Big Tech’s Market Dominance: Challenges And Interventions

- by Tejas Jain, student at Vivekananda Institute of Professional Studies, GGSIPU. This is the 10th winning entry of the National Article Writing Competition organized by CBLT.

“Competition is not only the basis of protection to the consumer, but is the incentive to progress.”

                                                               — Herbert Hoover, 31st President of the United States

INTRODUCTION

While speaking at a panel discussion on the regulatory landscape for start-ups, the Director General of the Competition Commission of India (CCI) Ansuman Pattnaik expressed concerns over the challenges faced by Indian startups in growing due to big digital firms like Google, Apple, Facebook, Amazon and Microsoft as they are “very powerful and they have rich resources of data” and that “they do not perform in a neutral way.” [1] Google, for instance, dominates market share in search while Apple earns more in annual profit than Starbucks makes in revenue and Amazon runs one-third of the internet through Amazon Web Services. Further, network effects and the advantage of market incumbency enables them to maintain this stranglehold. As a result, they generate the highest amounts of consumer data and cash which makes them near-invincible. [2]

However, governments have not been sitting ducks in response to this. The European Union, India as well as other jurisdictions have undertaken measures to combat Big Tech dominance – the effectiveness of these measures notwithstanding. Recently, for example, Google was fined USD 160 million by the CCI for abuse of its dominant position and unfair trade practices.[3] And governments around the world are in the process of introducing or strengthening existing anti-trust legislations and policies to suit the needs of an increasingly digitised economy. However, combating the ill-effects of the power and influence of these tech giants, as described above, will undoubtedly be challenging.  

Thus, this article elucidates on the nature of Big Tech’s dominance, the challenges it brings forth for smaller competitors, as well as the variety of measures undertaken so far by governments across the world to uphold the principles on which modern competition law is based.

NATURE OF BIG TECH’S DOMINANCE

 The advent of the information and digital age has brought about the ascendancy of a handful of tech companies - such as Google, Microsoft, Apple and so on - that dominate the digital landscape today. These companies have been able to successfully establish a dominant position within their respective markets/niches, and consumers as well as smaller competitors alike have paid a price for this success.[4]  In fact, their business success, and the consequences it has had for consumers and competitors, are inextricably linked. Although one should not dismiss the real innovation spurred by these companies which has also enabled them to become what they are today, it is also the case that they have used their unique and dominant positions within the markets to further entrench this dominance.[5] 

Firstly, these companies providing crucial digital services like Facebook, Google, etc., have well-established and highly sophisticated behavioural marketing and advertising businesses that collect massive volumes of data from their users. Thus, what was formerly private information is extracted by these companies (often without permission) to become a corporate asset.[6] This allows these companies to enhance user algorithms, and display content that would be psychologically appealing to the consumer which pushes him to keep using the service. [7]

Then, there are the ‘network effects.’ Simply put: users are attracted to a particular service or platform more when there are other users already using it – and this is especially the case when the platforms are supposed to connect different kinds of transaction partners such as riders and drivers, or buyers and sellers, etc. With more users joining the platform, the value of the platform also increases. For instance, the ability of the Uber platform to attract more riders attracts more drivers to the platform, resulting in increased availability.[8] Riders naturally tend to choose the platform that everyone in their network is using. Another example is WhatsApp - and how it dominates partly because many already use it. And as more users join, the more indispensable it becomes, creating a self-reinforcing loop. New entrants, no matter how innovative, struggle to break this network effect.[9]

Further, the absence of territorial barriers makes it easier for such platforms to build massive customer bases and attain economies of scale on a global level. This allows the companies to establish their roots across the digital space resulting in the dilution of competition. And in addition to this, they engage in the more commonly known anti-competitive practices such as price discrimination, self-preferencing (the practice of showing own products at more prominent places in the online search engines) and predatory pricing – all carried out with the intent to unfairly exploit a captive customer base as well as driving out the competition. Price discrimination is the pricing strategy where a seller offers the same product or service at different prices to different buyers with the goal of maximising revenue through capturing more consumer surplus, whereas predatory pricing is the pricing strategy which involves reducing the retail prices to a level lower than competitors so as to eliminate competition.  Needless to say, given the lack of competition within the market, the user is left with no choice but to succumb to being exploited. [10]

