CCI introduces Leniency “Plus” regime in India- Will it suffice?
Will India prove to be the nemesis for the Digital Cab Aggregator Giant Uber?
Readers may recall this question , which I raised when reporting in my earlier blog published on 25 November 2019 on Taxi cab aggregator, Uber , lost is first round of litigation in Supreme Court second appeal against NCLAT order directing investigation.
The answer, at least for now, appears to be NO!
Due to the vagueness in India’s legal framework[1] , CCI vide its recent order dated 14.7.21 has now closed the case against Uber as even after the investigation by the Director General (DG), no case for abuse of dominant position has been held against Uber under Section 4 of the Competition Act,2002 (the Act), primarily, because , as per the statutory framework of Section 4 of the Act, Uber can not be held as “dominant “ due the presence of a strong competitor , OLA , another major taxi cab aggregator in India.
BACKGROUND- (For background facts , readers may refer to my earlier blog of 25 November 2019 . ) . Those who still want a recap here it goes –
Meru Travels Solutions Pvt. Ltd (“Meru”) – a radio taxi service provider and a competitor to Uber- filed an information before CCI on 09.10.2015 alleging that Uber pays the drivers/owners attached to its network unreasonably high incentives which are over and above and in addition to the trip fair received from the passengers. As per Meru, the primary reason for Uber’s growth is the large global funding and anti-competitive business model which has led to Meru’s market share to drop to 11% in September 2015 from 18% in December 2013 by number of trips and also a loss of INR 107 Crores. On the other hand, Uber’s market share had increased to about 50% by the number of trips done on its radio service network. In order to show dominance of Uber, Meru relied on a market research report produced by New Age Tech Sci Research Pvt. Ltd (“Tech Sci”) which analysed radio taxi service in Delhi NCR region as on 30.09.2015 which revealed that Uber had 50.1% of the market share in Delhi NCR. Meru alleged that Uber was abusing its dominant position by resorting to predatory pricing and following unfair conditions by virtue of its dominance in the relevant market. The information contained allegation as to the kind of incentives being offered by Uber to its drivers/partners to build a network effect, the gains that drivers make out of their engagement with Uber, the losses that Uber makes out of every trip (INR 204 per trip) and the kind of discounts that Uber offers to its customers. The Commission did not find a prima facie case to order investigation based on the following grounds briefly:
- The Tech Sci report relied upon by Meru was contrary to another report- 6Wresearch which was presented before the Commission in an earlier case Fast Track Call Cabs Pvt. Ltd v ANI Technologies which raised doubts about the credibility of the Tech Sci report.
- CCI took Delhi as the relevant geographic market and not Delhi NCR region as requested by Meru on the ground that the regulatory framework in relation to taxi services and use of CNG in public transport were different in both regions.
- As per the CCI, there was a vibrant and dynamic radio taxi service in Delhi and Uber was not considered to be dominant in the relevant market.
Accordingly, the CCI vide its order dated 10.2.2016 closed the case under Section 26(2) of the Act. Meru filed appeal before COMPAT.
The appeal filed by Meru against the CCI order dated 102.2016 , the erstwhile COMPAT vide its order dated 7.12.2016 allowed the appeal noticing that though it cannot be said definitively that there is an abuse inherent in the business practices adopted by the respondents but the size of discounts and incentives show that there are either phenomenal efficiency improvements which are replacing existing business models with the new business models or there could be an anti-competitive stance to it. It held that facts on the record are enough to trigger an investigation by the DG and directed the DG to conduct to investigate the matter.
Uber challenged the above order of COMPAT by second appeal before the Supreme Court and the Hon’ble Supreme Court[2] vide judgment dated 03.09.2019 taking a strong exception and cognizance of the fact mentioned in the original information that Uber was losing INR 204 per trip in respect of the every trip made by the cars of the fleet owners, dismissed the appeal, by observing that the above factor is sufficient by itself to show that there existed a prima facie case under section 26(1) as to infringement of section 4 of the Act relating to abuse of dominant position by Uber. So, the DG commenced investigation.
