U.S. District Judge Amit P. Mehta dismissed two publisher lawsuits against Google on September 30, 2026, ruling that education firm Chegg and Penske Media failed to plead a plausible antitrust agreement that swapped publisher content for search referrals.

The ruling, filed in the U.S. District Court for the District of Columbia, ended the amended complaints against Google and its parent, Alphabet, at the motion-to-dismiss stage. Mehta treated properly pleaded allegations as true and asked only whether they supported viable legal claims.

What did the court say about the traffic-exchange theory?

Mehta's central finding collapsed the publishers' core legal theory. Both companies described allowing Google to index their content as a trade: publishers supplied information, Google supplied visitors. Their Sherman Act reciprocal-dealing claims alleged Google conditioned those referrals on free access to content for snippets, AI training and AI-generated responses.

Mehta found the alleged exchange lacked a plausibly pleaded agreement. The complaints identified no offered terms, no negotiations over quantity or duration, no commitments by either side, and no communications showing mutual assent.

"An expectation is not an agreement," Mehta wrote. Google's automated indexing and each publisher's decision to allow crawling served independent commercial interests, in his reading.

Why did Penske's tying claim also fail?

Penske additionally alleged unlawful tying — that Google forced users who wanted Search to take AI Overviews with it. That claim required two plausibly separate products with separate consumer demand.

The publisher argued ordinary search sends users elsewhere, while AI Overviews keep them on Google's results page. Mehta turned that argument back: if a user satisfied by an AI answer has little reason to click onward, demand for information existed regardless of format. The two were not distinct products.

The tying claim therefore failed on its separate-products premise.

How did market definition problems doom the monopoly claims?

The companies also alleged Google unlawfully maintained its search monopoly through AI Overviews. Mehta found the alleged subscription and licensing losses arose in publishing and content markets, not search.

The companies argued obtaining content for free gave Google an edge over rivals that paid for it. But the complaints did not explain how those costs excluded competitors or made publishers' losses indispensable to maintaining Google's search monopoly.

Penske's proposed market covered essentially all text published online. Mehta called that too broad. The complaint did not explain why a legal brief, fictional story and news article belong in one market, or quantify Google's share of it.

Chegg proposed a narrower educational market, but its boundaries stayed unclear. The court said Chegg failed to distinguish learning material from ordinary information or place Google's answers inside the curated educational market it described.

Those defects undermined both companies' attempted-monopolization and monopoly-leveraging theories.

What traffic data sits behind the cases?

Independent measurements help quantify the publishers' concern. In Pew Research Center's March 2025 web browsing analysis, traditional-result clicks occurred on 8% of visits to pages with AI summaries, compared with 15% without summaries. Only 1% of summary-page visits produced a click on one of the first three source links within a summary.

• Sample: 900 U.S. adults
• Browse period: March 2025
• Search results reconstructed for April 2025

Pew noted different query types more often triggered summaries. Click behavior could shift as Google's systems and the queries they see change.

Google offered a competing account. In an August 2025 response, Search chief Liz Reid argued AI answers encourage longer, more complex questions and new discovery paths. Google described visits that do not bounce straight back to Search as higher-quality clicks — a post-click argument that contrasts with Pew's pre-click measurement.

What does the ruling leave open?

Mehta dismissed the federal claims, then declined to exercise supplemental jurisdiction over parallel California unjust-enrichment allegations. Those state claims fell with the federal ones.

Penske's order expressly dismisses its complaint "without prejudice," preserving possible refiling. Chegg's order grants dismissal without specifying prejudice. Both orders are final and appealable.

AI Overviews launched in the United States in May 2024. Chegg filed its suit in February 2025; Penske followed that September. Both amended their complaints before Mehta weighed the dismissal motions together.

Watch for any appellate filings in the next 30 days and for the next round of third-party measurement of summary-page click behavior, since publishers' commercial-harm arguments still lean heavily on that data.