US District Judge Amit Mehta has dismissed antitrust lawsuits filed by Chegg and Penske Media against Google, ruling that the company's AI search products — including AI Overviews — do not violate antitrust law even though they have driven traffic declines at numerous websites.

The dismissal is a significant setback for publishers and content platforms that have watched referrals from Google search erode as AI-generated answers absorb queries that once ended in clicks. Mehta's ruling, published via DocumentCloud, closes — for now — the first major legal test of whether harvesting indexed web content to power AI answers constitutes an antitrust injury.

Chegg, an education and learning platform, filed its suit in 2025. The company accused Google of illegally scraping its educational content and using it to train and ground Gemini models, which could then essentially recreate that content in AI answers and reduce traffic to Chegg's site. Penske Media, the publisher behind Rolling Stone and Variety, filed a parallel case alleging lost traffic from the same behavior.

Penske's complaint zeroed in on a structural complaint shared across the publishing industry: sites that allow indexing for organic search have their content harvested for AI answers, with no mechanism to opt out of one while remaining in the other. Google moved to dismiss both cases earlier this year.

Mehta was not persuaded. The judge held that Google's implicit arrangement with websites — index your content, receive search traffic in return — has no legal relevance under antitrust statutes.

"Plaintiffs have pleaded only that they have an 'expectation' that Google will send them search traffic if they make their content available for free," Mehta wrote. "But an expectation is not an agreement. It is simply how a general search engine works."

The distinction matters. Antitrust claims generally require proof of harm to competition arising from conduct that violates specific legal prohibitions — not simply harm to a business from a change in how a product operates. Mehta's framing suggests that a traffic-referral expectation, however reasonable publishers considered it, does not rise to the level of an enforceable commercial agreement whose breach could anchor an antitrust case.

The ruling leaves publishers without a clear legal path for challenging AI summarization under current US antitrust doctrine. Chegg has been among the most visibly affected companies: its business depends on students finding its subscription content through search, and AI Overviews answer many of those queries directly. Penske's portfolio of entertainment and trade publications faces a different but related pressure, as AI answers increasingly satisfy informational queries without a click-through to the source.

For Google, the decision removes one legal cloud over its AI strategy at a moment when the company is embedding Gemini-generated answers more deeply into search. The company had already signaled some accommodation to publisher concerns — it has moved to place more links to websites inside AI Overviews — but Mehta's ruling means such concessions remain voluntary product decisions rather than legal obligations.

The publishers retain the option to appeal, and parallel fights over AI training data and content licensing continue in other courts and jurisdictions, including copyright-based claims brought by news organizations against AI developers. Whether Chegg and Penske pursue an appeal, the dismissal establishes an early precedent that traffic displacement by AI search products does not, on its own, state an antitrust claim — a precedent that will shape how publishers weigh licensing negotiations, paywalls, and technical restrictions on indexing going forward.