DG INVESTIGATION
DG on analysis of the market found that in the asset model radio taxis are owned by the radio taxi service providers and in the aggregator’s model, the operator does not own the radio cabs but only acts as an aggregator (platform) that connects the drivers with the prospective consumers. Uber and its biggest competitor Ola work under the aggregator model. Mega and Meru are a mix of both. The DG did not stand in tandem with the contention of Uber that auto- rickshaws, bike-taxis, buses, Metro and private car-pooling in Delhi-NCR, form part of the same relevant market. The DG delineated the relevant product market as ‘the market for radio taxi services. The relevant geographic market was held as “Delhi NCR’. Hence, DG determined the relevant market as the market for Radio Taxi services in Delhi NCR’.
To investigate the claim of Uber being dominant the DG collected information based on trip size. The current market share of Uber was found to be very low as compared to Meru and Ola. But in the year 2015 the market share of Uber and Ola increased manifold. The DG noted that the market share (in % terms) of Meru, Mega and Easy Cab declined faster than their absolute trip size which showed that these players were not able to catch-up with the growth in the market.
In the period from January 2014 to December 2014 Ola was able to raise its trip size and market share from [5-10] % to [30-35] %. From January 2015 to August 2016, Ola was the market leader having market share in the range of 45 % to 70 % in Delhi NCR market, and was followed by Uber whose market share was in the range of 30% and 40% between April 2015 and July 2016. The absolute trips size of these two competitors also increased manifold from January 2015 till August 2016. During the months of September 2016 to April 2018, Ola and Uber displaced each other as market leader on repeated occasions. The DG observed that in such a highly fluctuating market hence it cannot be established that Uber was in a position of dominance.
Uber vs. Ola -Uber being a global player it is not possible that all its funds are allocated to the Indian market. The total funds received by Uber from 2013-19 was ₹ 8126.17 crore. While the funding in Ola by 2015-16 was to the tune of ₹ 8,079.25 crore. The DG found out that Ola has an edge in financial resources over Uber. Thus , Uber does not have an exclusive access to funding/investment. Ola has its presence in 142 cities of India while Uber is active only in 42 cities. From January-2015 to April-2018 Ola overtook all its competitors in the market. In May 2018 Uber overtook Ola but still Ola poses a significant threat to Uber. The DG notes that the viability of radio taxi business depends upon the quick availability of vehicle from customers’ perspective and minimum idle running from the drivers’ perspective. Thus, the business of radio taxi service can only be profitable when the service/platform provider has a sizeable number of customers and sizeable number of vehicles/drivers at various locations within the city to meet the demand. In the present case, Uber’s aggressive pricing strategy has not worked as a deterrent or a barrier for network expansion for Ola. DG concluded that Uber is not in a dominant position in the relevant market. Since Uber was not found in a dominant position the question of abuse did not arise. The DG noted that both Uber and Ola, the two major competitors in the Delhi- NCR radio taxi market, adopted the “below-cost pricing strategy” during the period from January-2014 till September- 2017, and from April-2014 to March-2018, respectively. But since neither can be held as dominant provisions Section 4 of the Act were not attracted. .
Investigation of possible market foreclosure due to exclusive agreements under Section 3(4) of the Act– Before the DG, Meru claimed, in the alternative, that Uber had entered into exclusive contract s with its driver partners which are in violation of Sections 3(1), 3(2) and 3(4) of the Act as those contracts restrain the driver partners from getting attached on the network of other competing radio taxi operators. The effect of these agreements was the marginalization of all other competitors except Ola.
Uber submitted that it does not restrict its driver-partners from being simultaneously active on competing platforms and in fact its driver-partners are typically registered on more than one platform and routinely multi-home. According to Uber’s estimates at any given point, more than 50% of its driver-partners are also registered with other aggregators.
Meru further claimed that the Uber’s Ratings mechanism for its driver- partners according to which the drivers must maintain a minimum average rating and a failure to do so would entitle Uber to deactivate the driver from login into the Uber App. Rating system is a mechanism to keep the drivers locked onto the Uber network which restricted competition in the market.
Uber counterclaimed that this provision was to ensure that users (riders) have access to high quality service, through Uber’s app. The Informant further alleged that the incentive scheme of Uber is designed in such a manner that driver would get incentives on an accelerated basis, which means that the driver would receive ratings based on the number of trips accepted in a day and thus they remain logged in network of Uber. Uber replied that that the incentives are not based on any long-term agreement with the driver-partners but are provided on an ad-hoc basis, assessing the demand and supply in the market at the time.
