consumer welfare standard, monopolies are measured with the interest of the consumers. [8] The Supreme Court explains it as the distinction between anticompetitive effects harmful to the consumer and stimulation of competition that are in the consumer’s best interest. In other words, illegal monopolistic actions are determined by how much the consumer is harmed. If the consumers are harmed significantly, then it is monopolistic. If the company’s actions do not harm the consumer. With zero price markets, which these tech platforms are, they technically are not monopolies under the consumer welfare approach. [9] By following the consumer welfare approach, Lina Khan, the chairperson of the Federal Trade Commission (FTC), argues that other key aspects of the free market are overlooked. [10] For example, by focusing on consumers, the welfare of other competing companies are overlooked. Google offering its internet search services for free may be good for the consumer but is another way of undercutting prices for competitors who may not have the ability to solicit advertisements. Advertisers would not want to pay for advertisements on platforms that no one uses, but those platforms could never get the funds they need unless they get advertisements or charge money for their services. But if other companies offer that same service for free, those new platforms and technology companies will never rise to the level to compete with those massive tech companies like Google. This is similar to the FTC lawsuit against Amazon recently. The Google antitrust case would set the precedent for whether or not courts and the law should view monopolies based on consumer welfare or another approach that views other parts of the market, not just consumer welfare. Again, the Sherman Antitrust Act of 1890 did not account for such business strategy, and the new Google antitrust case would indirectly expand or shrink the power over tech companies that the Sherman Antitrust Act has.
The DOJ argues that search services that Google provides have no substitutes and still come with hidden costs that are harmful to consumers. Firstly, there are no adequate substitutes for search engines. It ties into switching costs: it costs a lot for a user to leave a network, service, or platform for a competitor. While it may not cost monetarily, the user still has to adapt to the new platform. [11] If Google and Microsoft made deals with original equipment manufacturers, internet service providers, and browser developers to preinstall their products and make their services the default, the companies are restricting and nearly forcing consumers to use their products. Google, and Microsoft before it, persists that consumers can still easily switch out of the default search engine and operating system and move to another one of the consumer’s choice. The new Google antitrust case would also indirectly decide whether or not such switching costs would constitute anti-competitive behavior on Google’s part.
IV. Precedent: Microsoft Antitrust Case D.C. Cir. 2001
In 1990, the Federal Trade Commission started an investigation into Microsoft and its monopolistic abuse in the PC operating system market. In 1993, the FTC closed the investigation because the commissioners did not have a majority vote to continue with the investigation. However, the Department of Justice continued with the investigation into Microsoft. Not wanting to risk a public court trial, Microsoft and the DOJ settled in 1994. [12] The settlement included that Microsoft should not sell other Microsoft products along with Windows, but additional improvements and features can be added to Windows to improve the product. However, Microsoft continued selling Internet Explorer along with Windows, claiming it as a feature to Windows while the DOJ called it its own separate product. In 1995, the DOJ started building its case against Microsoft for court. The case hinged on whether or not combining Windows and Internet Explorer was anti-competitive or not. The DOJ claimed that the combination led to Microsoft winning the browser wars in the 1990s. [13] Every Windows user had Internet Explorer, and that restricted other web browsers like Opera. It would have taken extra time to install another browser, and consumers would not do that because Internet Explorer was already there. It gave Internet Explorer an unfair advantage because of its connection with Windows. This concern was reinforced since Microsoft had contracts with original equipment manufacturers to preinclude Windows and Internet Explorer in their equipment before sale. These contracts were considered restrictive licensing agreements. Microsoft’s defense was that Internet Explorer was a feature of Windows, a necessary advancement in technology to keep up with competition. Additionally, Microsoft appealed to consumer welfare by claiming that consumers were then receiving Internet Explorer benefits for free, which is better than selling it as a separate product. Microsoft CEO Bill Gates claimed that Microsoft did not violate any existing regulations, and compared it to IBM, a big company from evolving technology that grew out of phase because it did not keep up. The DOJ argued against Microsoft’s defense by saying that because another version of Internet Explorer exists for Mac OS users, which means that Internet Explorer is separate from the operating system and not simply a part of Windows. Additionally, the DOJ claimed that Internet Explorer was not free and not good in terms of consumer welfare since Internet Explorer being tied to Windows means that the price of Windows increased. [14]
United States v. Microsoft (2001) was first tried in the United States District Court in the District of Columbia in 1998. The DOJ was joined by 20 states and the Attorney General of Washington DC. The focus the DOJ emphasized was the barriers of entry Microsoft was artificially rising. The DOJ argued its case on Internet Explorer being a part of Windows. Microsoft provided videos that showed Windows not working if Internet Explorer was taken out of it, but the DOJ claimed that such videos could have been falsified because of inconsistencies in the video. Another video submitted by Microsoft showed the simplicity in downloading Netscape Navigator, but the DOJ produced its own video showing how Microsoft’s video was falsified, which Microsoft vice president Brad Chase admitted to. Microsoft emphasized that by decoupling Windows and Internet Explorer, it would be an obsolete version of Windows. Microsoft defended itself in the news and public opinion by saying that it is not illegal to be better than competitors. In 2000, Judge Thomas Penfield Jackson ruled that Microsoft had a monopoly in the operating system market and that Microsoft had illegal anticompetitive practices. Microsoft was in violation of the Sherman Antitrust Act, Sections 1 and 2. Microsoft would have to break up: one to sell operating systems and the other to produce software. Microsoft appealed the decision.
