With advancements in artificial intelligence, the use of algorithmic software has increased across a variety of industries. So too has scrutiny by antitrust agencies, private plaintiffs, and state and local governments across the country.

The July 2025 decision by the Ninth Circuit Court of Appeals in Epic Games v. Google marks a landmark development in the ongoing evolution of antitrust remedies for unilateral conduct in the technology sector. The court’s willingness to affirm not just prohibitory, but also mandatory, forward-looking injunctions—requiring Google to take affirmative steps to open its Android app ecosystem to competition—signals a vigorous approach to restoring competition in digital platforms.