Despite the detailed arguments presented by both Chegg and Penske Media, Judge Mehta was ultimately unpersuaded that Google’s practices amounted to unlawful monopolization or anti-competitive conduct under existing federal antitrust statutes. In his written opinion granting Google’s motion to dismiss, Mehta highlighted a fundamental legal distinction between informal corporate expectations and enforceable legal agreements. The judge explained that the traditional relationship between web publishers and search engines is built upon a mutual, informal framework rather than a binding legal contract that imposes statutory obligations under antitrust law.
Addressing the core of the plaintiffs’ claims, Judge Mehta clarified that an operational expectation of receiving web traffic does not create an actionable legal duty for a search engine to preserve its historic referral patterns. "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 in the ruling. "But an expectation is not an agreement. It is simply how a general search engine works." Because Google had never entered into a formal, binding contractual arrangement with either Chegg or Penske Media regarding guaranteed traffic volumes or exclusive content distribution terms, the court concluded that federal antitrust law could not be applied to penalize Google for modifying how its search engine displays answers to public user queries.
The court’s ruling establishes that the mechanics of web indexing and search referral traffic, even when altered significantly by new technological developments like artificial intelligence, fall within the general operational functions of search engine design. In the absence of explicit anti-competitive agreements, exclusive dealing arrangements, or direct contractual breaches, the financial losses suffered by web publishers as a consequence of evolving search features do not equate to illegal conduct under federal antitrust legal frameworks.
The legal standard applied in this ruling is particularly notable given Judge Mehta’s deep judicial familiarity with Google’s search operations, business practices, and market dominance. Judge Mehta previously presided over the U.S. Department of Justice’s high-profile, long-running search antitrust trial against Google. In that historic enforcement action, Mehta issued a landmark ruling concluding that Google had indeed operated as an illegal monopoly and violated federal law to maintain its dominance over the general search market, primarily through exclusive distribution agreements that secured default search status on mobile devices and web browsers.
