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Your disavow file is now an evidence file

A judge let a negative SEO lawsuit over 2,350 toxic backlinks proceed as false advertising, and the hook was not the ranking damage. It was the anchor text.

JBJosh BernsteinManaging Partner · AUG 14, 2026 · 10 MIN READ
2,350+
toxic backlinks alleged in the campaign
6 mo
duration of the alleged campaign, April to October 2025
JUN 2
date of the ruling on the motion to dismiss
1
claim that survived, and it was not a ranking claim
TL;DR · 60 SECONDSIn Montway LLC v. Nexus AT LLC, Judge Matthew Kennelly ruled on June 2, 2026 that false advertising claims under the Lanham Act could proceed over an alleged campaign of more than 2,350 toxic backlinks built between April and October 2025. California unfair competition claims were dismissed. The reasoning that survived had nothing to do with rankings: the court treated the anchor text itself as a literally false statement, because it appeared to promise one destination and sent users elsewhere. That reframing is what makes this negative SEO lawsuit worth reading closely.

Negative SEO has always been a frustrating problem to raise with a client, because the honest answer was that there was rarely anything to do about it beyond disavow and wait. There was no forum, no remedy, and no credible way to price the damage. A ruling from June, surfaced this week, changes the shape of that conversation.

Two caveats before anything else, and they matter. I am not a lawyer and none of this is legal advice. And a ruling on a motion to dismiss is not a finding that anybody did anything. It means the plaintiff has alleged enough that the case can proceed to be tested. Plenty of claims that survive dismissal go on to lose.

What the negative SEO lawsuit actually alleges

The plaintiff alleges a campaign running from April to October 2025 in which more than 2,350 backlinks were built to its site from low-quality sources, with anchor text designed to mislead. The claims were brought under the federal Lanham Act, which governs false advertising and unfair competition between businesses, and under California unfair competition law.

Kennelly allowed the Lanham Act false advertising claims to go forward and dismissed the California claims. The reported reasoning on the surviving claim is the interesting part: the anchor text was literally false because it appeared to promise one destination but sent users elsewhere.

ELEMENTDETAILWHY IT MATTERS
CaseMontway LLC v. Nexus AT LLCBusiness against business, not platform against spammer
Ruling dateJune 2, 2026Motion to dismiss, not a merits decision
Volume allegedMore than 2,350 backlinksScale supports intent rather than accident
Window allegedApril to October 2025Sustained campaign, not a one-off
Surviving claimLanham Act false advertisingA commercial-speech theory, not a ranking theory
Dismissed claimCalifornia unfair competitionThe federal route is the one that worked
THE FRAMING THAT CARRIESThe court did not have to decide whether Google was harmed, whether rankings moved, or how search works. It only had to decide whether a public statement about a business was false. That is a much easier thing to prove.

The reasoning that makes this portable

Every previous attempt to litigate negative SEO ran into the same wall. To claim ranking damage you have to explain an algorithm nobody outside Google understands, prove causation inside a system with hundreds of moving parts, and quantify a loss that depends on counterfactual traffic. Courts do not enjoy any of that and defendants can muddy all of it.

The anchor text theory sidesteps the entire problem. Anchor text is a published statement, visible to humans, that describes where a link goes. If it says one thing and the link goes somewhere else, that is a false statement made in commerce. No algorithm needs explaining.

1The statement is the artifactA link with misleading anchor text is evidence you can screenshot, archive, and hand to a court. It does not require an expert witness to interpret.
2The audience is consumers, not crawlersFalse advertising law protects people who might be deceived. The claim works precisely because the anchor text is aimed at a reader, whatever the builder's real target was.
3Volume supplies intentOne bad link is noise. Two thousand three hundred and fifty over six months is a pattern, and patterns are how plaintiffs get past the argument that something was accidental.

That third point is worth dwelling on for anyone who builds links for a living. The same reasoning that makes a malicious campaign actionable does not stop at malice. A large-scale link programme with anchor text that misdescribes the destination is, on this theory, making a lot of statements. Nobody should read one ruling as an existential threat to link building and digital PR, but the sloppy end of the industry has been writing anchor text as a keyword slot rather than as a claim, and that habit now has a downside it did not have in May.

Why the ranking harm was never the point

It is worth being clear that this case does not establish that toxic backlinks damage rankings, and it would be a mistake to let it get quoted that way. Google has said for years that most spammy inbound links are simply ignored, and the practitioner consensus, with plenty of exceptions and loud arguments at the edges, has broadly moved that way too. Nothing in a ruling on a motion to dismiss tells you anything about how a search algorithm behaves.

Expect the misreading anyway. A headline about toxic backlinks and a court will be compressed into proof that negative SEO works, and somebody will use it to sell a monitoring subscription. It is worth being the person in the room who has read the actual reasoning, because the reasoning is more useful than the misreading, and it points at a different set of actions. The teams we work with on digital PR and its measurement have been having a version of this argument about anchor quality for a while.