Finally, all these issues are rendered harder to resolve given the increasing influence and power of Big Tech companies (both in India and abroad) in politics. Aside from these companies being major donors to political parties, they also (specifically social media platforms such as Facebook, WhatsApp, etc.) shape narratives.[11] And in a world that becomes more and more digitized and interconnected through the internet, where more and more people obtain their daily news from social media; these platforms become increasingly critical for politicians in campaigning for elections and winning the ‘narrative wars.’ In fact, these platforms have become so pertinent in determining how the average citizen thinks about politics that, according to a recent NewYorker article, “social media is no longer just a tool for politicians to get out their message; politicians now have to shape themselves into optimized vessels for social media,” i.e., mould their message to the electorate so that it attracts as many eyeballs as possible on the internet. [12]

ANTI-TRUST CHALLENGES

Significant antitrust challenges are unavoidable when market concentration amongst a handful of companies occurs.  Though they continue to drive innovation, they also raise concerns about monopolistic practices, data exploitation, and unfair competition. Regulating them becomes tougher as they leverage their market dominance to create entry barriers for smaller competitors. Google, for instance, has faced scrutiny for allegedly prioritizing its own services in search results (i.e. ‘self-preferencing), disadvantaging smaller businesses and startups, as well as several other unfair practices discussed above. [13]

These disadvantages have significant implications for the ability of smaller businesses to stay afloat – let alone compete against the tech behemoths. They get affected in the following ways: -

1. 1.      Regulatory Burden: Smaller businesses often lack the resources to navigate complex regulatory environments. Antitrust investigations, as well as potential changes in laws, always create uncertainty, leading to increased compliance costs. These costs are disproportionately burdensome for small firms compared to larger corporations as the latter usually have more extensive legal and compliance departments.[14]

2. Market Access: Big Tech's dominance limits smaller businesses' access to important digital platforms. For example: if a small business relies on Google's search engine or Amazon's e-commerce platform for visibility, any changes in these platforms' policies significantly impacts their market reach which affects the potential for future growth.

   
   

3. Resource Constraints: Smaller businesses also lack the financial resources to invest in research and development, or marketing, making it difficult to compete with the scale and reach of the powerful tech giants.[15] This disparity exacerbates existing barriers to entry and growth in digital markets.

   
   

4. Innovation Barriers:  Big Tech companies control critical resources such as datasets, funding networks, and digital infrastructure. Smaller firms struggle to access these resources, limiting their ability to experiment and bring innovative products to market. As a result, creative and disruptive ideas from startups struggle to survive without the tools the tech giants monopolize.[16]

There are a myriad of other ways in which Big Tech’s stranglehold over the digital economy is hampering healthy competition – the bedrock of the modern free market system. It reshapes the market in ways that challenge the foundational principles of competitive capitalism. Even without overtly illegal conduct, their entrenched position in the digital economy distorts fair market functioning as innovation and competition are no longer determined purely by merit, but by access to ecosystems that only a handful of companies’ control. This affects developing economies too as they are heavily reliant on these platforms, which leads to dependency, reduced local innovation, and limited digital sovereignty. As a result, the global digital economy risks being shaped around the interests of a few dominant players.[17].

Examples of this phenomenon include the case of Google Android: in the relevant market, it commands a near 90% share which makes it nearly impossible for alternate mobile operating systems to gain traction - even if they are technologically superior. In October 2022, the CCI found that Google abused its dominant position by requiring device manufacturers to pre-install the Play Store and mandate use of its billing system. It was fined ₹1,337.76 crore and issued a cease-and-desist order[18] Subsequently, the NCLAT upheld much of the CCI’s findings but reduced the fine to ₹216.69 crore, retaining behavioural remedies related to billing transparency and data usage. [19]