The DG, looking at all claims raised by Meru, however, concluded that the performance linked incentives offered by Uber and Ola, which were intended to build the network of drivers and attain growth, cannot be stated to have foreclosed competition in the market.
SUBMISSIONS OF THE PARTIES BEFORE CCI
MERU-
Meru challenged the findings in the DG investigation and analysis mainly on the alleged failure of the DG to understand the market behavior of Uber qua its drivers, cash-burn by Uber to sustain otherwise uneconomic model to create indirect exclusivity and locking in the drivers with loans to buy additional cars etc. to prevent multi-homing by them. Meru alleged that DG ignored capital-dumping, high barriers to entry and adverse effects on competition and laid too much emphasis on ‘absence of dominance’ based on wrong notions/understanding to conclude no contravention against Uber.
Meru alleged that DG failed to investigate one of the principal cohorts in the matter i.e., drivers as the DG did not interview even a single driver during investigation. Meru argued that the DG has failed to appreciate that the market has grown by 62.51 times in terms of monthly trip size, and 42.58 times in terms of number of fleet size, from 2014 to 2019 and that both, Ola and Uber have been able to corner the growth among themselves in such expanded market. Meru also refuted the defence of Uber that there is no exclusivity clause in the agreement being not tenable as there is no requirement of specific exclusivity clause in case exclusivity is ensured by Uber through the implementation and effect of various clauses in the agreement and most importantly through the effect of the incentives offered to the drivers. Meru added that the way such incentive schemes are devised would show that the drivers are not left free to multi-home once they log on to Uber’s network and hence in effect there is no fluidity in the market with the creation of exclusivity. Further, these incentive schemes were also devised in such a manner that maximum incentives are given during peak hours, to dissuade drivers from accessing other cab aggregators. Meru commented that real block can be demonstrated by how drivers / aggregators were induced into purchasing additional cars to ply on the Uber platform on account of high incentives. However, once the incentives were pulled back by Uber, the drivers beset with the high cost of ownership of the cars had nowhere else to go. Based on this, Meru deduced that the only option left with the drivers to recover their costs was to increase the number of trips on the platform to sustain themselves in the market.
Meru added that incentives given to drivers depends upon the number of rides completed by a driver, mileage clocked, or the revenue received in a particular time frame which essentially compels continuous usage of the Uber app. Therefore, drivers can earn maximum profit only when they use only one app for a maximum period of time. Meru has highlighted that Uber has a policy of rating its drivers on the basis of acceptance rate and the customer ratings. Where drivers are logged in to the application and they do not accept the leads sent by Uber, then after a particular number of non- acceptances, such driver would not be sent any more leads. The threat of deactivation by Uber of a driver based on the said rating mechanism keeps the driver under the control of Uber and also tied to its platform. Further, Meru mentioned that Uber also mandates its drivers to insert the logo of Uber on its car, thus adopt the branding of Uber. This also leads to de facto exclusivity. Drivers on acceptance rate falling below 80% receive warning signals and if the driver’s acceptance rate doesn’t improve, the warnings escalate to automatic logging off of the drivers. Moreover, a collective 10 minutes log off from the system, results in penalty.
To prove Uber dominance Meru relied on the following factors-
Market Power: Uber commands a high market share (more than 50% since 2015). Meru also mentioned that Uber has global presence in over 300 cities across the world. It has only withdrawn from few markets on instructions of its biggest investor Softbank, which incidentally is also the highest stake holder in Ola.
Foreclosure of competitors and creation of entry barriers: Meru submitted that Uber is doling out incentives based on their funding and the incentive scheme is devised in such a manner to ensure that the drivers complete maximum number of trips on their platform.
Lack of consumer benefit: Meru highlighted that with no efficiency development in the business model and in absence of any path breaking technological advantage on account of the model adopted by Uber, they are not aiming for any public good but for foreclosure of competition and making profits with a little delay thereafter.
