Judge Amit Mehta has dismissed the amended antitrust complaints filed by Chegg and Penske Media against Google, granting Google's motion to dismiss without prejudice and making the order final and appealable — while explicitly acknowledging in the same ruling that publishers are suffering real harm from Google taking and repurposing their content without compensation.

The ruling is not a finding that publishers are unharmed. It is a finding that the plaintiffs' allegations, as pleaded, do not meet the requirements of federal antitrust law.

What did the judge actually say about publisher harm?

The order in the Penske case contains an unusually direct acknowledgment of the allegations at the heart of the publishers' case. Mehta wrote:

"The court does not treat Plaintiffs' alleged harms lightly. Nor is it unsympathetic to the situation publishers now find themselves in, and the knock-on consequences to journalists, educators, and other online creators whose content Google takes and repurposes without compensation."

That language matters for SEOs and publishers tracking the broader legal fight over AI Overviews and search traffic loss: the court recognized the injury narrative but separated it from the legal question of whether the complaints state valid antitrust claims.

Which five claim categories did the court reject?

The judge dismissed every category the plaintiffs raised:

• Reciprocal dealing — the alleged exchange of crawl access for referral traffic
• Tying — bundling Google Search with AI Overviews
• Unlawful monopoly maintenance — in the general search services market
• Attempted monopolization and monopoly leveraging — in publishing markets
• Unjust enrichment — a California state law claim

Why did the reciprocal dealing claim fail?

Reciprocal dealing requires an actual agreement: publishers let Google crawl and index their content, and Google sends referral traffic in return. The judge found the plaintiffs never plausibly alleged that such an agreement exists — no alleged elements of one, no circumstances of its formation, no communications showing negotiation or discussion between Google and the plaintiffs.

Mehta identified the core defect bluntly:

"Plaintiffs have pleaded only that they have an 'expectation' that Google will send them search traffic if they make their content available for free. But an expectation is not an agreement."

For site owners who have long framed robots.txt as an implied traffic bargain, the court drew a hard line: an expectation of referrals does not create a contract enforceable under antitrust law.

How did the court handle the tying and standing arguments?

On tying, the ruling says Penske failed to plausibly establish that Google Search and AI Overviews are separate products with separate consumer demand — a foundational element for any tying claim.

On monopoly maintenance, the judge held that the publishers lack antitrust standing to challenge Google's conduct in the general search services market. Mehta wrote:

"To survive a motion to dismiss, Plaintiffs must plausibly establish that they have antitrust standing as to these claims. As with other plaintiffs appearing before this court, they have not."

The plaintiffs had advanced two standing theories: that they are suppliers of Search Index Data and purchasers of Search Referral Traffic within the search market, and alternatively that their injuries are "inextricably intertwined" with injuries to Google's new AI competitors. Mehta rejected both: "Neither theory persuades."

Why did the attempted monopolization claims collapse?

The plaintiffs did not clearly define the publishing markets they claimed Google is trying to dominate, nor show Google has a dangerous probability of monopolizing them. Mehta wrote that by failing to define plausible markets, the plaintiffs miss a necessary element of the attempted monopolization claims, and that the leveraging claims fall for the same reason.

He singled out the evidentiary gap in Penske's complaint:

"The PMC Plaintiffs do not even attempt to quantify Google's market share in online publishing or offer a single fact to support their allegation that Google has a dangerous probability of monopolizing the sweeping market they describe."

Chegg fared no better: Mehta wrote that Chegg "has not plausibly pleaded that Google has a dangerous probability of monopolizing a market in which it participates." Count V of Chegg's amended complaint and Count VI of the Penske complaint were dismissed.

After all federal claims fell, the judge declined to exercise supplemental jurisdiction over the remaining state law claims, including unjust enrichment, citing judicial economy, convenience, and fairness to litigants.

What should publishers and SEOs watch next?

The dismissal is without prejudice, and the order is final and appealable — so the immediate question is whether Chegg and Penske appeal, refile with restructured market definitions and agreement allegations, or both. Mehta's ruling also signals that any future publisher suit over AI Overviews traffic loss will need quantified market share data and a plausible agreement theory, not expectations, to survive a motion to dismiss.