Or take the case of Microsoft Teams that came pre-integrated with Office 365, creating an environment where startups like Slack or Zoom face an uphill battle - not necessarily because of lower quality of products, but instead because Microsoft’s distribution power is overwhelming. In fact, in the EU, this led to formal antitrust investigations in 2023,[20] To which Microsoft responded by decoupling Teams from Office and improving interoperability with rival products.[21] This led to the EU considering accepting Microsoft’s changes, potentially allowing the company to avoid hefty fines if the anti-trust promises prove sufficient.[22]

Further, innovation gets hampered. Startups developing app-based services (for example: in edtech or fintech) often express concern about dependence on the Google Play Store or Apple App Store. Their inability to control their own distribution limits risk appetite and product design, especially when platform policies can change without recourse.[23] According to the US House Judiciary Committee’s 2020 Big Tech report, Facebook’s acquisition of WhatsApp and Instagram effectively killed major sources of innovation in social media.[24]

There is another concern about Big Tech dominance that is not acknowledged enough. It creates monocultures, i.e., single platforms that become indispensable infrastructure. This makes the entirety of the market and the economy dependant on a few entities. For instance – relying on Google for search, Android, email (Gmail), maps, and payments (GPay) renders consumers as well as businesses dependent on a single private entity for core, 21^st century digital functions. If Google were to withdraw or suffer disruption, entire sectors would be affected overnight. Another example of this is the influence of Amazon Web Services (AWS) which powers much of the internet - including startups, governments, and Fortune 500 companies.[25] This raises national security and data privacy concerns as critical infrastructure and sensitive information is centralised in the hands of a few private companies. These companies provide essential services used by governments, businesses, and individuals which creates a single point of failure capable of crippling economies if disrupted by cyberattacks, outages, or corporate decisions. Further, dependence on foreign infrastructure undermines sovereignty and exposes states to external pressures – making national security vulnerable. [26]

However, there are solutions to these challenges as well – one of which being stronger antitrust enforcement and remedies. Regulators must move beyond imposing fines (which are often negligible for trillion-dollar firms) and focus on structural interventions. These could include mandating interoperability between platforms, restricting forced bundling of services, and perhaps in extreme cases, even considering the breakup of monopolistic entities if their market control threatens economic stability. At the same time, governments need to streamline compliance for smaller businesses, which would ensure that regulations do not disproportionately burden startups.

Another solution lies in “digital sovereignty,” i.e., building alternative infrastructures to reduce dependency on a few foreign private companies. Alongside regulation, governments should also invest in public digital infrastructure, whether it is open-source payment systems or interoperable app marketplaces, to provide credible alternatives to Big Tech platforms. This would not only reduce the systemic risks discussed above, but also encourage local innovation by giving startups greater control over distribution and data. Therefore, a mix of regulation, structural remedies, and investment in domestic digital infrastructure could ensure that the digital economy serves broader public interest.

Thus, as can be clearly seen, India as well as the world is already beginning to face the consequences of allowing a few companies rule over one of the most, if not the most, crucial and pertinent market in the 21^st century. Their dominance of this part of the economy has created great systemic risks, which is not only damaging competition and innovation, but is also making societies vulnerable to data privacy breaches, national security threats, and economic downturns as explained above.

 

GOVERNMENT INTERVENTIONS

As mentioned in the introductory part of this article, governments in India and across the world have not been sitting ducks in the face of Big Tech capture of the digital economy. The Indian government, for instance, recently brought in the Digital Competition Bill, 2024[27] (taking a leaf out of the European regulatory handbook; in particular, the ‘Digital Markets Act’ of 2023[28]) to pre-emptively regulate dominant digital platforms. The bill proposes “Ex-ante regulations,” i.e., proactive rules to prevent anti-competitive behaviour by designating companies to be "Systemically Significant Digital Enterprises" (SSDEs) based on their market influence – the criteria of which would undoubtedly cover the tech giants. It also proposes a specialized unit within the CCI to oversee compliance and enforcement, and proposes faster timelines for investigations, with limited opportunity for interim relief in order to prevent endless litigation delays.[29] Over 100 stakeholders, including startups and legal experts, had provided input during the March–May 2024 consultation period, and currently, The Ministry of Corporate Affairs (MCA) is reviewing feedback to refine the bill.[30]

