On September 30, 2026, U.S. District Judge Amit P. Mehta dismissed amended antitrust complaints from Chegg and Penske Media Corporation (PMC) against Google LLC and Alphabet Inc. The ruling concerned claims about Google Search and its AI products, including AI Overviews and Gemini.
What Chegg and Penske Media alleged
Chegg and PMC, which brought its case with affiliated publishers, alleged that Google conditioned access to search referrals on publishers making content available without payment, then used publisher material in search and generative-AI features. They also alleged that the conduct diverted traffic and revenue from their businesses.
Why the court dismissed the complaints
The court found that the complaints did not plausibly allege an agreement between Google and the publishers. The plaintiffs described an expectation of receiving search traffic when they made content available; the court found that expectation did not establish a mutual agreement, as required for their reciprocal-dealing claims.
The opinion also identified other pleading problems. The plaintiffs had not plausibly established antitrust standing for their alleged injuries or shown how the challenged conduct maintained Google’s general-search monopoly. The court found their proposed online-publishing and online-educational-publishing markets insufficiently plausible or specific for their monopoly-related claims.
PMC’s tying claim faced a separate problem: the court found that the complaint did not plausibly allege general search and AI Overviews as separate products. The court also declined supplemental jurisdiction over the plaintiffs’ remaining state-law unjust-enrichment claims and dismissed them.
