ERDEM-NEWSLETTER-2018-metin

115 COMPETITION LAW inclusion of an explicit article into the Mobile Implementation Dis- tribution Contracts, stating that the pre-installation of rival apps and implementations, along with Google apps, are not restricted. According to the decision, Google Economic Unity shall also modify its contracts with device manufacturers in line with the Board’s decision. Conclusion The press release of the Board decision indicates that the main illegal action determined in the Turkish case is the illegal tying of Google Economic Entity’s search apps. The Google Economic En- tity’s actions have been found to be illegal, since it ties its Google search apps to its services in the licensable smart mobile operating systems market. Consequently, Google’s fined implementations are similar in the Commission and Board decisions; however, the Turkish press release is not sufficient to assist us in comparing the relevant decisions; for example, the press release does not address whether Google Economic Entity has made illegal payments to be conditional on exclusive pre- installation of Google Search, as it is so determined in the Commission decision. In any event, both of the Authorities determinations of illegal actions overlap, and we will be able to finalize the full comparison after the reasoned decisions are rendered.