Reddit DMCA anticircumvention decision strengthens the value of structured data licensing

Plaintiff Reddit sued defendants SerpApi and Perplexity AI over alleged efforts to bypass technological measures restricting automated access to Reddit-related content appearing in Google search results. Plaintiff alleged SerpApi offered scraping technology that circumvented Google’s SearchGuard system, while Perplexity used that technology to retrieve Reddit content for its AI-powered answer engine. SearchGuard is Google’s anti-bot technology that uses tools such as JavaScript challenges and CAPTCHAs to distinguish ordinary human users from automated systems seeking to access search results at scale.
Defendants asked the court to dismiss plaintiff’s claims, including anticircumvention claims under Section 1201 of the Digital Millennium Copyright Act. Those provisions generally prohibit bypassing technological measures that effectively control access to copyrighted works and prohibit providing or trafficking in certain technologies or services designed to defeat those protections. Plaintiff argued that SearchGuard qualified as such an access-control measure because it permitted ordinary human access to Google search results while restricting automated bulk access.
The court largely denied defendants’ motions and allowed plaintiff’s principal DMCA claims to proceed. It held that plaintiff plausibly alleged SearchGuard was an effective access-control measure, that SerpApi circumvented or provided technology capable of circumventing that measure, and that Perplexity could itself face circumvention liability based on allegations that it used SerpApi’s technology to conduct and configure the relevant searches. The court dismissed a separate DMCA claim involving measures that protect against copying after access is obtained, as well as plaintiff’s unjust enrichment and unfair competition claims.
The decision is especially important for businesses that grant licensed access to valuable online data. In this context, licensed access means allowing selected third parties to retrieve or use data under contractual terms that define permitted uses, restrictions, security obligations, and other conditions of access. The court gave weight to plaintiff’s allegations that its structured licensing arrangements defined how partners could use Reddit data and authorized partners such as Google to protect that data through technological measures, suggesting that businesses that clearly document access rights, partner responsibilities, usage restrictions, and authority to deploy protective technology may be in a stronger position to pursue DMCA circumvention claims when third parties bypass those controls.
Reddit, Inc. v. SerpApi LLC, 2026 WL 2210094 (S.D.N.Y., July 31, 2026)