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Case 2:24-cv-04055 Document 1 Filed 03/21/24 Page 4 of 88 PageID: 4

across many technologies, products, and services, including super apps, text messaging, smartwatches, and digital wallets, among many others.

Apple’s conduct also stifles new paradigms that threaten Apple’s smartphone dominance, including the cloud, which could make it easier for users to enjoy high-end functionality on a lower priced smartphone- -or make users device-agnostic altogether. As one Apple manager recently observed, “Imagine buying a [expletive] Android for 25 bux at a garage sale and it works fine…. And you have a solid cloud computing device. Imagine how many cases like that there are.” Simply put, Apple feared the disintermediation of its iPhone platform and undertook a…

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