Microsoft originally wanted to skip the circuit court and go right to the Supreme Court, which the Supreme Court rejected. In the D.C. Circuit Court, the court ruled that Judge Jackson violated the Code of Conduct for judges by discussing the case with the media while the case was still ongoing. Judge Jackson stood by his claim that he was biased against Microsoft because they kept using false evidence. Ultimately, the D.C. Circuit Court remanded the case back to the D.C. District Court with Judge Colleen Kollar-Kotelly. In 2001, the DOJ and Microsoft reached an agreement that Microsoft would allow original equipment manufacturers to use other operating systems that are not Windows. In exchange for not being forced to change any code or software, Microsoft was ordered to share its technology with competitors and operate with an oversight committee. In 2004, the settlement was approved, and the states that did not agree with the settlement were dismissed. [15]
United States v. Microsoft (2001) is the primary example of an antitrust case against current tech giants. Previously mentioned approaches and theories have all come into play during the Microsoft antitrust case. Network effects raised the barriers to entry for the market, contributing to the DOJ’s case that Microsoft was a monopoly in the operating systems market. The zero price markets and consumer welfare approach also tied into the Microsoft case as it claimed that their system helped the consumers. Additionally, the zero price markets squeezed competition out of the market. Another key part of the case was the switching costs, which the DOJ proved that it is difficult to switch between search engines. It sets the precedent that these tech companies can lose antitrust cases, but the case also showed the near impossibility of breaking up big tech companies. Its precedent was not firmly set because of the overturn in the original district court case and the settlement in the second district court case. In general, even though many giant tech companies have grown to the size of monopolies, even larger than Microsoft was in the 1990s, no major cases have been brought up against these tech companies, until 2023. In 2023. The DOJ and FTC have brought major cases against Google and Amazon. The first of these cases to be tried, United States v. Google LLC (2023), will either extend or destroy the legacy of United States v. Microsoft (2001).
