From: Fitch Daniel Pitney
Founder
South Whidbey Online, A Social Purpose Corporation
2620 Dreamland Lane
Langley, WA 98260
Tel 206-383-6903
em: 450ktm@gmail.com
To: Honorable District Judge Amit P. Mehta
U.S. District Court for the District of Columbia
333 Constitution Avenue, N.W.
Washington D.C. 20001
Re: Proposed Remedies for Reuniting Local Communities in the United States v. Google LLC
We propose industry-wide remedies which more closely resemble the equal-access principles which regulated AT&T and the regional bell companies. Today the commodity to be regulated is the inclusion or exclusion of a given individual or organization in search results, especially at the regional, local level. For instance, there is only one correct answer to the question "what plumbers are near me?" Yet Google, under the status quo, is hiding most local plumbers and instead showing the results of the highest bidders, which are mostly non-local plumbers and agencies which have invested heavily in search engine optimization. Google has not always presented data this way and there are simple changes which can restore the Internet, and Google's original mission, of making data more universally accessible and useful.
The competitive landscape for Internet search peaked in the late 1990s and 2000s when phone books offered comprehensive local directories and Internet search companies sought to match and exceed their functionality. Indeed, Google's mission of "organizing the world's information and making it universally accessible and useful" originally included actual directories, as shown below:
In late 2011 a pivotal shift took place as Google abandoned its directory. Having already ascended to the #1 spot for Internet search, a financial incentive became clear: How large is the advertising revenue opportunity if all organizations are readily discoverable? For instance, if a search for "plumbers near me" results in an actual and correct list of nearby plumbers, how incentivized would the plumbers be to advertise? Alternatively, how large would the advertising revenue opportunity be if, instead of presenting "organized" data which can be sorted by proximity, A-Z, etc., what if search-result ranking was the only means of information access?
Of course Google was correct in choosing the latter route to maximize revenue, but at what cost to society?
Today, according to our study in South Whidbey, 94% of local organizations are undiscoverable on Google by keyword search.
Intra-community communication, the foundation of human culture,1 is decades in decline.2 In 2023, the U.S. Surgeon General declared an 'Epidemic of Loneliness and Isolation'3 and included technology as a contributing factor. For local communities, Google search can be a gateway or a gatekeeper, depending on the extent to which local inquiries produce local results.
By leveraging verified reference data, we measure Google's search inclusivity (of local organizations) and explore the limitations of Google's search-only approach to Information Retrieval (IR.) We conclude with recommendations for corrective actions as remedies in the United States v. Google LLC.
Local organizations of all types serve as productive centers for cultural and economic exchange, hence we started with inclusivity as a first-principle: All South Whidbey organizations and individuals doing business in their own name are included. Specifically, the reference data includes all of the following:
621 local organizations were identified and organized according to three levels of detail for categorical search-term purposes:
For instance, a pet-care service and graphic-design consultancy may have keyword-search phrases per the above as:
(Tricia's Pet Care) | (CK Graphic Design) | |
---|---|---|
1. (Main Categories) | Animal and Pet Care | Services and Retail |
2. (Subcategories) | Pet Sitting | Web-Design |
3. (Subcategory Details) | Overnight Pet Resort | Full Service Creative Agency |
By arriving at a reference-data set, we can measure Google's inclusion and/or exclusion of local organizations.
Gatekeeping, in this context, refers to limiting information access in order to charge a premium for increased visibility (advertising). We identify two ways Google limits access to local organizations: first, by underrepresenting local organizations in search-results, and second, by limiting information retrieval tools to advertisement-based ranking schemes.
For the first causal mechanism, the underrepresentation of local organizations in search-results, we analyzed 930 search results from 31 carefully selected key-word searches. Each search-phrase was derived from the verified reference data to ensure at least 10 local results, on average, were possible for each query. "Near me" was appended to each search with location services activated at the approximate center of the South Whidbey area. We then classified all 930 results, by URL, as either local or non-local. 58 of the 930 results, or 6%, were local, and the rest were non-local. We believe this lack of local information is having a highly divisive impact on our local community and likely on most local communities Nationwide.
