M/s Zucol Solutions Private Limited vs. Google India Private Limited

Public Version

COMPETITION COMMISSION OF INDIA

Case No. 17 of 2025

In re: M/s Zucol Solutions Private Limited …Informant Unit No. 201, 2^nd Floor, Mangalam Signature Tower, Lal Kothi, Tonk Road, Jaipur – 302015 Rajasthan.

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And

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Google India Private Limited …Opposite Party No. 3, RMZ Infinity – Tower E, Old Madras Road, 4^th & 5^th Floors, Bangalore – 560016, Karnataka.

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CORAM: Ms. Ravneet Kaur Chairperson Mr. Anil Agrawal Member

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Ms. Sweta Kakkad Member

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Mr. Deepak Anurag Member

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Order under Section 26(2) of the Competition Act, 2002

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The Information has been filed by M/s Zucol Solutions Private Limited (‘ Informant ’) under Section 19(1)(a) of the Competition Act, 2002 (the ‘ Act ’), against Google India Private Limited (‘ OP ’/‘ Google ’), alleging contravention of the provisions of Sections 3 and 4 of the Act.

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The Informant is stated to be a private limited company incorporated under the provisions of the Companies Act, 2013. It is stated to be engaged in the business of digital software development and mobile application services.

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The OP is stated to provide a digital distribution platform through the Google Play Store (‘ Play Store ’), which allows developers to publish, manage and distribute Android applications to users globally. It facilitates in-app billing, user reviews, app analytics, and policy enforcement tools. Additionally, it also offers backend services like Firebase, APIs, and advertising platforms to support app growth and monetization. It is stated that given its dominance in the Android ecosystem, the Play Store is often the primary gateway for app visibility and user access.

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The Informant stated that it had created a Google Developer Account (‘ GDA ’) (account ID: 6466909330537599514) (‘ First Account ’) on the Google Play platform, which operates under the Google Play Services ecosystem – an entity that holds a dominant position in the Android mobile application market, to list the mobile applications developed by the Informant.

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It is further stated that the OP, without giving any prior notice or intimation, terminated the Informant’s GDA on 20.09.2023 stating that the said account is violating Google’s Developer Program Policies (‘ DPP ’) and Developer Distribution Agreement (‘ DDA ’).

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It is stated that after the GDA was terminated, the Informant tried to communicate with the OP asking for the reason for termination and an appeal was raised on the ‘Google Play Console’ platform on 21.09.2023. It was claimed by the OP that the termination of the Informant’s GDA was on account of the application titled ‘ Pobreflix – Series, Movies ’, which was alleged to be in violation of the Google’s DPP and DDA.

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As per the Informant, that it was communicated to the OP that the said application did not belong to the Informant and that it was developed and published by an external contractual developer. It is stated that upon receiving information regarding the alleged policy violations associated with the said application, the Informant immediately terminated all contractual relations with the concerned developer and requested the OP multiple times

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to take necessary and appropriate action limited to the said application, while also requesting a fair and impartial review of the remaining compliant applications under the Informant’s developer account.

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It is stated that despite these representations and requests, the OP in an arbitrary and unjust manner, proceeded to terminate the entire developer account of the Informant without any reasonable justification. The Informant has alleged that this conduct of the OP not only violates the principles of natural justice but also amounts to abuse of dominant position and is liable to scrutiny.

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It is further alleged that even as on the date of filing the Information, the application responsible for the alleged violations remains active and publicly listed on the Google Play Store under a different developer account.

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It is stated that further correspondence was initiated by the Informant with the OP, requesting that if the application ‘Pobreflix – Series, Movies’ or any other particular app was found to be in violation of the DPP and DDA, the OP may take necessary action solely against that application and review the remaining compliant applications fairly and independently. It is alleged that despite repeated requests for a specific review and resolution, OP failed to respond appropriately and instead stuck to the termination of the entire developer account without providing any proper justification or due process.

