Closure of Information Regarding Alleged Anti-Competitive Practices

Case No. 36 of 2025 Page 1 of 7

COMPETITION COMMISSION OF INDIA

Case No. 36 of 2025

In Re: Preeti Kodwani A-402, Shiv Ganga Park, Near Punjabi Colony, Ulhasnagar – 421 003.

Informant And Sundar Pichai LOS Altos Hill, CA, FIFC, 7th Level, BKC, Bandra, Mumbai – 400 051.

Opposite Party-1/OP-1 Bhavesh Jeswani B-103, Shiv Ganga Park, Ulhasnagar – 421 003. Opposite Party-2/OP-2 Samaira Jeswani B-103, Shiv Ganga Park, Ulhasnagar – 421 003. Opposite Party-3/OP-3 Rushan Hafiz 1001, Reyhaan Towers, Sahar Rd, Jogeshwari, Mumbai – 400 102. Opposite Party-4/OP-4 EY (Rohit Limaye, Joval Varghese) B2, 5th Floor, Nirlon Knowledge Park, Goregaon, Mumbai. Opposite Party-5/OP-5 Kuwarjit Singh Duggal Plot No. 2, Sant Kripal Singh Marg, Canal Rd, Vijay Nagar, Delhi – 110 009. Opposite Party-6/OP-6

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Alankrita Rana Shop No. A1-10, Kolte Patil Downtown, Ashoka Nagar, Kharadi, Pune – 411 014. Opposite Party-7/OP-7 Mohit Krishnani 10th Floor, Hiranandani Knowledge Park, Wing-Alpha, Powai, Mumbai – 400 076. Opposite Party-8/OP-8 Tanya Khanchandani Meera Avalon, 2nd Floor, Ambernath. Opposite Party-9/OP-9 Pearl Jain 10350 Richmond Avenue, Suit 400, Houston, Texas, USA. Opposite Party-10/OP-10 Nishant Shedale & Associates Duke University, 2138 Campus Dr. Durham, NC 27708. Opposite Party-11/OP-11 Apple LLC Apple Park, 1 Infinite Loop, Cupertino, CA 95014, USA. Opposite Party-12/OP-12 Mohit Rohra B-104, Shiv Ganga Park, Ulhasnagar – 421 003.

Opposite Party-13/OP-13 Hitesh Jeswani B-104, Shiv Ganga Park, Ulhasnagar – 421 003. Opposite Party-14/OP-14 Rajinder Singh Ji Maharaj Plot No. 2, Sant Kripal Singh Marg, Canal Rd, Vijay Nagar, Delhi – 110 009. Opposite Party-15/OP-15

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Rasmi Rana IT Building No. 3, 8th Floor, Nesco IT Park, Goregaon, Mumbai – 400 063. Opposite Party-16/OP-16 Meet Merchant Memories Photo Studio, Shop No. 3, Himanshu Residency, Prem Nagar, Borivali (W), Mumbai - 400 092. Opposite Party-17/OP-17 Anam Hafiz 1001, Reyhaan Towers, Jogeshwari, Mumbai – 400 102. Opposite Party-18/OP-18 Arshaan Hafiz 1001, Reyhaan Towers, Jogeshwari, Mumbai – 400 102. Opposite Party-19/OP-19 Bhairavi B-501, Shiv Ganga Park, Ulhasnagar – 421 003. Opposite Party-20/OP-20 Amazon Seller Services Pvt. Ltd. Bagmane World Technology Center, SEZ, Mahadevpura, Bangalore, Karnataka – 560 048. Opposite Party-21/OP-21 Flipkart Internet Pvt. Ltd. Buildings Alyssa, Begonia & Clove Embassy Tech Village, Outer Ring Road, Devarabeesanahalli Village, Bengaluru, Karnataka – 560 103. Opposite Party-22/OP-22 Wix.com Ltd. 500 Terry A. Francois Blvd., 6th Floor, San Francisco, CA 94158. Opposite Party-23/OP-23

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CORAM:

Ms. Ravneet Kaur Chairperson

Mr. Anil Agrawal Member

Ms. Sweta Kakkad Member

Mr. Deepak Anurag Member

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

1. The present Information has been filed by Preeti Kodwani (‘Informant’) under Section 19(1)(a) of the Competition Act, 2002 (‘Act’), against Sundar Pichai (‘Opposite Party- 1’/ ‘OP-1’), Bhavesh Jeswani (‘Opposite Party-2’/ ‘OP-2’), Samaira Jeswani (‘Opposite Party-3’/ ‘OP-3’), Rushan Hafiz (‘Opposite Party-4’/ ‘OP-4’), EY (Rohit Limaye, Joval Varghese) (‘Opposite Party-5’/ ‘OP-5’), Kuwarjit Singh Duggal (‘Opposite Party-6’/ ‘OP-6’), Alankrita Rana (‘Opposite Party-7’/ ‘OP-7’), Mohit Krishnani (‘Opposite Party-8’/ ‘OP-8’), Tanya Khanchandani (‘Opposite Party-9’/ ‘OP-9’), Pearl Jain (‘Opposite Party-10’/ ‘OP-10’), Nishant Shedale & Associates (‘Opposite Party-11’/ ‘OP-11’), Apple LLC (‘Opposite Party-12’/ ‘OP-12’), Mohit Rohra (‘Opposite Party-13’/ ‘OP-13’), Hitesh Jeswani (‘Opposite Party-14’/ ‘OP-14’), Rajinder Singh Ji Maharaj (‘Opposite Party-15’/ ‘OP-15’), Rasmi Rana (‘Opposite Party-16’/ ‘OP-16’), Meet Merchant (‘Opposite Party-17’/ ‘OP-17’), Anam Hafiz (‘Opposite Party-18’/ ‘OP-18’), Arshaan Hafiz (‘Opposite Party-19’/ ‘OP-19’), Bhairavi (‘Opposite Party-20’/ ‘OP-20’), Amazon Seller Services Pvt. Ltd. (‘Opposite Party-21’/ ‘OP-21’), Flipkart Internet Pvt. Ltd. (‘Opposite Party-22’/ ‘OP-22’) and Wix.com Ltd. (‘Opposite Party-23’/ ‘OP-23’) inter alia alleging contravention of the provisions of Sections 3 and 4 of the Act.

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2. It is stated that the Informant is engaged in legitimate business activities and invests considerable resources in marketing and client acquisition through online platforms such as Google and other digital intermediaries. As per the Information, certain dominant players in the digital ecosystems including major technology companies and their associated Artificial Intelligence or ad serving systems are allegedly engaging in practices that unfairly restrict the Informant's market access and divert its commercial opportunities to competitors.

3. It is stated that the cumulative and persistent behaviour has already resulted in severe and fundamental commercial distress for the Informant, specifically by undermining professional roles and effectively cutting off access to funding and investment opportunities.

4. It is alleged that the Informant's digital identifiers (such as email IDs, website accounts, or ad campaign data) are being manipulated or interfered with. Further, leads and customers who search for or interact with the Informant's brand are diverted to competitors, despite paid marketing efforts by the Informant and such diversion constitutes “market allocation" and denial of market access under Section 3(3) and Section 4(2)(c) of the Act, respectively.

5. It is further alleged that platforms with a dominant position in online advertising and search services are using their control to bias search results and ad placements, intentionally suppressing visibility of the Informant's business which amounts to imposing unfair or discriminatory conditions in the sale of services, in contravention of Section 4(2)(a)(i) of the Act.

6. As per the Information, there are attempts to influence international customers (including those in the USA) to boycott the Informant's brand. It is stated that if this involves collusion among competitors or coordinated platform behavior, it represents a concerted refusal to deal.

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7. It is stated that the Informant is deprived of access to customers/clients and markets despite legitimate advertising expenditure, compounding the pre-existing harm to its funding and business stability. The Informant further states that competitors gain an unfair advantage through manipulated visibility, therefore harming not only the Informant but also consumer choice and market transparency, leading to appreciable adverse effect on competition (‘AAEC’) in India's digital services market.

8. The Informant has sought the following interim relief under Section 33 of the Act from the Commission: to restrain ongoing hijacking, diversion of traffic and suppression of listings; order for restoration of fair access to digital marketing and ad-serving systems; and immediate cease-and-desist order (injunction) to stop all acts of defamation and malicious interference with the Informant's client acquisition and business relationships. Further, the Informant has requested the Commission to issue a direction to investigate abuse of dominance and collusive behaviour.

9. The Commission, in its ordinary meeting held on 10.12.2025, considered the Information and decided to pass an appropriate order in due course.

10. The Commission notes that the allegations levelled in the Information are vague, broad, and devoid of the requisite particulars, and the nature of the alleged contraventions have not been clearly articulated. Furthermore, there are 23 OPs arrayed in the present matter; however, the specific role, conduct, and contribution of each OP have not been mentioned in the Information.

11. The Commission further notes that the evidence furnished in the Information in the form of screenshots is largely illegible and incapable of proper scrutiny. Even otherwise, the Informant fails to specify the manner in which provisions of the Act are allegedly violated. Therefore, in these circumstances, the allegations remain indeterminate and legally unsustainable.

12. Upon consideration of the facts and circumstances of the present case, the Commission is of the view that there is no prima-facie contravention of provisions of Sections 3 and 4 of