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A federal judge dismissed the Sherman Act antitrust claims brought by Chegg and Penske Media Corporation over Google’s use of publisher content in search products, including AI Overviews. The ruling found that the complaints did not adequately plead the legal elements of their antitrust theories. It did not decide that AI Overviews had no effect on publisher traffic, or that Google’s conduct is lawful under every possible legal theory.
What the judge dismissed—and what remains undecided
U.S. District Judge Amit Mehta dismissed the plaintiffs’ federal antitrust claims. The decision addressed whether Chegg and Penske had pleaded viable claims under the Sherman Act—not whether their allegations about lost clicks or revenue were proven at trial.
The complaints also included California unjust-enrichment claims. The court declined to exercise supplemental jurisdiction over those state-law claims, leaving their merits undecided. That is different from ruling that the claims were either valid or invalid.
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The dismissal was reported as without prejudice and accompanied by a final, appealable order. Those terms describe the reported disposition; they do not establish whether either plaintiff later appealed.
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Why the reciprocal-dealing theory failed
Chegg and Penske argued, in substance, that publishers make content available for Google to crawl in expectation of receiving search referrals, while Google uses that content in features that can answer a search without sending the user to a publisher’s site. The legal question was whether the complaints plausibly alleged an agreement to exchange content for referrals.
Judge Mehta concluded they alleged an expectation of traffic, not an agreement with Google to provide it in return for content. As quoted by Ars Technica and VERDICT News, he wrote: “But an expectation is not an agreement. It is simply how a general search engine works.” The distinction matters: the court did not say publishers receive no referrals, or find that Google’s search features never reduce visits. It found the pleaded facts insufficient to show the mutual assent required for the reciprocal-dealing theory.
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Why Penske’s tying theory failed
Penske argued that Google tied AI Overviews to general search. The court assumed without deciding that the stricter per se standard for tying applied, then found the pleadings insufficient to show that Google Search and AI Overviews were separate products for antitrust purposes.
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1Scan for outdated or missing drivers - takes under a minute2Repair Windows errors before they cause bigger problems3Fix the driver behind crashes, sound loss and screen glitchesThat analysis concerned whether the products had distinct consumer demand, not how many clicks an Overview might divert. A claim that a search feature changes user behavior does not, by itself, establish that the feature and search are separate products under antitrust law.
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Market definition and antitrust standing were also problems
The court identified defects in the plaintiffs’ proposed markets and standing theories. It considered the alleged broad market for online publishing implausibly broad because it swept together unlike forms of content. Chegg’s proposed educational-publishing market, by contrast, was not defined clearly enough. The monopolization and attempted-monopolization theories tied to general search also failed for lack of antitrust standing.
These are legal and pleading conclusions. They do not amount to a finding that publishers’ businesses were unaffected by changes in Google Search, nor do they resolve every potential legal claim arising from the use of publisher content.
How the two cases differed
| Plaintiff | Business described in the case | Key antitrust theories | Reason the federal claims failed |
|---|---|---|---|
| Chegg | Education platform | Reciprocal dealing and monopolization-related theories | No sufficiently pleaded agreement to exchange content for referrals; defects in the proposed educational-publishing market and antitrust standing for theories tied to general search. |
| Penske Media Corporation | Publisher | Reciprocal dealing, tying, and monopolization-related theories | No sufficiently pleaded reciprocal-dealing agreement; no plausible showing that Search and AI Overviews were separate products; and defects in market definition and standing. |
Both plaintiffs’ California unjust-enrichment claims were left undecided on their merits after the court declined supplemental jurisdiction.
What the ruling does—and does not—say about traffic losses
The court acknowledged the alleged harms and expressed sympathy for publishers and creators. Mehta wrote: “The court does not treat Plaintiffs’ alleged harms lightly.” He also referred to “the knock-on consequences to journalists, educators, and other online creators whose content Google takes and repurposes without compensation.” He nevertheless concluded that the court had to apply the law as written to the claims pleaded.
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Numbers cited in Penske’s complaint should be read as allegations or as figures from studies the complaint cited—not as findings adopted by the judge:
- Penske alleged that organic affiliate revenue across its portfolio had fallen by more than a third from its peak by the end of 2024. That is Penske’s allegation, not a court finding.
- Penske’s complaint cited an Ahrefs 2025 figure of up to 34.5% lower click-through rate for the top organic search result. The figure is attributed to Ahrefs as cited in the complaint; it is not a universal estimate or a judicial finding about AI Overviews in these cases.
- The complaint also cited a Bain & Company 2025 figure that 60% of searches end without a click. That is a cited study figure, not a finding in the ruling and not specific proof of AI Overviews’ effect in these cases.
Those figures provide context for the concerns raised in Penske’s complaint, but they cannot be treated as proof of what caused the alleged losses or as measurements made by the court.
Why dismissal is not a ruling that Google’s conduct is lawful in every sense
A dismissal for insufficiently pleaded antitrust claims answers a narrower question than whether a product affects publishers or whether every aspect of its operation complies with every potentially applicable law. Here, the court found that the complaints did not adequately allege the agreement, separate products, market definitions, or standing needed for the federal antitrust theories at issue. It did not decide the merits of the state unjust-enrichment claims, and it did not make a factual finding that publisher traffic was unaffected.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchThe court’s quoted statement that it was “bound to apply the law only as it is written, not how the court or any party believes it ought to be” captures that limit: the ruling concerns the legal claims before it, not a general endorsement of every practice associated with AI Overviews.
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