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It is stated that subsequently, on 31.05.2024, the Informant created a separate and independent developer account on Google Play platform (account ID: 7941074486004459573) (‘ Second Account ’) through which only a single application namely BTHAWK was listed. However, on 06.07.2024, the Second Account was also terminated by the OP on the ground of past policy violations associated with the Informant’s First Account. According to the Informant, the new developer account had no connection to any previous violations or flagged accounts, and the termination of the same by the OP without any specific or detailed explanation was arbitrary and entirely unjustified.

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It was further stated that subsequent to the termination of the Second Account, the Informant submitted an appeal to the OP on 20.07.2024 seeking clarification and justification for the termination and on the same day, the OP provided a response via email asserting that the Second Account is terminated due to its connection with the First Account, including information sharing.

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The Informant has alleged that the OP had only offered a vague acknowledgement of their action, and had failed to provide a clear justification for the same. It is alleged that the OP has not provided any evidence substantiating the relationship between the two accounts. It was alleged that the OP has not identified specific provisions within the DPP or the DDA that the Informant is purported to have violated. Furthermore, the OP had expressly cautioned the Informant against creating a new developer account, stating that any such account shall also be subject to immediate termination. According to the Informant, this warning effectively prohibits the Informant from re-entering the market and amounts to a denial of access to the Android app distribution ecosystem.

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It was stated that the Informant served legal notices dated 29.03.2025 and 01.05.2025 to the OP through its legal counsel. Despite multiple representations and follow up communications, the OP failed to provide any specific explanation or a fair opportunity of appeal, which resulted in substantial financial losses, reputational harm, and exclusion from the market. The Informant has alleged that such conduct constitutes abuse of dominant position under Section 4 of the Act.

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In view of the above, the Informant had prayed for the following reliefs from the Commission:

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a) Direct the Director General (‘ DG ’) to initiate an investigation under Section 26 (1) of the Act;

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b) Declare that the OP has contravened Sections 3 and 4 of the Act; c) Direct the OP to reinstate the Informant’s developer accounts or allow creation of a new account with transfer of all compliant applications;

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d) Order monetary compensation of INR 57 Crore to the Informant for the losses incurred;

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e) Issue any other directions or relief as the Commission deems fit and proper in the interest of justice.

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The Commission considered the Information filed by the Informant in its ordinary meeting held on 27.08.2025 and decided to seek the response of the Informant to the following:

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“Vide email dated 16.11.2024, the OP, in reply to the review appeal by you, stated that “ the app Pobreflix – Series, Movies…triggers your development account ban. ” In reply dated 20.11.2024, you stated that ‘… this App is no longer needed and should be removed…I would request you to have a look on other available apps ”. Further, vide email dated 29.11.2024, OP stated that “ I understand you are having trouble collecting information of the app ‘Pobreflix – Series, Movies’…. as the person in charge left your company. ” This appears to be in contradiction with your statement in para 6 of the Information that “… it was duly communicated to the Opposite Party that the said application did not belong to the Informant and was, in fact, developed and published by the external contractual developer ”.”

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In this regard, the Commission directed the Informant as follows:

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(a) To provide clarification whether the app ‘ Pobreflix – Series, Movies ’ was published under the Informant’s development account;

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(b) To provide clarification whether the aforesaid app was developed and published by an external contractual developer or by an internal employee;

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(c) To identify the said contractual developer/employee along with relevant details;

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(d) To provide a copy of the communication with the OP as referred to in para 6 of the Information.

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The Commission also directed the Informant to provide complete trail of communication between it and the OP from 21.09.2023 onwards along with the attachments and to furnish replies, if any, to the legal notices dated 29.03.2025 and 01.05.2025 served by the Informant.

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Further, the Commission also directed to forward a copy of the Information to the OP for submitting its comments on the allegations contained therein.

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The Informant and the OP were directed to provide the afore-mentioned response/comments, within a period of 04 (four) weeks of receipt of the order.

