Michael G. Stern

Google is opposing a move by Unlockd Media seeking the recusal of U.S. District Judge Haywood S. Gilliam Jr. in an antitrust lawsuit in California federal court, arguing that the judge's close relationship with Google's vice president for litigation and discovery doesn't require him to step away from the case. In a response filed Wednesday, Google said the instant case does not merit Judge Gilliam's recusal, as the litigation VP, Cassandra Knight, joined the technology giant well into the case and has had no involvement in the matter. "Ms. Knight's lack of involvement in this case, coupled with the fact that she is one of hundreds of legal team members and many thousands of employees who work at Google, confirms that no reasonable person could question the court's impartiality here," according to the filing. "As the court's multiple orders granting Google's respective motions to dismiss made clear, all the at-issue conduct in this case began many years before Ms. Knight started working at Google." Google added that the case began well before Knight began working for the company in August 2022 and that Unlockd brought its first complaint in September 2021. The case was assigned in October 2021, and Unlockd filed an amended complaint in January 2022, Google pointed out, adding that the parties had fully briefed Google's motion to dismiss by June 2022. The friendship between Judge Gilliam and Knight was documented in a July 2025 article in the Stanford Lawyer Magazine that noted the judge officiated at Knight's wedding in 2021 and that Knight had spoken at Judge Gilliam's investiture ceremony about a decade ago. These same revelations recently prompted video-sharing site Rumble to request Judge Gilliam's recusal in its own antitrust suit against Google. Rumble's counsel reportedly learned about the judge's connection to Knight in October. When seeking the judge's recusal in November, Unlockd cited Rumble's case and raised the same concerns about the appearance of impropriety. It wrote that "this court's nondisclosure is particularly significant here because it continued presiding over this case — including through the entry of summary judgment in Google's favor — despite issuing recusal orders in other Google-related matters after Knight's arrival at Google." Unlockd added that it wasn't aware of the relationship until after the Rumble filing. Google countered that Unlockd didn't make any arguments of its own and instead pointed "to a different motion filed by a different plaintiff in an unrelated case, with little attempt to apply the arguments to this case." The tech giant also said Unlockd cited two cases in support of its motion but did not explain why they were relevant when neither case showed that a friendship between a judge and an employee of a party can give rise to an appearance of partiality. Furthermore, Google asserted, Unlockd's citations to other cases where Google and Knight's prior employer is a party and the court issued recusal orders also do not support recusal in this matter. The company reiterated Knight's lack of employment at the time and lack of involvement. Judge Gilliam granted Google's request to dismiss the case earlier this year, saying in a February opinion that Unlockd "has offered no factual support from which the court could assume that harm to plaintiff is somehow tantamount to harm to this entire [digital advertising] market." "Plaintiff's theory is also further undermined by its acknowledgment that similar products do continue to exist in the digital advertising market," he wrote. Unlockd is appealing the decision to the Ninth Circuit. In Wednesday's filing, Google alternatively contended that Unlockd is only seeking a prospective recusal if the case returns to the lower court and that the court can defer its ruling unless and until the Ninth Circuit reverses and remands the matter. Counsel for the parties in the case Unlockd brought did not immediately respond to Law360's requests for comment Thursday. Unlockd is represented by Allan B. Diamond, Justin B. Strother and Damion Robinson of Diamond McCarthy LLP and Nicholas A. Gravante Jr., Philip J. Iovieno and Jack G. Stern of Cadwalader Wickersham & Taft LLP. Google is represented by Beatriz Mejia, Alexander J. Kasner, Ashley K Corkery, Deepti Bansal and John C. Dwyer of Cooley LLP. The case is Unlockd Media Inc. Liquidation Trust v. Google LLC et al., case number 4:21-cv-07250, in the U.S. District Court for the Northern District of California.