Further, the Competition (Amendment) Act, 2023 contains provisions which affect Big Tech. For example: the amendment mandates CCI approval for mergers/acquisitions exceeding ₹2,000 crore, curbing "killer acquisitions" of startups. Killer acquisitions refer to the practice where large, dominant firms (especially in the tech and pharmaceutical sectors) acquire smaller, innovative startups mainly to eliminate potential future competition, rather than to integrate or scale their products. Usually, the acquired firm’s projects or technologies are discontinued post-acquisition which prevents disruptive innovations from reaching the market, and therefore, reduces consumer choice.[31]

Also, fines are based on companies’ worldwide revenue which ensures tangible and meaningful consequences for these companies.[32] In addition to this, the Indian government has undertaken a number of enforcement actions holding the tech giants accountable for their anti-competitive behaviour. For instance, Google being fined ₹1,337.76 crore for abusing Android dominance, including restrictions on third-party app stores and preferential search practices; Amazon and Flipkart having been investigated for favouring select sellers, predatory pricing, and leveraging seller data for private labels; and, scrutiny of Apple’s App Store’s commission fees and payment restrictions.[33]

Globally, there have been several responses to Big Tech’s abuse of power as well. Most prominent of them is the European Union-adopted Digital Markets Act (DMA)[34] introduced in 2023. Similar to the Digital Competition Bill, the DMA imposes ex-ante obligations on what it terms “gatekeepers” (companies meeting size and control criteria). These ‘gatekeepers’ are mandated to prohibit self-preferencing in rankings, allow users to uninstall pre-installed apps, requires data portability and interoperability with third-party services and bans the use of non-public business data from dependent users (e.g., third-party sellers).[35] Apple, Google, Meta, Amazon and Microsoft have been designated as ‘gatekeepers’ under the DMA. [36]

Even the US government – known for upholding the laissez-faire approach to the American economy – has chosen to take actions in recent years. For example: the two lawsuits initiated by the Federal Trade Commission and Department of Justice against Meta and Google respectively. The former challenged Meta’s acquisitions of Instagram and WhatsApp,[37] arguing they were designed to neutralize competition. US Courts have allowed the lawsuit to proceed to trial, finding some merit in the anti-trust concerns. If they ultimately find Meta in violation, they could order the company to restore market competition by divesting from the acquisitions.[38]

The lawsuit against Google, on the other hand,  attacked the company’s dominance in the search advertising market, alleging it monopolized key ad tech services to stifle rivals and publishers.[39] US Courts found it had unlawfully monopolized two key segments of the open-web digital advertising market through tying and exclusionary conduct, in violation of the Sherman Act. However, the government failed to prove monopoly in the advertiser ad network market, and now the courts will consider possible structural actions to correct the anti-competitive harm.[40] Further, while efforts like the American Innovation and Choice Online Act, (containing provisions that target self-preferencing and discriminatory access to platform infrastructure) have stalled in the US Congress, they still reflect bipartisan intent to curb Big Tech’s power.[41]

But although government interventions are increasingly shifting from narrow enforcement actions to structural reforms that seek to reshape digital markets, they are still proving to be insufficient to deal with the anti-trust challenges brought about by Big Tech’s domination effectively. The regulatory response has often lagged behind the technological and commercial agility of the very companies it seeks to contain. In India, for instance, while the CCI has passed landmark orders, implementation has proved to be a much slower affair. Enforcement frequently runs into legal bottlenecks, with tech giants securing stays or delays through appellate litigation.[42] The existing competition framework, grounded in the Competition Act, 2002, is largely ex post, requiring demonstrable harm before action can be taken. The Digital Competition Bill, which proposes an ex-ante framework modelled on the EU’s DMA, may eventually fill this gap - but for now, it remains a draft.