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In response to the above, the Informant filed additional information on 22.09.2025, while OP filed an Interlocutory Application (‘ IA ’) No. 408 of 2025 dated 01.10.2025 seeking extension of time by 06 weeks till 17.11.2025 to file a comprehensive response to the Information and the Commission’s queries raised vide order dated 27.08.2025.

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Vide order dated 22.10.2025, the Commission took note of the response filed by the Informant. Further, the Commission, upon consideration of OP’s request for extension of time, decided to grant to the OP, an extension of time till 17.11.2025 to submit its comments on the Information.

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Subsequently, OP filed another I.A. No. 447 of 2025 dated 14.11.2025 seeking extension of time by 04 weeks till 15.12.2025 to file response to the Information.

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The Commission vide order dated 10.12.2025 considered the aforesaid application and decided to grant to the OP, an extension of time till 15.12.2025 to submit its comments on the Information.

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The OP has submitted its response both (confidential and non-confidential version) on 15.12.2025. Further, OP filed voluntary submission supplementing its response dated 15.12.2025 (confidential and non-confidential version) on 07.01.2026.

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In its Additional Information, the Informant stated, inter alia , that the app " Pobreflix — Series, Movies " was published under its development account by a contractual developer and was not developed by any of its current employees or ex-employees. It is stated that the said app was created a while ago by a developer who was only given a one-time opportunity to grow. Furthermore, he is no longer associated with the Informant, and the Informant has no ongoing engagement with him. It is stated that since the developer is no longer with it, the Informant is unable to provide his present details. However, the Informant has clarified that the concern raised by OP was only with respect to the abovementioned app and accordingly, the Informant had also requested OP to remove that

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app if it was in violation, but its request was that the same should not affect its other running apps, which have always complied with policies and never faced any objections.

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It is further stated that it was specifically conveyed to the OP, through the email sent by advocate Shakti Mathur that “ Pobreflix was merely one of our contractual developers and is no longer associated with us ”. It is stated that this clarification was duly furnished to OP at the relevant time.

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The Informant has further highlighted that the very same application, which was cited as the reason for termination of its developer account, continues to remain live on the Google Play Store under another developer account. As per the Informant, this shows that the application in question was not inherently violated, and yet it was made the basis for penalising the Informant. It is stated that if the said application is permitted to be republished and remain live, it is difficult to appreciate why Informant’s genuine applications - fully compliant with OP's stated policies - should not be reviewed afresh and duly reinstated. The Informant has further stated that as regards the legal notices, no reply has been received from the OP's side.

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The Informant has stated that it is annexing the complete chain of email communications exchanged with OP from 21.09.2023. It is stated that the OP has failed to provide any resolution despite repeated requests and the information sought by the OP was already supplied by the Informant. It is further stated that, as evident from the email trail, the OP has explicitly instructed the Informant not to re-enter the Play Store market, threatening termination of the account if such action is attempted. It is stated that this directive has been enforced by terminating an account that was entirely unrelated to the previous one, thereby preventing the Informant from participating in the market. The Informant has alleged that OP is leveraging its dominant position, as for Android users, the Play Store remains the only trusted platform, and restricting access undermines fair competition and consumer choice.

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Further, the Informant has requested the Commission to: (a) Acknowledge the grave loss suffered: take note that due to the arbitrary and anti-competitive conduct of OP, the Informant has suffered an estimated financial loss of approximately Rs.57 Crores, besides

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irreparable harm to goodwill and reputation; (b) Direct corrective measures: issue appropriate directions to OP to review the Informant's compliant applications afresh and restore them on the Play Store, thereby ensuring a level playing field; (c) Compensate the losses: direct OP to compensate the Informant for the losses caused on account of the wrongful suspension of the developer account and the denial of market access, including loss of existing customers and inability to onboard new clients; (d) Address abuse of dominance: hold that OP, by virtue of its dominant position in the Android ecosystem and Play Store market, has abused its position by unjustly penalizing the Informant, and pass such remedial directions as deemed fit and (e) Any other relief: grant such further or other relief(s) as the Commission may deem just and proper in the facts and circumstances of the present case.

