South Korea Accuses Google of Abusing Its Dominant Position in the Android App Market

The Korea Fair Trade Commission (KFTC) announced that Google abused its dominant position in the Android app market to restrict competition. The Commission's Market Monitoring Bureau completed an expert report and estimated the affected revenue at 14.16 trillion won, equivalent to about 9.1 billion dollars. If the Commission finds a violation following its review, the fine could reach up to 6% of that amount, meaning up to 849.6 billion won in theory. Google has eight weeks to submit written objections and review the case materials, after which the KFTC plans to convene a plenary session and issue a final ruling.


The Substance of the Claims


From July 2019 to March 2026, Google ran the Games/Google Velocity Program, known internally as Project Hug. Game developers received financial support covering Google cloud services, advertising, and YouTube, on condition that their games launched on Google Play under terms no worse than on competing platforms, including launch timing and placement quality. The agreements were structured so that the level of support grew along with the developer's revenue through Google Play, which strengthened the incentive to prioritize that platform.


According to the KFTC's assessment, this arrangement reduced developers' incentive to distribute games through competing stores, particularly the South Korean OneStore, limited the ability of competitors to grow, and effectively turned program participants into de facto exclusive partners of Google. The program covered contracts with 22 of the largest game companies by revenue, including five South Korean firms (NC, Nexon, Netmarble, Pearl Abyss, Com2uS) and 17 foreign companies, among them Activision Blizzard King and Riot Games. Google's share of the Korean Android app market exceeds 80%.


The KFTC classified Google's conduct under Article 5(1) of the Fair Trade Act on two counts at once: obstruction of competitors' business activities and coercion into effectively exclusive deals.


Background


The case was initiated after complaints filed in November 2024 by the Citizens' Coalition for Economic Justice and the Korea Game Consumers Association. The KFTC reviewed materials from foreign court proceedings, conducted on-site inspections, and interviewed witnesses, after which it sent the expert report to three respondents: Google LLC (USA), Google Asia Pacific Pte Ltd (Singapore), and Google Korea Ltd. A KFTC representative separately emphasized that the case concerns Google's abuse of its position specifically, not collusion among game companies: given Google's dominant position, it was practically difficult for developers to refuse the support offered.


Not the First OneStore Related Case


In April 2023, the KFTC had already fined Google 42.1 billion won for a similar scheme: at the time, the company offered featured placement on the Google Play home screen and support for entering foreign markets in exchange for developers not listing their games on OneStore. Since the KFTC had already fined Google in 2023 for a similar scheme in spirit, the Commission is treating the prior violation as a factor that could increase the final fine.


Google's Position


Google called the accusation unfounded. In a statement to the press, a company representative said Google had cooperated in good faith with the Commission throughout the investigation and would continue to demonstrate that no violation of the law occurred. An official response on the merits of the case is expected later, within the eight-week period for submitting objections.


International Context


The mechanics of Project Hug have already been the subject of litigation in the United States, in the Epic Games v. Google case. According to materials filed with the US Supreme Court, under this program Google paid Activision Blizzard King 360 million dollars in cash and other benefits in exchange for the company ongoing exclusive or early launches of its games on competing app stores. This shows that the KFTC's claims are not an isolated national episode but part of a picture that foreign courts have already established regarding how the program was structured.


What This Means for Business


Formally, Google did not prohibit developers from working with competing app stores, but the terms of Project Hug made doing so economically unviable, and it is this model that has drawn the regulator's attention. For international publishers and developers participating in similar support programs run by major platforms, this means they need to assess the structure of such agreements in advance for signs of de facto exclusivity, even when the contract language contains no direct prohibition on working with competitors.


In addition, the overlap in factual circumstances between the KFTC proceedings and the Epic Games v. Google case shows that materials gathered in one jurisdiction are increasingly being used by regulators and plaintiffs in another as ready-made evidence. This speeds up subsequent cases and lowers the cost of independent investigation, meaning the outcome of the Korean case could affect the platform's operating terms beyond South Korea as well.


REVERA Recommendations


Analyze the terms of support programs offered by major platforms before signing them, paying attention not only to direct restrictions but also to bonus accrual structures that can create de facto exclusivity.


Record and retain documentation of negotiations and platform terms in case of future regulatory review or disputes.


Keep in mind that participation in such a program does not by itself protect a developer from risk if the platform is later found to have violated antitrust law.


Monitor parallel proceedings against Google in different jurisdictions, since final decisions may affect the platform's operating terms globally.

 

The REVERA law group Arbitration & IT Disputes team is ready to help companies assess the terms of existing or planned cooperation programs with major platforms, conduct an audit for antitrust related risks, and prepare a position for engaging with regulators or defending interests in a dispute with a platform.
 

 

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