Dec 4

3 min

Google is urging the Ninth Circuit to disregard concerns Rumble has raised about the trial judge's relationship with the tech giant's litigation vice president, saying Friday that the information is irrelevant to the YouTube rival's appeal of the court's ruling that its antitrust lawsuit was filed too late. Rumble asked the appeals court earlier this month to take notice of a Stanford Law School article detailing U.S. District Judge Haywood S. Gilliam Jr.'s years-long friendship with Google's vice president for litigation and discovery, Cassandra Knight, as well as recusal orders Judge Gilliam has issued in other cases. The Stanford Lawyer Magazine article detailed how Judge Gilliam officiated at Knight's wedding in 2021 and how Knight spoke at his investiture ceremony about a decade ago. Those revelations also prompted now-defunct advertising app maker Unlockd Media to request his recusal in its antitrust dispute with Google, which the judge dismissed in February. Google, however, argued Friday that these materials are "irrelevant to [Rumble's] appeal." That came after the tech giant called the streaming platform's recusal bid a "cynical maneuver" for its appeal last week, arguing that federal courts have repeatedly recognized that friendships between lawyers and judges, "without more," don't require recusal. "Rumble's strategy in bringing this motion is transparent," Google's most recent filing said. "Filed just days after Google's answering brief in which Google explained why summary judgment should be affirmed for multiple reasons, Rumble's motion seeks to distract from its meritless appeal by attempting to unfairly cast doubt on the district court's impartiality. Yet at the same time, Rumble expressly acknowledges — as it must — that there is no evidence of actual bias in this case." Counsel for the parties did not immediately respond to Law360's request for comment. Judge Gilliam tossed Rumble's case back in May, siding with Google that its monopolization claim is barred by its four-year statute of limitations. The lawsuit accused Google of rigging its search results to favor subsidiary YouTube over Rumble. Rumble is represented by Robert W. Dickerson Jr. and Allan W. Jansen of Competition & Technology Law Group LLP, Nicholas A. Gravante, Philip J. Iovieno, Jack G. Stern and Kristen J. McAhren of Cadwalader Wickersham & Taft LLP and David Boies of Boies Schiller and Flexner LLP. Google is represented by John E. Schmidtlein, Stephen J. Fuzesi, Benjamin M. Greenblum, Daniel Whiteley and Jesse T. Clay of Williams & Connolly LLP and David H. Kramer of Wilson Sonsini Goodrich & Rosati PC. The case is Rumble Inc. v. Google Inc., case number 5:21-cv-00229, in the U.S. District Court for the Northern District of California.

Nov 24

2 min

Law360 (November 20, 2025, 2:34 PM EST) -- Unlockd Media has become at least the second Google antitrust foe to seek the recusal of U.S. District Judge Haywood S. Gilliam Jr. over his close relationship with Google's vice president for litigation and discovery. The now-defunct advertising app maker said Wednesday that the judge failed to disclose a longstanding friendship with the litigation VP, Cassandra Knight. The friendship was documented in July in a Stanford Law School article, which noted that Judge Gilliam, of the Northern District of California, officiated at Knight's wedding in 2021 and that Knight spoke at Judge Gilliam's investiture ceremony about a decade ago. These same revelations recently prompted video-sharing site Rumble to request Judge Gilliam's recusal in its antitrust suit against Google. Rumble's counsel reportedly learned about his connection to Knight in October. " In addition to the same appearance-of-impropriety concerns raised in Rumble, Unlockd submits that this court's nondisclosure is particularly significant here because it continued presiding over this case — including through the entry of summary judgment in Google's favor — despite issuing recusal orders in other Google-related matters after Knight's arrival at Google," Unlockd said. "Unlockd and its counsel were unaware of this relationship until after the Rumble filing, and have moved without undue delay upon learning of the conflict." Unlockd filed its lawsuit against Google in 2021. The company has alleged that Google's decision to ban it from the Google Play Store and AdMob, Google's advertising subsidiary, "was the direct cause of Unlockd's demise." "Ultimately, Google succeeded in eliminating Unlockd as a competitor," it said in an amended complaint. "With existing partners backing out, new partners unwilling to commit and investors reluctant to supply more capital — all due to Google's actions — Unlockd was forced to file for bankruptcy and cease operations." Judge Gilliam granted Google's request to dismiss the case earlier this year, saying in a February opinion that Unlockd "has offered no factual support from which the court could assume that harm to plaintiff is somehow tantamount to harm to this entire [digital advertising] market." "Plaintiff's theory is also further undermined by its acknowledgment that similar products do continue to exist in the digital advertising market," he added. Unlockd is appealing the decision to the Ninth Circuit. Counsel for the parties in this case did not immediately respond to Law360's request for comment Thursday. Unlockd is represented by Allan B. Diamond, Justin B. Strother and Damion Robinson of Diamond McCarthy LLP, and by Nicholas A. Gravante, Jr., Philip J. Iovieno and Jack G. Stern of Cadwalader Wickersham & Taft LLP. Google is represented by Michael Graham Rhodes, Alexander J. Kasner, Ashley K Corkery, Beatriz Mejia, Deepti Bansal and John C. Dwyer of Cooley LLP. The case is Unlockd Media Inc. Liquidation Trust v. Google LLC et al., case number 4:21-cv-07250, in the U.S. District Court for the Northern District of California. –Additional reporting by Emily Sawicki. Editing by Karin Roberts. For a reprint of this article, please contact reprints@law360.com.