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In its response filed on 15.12.2025, OP has submitted that the issues presented by the Informant regarding Google's Play Store policies (‘ Play Policies ’), their terms, enforcement discretion, and account terminations are substantially identical to those already examined and decided upon by the Commission. It is stated that in Case Nos. 39 of 2018 ( Umar Javeed and Others v. Google LLC and Another ) (‘ Google Play Case ’) and in Case No. 07 of 2025 ( Liberty Infospace Pvt. Ltd. v. Alphabet Inc. & Ors.) (‘ Liberty case ’) the Commission had extensively reviewed the terms of DDA and DPP including allegations about (a) OP’s sole determination of DDA and DPP terms; (b) continuous changes in these terms by OP to dynamically address evolving issues in developer enforcement; (c) OP’s discretion to suspend or remove an app from the Play Store; (d) discretion to choose punitive action to be taken against bad actors, and (e) providing limited reasons for termination of accounts.

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It is stated by the OP that the Commission, in the Liberty case, also extensively reviewed the DDA, DPP, the Relation Ban Policy, and the appeals process in a similar account termination complaint filed by another developer. Following this extensive review, the Commission held that (a) terms and conditions, such as the DDA and DPP, are standard industry practice and not anti-competitive; (b) providing limited disclosures explaining the termination of an account for violation of the Relation Ban Policy is reasonable; and (c) OP’s appeal process is neither abusive nor discriminatory. OP has requested that under Section 26(2A) of the Act, the Commission should not conduct an inquiry into matters

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where the same or substantially similar facts and issues have already been decided, making further inquiry redundant in the present matter.

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It is stated by the OP that the Informant has not suggested an appropriate relevant market for the alleged anticompetitive conduct based on Sections 2(r), 2(s) and 2(t) of the Act, nor does the Information demonstrate how the alleged anticompetitive conduct is related to the market for app store for Android OS. OP has stated that defining a relevant market for app stores for Android OS excluding app stores on other platforms is incorrect under the Act’s legal requirements to test similar prices, characteristics, and intended use. Therefore, OP has disagreed with the narrow relevant market suggested by the Informant. OP has further stated that separately, the issue of appropriate relevant market for app distribution is pending before the Hon’ble Supreme Court (Civil Appeal No. 4098/2023 and Civil Appeal No. 228 of 2025). Considering this, OP has requested the Commission to not delineate a relevant market in the present case.

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The OP has further stated that its established mechanisms found policy violations requiring enforcement action against the Informant under the Play Policies. It is stated that OP’s detection tools identified certain malware violations with an app “ Pobreflix - Series, Movies ” (‘ Malware App ’) among its multiple mobile apps published through the First Account.

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As per the xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
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xxxxxx It is stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
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It is stated that vide its communication to the Informant dated 04.10.2023, OP served a termination notice for the First Account under its policies preventing malware (‘ Malware

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Policy ’), and behavior transparency issues related to deceptive behavior (‘ Deceptive Behavior Policy ’).

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It is stated that despite OP’s explanation that the Informant should not create a new related
account, the Informant created a new developer account i.e. the Second Account. The
Informant used this to publish an app BTHAWK. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
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37. As per the xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxx xxxxxxxx xxxxxx xxxxxx xxxxxxxxxxxxxxxxxxx (‘ Transitory Account ’), xxxxx
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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
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xxxxxxxxxxxxxxxxxxxx OP formally notified the developer that the Transitory Account
would not be reinstated and that any attempt to register a new account would be closed.

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OP has stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
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xxxxxxxxxxxxxxxxxxxxxxxxxxxxx OP has submitted that xxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxxxxxxxxxxxxxxxxx.

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39. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx .

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It is stated that the Second Account was accordingly terminated in compliance with Play Policies disallowing developers with a history of violations from creating new accounts to circumvent Google Play’s policy enforcement efforts and access Google Play. It is stated that the Commission recently acknowledged OP’s enforcement actions against spammy related accounts and the Second Account remains terminated.

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It is stated that the Informant filed the First Appeal against the termination of the First Account. In response, the OP reviewed all submitted materials and provided clear reasoning for the termination of the First Account. It informed the Informant that the Malware App had triggered the termination of the First Account and sent a form to the Informant asking for additional information to aid it in reviewing its enforcement action,

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. OP also specifically clarified that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx When the Informant provided the information requested by OP, it found that the Informant had incorrectly provided details

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Accordingly, in good faith, OP granted a second opportunity to the Informant to provide accurate details xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxx.

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxx .

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It is stated by the OP that based on this assessment, OP responded to the Informant’s appeal, stating that the Informant’s account violated the behavior transparency section of OP’s Deceptive Behavior Policy and Malware Policy and therefore could not be reinstated.

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It is stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxx .

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OP has submitted that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx It is stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Subsequently, it is stated that, xxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx .

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It is stated by the OP that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

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xxxxxxxxx .

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OP has submitted that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxx .

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Accordingly, it is stated that OP informed the Informant that its First Account has been reinstated. This communication also requested the Informant to resubmit its apps for them to be live on the Play Store. Despite this, it is stated by the OP that, the Informant has not submitted any of its apps under its reinstated First Account. Accordingly, the Information is infructuous.

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OP has further stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.

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OP has stated that xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx OP has submitted that xxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx .

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It is stated that, contrary to the Informant’s view, providing a fair chance for review and reinstatement under these circumstances should thus be viewed as evidence of a nonarbitrary, equitable, and proportionate compliance process. In any event, OP’s interests

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are closely aligned with those of developers and consumers in this process; excluding quality apps that users want would only drive them away from the Play Store.

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With regard to the Informant’s allegations of anti-competitive conduct, OP has submitted that it has no incentive to remove a compliant and policy-abiding app or developer account from the Play Store. The Play Store offers a large diversity of apps. More apps attract more users, benefiting both developers and Google alike. Millions of small and independent developers successfully operate on the Play Store. Highlighting isolated instances of OP enforcing against spammy or non-compliant apps is not a sufficient basis to claim that its practices and policies are unfair or illegal. Further, terminating developer accounts without cause would not be commercially prudent for OP, as it would undermine Play Store’s ecosystem.

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OP has further stated that it is critical to maintain Play Store’s security, including protecting it from spammy developers, which can disrupt and negatively impact other apps and users. It is stated that the termination of the Informant’s accounts was based on transparent, consistently applied Play Policies, specifically the Malware Policy and Relation Ban Policy, which are designed to protect platform integrity and user safety.

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It has been further stated by the OP that the Play Policies under which the Informant’s accounts were terminated are critical and commercially necessary measures to prevent bad actors from hampering user safety and to prevent such bad actors from circumventing enforcement by creating new accounts. The Play Policies are essential for maintaining a secure and trustworthy environment for users and developers, and are neither arbitrary nor unfair. Given the mandate of safety and security, OP maintains clear, robust, and effective risk detection and redressal mechanisms. Further, Play Policies (including the enforcement actions) are publicly available, demonstrating OP’s commitment to transparency and fairness for all developers.

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It is further submitted by the OP that it provided clear and adequate disclosure regarding the termination of the First Account by (a) specifying the precise triggers for termination, and (b) setting out the basis for attributing responsibility for the violation to the First Account.

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OP has stated that Play Store’s appeals process is meaningful, effective, and consistent with global best practices, ensuring procedural fairness and the possibility of reinstatement where merited. The Informant was afforded multiple opportunities to appeal the enforcement action, with each appeal reviewed by separate teams, including support agents.