As per Meru, the definition of dominance under Explanation (a) of Section 4 has two limbs to it, (i) operate independently of competitive forces in the relevant market, or (ii) affect its competitors or consumers or the relevant market in its favour. The entire focus of DG has only been on Ola. In the first limb the analysis of the DG, which is limited to only a single competitor (i.e. Ola in this case) and doesn’t take into consideration all/other competitors, is in stark contrast to the true import of the definition of ‘dominance’ under the Act. Further, Meru submitted that the second limb of the explanation also clearly requires an assessment of the ability of the dominant player to affect its ‘competitors’ and not just one competitor. In this regard, the DG has focused merely on Ola and has therefore reached an erroneous conclusion. Meru submitted that the conclusion of DG regarding dominance is incorrect since (i) Uber has successfully affected competitors in its favour and (ii) Ola has also been affected because it had to adopt the loss-making model of Uber and burn more capital to remain relevant in the market. The consumers are also at a loss as at one point there given so many discounts and incentives but now that they are withdrawn customer has been left with no recourse. According to Meru, Uber has maintained its position of having more than 50% market share since October 2016, except for minor aberrations and as of March 2019, continues to have a staggering market share of 70%. With the highest number of taxis aggregated, large customer base and highest number of trips on its platform, Uber enjoys the benefit of network effects which has given it a significant edge in the market over its other competitors. Meru also explained about the massive capital requirement to enter in the market and Uber’s ability to successfully choke entry into the market with the argument that DG has ignored that venture funding would be difficult for any player other than Ola and Uber including for new entrants since investors must invest more and be ready to suffer losses. Meru also highlighted that existing investors in Ola and Uber have non-compete obligations which would preclude the existing investors from investing in other radio taxi operators.
According to Meru, both Ola and Uber deserved to be given the dominant position. According to Section 4 provides that ‘No enterprise or group shall abuse its dominant position’. As per Meru, the section does not stipulate that in a given relevant market, there can only be ‘one dominant enterprise’. The radio taxi business has been reduced to a duopoly.
Meru also submitted that agreements leading to foreclosure for competitors based on creation/strengthening of barriers to entry/expansion including below cost pricing considerations are considered inherently anti- competitive if done by players in position of substantial market power and in this case, below cost pricing has been done by way of vertical agreement, which can be analyzed under Section 3(4) of the Act.
UBER
Uber at the outset denied indulging in violating Section 3(4) of the Act as there is no exclusivity agreement with taxi owners, and Uber’s incentives were not exclusive or loyalty inducing. Its incentives were aimed at achieving a minimum viable scale through building of network, which is essential for enabling an economic activity and is a legitimate business strategy, particularly in nascent and evolving markets, like the relevant market. Uber highlighted that Ola gained market share when the margin per trip of Uber was positive and Ola was still making negative margins per trip, indicating the fluctuations of market share among both the entities. Uber added that the huge fleet size of Ola is also a competitive constraint on Uber. Uber submitted that there is ease of switching between the applications, low or no switching cost, absence of regulatory barriers while multi-homing and equitable access to funding, indicating that Uber India is not dominant in the relevant market. Uber argued that Ola received more funding when compared to Uber in the relevant period.
Uber averred that it did not have the ability to operate independently of its competitors and customers in the relevant market and Meru has argued in a vacuum disregarding the existence of Ola – which is not merely a competitor, but a better funded, well resourced, fierce competitor which imposes a significant competitive constraint on Uber.
Uber submitted that the purpose of the high investment at the time of entry was to evolve in the market and attract drivers and to attract the riders to leave the current existing transportation system and utilise the services of radio taxi. It also benefits other competitors as drivers and riders can multi home as the incentives provided by Uber helps to create a bigger pool of drivers and riders.
In relation to the common ownership and role of investors in Ola and Uber, Uber submits that after October 2017, their margins are positive, so they are less dependent on the external sources and, they have the ability to gain positive returns with the increase in pool size and market size, so dependency on the investors has reduced.
As regards the argument that no new entrant has entered the relevant market in past few years, Uber stated that this claim was rejected in Fast Track Call Cabs Pvt. Ltd. vs. ANI Technologies Pvt. Ltd[3] by the Commission while rejecting complaint of predatory pricing against Ola on the basis that there can be markets which may not be competitive even with large number of players and equally possibly there can be markets which can work perfectly well with fewer players, constraining the conduct of each other. You can read about this order in my earlier blog here.
Uber added that drivers and riders have the option to multi-home and the rating system is not restrictive as the drivers have an option to switch to Ola, if Ola provides better incentives. Uber also highlighted that the agreement allows the drivers to switch off the application whenever they are accessing the application of competitor and approximately 50% of its driver partners are also registered with other aggregators. On the nature of financial incentives, Uber submitted that such promotional incentives are provided in order to gain a toehold in the market and to achieve a minimum viable scale, like any other new entrant in a market to ensure that there was an efficient network of Driver-Partners and Riders on its platform.