Nov 20

2 min

Law360 (November 20, 2025, 2:34 PM EST) -- Unlockd Media has become at least the second Google antitrust foe to seek the recusal of U.S. District Judge Haywood S. Gilliam Jr. over his close relationship with Google's vice president for litigation and discovery. The now-defunct advertising app maker said Wednesday that the judge failed to disclose a longstanding friendship with the litigation VP, Cassandra Knight. The friendship was documented in July in a Stanford Law School article, which noted that Judge Gilliam, of the Northern District of California, officiated at Knight's wedding in 2021 and that Knight spoke at Judge Gilliam's investiture ceremony about a decade ago. These same revelations recently prompted video-sharing site Rumble to request Judge Gilliam's recusal in its antitrust suit against Google. Rumble's counsel reportedly learned about his connection to Knight in October. " In addition to the same appearance-of-impropriety concerns raised in Rumble, Unlockd submits that this court's nondisclosure is particularly significant here because it continued presiding over this case — including through the entry of summary judgment in Google's favor — despite issuing recusal orders in other Google-related matters after Knight's arrival at Google," Unlockd said. "Unlockd and its counsel were unaware of this relationship until after the Rumble filing, and have moved without undue delay upon learning of the conflict." Unlockd filed its lawsuit against Google in 2021. The company has alleged that Google's decision to ban it from the Google Play Store and AdMob, Google's advertising subsidiary, "was the direct cause of Unlockd's demise." "Ultimately, Google succeeded in eliminating Unlockd as a competitor," it said in an amended complaint. "With existing partners backing out, new partners unwilling to commit and investors reluctant to supply more capital — all due to Google's actions — Unlockd was forced to file for bankruptcy and cease operations." Judge Gilliam granted Google's request to dismiss the case earlier this year, saying in a February opinion that Unlockd "has offered no factual support from which the court could assume that harm to plaintiff is somehow tantamount to harm to this entire [digital advertising] market." "Plaintiff's theory is also further undermined by its acknowledgment that similar products do continue to exist in the digital advertising market," he added. Unlockd is appealing the decision to the Ninth Circuit. Counsel for the parties in this case did not immediately respond to Law360's request for comment Thursday. Unlockd is represented by Allan B. Diamond, Justin B. Strother and Damion Robinson of Diamond McCarthy LLP, and by Nicholas A. Gravante, Jr., Philip J. Iovieno and Jack G. Stern of Cadwalader Wickersham & Taft LLP. Google is represented by Michael Graham Rhodes, Alexander J. Kasner, Ashley K Corkery, Beatriz Mejia, Deepti Bansal and John C. Dwyer of Cooley LLP. The case is Unlockd Media Inc. Liquidation Trust v. Google LLC et al., case number 4:21-cv-07250, in the U.S. District Court for the Northern District of California. –Additional reporting by Emily Sawicki. Editing by Karin Roberts. For a reprint of this article, please contact reprints@law360.com.