For the second causal mechanism, we zoom-out to examine Google's approach to Information Retrieval (IR). Studies in IR demonstrate how search, when combined with categories and sorting, represent the most effective means of information retrieval.7 Indeed, we only need to look to the public library's catalog search, ebay.com or amazon.com to see all three of these IR tools being effectively utilized. Yet Google relies on search exclusively. We submit search alone limits information access and effectively heightens the importance of result-ranking based advertising. Consider the following example to illustrate:
South Whidbey is home to 110 General Contractors. Imagine all 110 increased their Google advertising budget to $5,000 per month. Yet Google only presents data in a "top 10" type ranking format, making it impossible for 110 General Contractors to be presented on a level playing field, such as could be readily accomplished with A-Z sorting or proximity sorting.
When Google began, it had to compete with phone books which, at the time, provided near 100% local, accurate, and inclusive content. Not surprisingly, Google was competitive at the time and even offered categories and location-specific data as can be seen via their search page from 2011 (Figure 1.) Now is the time to reinstate these fundamental community resources by putting local communities back into focus:
For any Nationwide web-search portal (NAICS 519130) we propose:
While the Internet and AI dwarf the telephony era by many measures, the empowerment of local communities continues to have a legacy "land-line" resonance. Unlike geographically anonymous URLs, phone numbers and street addresses were imbued with the local information which is lost in today's FAANG dominated Internet. We propose remedies to restore this community fabric.
Google's version of the Internet is less like the public network it was built upon and more like a pay-to-play gatekeeping service in which much of the data is hidden in order to increase the demand for advertising. Google is the only winner in this scheme.
The largest source is the Washington Secretary of State, which listed 2,009 active organizations, 580 of which were found to have active websites on Google. The total organizations found across all sources amounted to 621.
Source (A-Z) | No. of Entities supplemental to the WA SOS |
---|---|
Chamber of Commerce - Clinton | 1 net-new |
Chamber of Commerce - Freeland | zero net-new |
Chamber of Commerce - Greenbank | zero net-new |
Chamber of Commerce - Langley | 3 net-new |
Drewslist (notable mention) | Copyrighted newsletter, content excluded |
Facebook search by business categories | zero net-new |
Google search by business name | 2,009 searches using WA SOS data, 580 verified |
Google search by categories | Zero net-new |
Nextdoor | zero net-new |
Physical bulletin boards at Grocery stores | 5 net-new |
Port Of South Whidbey | zero net-new |
Tiktok, Instagram, X, Reddit | zero net-new |
Washington Secretary of State (WA SOS) | 580 net new |
Whidbey and Camano Islands Tourism | 3 net-new |
Whidbey Community Foundation | 5 net-new |
Whidbey Island Arts Council | 7 net-new |
Whidbey Island Grown Cooperative | 5 net-new |
Whidbey Telecom Phone Book | 13 net-new |
The first 30 results of each (930 total) were analyzed for inclusivity. 94% of results were non-local. Complete details are available via footnote no. 4.
1 Pagel, M., 2017. What is human language, when did it evolve and why should we care?. BMC Biol 15, 64. Link: https://bmcbiol.biomedcentral.com/articles/10.1186/s12915-017-0405-3
2 Putnam, R. D., 2000. Bowling Alone: The Collapse and Revival of American Community. Simon & Schuster. Link: https://muse.jhu.edu/article/16643
3 Julianne Holt-Lunstad, 2023. Our Epidemic of Loneliness and Isolation: The U.S. Surgeon General's Advisory on the Healing Effects of Social Connection and Community, Office Of The Surgeon General. Link: https://www.hhs.gov/sites/default/files/surgeon-general-social-connection-advisory.pdf
4 Pitney, F., 2025. Search results compared to reference data https://southwhidbey.online/search_comparison_results.json, Search results summary https://southwhidbey.online/search_comparison_summary.json
5 Ried, E.,2023. Supercharging Search With Generative AI. Link: https://blog.google/products/search/generative-ai-search/
6 Wei-Lin Chiang, Lianmin Zheng, Ying Sheng, Anastasios Nikolas Angelopoulos, Tianle Li, Dacheng Li, Hao Zhang, Banghua Zhu, Michael Jordan, Joseph E. Gonzalez, Ion Stoica, 2024. Chatbot Arena: An Open Platform for Evaluating LLMs by Human Preference. arXiv.Link: https://lmarena.ai/?leaderboard
7 Ben-Yitzhak, O., Golani, M., Ravid, G., & Shmueli, G.,2008. An exploratory approach for analyzing faceted search.