Uber submitted that decline in the market share of Meru was because of its own inefficiency and there is no evidence that the operations of Uber were anti-competitive.
OBSERVATIONS AND FINDINGS OF THE COMMISSION
On merits, the Commission, observed that the main grievance of the Informant is with regard to the alleged below cost pricing adopted by Uber. The Informant has alleged that the said allegation can be investigated both under Section 3(4) as well as Section 4 of the Act. Reliance has been placed on the prima facie order passed in Delhi Vyapar Mahasangh case as well as interim order passed in the MMT case. CCI noted that there is no statutory inhibition/restriction to look at the same conduct under Section 3(4) as well as Section 4 of the Act, provided that the necessary legal elements of the proposed provision, which is alleged to have been contravened, are met.
The Commission does not agree with the proposition of Uber that other modes of transport fall in the same market as the radio taxis because the relevant market should ideally compose of only those candidate products, which the consumer perceives as substitute by the reason of their basic characteristics intended end-use, price etc. The Commission therefore agreed with the relevant market as determined by the DG as the ‘market for radio taxi services in Delhi- NCR’.
CCI noted that Meru has stated that in an earlier case [Case No. 06 and 74 of 2015], the case against Ola was closed for the want of its dominance stating that Uber exists in the market as a stronger player, and now the DG has not found Uber to be dominant because of Ola’s presence in the relevant market. Meru thus alleged that these observations are contradictory as one of the two has to be dominant.
The Commission, however, differentiated between the two cases of Ola and Ober by observing that though Meru has alleged that this finding was contradictory to the earlier orders, there was no such infirmity in the said finding of the DG. Firstly, the relevant geographic market in the present case is Delhi-NCR while that in the earlier case was Bengaluru; and secondly, and more importantly, competitive constraints, generally, are not unidirectional in nature. Though there can be markets in which practically a situation may arise where the competitive constraints faced by players inter-se are not reciprocal and are indeed asymmetric. However, no such asymmetry or a superior position of any of the Radio taxi Service provider exists in the relevant market.
In the above context, the also Commission noted that the pivotal role of network effects in two-sided markets. The Commission noted that network effects may enable a large platform/network to become dominant and insulate itself from potential competition as entrants may find it difficult to challenge a large incumbent. However, the Commission noted that there can be certain countervailing market forces that reduce the ability of even a very large platform to insulate itself from competition. And in the facts of that case, the Commission was of the view that despite Ola having the largest network, the network effects were not strong enough to deter entry and rapid expansion of another big competitor ‘Uber’ who was competing fiercely with Ola in the relevant market of ‘radio taxi services in Bengaluru’. The Commission further observed that the radio taxi apps are offered for free and can be easily downloaded on smartphones and can co-exist on the same handset, thus, multi-homing was found to be possible for both drivers and riders.
The dominance assessment of the Commission was, therefore, restricted to the ascertainment of whether Uber held such position of strength in the relevant market so as to merit assessment of its conduct under the provisions of Section 4 of the Act.
The Commission noted that for any player to be considered dominant, it should be able to sustain its market share for a reasonable period of time. Durability of high market share over a period is one indicator of dominance. As per the data collected by the DG during the investigation, in the rapidly growing radio taxi market of Delhi NCR, Meru had been the market leader, having share of 20%-30% in terms of fleet size till October 2014 and 50%-60% in terms of trip size. Ola replaced Meru and continued as market leader till August 2016, and thereafter was replaced by Uber. In the intervening period, the fleet size and trip size of these two players witnessed exponential growth. During the months of September 2016 to April 2018, Ola and Uber displaced each other as market leader on repeated occasions. However, Uber has been able to maintain its lead position and increase its gap in subsequent months where its market share was at least within a range of 50-60%. Thus, Uber did not seem to maintain its high market share over a longer period of time as there has been close competition between Ola and Uber in the radio taxi market of Delhi NCR. Thus, in a highly fluctuating market and Uber is not dominant.
