On 5 March 2026, the Competition Council (CC) adopted a decision finding that the limited liability company “SS” (LLC “SS”) had abused its dominant position in the market for online classified advertising services in Latvia, thereby infringing Article 102 of the Treaty on the Functioning of the European Union. For the infringement, the CC imposed a fine of EUR 186,780.65 on the company and also established a legal obligation to develop clear and objective criteria for future cooperation with clients, in order to prevent similar cases in the future.
First, the CC established in its decision that LLC “SS” holds a dominant position in the market for online classified advertising services in Latvia. During the infringement period, LLC “SS” market share exceeded 60% of all classified advertising platforms in terms of the number of listings, while the market shares of other significant platforms were considerably smaller – the next largest market participant, Facebook Marketplace, did not exceed 15%.
Second, the investigation found that LLC “SS” abused its dominant position vis-à-vis its customers. In the period from 13 March 2020 to 27 May 2021, it engaged in exclusionary practices, namely by deleting and blocking user advertisement accounts on its online classified advertising platforms under the domain names ss.lv and ss.com (the “Advertising Platform”), where users simultaneously posted their advertisements on a competing platform - pp.lv, owned by INBOKSS.
Additionally, in cases where users wished to place advertisements on the Advertising Platform and provided an inbox.lv email address, registration of the advertisement was not possible unless an alternative email address was also indicated. Such conduct restricted the competitor’s ability to develop and reduced users’ freedom of choice.
LLC “SS” discouraged users from using a competing platform.
The CC found that LLC “SS” blocked user accounts and deleted advertisements in cases where users had also published their listings in parallel on pp.lv. This conduct was primarily directed at corporate clients - car traders and dealers, as well as real estate brokers.
Electronic correspondence obtained in the case indicates that this practice was implemented deliberately and purposefully in order to deter users from cooperating with the competing platform, thereby hindering its ability to attract users and establish itself in the market.
At the same time, the CC established in its decision that access to the Advertising Platform was essential for its users – both individuals and businesses, including, for example, used car dealers and real estate agents – in order to reach potential buyers. This is also confirmed by the correspondence obtained in the case, demonstrating that users actively approached representatives of LLC “SS” requesting the restoration of access to their accounts on the Advertising Platform.
For example, a representative of a real estate company sent an email to the administration of LLC “SS”:
“The user [..] has lost all advertisements and we are also unable to access the account—it says the password is incorrect. It is also not possible to reset the password.”
Regarding this email, the administration of LLC “SS” communicated internally, stating that the user was “blocked by decision of [..], as advertisements had been published on pp.lv. This is a preventive blocking intended to demonstrate the insignificance of the competitor. A refund will be issued after 11 September.” (English translation)
Moreover, shortly before the launch of the pp.lv platform, if a user wished to place an advertisement on the Advertising Platform and provided an inbox.lv email address, registration of the advertisement was not possible unless an alternative email address was also indicated. This requirement to provide an additional email address was not imposed where the user initially provided an email address other than inbox.lv. As a result, users were required to create an additional email account not associated with inbox.lv, for example on gmail.com or another service, which caused additional inconvenience.
The CC concluded that such conduct by LLC “SS” lacked objective justification. In particular, the information obtained in the case does not indicate that the blocking of accounts or deletion of advertisements was related to violations of the platform’s terms of use or other objective considerations. On the contrary, the case materials show that this practice was used as a means of excluding a competitor from the market.
The practice harmed both competition and users of the platforms.
The CC also concluded that LLC “SS” conduct caused significant harm to competition and market participants.
First, it restricted the competing platform’s ability to attract users at a time when it was attempting to enter the market and develop its operations. In digital markets, this stage is particularly critical, as a new platform needs to reach a sufficient user base in order to compete effectively.
Second, harm was caused to the advertisers themselves, who were deprived of the possibility to use multiple sales channels simultaneously, reach a broader audience, and choose potentially more advantageous or innovative services. Moreover, in certain cases, users had paid for a service which they did not actually receive, as access to the Advertising Platform was restricted.
Third, a negative impact was also inflicted on viewers of advertisements, as unjustified deletion of listings and blocking of accounts reduced the range of advertisements available on the Advertising Platform. This, in turn, affected the quality of the service and limited consumers’ ability to access a broader offering.
CC Decision
By its decision, the CC found that LLC “SS” had infringed the prohibition of abuse of a dominant position by engaging in exclusionary practices against a competing classified advertising platform.
In order to ensure clearer and more transparent principles of cooperation for users of the advertising platform going forward, the CC imposed several legal obligations on LLC “SS”.
First, the company is prohibited from engaging in exclusionary practices against competitors in the future, namely from blocking user accounts or deleting advertisements placed on the Advertising Platform on the grounds that they are also published on competing platforms, unless there is an objective justification arising from the platform’s terms of use.
Second, within three months from the entry into force of the decision, LLC “SS” must amend or establish the platform’s terms of use by providing for:
- objective grounds for the deletion of advertisements and blocking of accounts;
- procedures for handling complaints and appeals;
- an obligation to explain the reasons for deletion or blocking;
- the possibility to update the terms while maintaining the established conditions.
Taking into account the gravity, nature, and consequences of the infringement, as well as LLC “SS” role in committing it, the CC imposed a fine of 1.5% of LLC “SS” net turnover for 2024, amounting to EUR 186,780.65.
At the same time, the CC emphasises that, given LLC “SS” dominant position, it bears a special responsibility to comply with the rules of conduct stemming from Article 13 of the Competition Law, which prohibits the abuse of a dominant position.