Anti-Circumvention: Reddit's Case Against Perplexity

On October 22, 2025, Reddit, Inc. filed a federal lawsuit in the Southern District of New York against Perplexity AI, Inc. and associated data-scraping firms, alleging violations of the Digital Millennium Copyright Act's anti-circumvention provisions (17 U.S.C. §1201), along with related claims for unjust enrichment and unfair competition. Building on the strategy advanced in its earlier Anthropic suit, Reddit frames the dispute not as a garden-variety copyright infringement case but as a §1201 anti-circumvention suit targeting what it calls "industrial-scale" evasion of technical controls used to harvest Reddit content through Google's search results. According to the complaint, the defendants allegedly masked identities, rotated IP addresses, and bypassed access controls to scrape billions of Google search-engine results pages ("SERPs") containing Reddit URLs, text, images, and videos—data that Reddit claims Perplexity subsequently incorporated into its "answer engine."

There are two notable factual allegations that distinguish this case. First, Reddit alleges that it created a post that was indexable by Google's search engine but not otherwise accessible, and that Perplexity's answer engine surfaced material portions of that post within hours; evidence that, Reddit contends, demonstrates Perplexity (directly or through the co-defendants) scraped Google's results and ingested the data. Second, after Reddit issued a May 2024 cease-and-desist, Perplexity's citations to Reddit purportedly increased forty-fold, despite public statements that it respects robots.txt directives.

Rather than challenging how Perplexity ultimately used the copyrighted materials, Reddit's §1201(a)(1) claim shifts the focus upstream to the act of bypassing technological measures that control access to copyrighted works, whether or not the ultimate use might otherwise be defensible. The complaint also highlights the allegedly unlawful conduct of the data-scraping co-defendants, asserting that Perplexity collaborated with them to facilitate "industrial-scale" circumvention of Reddit's and Google's access controls. Reddit pleads contributory and assisting circumvention theories together withunjust-enrichment and unfair-competition claims, seeking both injunctive relief and damages for business harm.

Reddit situates Perplexity within a broader ecosystem of data brokers and scrapers and contrasts Perplexity's approach with Reddit's paid license partnerships with OpenAI and Google, positioning this suit as a defense of a licensing model Reddit asserts Perplexity's competitors are honoring. Reddit alleges that Perplexity's practices not only diminish the value of existing licensing arrangements, but also divert user engagement away from Reddit, removing the need to access Reddit content directly via its website, mobile app, or services and thereby impairing the platform's commercial utility. The complaint further asserts that by bypassing Reddit's technical controls, the scraping captured deleted, private, or otherwise restricted posts, preventing Reddit from honoring users' deletion requests and privacy preferences. This, Reddit alleges, jeopardizes users' ability to protect their privacy interests and control access to their content, ultimately undermining Reddit's ability to maintain user trust and engagement.

We expect threshold disputes in this case, the resolution of which will be predicated on (i) whether or not Google's and Reddit's measures qualify as §1201 "technological measures" that effectively control access, (ii) whether or not scraping SERPs to obtain Reddit content constitutes access to the underlying copyrighted works, and (iii) Perplexity's knowledge/intent and the role of intermediary data-scraping firms. Perplexity may emphasize public availability of SERP snippets and argue that any limits regulate automated volume rather than access to protected expression.

Reddit v. Perplexity illustrates how platforms are increasingly turning to access-control and contract-based theories where direct copyright claims are unavailable or uncertain. For content owners and rightsholders, the case highlights the importance of pairing technical barriers (e.g., API gating, rate-limiting, robots.txt) with contractual enforcement and auditable logs to promptly detect and substantiate circumvention claims. For AI developers, it reinforces that publicly available content is not necessarily "free for training" if obtained through methods that evade access restrictions, an increasingly risky strategy under §1201(a)(1) of the DMCA.

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