When Chatbots Compete: Remedies in Google Antitrust Case 

Written By: Hanna Nelson 

Many people use “Google” as a verb to describe looking something up on the internet, indicating the pervasiveness of the search engine. Following a finding by the District Court for the District of Columbia that Google has a monopoly, Google and the U.S. cross appeal. Google appeals its liability, while the U.S. is likely to challenge the remedies. District Judge Mehta stated that the remedy stage of litigation was contentious. In part, the remedy may depend on the extent to which AI chatbots compete with Google as a search engine and whether Google is likely to dominate this market as well.  

In 2020, the DOJ, joined by 30 states, sued Google alleging violations of the Sherman Act. The Sherman Act prohibits certain monopolies or anti-competitive behaviors. After 38 states filed their own suit, the Court consolidated the two cases. Plaintiffs allege that Google used its monopoly power to drive competition out of general search engine and general search text advertising markets. Almost everybody is familiar with a google search, which is a general search engine because it allows the searcher to ask almost any question. Relatedly, general search text advertising is an advertisement that pops up when an individual is conducting a google search. Google occupies a majority position in these markets. However, merely having a monopoly in a market does not violate the law. The law is violated when a company acts unlawfully to stifle competition.  

Plaintiffs’ factual basis for their claims arises out of exclusive contracts making Google the default search engine on a multitude of consumer products. For example, when an individual purchases a new Apple iPhone, the default search engine is Google. Plaintiffs allege that these exclusive contracts prevent competition in the market. In addition, Plaintiffs allege that Google’s conduct weakens Specialized Vertical Providers, which are companies that serve specific markets, by limiting their visibility and demanding that they make their data available. Finally, Plaintiffs allege that Google delayed implementation of a search tool used by purchasers of digital advertisements in such a way that it harmed competitor Microsoft.  

On August 5, 2024, following a bench trial, Judge Mehta issued a decision. The bottom line of the Court’s decision was “Google is a monopolist, and it has acted as one to maintain its monopoly.” The Court found a violation of Section 2 of the Sherman Act based on Google’s monopoly in the general search services and general text advertising markets. The conclusion appeared to rest on Google’s exclusive contracts to be the default search engine on many consumer products. Google filed an appeal on the finding of liability.  

After a finding of liability, the Court must turn to the remedy. Uniquely in this case, the arguments about the appropriate remedy are dramatically different from the arguments about liability. At the liability trial, no witness testified about Generative AI being a threat to Google’s monopoly. In contrast, the witnesses at the remedy hearings focused heavily on Generative AI. Rather than concern about Google competing with other general search engines, a market where Google was found to have a monopoly, Plaintiffs focus on ensuring Google does not create or maintain a monopoly in the Generative AI space.  

The District Court fashioned a remedy. Under the District Court’s ruling, Google is prohibited from entering into exclusive contracts, conduct that was found to be unlawful. However, Google is not required to sell certain assets, including web browser Google Chrome and the Android Operating System, despite Plaintiffs’ arguments suggesting this remedy. The Court noted that Generative AI systems are a competitive threat to general search engines, a market that Google dominates. Plaintiff advocates that Google’s investment in AI should be limited to avoid an unlawful monopoly in that market as well.  

On February 3, 2026, the U.S. indicated that it was filing an appeal. The Court of Appeals is likely to have to decide how the remedies should be fashioned under changing circumstances, as technology continues to advance.   

The decision in this case is likely to have implications on antitrust law and enforcement. Some argue for anti-trust reform, including broadening the scope of antitrust remedies. Others argue that the Court’s ruling allows competition to happen naturally, especially as AI technologies appear to be entering the search engine markets. District Judge Mehta exhibited concern about fashioning a remedy without knowing what the future of the market holds. Ultimately, antitrust law is intended to promote competition. Is Generative AI providing competition to Google’s general search engines, or will Google monopolize that industry as well? 

Sources 

Jeffrey Westling, Aryan Mirchandani, The Impact of Google’s Antitrust Remedies on the Future of Monopolies (Oct. 7, 2025), https://www.americanactionforum.org/insight/the-impact-of-googles-antitrust-remedies-on-the-future-of-monopolies/. 

US files appeal in Google search antitrust case, Reuters (Feb 3, 2026 3:59 PM), https://www.reuters.com/world/us-states-file-appeal-google-search-case-court-filing-shows-2026-02-03/.  

U.S. v. Google: A Landmark Case and Warning Shot to Big Tech, Purdue Glob. L. Sch. (Sept. 3, 2025), https://www.purduegloballawschool.edu/blog/news/google-landmark-case. 

United States v. Google LLC, 687 F. Supp. 3d 48 (D.D.C. 2023). 

United States v. Google LLC, 747 F. Supp. 3d 1 (D.D.C. 2024). 

United States v. Google LLC, 803 F. Supp. 3d 18 (D.D.C. 2025).