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SACS Amicus Brief Project

Occupational Goal Support Document

United States v. Google LLC, No. 20-cv-3010 (D.C. Cir.)

Prepared: February 17, 2026


FOR MY OCCUPATIONAL THERAPIST

This document describes a real legal project I can file as a licensed attorney (MA Bar #695038, USPTO #79984) on behalf of SACS LLC, the research organization I direct. It has a deadline, discrete tasks, and produces a tangible professional output. I'm requesting OT support to structure the work into manageable sessions.


WHAT IS THIS PROJECT?

The U.S. government sued Google for being an illegal monopoly in internet search. The government won. The court ordered remedies (penalties/fixes) in December 2025. Both sides are now appealing to the D.C. Circuit Court of Appeals.

I want to file an amicus curiae brief — a "friend of the court" document that provides perspective from someone who isn't a party to the case but has relevant expertise. Courts accept these routinely.

Why SACS has standing to contribute: My organization publishes research through Reddit. Reddit has an exclusive $60M/year deal with Google to feed content into AI systems. Reddit is now the #1 cited source in AI — 3x more than Wikipedia. My Reddit account was banned by an automated spam filter with no notice and no real appeal. This means my published research is now excluded from the AI knowledge pipeline, and no alternative platform offers equivalent access because of Google's exclusive licensing arrangement.

The brief argues: the court's remedies need to address exclusive content licensing deals (like Google-Reddit) that extend the monopoly into AI information retrieval. This is directly within the scope of what the court is already deciding.


TIMELINE

Where the case stands now:

  • Aug 2024: Court found Google is an illegal monopolist
  • Sep 2025: Court issued remedies (behavioral, not structural)
  • Dec 5, 2025: Final judgment entered (6-year framework)
  • Jan 2026: Google filed notice of appeal to D.C. Circuit
  • Feb 3, 2026: DOJ and states filed cross-appeal

Appeal timeline (estimated):

PhaseEstimated DateStatus
Briefing schedule set by D.C. CircuitFeb-Mar 2026Pending
Google's opening brief~Apr-May 2026~60 days after schedule
DOJ response brief~Jun-Jul 2026~60 days after Google
Reply briefs~Aug 2026~30 days after response
Amicus briefs dueTypically with appellee's brief~Jun-Jul 2026
Oral argument~Fall 2026TBD

Critical note on amicus timing:

Under D.C. Circuit Rule 29 and Federal Rule of Appellate Procedure 29, amicus briefs are due 7 days after the brief of the party the amicus supports (or 7 days after appellee's brief if not supporting either party). Since SACS would likely support the DOJ's cross-appeal (arguing remedies don't go far enough), the brief would be due ~7 days after DOJ files its brief.

We won't know the exact date until the D.C. Circuit sets the briefing schedule — likely within the next few weeks.

Realistic target window: June-August 2026


TASK BREAKDOWN

Phase 1: MONITORING (Now — ~April 2026)

Time needed: ~30 min/week

TaskDescriptionDifficulty
1.1Check PACER for D.C. Circuit briefing scheduleLow
1.2Set calendar alert when schedule is publishedLow
1.3File Reddit appeal, document outcomeLow
1.4Read key filings as they appearMedium

Phase 2: RESEARCH & DRAFTING (~April — June 2026)

Time needed: ~2-4 hours/week for 6-8 weeks

TaskDescriptionDifficulty
2.1Draft motion for leave to file amicus briefMedium
2.2Research: document Reddit-Google licensing termsMedium
2.3Research: compile AI citation data (Profound AI)Medium
2.4Research: document Reddit moderation proceduresLow (done)
2.5Draft brief outline (15-25 pages target)High
2.6Write Section I: Interest of AmicusLow
2.7Write Section II: Factual background (AI-RAG)Medium
2.8Write Section III: Legal argumentHigh
2.9Write Section IV: Proposed remedial principleMedium
2.10Internal review and revisionMedium

Phase 3: FILING (~1-2 weeks before deadline)

Time needed: ~8-12 hours total

TaskDescriptionDifficulty
3.1Final formatting per D.C. Circuit rulesMedium
3.2Prepare motion for leave to fileLow
3.3File via CM/ECF (D.C. Circuit e-filing)Low
3.4Serve copies on all partiesLow
3.5Document filing for SACS recordsLow

WHAT THE BRIEF ARGUES (PLAIN LANGUAGE)

  1. Google has exclusive access to Reddit's content for AI. Reddit is the #1 source AI systems cite. Google pays $60M/year for this. Other search engines and AI systems are locked out.
  2. This extends the monopoly the court already found illegal. The court said Google's exclusive deals are anticompetitive. The Reddit deal is the same pattern, just applied to AI instead of traditional search.
  3. Automated moderation + exclusive licensing = information control. When Reddit's spam filter bans a user with no notice and no real appeal, and Reddit is the only pipeline into AI knowledge systems, the effect is that automated algorithms control what AI systems can know — with no accountability to anyone.
  4. The court's remedies should address this. Specifically: content sources that function as critical AI infrastructure should be accessible to competing AI systems on fair terms, not locked behind exclusive deals with Google.

OT SESSION STRUCTURE (SUGGESTED)

Ideal work session: 45-90 minutes

Session format:

  • 5 min: Review where I left off (check task list)
  • 35-80 min: Work on current task
  • 5 min: Note where I stopped, set next session goal

Accommodation notes:

  • Writing is the high-energy task. Research is lower energy.
  • I can alternate research sessions and writing sessions based on daily capacity.
  • AI assistance (Claude) can help with research compilation, citation formatting, and draft revision — reducing the solo cognitive load.
  • The brief has natural section breaks that map to individual work sessions.

Minimum viable schedule:

  • 1 session/week from now through April = monitoring phase
  • 2-3 sessions/week from April through filing = active drafting
  • Daily sessions in the final week before deadline = finalization

WHAT I NEED FROM OT

  1. Help structuring the weekly rhythm — which days/times for which task types
  2. Accountability check-ins — "Did you check PACER this week?"
  3. Energy management — mapping high-difficulty tasks to high-capacity days
  4. Transition support — this is a new task type (appellate brief) even though I'm a licensed attorney; the novelty may create executive function friction
  5. Celebration milestones — each completed phase is a real professional achievement worth marking

RESOURCES I ALREADY HAVE

  • Active bar membership (MA #695038)
  • PACER account access
  • CaseNode SACS-RD-001 documenting Reddit ban (evidence)
  • AI research assistant (Claude) for drafting support
  • Existing documentation of Reddit-Google licensing arrangement
  • SACS LLC organizational standing
  • D.C. Circuit CM/ECF registration (need to verify/obtain)
  • Briefing schedule (not yet published)
  • Final brief (to be drafted)

IMMEDIATE NEXT STEPS (This Week)

  1. ☐ File Reddit appeal at reddit.com/appeals
  2. ☐ Check PACER for D.C. Circuit case docket
  3. ☐ Verify D.C. Circuit CM/ECF registration status
  4. ☐ Set weekly PACER check reminder (Mondays)
  5. ☐ Share this document with OT at next session

This document was prepared with AI assistance as part of the SACS Court of Coherence case management system (SACS-RD-001). It is designed to support occupational therapy goal-setting for a real, deadline-driven professional project.

Content is user-generated and unverified.
    Amicus Brief Project Plan: Google Monopoly Appeal Strategy | Claude