Nov 20

2 min

Google is opposing a move by Unlockd Media seeking the recusal of U.S. District Judge Haywood S. Gilliam Jr. in an antitrust lawsuit in California federal court, arguing that the judge's close relationship with Google's vice president for litigation and discovery doesn't require him to step away from the case. In a response filed Wednesday, Google said the instant case does not merit Judge Gilliam's recusal, as the litigation VP, Cassandra Knight, joined the technology giant well into the case and has had no involvement in the matter. "Ms. Knight's lack of involvement in this case, coupled with the fact that she is one of hundreds of legal team members and many thousands of employees who work at Google, confirms that no reasonable person could question the court's impartiality here," according to the filing. "As the court's multiple orders granting Google's respective motions to dismiss made clear, all the at-issue conduct in this case began many years before Ms. Knight started working at Google." Google added that the case began well before Knight began working for the company in August 2022 and that Unlockd brought its first complaint in September 2021. The case was assigned in October 2021, and Unlockd filed an amended complaint in January 2022, Google pointed out, adding that the parties had fully briefed Google's motion to dismiss by June 2022. The friendship between Judge Gilliam and Knight was documented in a July 2025 article in the Stanford Lawyer Magazine that noted the judge officiated at Knight's wedding in 2021 and that Knight had spoken at Judge Gilliam's investiture ceremony about a decade ago. These same revelations recently prompted video-sharing site Rumble to request Judge Gilliam's recusal in its own antitrust suit against Google. Rumble's counsel reportedly learned about the judge's connection to Knight in October. When seeking the judge's recusal in November, Unlockd cited Rumble's case and raised the same concerns about the appearance of impropriety. It wrote that "this court's nondisclosure is particularly significant here because it continued presiding over this case — including through the entry of summary judgment in Google's favor — despite issuing recusal orders in other Google-related matters after Knight's arrival at Google." Unlockd added that it wasn't aware of the relationship until after the Rumble filing. Google countered that Unlockd didn't make any arguments of its own and instead pointed "to a different motion filed by a different plaintiff in an unrelated case, with little attempt to apply the arguments to this case." The tech giant also said Unlockd cited two cases in support of its motion but did not explain why they were relevant when neither case showed that a friendship between a judge and an employee of a party can give rise to an appearance of partiality. Furthermore, Google asserted, Unlockd's citations to other cases where Google and Knight's prior employer is a party and the court issued recusal orders also do not support recusal in this matter. The company reiterated Knight's lack of employment at the time and lack of involvement. Judge Gilliam granted Google's request to dismiss the case earlier this year, saying in a February opinion that Unlockd "has offered no factual support from which the court could assume that harm to plaintiff is somehow tantamount to harm to this entire [digital advertising] market." "Plaintiff's theory is also further undermined by its acknowledgment that similar products do continue to exist in the digital advertising market," he wrote. Unlockd is appealing the decision to the Ninth Circuit. In Wednesday's filing, Google alternatively contended that Unlockd is only seeking a prospective recusal if the case returns to the lower court and that the court can defer its ruling unless and until the Ninth Circuit reverses and remands the matter. Counsel for the parties in the case Unlockd brought did not immediately respond to Law360's requests for comment Thursday. Unlockd is represented by Allan B. Diamond, Justin B. Strother and Damion Robinson of Diamond McCarthy LLP and Nicholas A. Gravante Jr., Philip J. Iovieno and Jack G. Stern of Cadwalader Wickersham & Taft LLP. Google is represented by Beatriz Mejia, Alexander J. Kasner, Ashley K Corkery, Deepti Bansal and John C. Dwyer of Cooley LLP. The case is Unlockd Media Inc. Liquidation Trust v. Google LLC et al., case number 4:21-cv-07250, in the U.S. District Court for the Northern District of California.

Dec 4

3 min