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It is stated by the OP that it cannot disclose detailed technical signals or the identities of related accounts when enforcing its policies. Doing so would undermine the effectiveness of its detection systems, allowing malicious actors to game the system and evade enforcement (as also recognized by the Commission in the Liberty case). Nevertheless, developers are informed of the reason for enforcement and provided an opportunity to appeal. Further, the Informant, by its own admission, was aware of the related spammy account and does not dispute the connection.

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OP has submitted that its enforcement action against the Informant does not constitute an abuse of dominance or result in appreciable adverse effect on competition (‘ AAEC ’). The Informant provides no evidence to suggest any anti-competitive effect of OP’s actions in the market. The enforcement action was a routine application of the platform policy, with no evidence of market-wide harm, denial of market access, or restriction of technological development.

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The Commission considered the Information and other material available on record in its ordinary meeting held on 14.01.2026 and decided to pass an appropriate order in due course.

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Commission’s Analysis:

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The Commission has carefully perused the Information and other material available on record. Based on the allegations levelled in the Information, it is observed that the Informant is inter alia aggrieved by the termination of its developer account by OP and alleged non-redressal of its appeal against the same.

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The Commission, on the basis of the material available on record, notes that the following issues arise for consideration and determination in the present case:

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(i) What is the relevant market in the facts of the case?

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(ii) Does OP appear dominant in the relevant market?

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(iii) If yes, whether the alleged conduct amounts to violation of Section 4 of the Act?

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Issue (i): What is the ‘relevant market’ in the present case as defined in Section 2 (r) of the Act?

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One of the relevant markets delineated by the Commission in the Case No. 35 of 2021 titled XYZ (Confidential) v. Alphabet Inc. and Others (‘ Alphabet Case ’) was “market for app stores for Android OS in India” . The same relevant market was also defined in the Liberty Case by the Commission.

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The Commission is of the view that since, in the present matter also, the allegations pertain to abuse of dominant position by Google vis-à-vis app developers, the relevant market in the present case be delineated as the “ market for app stores for Android OS in India ”.

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Issue (ii): Whether OP holds a dominant position within the scope of Section 4 of the Act?

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The Commission, based on factors like market share analysis, barriers to entry in the delineated market, and side-loading being a cumbersome process, had observed in the case of Alphabet Case (supra) that Google via its Google Play Store, enjoys a dominant position.

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The Commission is of the view that, the above analysis holds good in light of the facts and allegations averred in the present matter also. Therefore, prima facie , OP holds a dominant position in the “market for app stores for Android OS in India”.

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Issue (iii): If yes, whether the alleged conduct amounts to violation of Sections 4 of the Act?

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The Informant has alleged that OP terminated the First Account on 20.09.2023, citing violations of DPP and DDA and the termination was linked to an app titled "Pobreflix – Series, Movies." which was created by an external contractor. Further, after the First Account was terminated, the Informant created the Second Account to list a single app called BTHAWK which was subsequently terminated by OP on 06.07.2024 due to its connection to the First Account. The Informant further alleges that OP failed to provide a specific explanation or a fair opportunity to appeal, despite legal notices served by the Informant due to which it suffers substantial financial loss, reputational harm, and exclusion from the digital market as a direct result of these terminations.

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Upon examination of the additional information furnished by the Informant pursuant to the directions of the Commission, several inconsistencies and material deficiencies are observed. In response to the Commission’s query regarding whether the application titled “Pobreflix – Series, Movies” was published under the Informant’s developer account, the Informant has stated that the said application was indeed published under its developer account by a contractual developer. However, this submission is found to be in contradiction with the Informant’s own averment made in paragraph 6 of the Information, wherein it was categorically stated that the application did not belong to the Informant and was developed and published by an external contractual developer, a fact allegedly communicated to the OP during the appeal process. The inconsistency in the Informant’s stance raises doubts regarding the veracity of its submissions.