V. United States v. Google LLC (2023): Precedent and Impact
The antitrust case against Google LLC is currently taking a very similar path as Microsoft in 1998. While the Microsoft case revolved more around the operating system market, the Google case is mostly focused on the search engine and advertisement market. The DOJ’s case rests upon Google's contracts with original equipment manufacturers, internet service providers, and program developers to have Google as the primary search engine. The DOJ claims that because Google has these restrictive agreements with companies like Apple, Google is making the market less friendly toward other search engine platforms. [16] In this case, Microsoft is testifying against Google, claiming that their search engines, Bing and Microsoft Edge, have no way of competing against Google because of these anti-competitive practices. [17] Google defends its dominance and large market share by citing its superior technology and advanced innovation. [18] The DOJ in response cited the cost of switching. Because Google is already preinstalled in most devices, it is a lot of effort to change to another internet provider. The DOJ also claims that Google is restricting distribution channels, so consumers do not even know that they can change search engines. Even if the consumers do know, most consumers go with what is there: it is difficult to deal with and measure consumer wants. Additionally, the DOJ argues that the network effect is what keeps Google alive: more people using Google makes it more valuable than other search engines, but this network effect is maintained by anti-competitive practices. [19] Other DOJ arguments have been thrown out. A few states claimed that Google’s search results heavily favor Google’s interests while ignoring Yelp and Expedia. The DOJ claimed that Google’s agreement with Android manufacturers being exclusionary was also dismissed. Two key claims of the case remain. Google’s search engine makes certain features in its own search engine but not other search engines, which makes things unfair. The more important of the two key claims is the agreements with the original equipment manufacturers, internet service providers, and the program developers to keep Google as the default search engine being illegal and anti-competitive. Some sources say that Google pays at least $20 billion to Apple alone each year to maintain the agreement. [20] That key payment, according to the DOJ, maintains Google’s monopoly in place. Considering the network effect, it is creating a self-reinforcing monopoly. Google is also a zero price firm, meaning that its search engine is free, but they make money from advertisements and selling user data to other firms. Search engines like DuckDuckGo cannot hope to compete with Google because of network effects but also business model. Most users would use the search engine preinstalled and without upfront costs. Google in this case is undercutting its competitors. DuckDuckGo cannot get advertisements without users. It cannot get users without money. It cannot get money without either getting advertisements or a user fee. DuckDuckGo cannot get a user fee because Google is undercutting the prices. DuckDuckGo cannot get advertisements because, again, there are no users. DuckDuckGo is just one example that the DOJ cites of Google using monopolistic practice to kick out competitors. Google again argues against this by saying that their service is simply better, and being better than an opponent in the market is not a crime. This court case started on September 18, 2023, and it is expected to go on for a few months before reaching a verdict or a settlement. [21]
The impacts of this case would affect the entire tech industry. If the DOJ wins, either Google will be broken up into smaller companies or the main part of the case, the anti-competitive agreements with the original equipment manufacturers, the internet service providers, and the program developers, will be voided and prohibited. Splitting up the company is unlikely, but not unheard of. Based on network effects, by splitting up Google, Google’s search engine’s value would be significantly diminished as the users, features, content, and advertisement revenue would all be split up between the remaining fractions of Google. It would not be in the interest of the markets based on the network effect to break up Google. It would most likely follow Microsoft’s footsteps and cut a deal. Even with the Microsoft case as precedent, this case is difficult for the DOJ for many reasons. Firstly, the Microsoft case was overturned by the D.C. circuit court and was settled before anything further came from the second district court. Secondly, a number of Supreme Court decisions since the Microsoft case have demonstrated a more lenient view of firm behavior and what constitutes monopolistic behavior. If Google prevails, then it is proof that Google, and by extension many other tech companies, are not illegally maintaining monopolies and can operate as it did. A win for Google could also set a precedent for the Amazon antitrust case that would be disastrous for the FTC and the DOJ. [22] That would give these tech companies a precedent to expand with less fear of being targeted by the government.
Ultimately, the outcome of the decision depends on personal viewpoint. If one thinks that the current tech companies are indeed monopolies and the DOJ wins, then the outcome was correct and that new restrictions on the practice of these tech companies is a good thing. If one thinks that the current tech companies are monopolies and Google wins, then one would be concerned with the future growth of such tech companies, and policymakers with this thought process would work toward new laws to restrict the tech companies. If one thinks that current tech companies are not monopolies and Google wins, then one would think that the outcome was correct, and less restriction on the tech industry would fuel more growth and innovation in that industry. If one thinks that the current tech companies are not monopolies and the DOJ wins, then one would be concerned that new restrictions on the tech industry would stop innovation and growth, which would overall hurt the economy.