While deciding on lack of individua dominance by Uber, as aforesaid, CCI also examined Meru’s argument that despite transient fluctuations in their market shares, Uber and Ola together held more than 95% of the relevant market during majority part of the period under investigation. Despite there being other fringe players, market is more like a duopoly and, as per Meru, harm to consumers in the long run from this duopoly market situation can also be demonstrated by factors such as presence of barriers to entry associated with likely foreclosure effects on the conduct. Further, relying on the findings of the Court of Appeal in Canadian Mastercard /VISA matter, Meru stated that the reduction in options for consumers is not good for competition, as such reduction in number of competitors on account of anti- competitive practices leads to disruption of competitive fabric in the market which must be remedied at the earliest.
In the above context, CCI however observed that while this argument may appear be appealing but it requires a deeper understanding of the market. CCI noted that “in digital economy markets, network effects play a pivotal role. Network effects depend heavily on number of players/participants joining the network on each side of two-sided or multi-sided markets e.g. in case of radio taxi/cab aggregators, the network effects depend upon the drivers and riders joining the network. More riders mean more demand scattered across a geographic region owing to higher density of riders, leading to more ride requests on a particular platform as compared to its competitor, which in turn lead to the requirement of more drivers to serve such riders. More drivers improve the service (in terms of pickup time and geographical coverage) for riders, thus attracting more riders which in turn attracts more drivers. Such increased number of rides through limited platforms also generate efficiencies through higher utilization rate and lesser idle time for cabs/taxies.
The CCI further noted that in accordance with its mandate of promoting competition, what is of significance is the strength of competitive constraints faced by players in a relevant market. While quoting from its order in Case No. Case No. 06 & 74 of 2015, CCI observed that ‘as long as there is competition in and for the market satisfying these outcomes, regulatory intervention is not warranted to either protect the existing players or to increase the number of players in the market. ‘. Towards that end, Competition and competition law is not about counting the number of firms in a particular relevant market to determine whether or not that market is competitive.’ Further, ‘every market is unique with a unique number of players that are determined organically by competitive forces. There can be no sacrosanct number of firms that ensures the presence or absence of competition. There can be markets which may not be competitive even with large number of players and equally possibly there can be markets which can work perfectly well with fewer players, constraining the conduct of each other. What is significant is that the existing firms are effective enough to constrain the behaviour of one another so as to dissuade independent abusive conduct by any of them.’
Hence, Uber was not found to be dominant. In the absence of dominance of Uber, examination of abuse or any analysis of pricing strategy by Uber is not warranted under the provisions of the Act, held the Commission
The CCI also proceeded to examine Meru’s allegation of “predatory pricing’ and relied upon its observations in its earlier decision dated 19.7.2017 in the case against Ola wherein it had again dismissed the allegation of predatory pricing to again dismiss the allegations. You may read about the said order in my earlier blog CCI rejects predatory pricing allegations against OLA yet again published on 28.7.2017 .
COMMENT: The CCI must be complimented for a well-reasoned order with sound economic analysis under the exiting legal framework. However as stated in the beginning of the blog, there is a lacuna in our law as it fails to capture “attempts to monopolize” which both Uber and Ola, in my view, can be accused of indulging in due to the use of strong network effects with highly advanced Analytics / Algorithms , which has destroyed the level playing field between the old assets based model and the aggregate / platform model of Ola abs Uber. In my view, before finally closing, CCI could have waited for more time to see the effect on Competition.
Incidentally
, my above comments were quoted in the
news story published immediately after the CCI order dated 14.7.2021 and the
same are available at https://indianexpress.com/article/business/companies/cci-rejects-anti-competitive-conduct-charges-against-uber-7405212/
Key Words: #Uber #Ola #CCI # Competition #networkeffects
[1] No provision for punishing attempt to monopolize unlike in USA. May like to refer to my article HEAR THE MONOPLOYPHONY published in ECONOMIC TIMES on 04 March 2020.
[2] Of course, the Hon’ble Apex Court did not decide upon the moot issues, which the COMPAT order dated 7.12.2016 raised, such as, whether COMPAT had the power to direct an investigation directly by the DG , Whether Uber could be held as dominant and what was the correct relevant market to assess Uber’s dominance etc. I had commented on these apparent omissions in the Supreme Court judgment which you may read in my earlier blog dated 25 November 2019
[3] Case No. 6 & 74 of 2015, CCI Order dated 19.7.2017 rejecting complaint of predatory pricing against Ola .
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