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Further, when asked to clarify whether the application was developed and published by an external contractual developer or by an internal employee, the Informant submitted that the application was not developed by any of its current or former employees and that it was created “a while ago” by a developer who was given a one-time opportunity and is no longer associated with the Informant. The Commission notes that such submission is vague and lacks material particulars. No name, identity, or documentary evidence of the alleged contractual arrangement have been provided, nor has any timeline been furnished with respect to the commencement or termination of the said engagement. The use of imprecise expressions such as “a while ago” further weakens the credibility of the Informant’s submission.

¶160

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With respect to the Commission’s direction to identify the contractual developer along with relevant details, the Informant has stated that the developer is no longer associated with it and that his present details are unavailable. The Commission observes that it had not sought the present whereabouts of the developer but merely his identification and relevant details. The failure of the Informant to identify the individual responsible for development of the impugned application leaves open the crucial issue as to whether the application was developed by a contractual developer or an internal employee. In this regard, the Commission also takes note of an email dated 17.04.2025, annexed in the OP’s submission, sent by the Informant’s legal representatives to the Hon’ble Minister of Electronics and Information Technology, wherein it is stated that the Informant had “terminated the employee responsible for prior inadvertent mistakes.” This statement directly contradicts the submissions made before the Commission that the application was developed by an external contractual developer, thereby indicating that the Informant has not approached the Commission with clean hands.

¶164

Regarding the direction to furnish a copy of the communication with the OP referred to in paragraph 6 of the Information, the Informant has relied upon an email dated 10.03.2025 sent by its legal representative objecting to the termination of the developer account. The Commission notes that the said email is of a much later date and does not constitute the communication sought, which was allegedly made contemporaneously during the appeal process. Accordingly, the Informant has failed to comply with the Commission’s direction in this regard.

¶165

The Informant was further directed to provide a complete trail of communication exchanged with the OP from 21.09.2023 onwards along with all attachments. However, the Informant has not furnished the complete email trail, and communications exchanged between 27.10.2023 and 16.11.2024 are conspicuously absent. Such selective disclosure prevents the Commission from forming a complete and accurate understanding of the sequence of events.

¶166

The Commission further observes that the Informant has failed to approach the Commission with clean hands, having suppressed material facts regarding- (a) reinstatement of the First Account by the OP which was communicated to the Informant

¶167

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vide email dated 19.09.2025, (b) the identity of the said contractual developer/internal employee, (c) complete email correspondence trail with the OP, (d) a third account created by the Informant and subsequently terminated by the OP and (e) email dated 17.04.2025 sent to the Hon’ble Minister of Electronics and Information Technology.

¶171

The Commission further noted that vide email dated 19.09.2024, OP had intimated the Informant about reinstatement of its First Account however the additional information filed on 22.01.2025 by the Informant, did not contain any information with regard to the same. Further, the Informant also sent a follow up email to the Commission dated 03.10.2025, but even in this correspondence, no mention of the said reinstatement was made. Further, the statement by the Informant in para 6 of the Information that “…it was duly communicated to the Opposite Party that the said application did not belong to the Informant…” is factually incorrect as nowhere in the email communication trail provided by either the Informant or the OP does this statement appear and it stands in contradiction with Informant’s admission in the additional information that the said app was developed under its own developer account.

¶172

It is further noted by the Commission that the Informant has filed evasive replies to the specific queries of the Commission such as – (a) not revealing the identity of the said contractual developer/employee and giving contradictory information about the same to the Commission and OP on one hand and to the Hon’ble Minister of Electronics and Information Technology on the other, (b) not providing complete email trail and (c) providing a completely unrelated email in response to the specific direction of the Commission to provide a copy of the communication referred to in para 6 of the Information. The above conduct of the Informant amounts to selective and misleading representation of the facts before the Commission.

¶173

It is noted by the Commission that OP gave clear communication of termination of the First Account to the Informant while giving it an opportunity to appeal against the same and OP also warned the Informant not to open any other account, stating that the same will be terminated by the OP under its Relation Ban Policy and despite such a warning, the Informant went ahead with opening of the Second Account and uploading BTHAWK app under the same. As expected, the OP terminated the second account under its Relation

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Ban Policy. From the submission of the OP, it has also come to light that a third account xxxxxxxxxxxxxxxxxxxxx was also opened by the Informant which was also terminated by the OP due to its strong relations with the First Account. This fact was also withheld from the Commission by the Informant.