VI. Weaknesses of the Sharman Antitrust Act of 1890
Antitrust law enforcement agencies in the United States have not successfully regulated Big Tech firms. The DOJ and FTC still rely on a law passed 130 years ago to deal with a new tech industry that started 40 years ago. The last time Congress updated the antitrust laws was 1976. It is not a lack of effort on the part of the DOJ and FTC, but the courts and Congress need to produce new, meaningful regulation for new tech businesses instead of relying on the Sherman Antitrust Act of 1890. The internet and its platforms changed the production and consumption of the market. A 2021 poll showed that 55% of Americans thought that major tech companies need more government oversight. Americans are also unsure of tech companies collecting data, and the confidence in these tech companies is decreasing constantly. While legal experts, the Supreme Court, and Congress all agree that the Sherman Antitrust Act and other laws meant to restrict monopolies should be up for interpretation by the Supreme Court on a base-by-base case, Congress has not made clear their intentions or goals in the realm of antitrust. [23] Previously, the courts adopted three approaches to regulating and measuring monopolies and the antitrust doctrine. The courts have now rested upon consumer welfare as the main and sole standard for antitrust law. However, Lina Khan and the DOJ argue against consumer welfare because it disregards other actors in the market, like other producers. [24] The problem then arises: Congress never clearly established such a measurement for antitrust. Ultimately, it may not go well for Lina Khan, the FTC, and DOJ if the courts do not find sufficient evidence to rule against the use of consumer welfare and for the use of another form of measurement. Additionally, it would be quite difficult for the government to regulate network effects, zero price markets, and data collection and advertising without a case-by-base basis. With regulation of companies that have network effects, the regulation is bound to reduce the value of the company as the value of the company comes from the number of people using the service. Any regulation that reduces the number takes away from its value. For a zero price market,while it is true that it undercuts producers, consumers would be in uproar if companies like Google started charging for their products. That problem ties into data collection and advertising. If restrictions were put on data collection and advertising, tech companies may want to find other ways to make up for that lost money, which would probably land on consumers eventually. With data collection and advertisement, the prices were indirect and not directly shown to consumers. Other costs may not have that bonus, which may cause uproar among consumers. If courts could decide with each case what action would be best for the economy, then these problems may not have as big of a damage on the economy. That brings the problem back to how courts should measure whether or not a company is a monopoly or not. That is something Congress has to set.
Congress must set new legislation that determines specifically how monopolies are to be measured, something that is not consumer welfare. A law simply stating that antitrust action should be determined by the positive and negative effect on the market would be enough. Then, Congress should leave enough ambiguity to have courts decide on a case-by-case basis to avoid the damaging effects of attempting to regulate network effects, zero price markets, data collection, advertising, etc.
VII. New Legislation and Conclusion
A new bill proposed in the Senate on March 30th, 2023 hopes to change some of the problems in the Big Tech industry. The Advertising Middlemen Endangering Rigorous Internet Competition Accountability Act (AMERICA) is a bill by Senator Mike Lee that wants to stop monopoly power in advertisement; the goal is to restrict Google and Facebook dominance. [25] Specifically, the AMERICA act will add to the Clayton Antitrust Act of 1914 to promote advertisement competition and avoid conflict of interest. The law would restrict companies that have over $20 billion in digital advertising. The bill, while promising, will have to make it through Congress with its changes. However, the risk of a broad law restricting digital advertising would be the risk of tech companies pushing the costs onto consumers.
ing digital advertising would be the risk of tech companies pushing the costs onto consumers. The decision of the United States v. Google LLC (2023) will determine how the technology industry will grow moving forward. A decision that finds Google to be upholding a monopoly with anticompetitive practices will put more restrictions on many tech giants beyond Google. A decision in favor of Google would embolden tech giants to expand further. Market and legal landscapes will evolve based on the outcome of this court case. The world shall wait in suspense as the district court announces its decision within the next few months.
Endnotes
[1] Wikipedia. “United States v. Google LLC (2023).” Wikipedia, October 16, 2023. https://en.wikipedia.org/wiki/United_States_v._Google_LLC_(2023).
[2] Bianchi, Tiago. “Global Search Engine Desktop Market Share 2023.” Statista, September 20, 2023. https://www.statista.com/statistics/216573/worldwide-market-share-of-search-engines/#:~:text=Global%20market%%2020share%20of%20leading%20desktop%20search%20engines%202015%2D2023&text=As%20of%20July%202023%2C%20online,share%20of%20around%2083.49%20percent.
[3] Feiner, Lauren. “Google Paid $26 Billion in 2021 to Become the Default Search Engine on Browsers and Phones.” CNBC, October 27, 2023. https://www.cnbc.com/2023/10/27/google-paid-26-billion-in-2021-to-become-a-default-search-engine.html.
[4] Page, William H. Lopatka, John E. “The Microsoft Litigation’s Lessons For United States v. Google. (2023)” University of Miami Law Review Volume 77, 319 Issue (Winter 2023) https://plus.lexis.com/document/?pdmfid=1530671&crid=58c10203-1fe2-4e67-8733-81ef53246878&pddocfullpath =%2Fshared%2Fdocument%2Fanalytical-materials%2Furn%3AcontentItem%3A67SC-NKX1-JC8V-43VR-00000-00&pdcomponentid=7371&pddoctabclick=true&ecomp=Jy7g&prid=cca22055-4b21-412b-a494-0700f1ab135f&cbc=0%2C0
[5] Ibid.
