According to the Complaint, Groupon offers a marketplace that connects consumers to merchants through mobile applications and websites. Historically, Groupon operates in three categories: Local, which comprises subcategories of local experiences, including events and activities, health and beauty, food and drink, home and garden, and automotive; Goods, which includes product revenue from merchandise inventory sold directly to customers and service revenue from thirdparty merchants who sell products using Groupon marketplaces; and Travel, which offers hotels, airfare and package deals at discounted and market rates.