The claim that survived does not depend on that question at all. A plaintiff does not need to prove the links moved anything in Google. It needs to prove false statements were made in commerce that could deceive and caused it harm. Reputational harm, diverted customers, and remediation costs are all on the table without an algorithm ever entering the room.

The legal question is not whether the links worked. It is whether the words attached to them were true.

That separation is healthy, and it points at something the industry has been sloppy about for a decade. We have treated anchor text as a ranking input and forgotten it is also a public description of somebody's business. When we wrote about which link types AI engines actually trust, the through line was that credibility is what carries weight. A link whose description is false is not a credibility signal in any system, machine or human.

What a negative SEO lawsuit needs that most teams do not keep

Here is the practical consequence for in-house and agency teams, and it has nothing to do with suing anyone. If a campaign is ever run against a client, the ability to do anything about it depends entirely on evidence that was collected while the campaign was happening. Backlink indexes are snapshots. Spam domains go offline. Anchor text gets edited. A link that existed in April and vanished in October leaves very little behind.

What to retain, and how often● LIVE
Weekly Full backlink export with anchor text, source URL,
first-seen date and target URL. Store it, do not overwrite.
 
Weekly Diff against last week. Flag: sudden volume spikes,
repeated exact-match anchors, anchors naming a competitor,
anchors that misdescribe the destination page.
 
On flag Archive the live page. A screenshot plus a web archive
capture, dated. The page will not be there later.
 
Monthly Snapshot referring-domain counts and organic visibility
so a before-and-after baseline exists without reconstruction.
 
Always Keep the disavow file versioned, with dates and reasons.

Most teams do none of this. They pull a backlink report when something looks wrong, which is exactly when the evidence has already started to decay. The change in practice is small and cheap: keep the exports, diff them, and archive anything anomalous while it still exists.

Monitoring and disavow, reconsidered

Disavow has had a strange decade. It went from essential to unnecessary to slightly embarrassing, and a lot of teams stopped maintaining the file at all on the reasonable grounds that Google says it rarely helps. The tooling followed the sentiment: plenty of agencies dropped backlink monitoring from their standard reporting entirely, on the view that it was a legacy metric kept alive by vendors who sell backlink data.

That view was defensible when the only question a backlink profile answered was a ranking question. It is less defensible now that the profile is also a record of what other people have published about your client. Those are different jobs with different retention requirements, and only one of them was ever satisfied by checking a dashboard once a quarter. Any serious SEO and GEO audit should treat the historical link record as a deliverable rather than a diagnostic.

That reasoning is still sound as search hygiene and now incomplete as risk management. A maintained, dated disavow file is a contemporaneous record that you identified a problem, when you identified it, and what you did about it. Whether or not it moves anything in Google, it is documentation, and documentation is what turns a vague grievance into a claim somebody can act on.

RECORD
Keep the file even if you doubt it worksIts value has shifted from ranking remedy to dated record. Version it, annotate it, and never overwrite history.
MONITOR
Alert on anchor text, not just volumeVolume spikes get noticed. Misleading anchors on normal volume do not, and the anchors are the actionable part.
HYGIENE
Audit your own anchors firstBefore worrying about attackers, check that every anchor pointing at your client accurately describes where it goes. Including yours.
PROCESS
Escalate early, quietlySix months of a sustained campaign is a long time to be gathering nothing. Tell counsel when the pattern appears, not when the traffic drops.

The third card is the one most likely to be uncomfortable. Plenty of legitimate link programmes have used anchor text that stretches: a phrase chosen because it is the target keyword rather than because it describes the page. That was a stylistic complaint last year. It is a slightly different kind of complaint now, and the fix costs nothing beyond writing accurate anchors, which is also better practice for the earned media that correlates with AI visibility.

What to change this month

Three changes, none of which need a budget. First, start keeping weekly backlink exports with anchor text and first-seen dates, and stop overwriting them. Second, add an anchor-accuracy check to your monitoring so an anchor that misdescribes its destination raises a flag on its own, without needing a volume spike alongside it. Third, review the anchors your own campaigns are producing and fix any that promise something the landing page does not deliver.

Then leave the legal question alone unless you have a real problem, in which case take it to counsel with your archive in hand rather than a hunch. One ruling on a motion to dismiss is a long way from settled law, and anybody telling you the industry just changed is getting ahead of the record. What has changed is cheaper and more certain: there is now a documented reason to keep evidence you were probably throwing away, and a documented reason to write anchor text that is true. Both were good ideas anyway.

Source: Montway LLC v. Nexus AT LLC, ruling of June 2, 2026, reported by Danny Goodwin at Search Engine Land, August 12, 2026 (coverage). Nothing here is legal advice.

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Josh BernsteinMANAGING PARTNER, SOMETHING INC.

Josh leads work at the intersection of SEO and generative engines at Something Inc., helping B2B brands get ranked and cited across every major AI engine.

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