On 20 March 2019, the European Commission (the “Commission”) handed down a EUR 1.49 billion fine against the U.S. tech giant Google, under Article 102 of the Treaty on the Functioning of the European Union (“TFEU”), for abusive practices relating to its online search advertising intermediation activities, known as “AdSense for Search,” with respect to which it was found to be dominant. Google discontinued the relevant practices in 2016, shortly after it had received the Commission’s Statement of Objections in this case, so this decision does not involve any complex forward-looking decisions on how Google should comply with the Commission’s findings. This decision is part of wider antitrust scrutiny of online advertising activities in Europe, including a recent challenge by the Commission of brand-bidding restrictions in online advertising in its fining decision against the fashion retailer Guess at the end of 2017.