On September 30, 2026, U.S. District Judge Amit P. Mehta granted Google LLC and its parent, Alphabet Inc., motions to dismiss amended antitrust complaints brought by Chegg and Penske Media Corporation (PMC), which was joined by nine affiliated publishers. The ruling turned on deficiencies in the claims as pleaded, including whether the companies had alleged an agreement to trade publisher content for search traffic and whether their theories fit the relevant antitrust markets.
The court dismissed both publisher antitrust complaints
The cases challenged Google’s use of publisher content in AI Overviews and other generative AI products. Mehta’s ruling resolved the federal antitrust claims brought under Sections 1 and 2 of the Sherman Act, the U.S. law at the center of the complaints.
Why the antitrust claims did not proceed
The publishers argued that they made content available with the expectation of receiving search referrals in return. The court found that the complaints did not plausibly allege an agreement requiring Google to provide a specified amount of referral traffic in exchange for that content. They also did not allege negotiated terms, mutual commitments or communications that would support such an agreement.
PMC’s tying claim had a separate pleading problem. Tying generally involves making access to one product depend on accepting another. The court found that PMC had not plausibly alleged separate demand for Google Search and AI Overviews in that claim.
The court also dismissed monopoly-maintenance claims tied to the general-search market for lack of antitrust standing. It reasoned that the alleged publishing-revenue losses and uncompensated use of content were injuries in other markets, and the complaints did not support the theory that the plaintiffs had purchased search traffic from Google.
Market definitions posed another obstacle to monopoly-leveraging and attempted-monopolization claims. The court found PMC’s proposed online-publishing market too broad and Chegg’s proposed online-educational-publishing market insufficiently defined.
How the court treated Search and AI Overviews
For PMC’s tying claim, the court treated Google Search and AI Overviews as an integrated search experience, rather than two separately demanded products. That finding addressed the pleaded tying theory in this case.
What the decision resolved
The court declined supplemental jurisdiction over the California unjust-enrichment claims after dismissing the federal claims, then dismissed the state-law claims on that basis. It did not decide whether those claims would succeed on their merits. The opinion addressed the pleaded antitrust claims and jurisdictional questions, not copyright liability.