Moreover, regulatory bodies in India often lack the technical expertise, digital literacy, and financial autonomy to effectively regulate multi-billion-dollar global platforms.[43] There is also the real concern of political economy as governments, reliant on foreign investment and digital infrastructure, may hesitate to confront Big Tech too aggressively.[44] And globally too, the story is not much different. The EU, like India, has struggled with the “compliance gap” - the space between rules and real-world implementation,[45] whereas in the United States, the antitrust revival has been louder in rhetoric than in legislative success. High-profile lawsuits have been filed against Google, Meta, and Amazon, but progress has been slow and the legal standards remain outdated.[46] Attempts to pass new antitrust legislation have faltered in Congress, stymied by partisan gridlock and intense lobbying by the very firms under scrutiny.[47]

CONCLUSION

The rise of Big Tech has not merely altered markets—it has redefined them. Through data-driven scale, network effects, and platform-centric ecosystems, a handful of these firms have entrenched themselves at the very core of the digital economy, often operating as infrastructural gatekeepers rather than mere competitors. Their dominance is not just commercial but structural - embedded in the very architecture of modern digital life.

This scale of dominance brings with it a unique set of antitrust challenges. And government interventions have begun evolving to meet this challenge, shifting from narrow, ex post enforcement to broader structural and ex ante regulatory tools. Jurisdictions like the EU and India are experimenting with legislative frameworks aimed at curbing their power before it solidifies further, while the United States is witnessing a long-overdue antitrust reawakening. Yet, these interventions, though ambitious, remain inconsistent, fragmented, and often undercut by legal inertia, institutional limitations, or political hesitation. The result is a regulatory response that remains one step behind the market.

As the digital economy continues to evolve, the regulatory imagination must evolve with it. Effective antitrust governance will require not just sharper tools, but deeper insight. Only by addressing the systemic nature of Big Tech’s dominance can regulators hope to foster truly open, competitive, and innovation-rich digital markets.

[1] Rakshit Kumar, 'Big Tech Firms Hinder Startup Growth, Says India's Antitrust Watchdog Chief' (2025) https://www.outlookbusiness.com/news/big-tech-firms-hinder-startup-growth-says-indias-antitrust-watchdog-chief accessed 5 April 2025.

[2] Jonathan Knee and Alison Beard, ‘Can Big Tech Be Disrupted?’ (2022) Harvard Business Review https://hbr.org/2022/01/can-big-tech-be-disrupted accessed 06 April 2025.

[3] ‘Google Fined over $160M by Indian Watchdog over Market Dominance’ (TRT World, 21 October 2022) https://www.trtworld.com/business/google-fined-over-160m-by-indian-watchdog-over-market-dominance-61832 accessed 08 April 2025.

[4] Tom Wheeler, ‘Big Tech Won—Now What?’ (Brookings, 16 October 2023) https://www.brookings.edu/articles/big-tech-won-now-what/ accessed 10 April 2025.

[5] Alessia D’Amico, Anna Gerbrandy, ‘Breaking up the Tech Giants for Real?’ (Kluwer Competition Law Blog, 29 January 2025) https://legalblogs.wolterskluwer.com/competition-blog/breaking-up-the-tech-giants-for-real accessed 10 April 2025.

[6] ibid.

[7] Shubha Ojha, ‘Tackling Big Tech’s Data Advantage: Is the Indian Regulatory Framework Geared Up?’ (2021) 6(2) Indian Constitutional Law Review 55 http://iclr.in/wp-content/uploads/2024/03/ICLR-Volume-62-Article-5-pp-55-73.pdf accessed 08 April 2025.

[8] Kate Gibson, ‘5 Ways to Leverage Network Effects for Business Growth’ (Harvard Business School Online, 16 July 2024) https://online.hbs.edu/blog/post/network-effects-business accessed 10 April 2025.

[9] ibid.

[10] ibid.

[11] Ankush Tiwari, ‘Big Tech Algorithms: The Discreet Power of Big Tech in Politics’ (CNBC TV18, 10 June 2024) https://www.cnbctv18.com/technology/big-tech-algorithms-the-discreet-power-of-big-tech-in-politics-2024-india-election-19425665.htm accessed 08 April 2025.

[12] Jay Caspian Kang, ‘The Big Tech Takeover of American Politics’ (The New Yorker, 12 February 2024) https://www.newyorker.com/news/fault-lines/the-big-tech-takeover-of-american-politics accessed 08 April 2025.

