July 1, 2026
The Secretariat of the Korea Fair Trade Commission (KFTC) has initiated deliberation procedures by submitting an Examiner’s Report to the Commission and officially dispatching it to the respondents on July 1. The report details the facts of the conduct, alleged illegality, and proposed sanctions regarding Google’s suspected violations of the Monopoly Regulation and Fair Trade Act.
The respondents in this case are Google LLC (USA), Google Asia Pacific Pte. Ltd. (Singapore), and Google Korea LLC (South Korea).
Note: The Examiner’s Report contains the examiner's findings on the illegality and proposed sanctions identified during the investigation, which do not bind the Commission's final decision. The final judgment on this case will be rendered following an independent deliberation by the Commission.
Background and Allegations
To prevent major domestic and international game companies from attempting to leave the Google app market—a movement triggered by high in-app purchase commissions—the respondents entered into GVP (Games/Google Velocity Program, a.k.a. "Project Hug") contracts with these game companies.
Under the GVP contracts, on the condition that game companies set their release dates, quality, and other factors more favorably or at least equally compared to other app markets (Most-Favored-Nation or MFN treatment), the respondents provided financial support to offset the costs of using Google platform services, such as Google Cloud, Ads, and YouTube. In particular, the contracts were designed with a progressive structure where Google's financial support increased proportionally as the game company's revenue within the Google app market increased.
The KFTC Examiner determined that the respondents, through the MFN conditions and progressive support structure of the GVP, significantly undermined the game companies' incentives to launch their games on competing app markets. This conduct hindered the business activities of competing app markets, such as ONE store, and effectively blocked the contracted game companies from entering the app market sector themselves. Furthermore, the examiner judged that the respondents essentially forced exclusive dealing through these GVP contracts.
The examiner calculated that the relevant revenue affected by this alleged abuse of market dominance in the Android app market amounts to 9.21777 billion USD (approximately 14.16 trillion KRW).
<Examiner's Proposed Sanctions>
The examiner judged the respondents' conduct to be a highly grave violation that falls under interference with business activities (Article 5, Paragraph 1, Subparagraph 3 of the Fair Trade Act) and dealing on exclusive terms (Article 5, Paragraph 1, Subparagraph 5) among the types of abuse of market dominance. Consequently, the examiner has proposed issuing a corrective order and imposing a penalty surcharge.
Following its deliberation, the Commission may impose a penalty surcharge of up to 6% of the relevant revenue affected by the abuse of market dominance, in accordance with relevant laws.
The respondents are fully guaranteed their right to defense and may submit written opinions and request the inspection or copying of evidentiary documents within 8 weeks from the date of receiving the Examiner’s Report.
Recognizing this case as a critical matter for the substantial restoration of competition in the app market, the KFTC plans to swiftly convene a Commission hearing and render a final decision as soon as the procedures guaranteeing the respondents' right to defense are concluded.