Every federal claim dismissed
US District Judge Amit Mehta has granted Google’s motions to dismiss the antitrust suits brought by Penske Media and Chegg over AI Overviews, the summaries Google places above its search results. The consolidated opinion, dated 30 September and reported on 1 October, disposes of all five categories of claim the two companies had brought.
The central theory was reciprocal dealing: that publishers were made to choose between letting Google feed their work into AI summaries and disappearing from search. Mehta rejected it on the simplest possible ground. Publishers expected traffic in return for making content crawlable, but an expectation is not an agreement, and antitrust law polices agreements.
Why each of the other four failed
The tying claim required Penske to show that search and AI Overviews are separate products with separate consumer demand. The court found it had not. The monopoly-maintenance claim failed on standing: as suppliers into the market for general search services rather than competitors in it, the publishers were not the right plaintiffs to bring it.
Attempted monopolisation and monopoly leveraging both required a plausible definition of the publishing markets Google was supposedly moving to monopolise, and a showing that it had a dangerous probability of succeeding. Neither was made out. With the federal claims gone, Mehta declined supplemental jurisdiction over the remaining California unjust-enrichment claim, so that one was not decided on its merits at all.
The Penske dismissal was granted without prejudice, and the accompanying order is final and appealable. Chegg filed its case in February 2025 and Penske — the owner of Rolling Stone, Billboard, Variety and The Hollywood Reporter — in September 2025.
The sympathetic part of the ruling
What makes this more than a routine win for Google is what Mehta wrote alongside it. He said he was not unsympathetic to creators whose content Google takes and repurposes without compensation, and that antitrust law is not a substitute for lawmakers addressing the disruption caused by new technology.
That is a pointed thing for this judge to say. Mehta is the judge who found that Google held an illegal monopoly in general search in the US government’s case against it, and who then wrote the remedies. A ruling from him that the publishers’ grievance is real but not an antitrust grievance closes a door a lot of media companies were counting on.
What to watch
Three things. Whether Penske appeals or amends, since the dismissal without prejudice leaves both open. Whether other publishers with pending or planned suits recast their claims as copyright rather than antitrust, which is where the content-reuse argument actually lives. And whether anything moves in Congress, which is where Mehta has now explicitly pointed — a court saying the legislature should act is not the same as the legislature acting.