[13] ‘Competition Law and Big Tech: Challenges in the Indian Market’ (LawVS, 19 February 2025) https://lawvs.com/articles/competition-law-and-big-tech-challenges-in-the-indian-market accessed 08 April 2025.

[14] James Broughel, 'Report: Regulations disproportionately impose costs on small businesses' (Competitive Enterprise Institute, 6 May 2024) https://cei.org/news_releases/report-regulations-disproportionately-impose-costs-on-small-businesses accessed 10 April 2025.

[15] Vijay Govindarajan, Baruch Lev, Anup Srivastava, Luminita Enache, ‘The Gap Between Large and Small Companies Is Growing. Why?’ (Harvard Business Review, 16 August 2019) https://hbr.org/2019/08/the-gap-between-large-and-small-companies-is-growing-why accessed 10 April 2025.

[16] Ibid. 

[17] Kean Birch, 'There Are No Markets Anymore: From Neoliberalism to Big Tech' (Transnational Institute, 3 February 2023) https://www.tni.org/en/article/there-are-no-markets-anymore accessed 08 April 2025.

[18] Competition Commission of India, In Re: Google LLC (Android Case) Case No 39 of 2018 (20 October 2022)

[19] Vajiram Editor, ‘Google vs CCI Case: Impact on India’s Android Ecosystem & Digital Market’ (Vajiram & Ravi, 12 August 2025) https://vajiramandravi.com/current-affairs/google-vs-cci-case-impact-on-indias-android-ecosystem-digital-market accessed 20 August 2025.

[20] European Commission, ‘Antitrust: Commission opens investigation into possible anticompetitive practices by Microsoft regarding Teams’ (European Commission, 27 July 2023) https://ec.europa.eu/commission/presscorner/detail/en/ip_23_3887 accessed 08 April 2025

[21] AFP, ‘EU to vet Microsoft pledges to avoid Teams antitrust fine’ (ET Legal World, 17 May 2025) https://legal.economictimes.indiatimes.com/news/international/eu-to-vet-microsoft-pledges-to-avoid-teams-antitrust-fine/121240546 accessed 20 August 2025.

[22] Ibid.

[23] ‘How Google plans to ‘change’ Play Store to avoid future fines in Europe’ (Times of India, 19 August 2025) https://timesofindia.indiatimes.com/technology/tech-news/how-google-plans-to-change-play-store-to-avoid-future-fines-in-europe/articleshow/123391118.cms accessed 20 August 2025.

[24] US House Judiciary Committee, Investigation of Competition in Digital Markets: Majority Staff Report and Recommendations (Subcommittee on Antitrust, Commercial and Administrative Law, 2020) https://judiciary.house.gov/uploadedfiles/competition_in_digital_markets.pdf accessed 08 April 2025.

[25] Tobi Opeyemi Amure, ‘The Cloud Computing Risk for the Economy That Many Don’t See Coming’ (Investopedia, 30 July 2025) https://www.investopedia.com/cloud-computing-risk-for-the-economy-11777456 accessed 20 August 2025.

[26] Ibid. 

[27] Draft Digital Competition Bill, 2024, (India) (un-enacted draft legislation published for consultation, March 2024) https://www.medianama.com/wp-content/uploads/2024/03/DRAFT-DIGITAL-COMPETITION-BILL-2024.pdf accessed 20 August 2025.

[28] Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector (Digital Markets Act) https://eur-lex.europa.eu/eli/reg/2022/1925/oj accessed 20 August 2025.

[29] Soumyarendra Barik, ‘Explained: What Is the Draft Digital Competition Bill, and Why Is Big Tech Opposed to It?’ (Indian Express, 16 May 2024) https://indianexpress.com/article/explained/explained-law/draft-digital-competition-bill-big-tech-opposes-9330370/ accessed 09 April 2025.

[30] Archana Rao, ‘India’s Digital Competition Bill Advances with Industry Insights’ (India Briefing, 17 March 2025) https://www.india-briefing.com/news/indias-digital-competition-bill-advances-with-industry-insights-36536.html/ accessed 09 April 2025.