¶178

The Commission further notes that OP in September 2025, reinstated the First Account and vide email dated 19.09.2025 asked the Informant to resubmit its apps. However, as per the submission of the OP, the Informant has not done so, nor has it informed the Commission about the development. In essence, the relief that the Informant was seeking in terms of reinstatement of his account has already been provided by the OP.

¶179

The Commission observes that the OP has followed its declared policy in terms of terminating accounts hosting applications exhibiting suspicious activity, following up with the appeals process, asking for relevant information from the Informant, and finally reinstating the account after updating its review process. In fact, the evolving review system of the OP appears to have given a chance to the developers including the Informant to continue hosting their apps on the platform on the basis of enhanced security mechanism and detection capabilities.

¶180

However, the Commission notes that, in the entire sequence of events, the Informant has not been forthcoming with complete information, has attempted to repeatedly open new and related accounts, despite being warned against the same by the OP, having been eventually terminated as per Relation Ban Policy and has not resubmitted its apps even after the First Account was reinstated by the OP.

¶181

With regard to the Informant’s allegation that the app Pobreflix continues to be hosted on the Play Store, it may be noted that as per publicly available information on Play Store – two applications under the name of Pobreflix and Pobreflix TV are being displayed which have different nomenclature than Pobreflix – Series, Movies which was operating under the First Account.

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Further, the Commission in the Liberty Case had observed that “ GPDDA and GPDDP are standard form contracts that have to be entered into by all developers wanting to list their apps on Google Play Store, which appears to be a standard industry practice .”

¶186

It had further observed that “ in terms of the facts of the present case, Google’s explanation in respect of its ‘relational ban policy’, reasons behind not giving detailed disclosures, rationale for termination, lacking incentive to terminate authentic apps appear to be reasonable .”

¶187

The Commission also noted that the facts of the present matter are similar to the Liberty case, and the Commission’s observations in the Liberty case are relevant for the present matter as well. The present matter is a case of individual grievance of a developer involving violation of Play Policies, where redressal has already been availed of through OP’s appeal mechanism. The Commission has already dealt with the competition issues of those policies and the appeal mechanism in the Google Play Case and the Liberty case.

¶188

In view of the facts and circumstances of the present case, the Commission finds that no prima facie case of contravention of the provisions of Section 4 of the Act is made out against OP in the instant matter. Accordingly, the Information is ordered to be closed forthwith in terms of the provisions contained in Section 26(2) of the Act.

¶189

Before parting with the order, the Commission deems it appropriate to address the requests for confidentiality filed by Google under Regulation 36 of the Competition Commission of India (General) Regulations, 2024 (‘ General Regulations, 2024 ’). The OP has sought confidentiality over certain documents/information submitted during the proceedings. Considering the grounds put forth by the OP for the grant of confidential treatment, the Commission grants confidentiality to such documents/information in terms of Regulation 36 of the General Regulations, 2024 read with Section 57 of the Act for a period of three years from the passing of this order. It is, however, made clear that nothing used in this order shall be deemed to be confidential or deemed to have been granted confidentiality as the same has been used for the purposes of the Act in terms of the provisions contained in Section 57 of the Act.

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The Secretary is directed to forward the public version of this order to the Informant, and confidential version of this order to the OP accordingly.

¶194

Sd/(Ravneet Kaur) Chairperson

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Sd/(Anil Agrawal) Member

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Sd/(Sweta Kakkad) Member

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Sd/(Deepak Anurag) Member

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New Delhi

¶199

Date: 24/03/2026

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M/s Zucol Solutions Private Limited v. Google India Private Limited

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M/s Zucol Solutions Private Limited v. Google India Private Limited

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