The content that follows was originally sent as a letter to the South African news media industry. Daily Maverick received the letter and published it below with permission from Google.

Although we do not necessarily agree with the submissions that were made in the recent public hearings, we recognise that the issues being raised are important. 

We remain committed to playing our part in supporting South African publishers to successfully transition their businesses into the online environment. 

We also wanted to address specifically the industry’s calls for increased transparency. This may have a number of components, including that publishers want greater visibility of how frequently we link to their content and the value that is generated when our products display news results. 

Although we are under no obligation, we are willing to engage with you about precisely what information will be helpful for you, but subject to a few cautions. 

First, it will not be valuable to create and share data for use in populating any flawed methodology for determining the value of news to Google. For instance, we know that publishers are interested in applying the methodology developed by FehrAdvice on behalf of the Swiss Media Publishers’ Association. 

This methodology is understandably popular with publishers because it asserts that about 40% of Google’s search revenue is attributable to news results and that 40% of such revenue ought to be paid out to news publishers under European copyright law. 

But the methodology itself is, unfortunately, deeply flawed in ways that make its results unreliable, and drastically inflate the true value of news to Google. Some of the flaws in the FehrAdvice study are explained in a recent analysis by Compass Lexecon, which we have attached as Annex 1, and our response to the commission’s FSOI, which we have attached as Annex 2. 

Second, it is important to recognise that we have different perspectives on the position of news in the online environment. We heard statements from participants in the public hearings that “news is the cornerstone of the internet”. 

This contrasts with the estimates cited by Oxford University’s Reuters Institute, that all news providers “are estimated to provide for about 3% of the time that people spend online”. 

The latter position aligns broadly with the user behaviour we see on Google Search in South Africa, where only a small fraction of searches seek news information. This discrepancy in perspectives of the role of news in the internet ecosystem for users, advertisers and platforms can create a tendency for publishers to either mistrust the data that has been shared, or to continually seek different information in the hope that it will align with their preferred viewpoint. 

For example, we have previously shared a number of 2022 data points with you that we believe provide a reliable indication of the approximate value exchange between our businesses. The 2023 figures below provide a more up-to-date picture: 

• In 2023, news queries comprised 0.95% of searches in South Africa. We earned just more than $900,000 (about R18-million) from advertising from clicks on ads displayed in response to these queries. We consider news queries for this purpose to be those queries that generate results with the Top Stories feature appearing in the top position on the results page. These are the circumstances where our systems detect that the primary intent of the query is to seek news;
• Google sent about 545 million clicks to South African publishers in 2023 from Google News, Search and Discover. According to the methodology used in a 2019 analysis by Deloitte, this traffic is understood to have created more than R350-million in estimated value for South African news publishers. Should it be helpful for you to further orientate the position of news results in our products, we would be happy to discuss what other data points would be relevant, representative and useful to you for us to create.

For example: 

• We heard representatives of Columbia University suggesting that, in their view, news-seeking queries could be identified as those where more than half of the results on the first page are news results. We would be willing to consider this methodology and share with you data on the share of news-seeking queries according to this definition;
• It may be useful to you to also look at the percentage of impressions on Google Search that were news results during a relevant, recent period;
• Information about how often ads are displayed, on Search results pages in response to news queries. Calculated by using the lower end of the range estimated by Deloitte, and applying the average exchange rate of the euro and South African rand for 2019 (R16.177). See, for example, this paper which mentions that news makes up just 3% of all internet time – even during an election period;
• The outcome of the calculations above would also depend on the list of domains included in the analyses – we would be happy to engage with you on this aspect, too;
• We also understand from the public hearings that publishers are interested in the Discover feature displayed on the landing page when using the Google Search app or the Chrome browser, as this feature creates valuable referral traffic. We would be willing to collate relevant impression and clicks data to help clarify the position of Discover relative to other products on which news publisher domains are linked, such as Google Search and Google News.

There is also substantial additional data relating to each publisher’s position and performance available through our various tools, as well on some publicly available third party tools such as Similarweb. 

As one example, for more granular, publisher-specific data, we recommend using Search Console, a tool that gives webmasters the opportunity to access data about their website’s performance in Google Search, Discover and Google News. Using Search Console, website operators can see (without the list being exhaustive) the number of clicks on a Google Search result which redirected the user to the press publisher or news agency’s website; the number of impressions on Search (i.e. the number of links to a press publisher or news agency’s website which are displayed in the search results in response to a user query); the click-through rate (CTR) (number of clicks divided by number of impressions) on the publisher’s website; the top queries which generated search result impressions of the press publisher or news agency’s website; and the average position of the press publisher or news agency on Search. 

Publishers can view that data for their site as a whole, for Discover, Google Search and Google News separately, and can sort further by device type, date ranges, and even specific search queries or pages on their sites. 

These data are subject to aggregation thresholds to protect the privacy of searching users. We would be happy to offer, at your convenience, either virtually or in person, any workshop or discussions that may help publishers to optimise their use of the analytics tools we already make available, as these provide substantial transparency. 

We also invite you to consult the training resources we make available publicly through our various portals such as The Search Console Training video series. 

Our continued openness to engage on solutions 

We want to be clear: the fact that news has limited commercial value to our business does not detract from our willingness to support the South African news industry. 

We invest in the news industry because we recognise the importance of news to democracy, but also because our business does better in open societies, and open societies depend on vibrant news ecosystems. 

But this is not unique to Google, and our role in any solution needs to be grounded in the commercial reality of the value of news to our business. 

We continue to believe that the product partnership and funding measures we discussed last year with the PSS and the AIP, as representative bodies for a large part of the industry, will make a meaningful contribution. Our proposed product partnership, Google News Showcase, is currently active in 25 countries. 

Read more in Daily Maverick: Battle for the future of media — Daily Maverick’s submission to the Competition Commission

Through Showcase, Google pays participating publishers to curate quality journalistic content for an improved online news experience that benefits readers and publishers.

Showcase helps publishers monetise their expertise and share their editorial voice through an enhanced storytelling experience and has already proved successful for many publishers globally. 

We are disappointed that some publishers have elected not to participate in Google News Showcase, as we need sufficient market coverage before we can roll out Showcase in South Africa for those publishers that do wish to participate. 

We are also excited about our ongoing work on the South African digital news transformation fund with the Association of Independent Publishers, which we believe will bring substantial benefits to local news publishers whose publications do not yet meet the eligibility criteria for Showcase, and for the publications of established publishers that similarly may not yet qualify for participation in Showcase. 

Google remains committed to engaging with the South African news industry on providing the appropriate level of support to help publishers thrive in the online environment. DM