[6] Ibid.
[7] Ibid.
[8] Sanofi-Aventis US LLC v. Mylan, Inc (United States Court of Appeals for the Tenth Circuit July 29, 2022). https://plus.lexis.com/document?pdmfid=1530671&pddocfullpath=%2Fshared%2Fdocument%2Fcases%2Furn%3A contentItem%3A661S-FTF1-JSJC-X51S-00000-00&pdcontentcomponentid=6394&prid=4d321932-60e7-4c45-b1b 2-5b21d6cd27cd&crid=fe2b78dc-db5e-4d69-8739-2ed4fec0f835&pdisdocsliderrequired=true&pdpeersearchid=3c6 82580-9d3c-4382-8c68-e832b2543eb4-1&ecomp=_7ttk&earg=pdsf
[9] Ibid.
[10] Khan, Lina M. “Amazon’s Antitrust Paradox.” The Yale Law Journal 126, 710 Issue (2017) https://www.yalelawjournal.org/pdf/e.710.Khan.805_zuvfyyeh.pdf
[11] Pasquale, Frank A. “When Antitrust Becomes Pro-Trust: The Digital Deformation of US Competition Policy.” Digital Commons @ UM Carey Law, May 2017. https://digitalcommons.law.umaryland.edu/fac_pubs/1616/
[12] Wikipedia. “United States v. Microsoft Corp. (2023)” Wikipedia, November 3, 2023. https://en.wikipedia.org/wiki/United_States_v._Microsoft_Corp.
[13] Ibid.
[14] Ibid.
[15] Ibid.
[16] Morrison, Sara. “What Google’s Trial Means for the Company - and Your Web Browsing.” Vox, September 11, 2023. https://www.vox.com/technology/2023/9/11/23864514/google-search-antitrust-trial.
[17] Kerr, Dara. “United States Takes on Google in Biggest Tech Monopoly Trial of 21st Century.” NPR, September 12, 2023. https://www.npr.org/2023/09/12/1198558372/doj-google-monopoly-antitrust-trial-search-engine.
[18] United States v. Google LLC (2023) (United States District Court for the Eastern District of Virginia, Alexandria Division September 18, 2023). https://plus.lexis.com/document?pdmfid=1530671&pddocfullpath=%2Fshared%2Fdocument%2Fcases%2Furn%3A contentItem%3A696K-XJ41-JX3N-B12C-00000-00&pdcontentcomponentid=6414&prid=24a98565-b154-4bd2-aeda-57058fae485c&crid=12121787-0585-4d2d-96b0-4b97958c4948&pdisdocsliderrequired=true&pdpeersearchid=62 0db4e8-aa5d-4780-a216-892001815800-1&ecomp=_7ttk&earg=pdsf
[19] Ibid.
[20] Morrison, Sara. “What Google’s Trial Means for the Company - and Your Web Browsing.” Vox, September 11, 2023. https://www.vox.com/technology/2023/9/11/23864514/google-search-antitrust-trial.
[21] Wikipedia, “United States v. Google LLC (2023),” Wikipedia, October 16, 2023
[22] Ibid.
[23] Kinan, Michael JKM. “Grandpa Sherman Did Not See Google Coming: Evolutions in Antitrust to Regulate Data Aggregating Firms.” Minnesota Law Review 107, 1759 Issue (April 2023). https://plus.lexis.com/document?pdmfid=1530671&pddocfullpath=%2Fshared%2Fdocument%2Fanalytical-material s%2Furn%3AcontentItem%3A68D3-M5V1-K0BB-S06F-00000-00&pdcontentcomponentid=7347&prid=cdf8a79a4011-4aff-ad36-a5a77940ab9d&crid=6bb987d9-166b-4e07-9fb3-c924f0b80b38&pdisdocsliderrequired=true&pdpe ersearchid=5277c661-ec4f-4d6d-a882-50cf5d4664a9-1&ecomp=_7ttk&earg=pdsf
[24] Ibid.
[25] Wikipedia, “America Act,” Wikipedia, September 16, 2023, https://en.wikipedia.org/wiki/AMERICA_Act.