Starr™ v. Google LLC, 2026 WL 1603313 (W.D. Tex. June 3, 2026)
The Western District of Texas granted Google’s motion to dismiss all claims brought by Katherine Starr (formerly Annabelle Cripps), a self-described “legal theorist” and former British Olympic swimmer who alleged that Google’s search results failed to prominently display her name in connection with her trademarked legal frameworks, including “Negligent Digital Architecture™” and “Digital Maritime Doctrine™.” Starr contended that when users searched for her frameworks, Google’s algorithm returned information about other people named Katherine Starr, thereby diverting professional opportunities from her business, KSTARR Enterprises LLC.
The court dismissed each of Starr’s four claims:
- Lanham Act false designation of origin: Starr failed to allege that Google placed her mark on goods or used her mark in connection with services in commerce.
- Tortious interference: Starr made only conclusory allegations and failed to identify any specific prospective business relationships; the alleged business impact resulted from Google’s general algorithmic practices, not targeted interference.
- “Negligent Digital Architecture”: The court found this novel cause of action was “based in her own legal frameworks, not state or federal law” and had no recognition under existing law. When Starr attempted to reframe this theory as a products liability claim, the court rejected the recharacterization because Starr did not allege that Google’s search engine was “unreasonably dangerous” or offer any facts suggesting its algorithms were unreasonably dangerous.
- “Commercial Attribution Rights”: No state or federal cause of action exists for this claim.
Although Google raised Section 230 as a defense, the court declined to address it, finding the claims failed on their own terms. The opinion was issued as a Report and Recommendation by the magistrate judge.
Surfaced via Eric Goldman’s Technology & Marketing Law Blog.