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On September 30, 2026, U.S. District Judge Amit P. Mehta dismissed the amended antitrust complaints brought by Chegg and Penske Media against Google in the U.S. District Court for the District of Columbia. He ruled that the companies had not pleaded facts sufficient to support their federal antitrust claims. The decision was not a trial finding that publishers suffered no harm or that every aspect of Google’s use of content was lawful.
What the judge decided
Judge Mehta granted Google’s motions to dismiss both amended complaints. The opinions concluded that the pleaded theories did not meet the legal requirements for the antitrust claims the companies brought. The court also declined to keep the companies’ state-law unjust-enrichment claims after dismissing the federal claims; it did not decide those state claims on their merits. The opinions state that final, appealable orders accompanied them. Read the Chegg opinion and the Penske opinion.
A dismissal on a motion to dismiss asks whether a complaint’s allegations, taken as pleaded, make out a legally sufficient claim. It is different from a trial that weighs evidence and determines what happened. The court therefore did not resolve every factual dispute about Google’s use of publisher content or the effects of AI-powered search.
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Both companies alleged that Google used publisher material to train or ground generative AI systems and republished information in AI-powered search results. They said features such as AI Overviews reduced the traffic and commercial opportunities publishers could otherwise receive from search referrals. Those are allegations in the complaints, not findings adopted by the court.
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| Case | Filed | Content and market at issue | Additional claim noted in the opinion |
|---|---|---|---|
| Chegg | February 24, 2025 | Educational content and an alleged online-educational-publishing market | The opinion discusses its attempted-monopolization and leveraging theories. |
| Penske Media | September 12, 2025 | Online publishing properties and an alleged online-publishing market | Penske also asserted a tying theory. |
The filing dates, alleged markets, and claims are described in the Chegg and Penske opinions. The cases shared important legal arguments, but the plaintiffs and their content businesses were not identical.
Why the reciprocal-dealing theory fell short
A central argument characterized publishers’ participation in Google’s search index as a reciprocal arrangement: Google would send referral traffic, and publishers would make content available for Google to use. The judge found that the complaints described an expectation of referrals, not facts establishing an agreement between the parties. They also did not adequately plead essential terms of a bargain, such as its price or quantity.
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As Judge Mehta put it, “an expectation is not an agreement. It is simply how a general search engine works.” The opinions said the pleaded harms—such as lost subscription revenue or allegedly inadequate compensation for content—were not sufficiently direct antitrust injuries in the general-search-services market. The companies also had not adequately pleaded an agreement to purchase traffic.
Why the market and standing theories were insufficient
The opinions also rejected the plaintiffs’ standing theories for claims tied to Google’s alleged monopoly in general search. In addition, the court found that the proposed online-publishing and online-educational-publishing markets were not adequately defined for the attempted-monopolization and leveraging claims. The Chegg complaint, in particular, did not provide enough boundaries and factual specificity for its proposed educational-publishing market. Penske’s tying theory was also among the claims dismissed under the applicable pleading standards.
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These rulings concern the sufficiency of the claims as pleaded. They do not establish that publishers experienced no traffic losses, nor do they decide every question about whether or how Google used particular content.
What the 21% figure does—and does not—show
Chegg’s 2025 complaint alleged, based on Similarweb clickstream data comparing October 2023 with October 2024, that the share of U.S. searches for terms relevant to Chegg’s education offerings that produced no click to a non-Google site rose 21% year over year. That is a figure alleged by Chegg in its complaint; the dismissal opinion did not adopt it as a finding. It should not be read as a measured impact on all publishers or all searches.
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The opinions say final, appealable orders accompanied the dismissals. That means the rulings can be appealed, but it does not establish whether an appeal was later filed. The state-law unjust-enrichment claims were not resolved on their merits: after dismissing the federal claims, the court declined supplemental jurisdiction over them.
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