[31] William Rinehart, ‘Are ‘Killer Acquisitions’ by Tech Giants a Real Threat to Competition?’ (Research in Focus, Center for Growth and Opportunity, 3 October 2023) https://www.thecgo.org/research/are-killer-acquisitions-a-threat accessed 20 August 2025.

[32] ‘Competition Law and Big Tech: How India’s Antitrust Regulations Are Evolving’ (LinkedIn, February 14, 2025) https://www.linkedin.com/pulse/competition-law-big-tech-how-indias-antitrust-regulations-xajjc/ accessed 09 April 2025.

[33] ibid.

[34] Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector (Digital Markets Act) https://eur-lex.europa.eu/eli/reg/2022/1925/oj accessed 20 August 2025.

[35] Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 (Digital Markets Act) [2022] OJ L265/1.

[36] European Commission, ‘Commission designates six gatekeepers under the Digital Markets Act’ (Press Release, 6 September 2023) https://ec.europa.eu/commission/presscorner/detail/en/ip_23_4328 accessed 10 April 2025.

[37] Federal Trade Commission, ‘FTC Sues to Block Meta’s Acquisition of Virtual Reality Fitness App Developer Within’ (13 July 2022) https://www.ftc.gov/news-events/news/press-releases/2022/07/ftc-sues-block-metas-acquisition-virtual-reality-fitness-app-developer-within accessed 10 April 2025.

[38] Naomi Nix, Julian Mark, ‘FTC confronts ex-Meta exec Sheryl Sandberg with her past emails about rivals’ (Washington Post, 16 April 2025) https://www.washingtonpost.com/technology/2025/04/16/meta-sheryl-sandberg-ftc accessed 20 August 2025.

[39] United States Department of Justice, ‘Justice Department Sues Google for Monopolizing Digital Advertising Technologies’ (24 January 2023) https://www.justice.gov/opa/pr/justice-department-sues-google-monopolizing-digital-advertising-technologies accessed 10 April 2025.

[40] Ronan Shields and Marty Swant, ‘Judge rules against Google in ad tech antitrust case’ (Digiday, 17 April 2025) https://digiday.com/media/judge-rules-against-google-in-ad-tech-antitrust-case accessed 20 August 2025.

[41] Cat Zakrzewski, ‘Congress Fails to Pass Big Tech Antitrust Bills Despite Bipartisan Support’ The Washington Post (7 December 2022) https://www.washingtonpost.com/technology/2022/12/07/antitrust-bills-congress-big-tech/ accessed 10 April 2025.

[42] Bar & Bench, ‘NCLAT stays part of CCI order against Google; directs deposit of 10% penalty’ (4 January 2023) https://www.barandbench.com/news/litigation/nclat-stays-cci-order-against-google accessed 10 April 2025.

[43] Pradeep S Mehta, ‘To regulate Big Tech, we need a Big Regulator’ The Hindu BusinessLine (10 March 2024) https://www.thehindubusinessline.com/opinion/to-regulate-big-tech-we-need-a-big-regulator/article67821532.ece accessed 10 April 2025.

[44] Raghav Tankha, ‘India's Digital Dilemma: Foreign Investment vs. Platform Regulation’ ORF Issue Brief (Observer Research Foundation, October 2023) https://www.orfonline.org/research/indias-digital-dilemma accessed 10 April 2025.

[45] Jennifer Rankin, ‘EU launches probes into Apple, Google and Meta under new digital law’ The Guardian (25 March 2024) https://www.theguardian.com/technology/2024/mar/25/eu-launches-probes-apple-google-meta-digital-markets-act accessed 10 April 2025.

[46] United States Department of Justice, ‘Justice Department Sues Google for Monopolizing Digital Advertising Technologies’ (24 January 2023) https://www.justice.gov/opa/pr/justice-department-sues-google-monopolizing-digital-advertising-technologies accessed 10 April 2025.

[47] Cat Zakrzewski, ‘Congress Fails to Pass Big Tech Antitrust Bills Despite Bipartisan Support’ The Washington Post (7 December 2022) https://www.washingtonpost.com/technology/2022/12/07/antitrust-bills-congress-big-tech/ accessed 10 April 2025.