Google's EU Copyright Submission: Site-Blocking Safeguards

Google's filing in the European Commission copyright review argues against broad infrastructure-level site blocking while accepting tightly constrained injunctions as a last resort. The submission targets blocks aimed at DNS resolvers, VPNs, CDNs, and shared IP addresses because those layers can carry lawful services unrelated to the alleged infringement. Google submission PDF, retrieved 10 August 2026.

Google's position

Google says injunctions should be subsidiary. A claimant should first show an attempt to reach the infringer, show that notice and takedown was insufficient, and show that removal at the hosting source was ineffective. Submission pages 29-30, retrieved 10 August 2026.

The company argues that orders should target the appropriate layer and source of infringing content. It gives stream-server IPs whose predominant purpose is infringement as an example of a narrower target, while arguing that injunctions should not target global infrastructure such as DNS resolvers, VPNs, or CDNs. Submission page 30, retrieved 10 August 2026.

Why shared infrastructure matters

The filing says a DNS block makes an entire domain inaccessible, including lawful content, and that modern IP addresses are often shared by multiple domains and services. It argues that blocking one shared address can restrict unrelated lawful sites. Submission pages 27 and 30, retrieved 10 August 2026.

Google also says DNS blocks do not remove content and can be bypassed with an alternative resolver. It cites a 2019 Portugal incident in which blocks on Google-hosted virtual IP addresses disrupted Google services and unrelated Cloud customers sharing those addresses. That incident description is Google's account in its own filing. Submission page 27, retrieved 10 August 2026.

The safeguards Google requested

• Evidence of ownership, infringement, and harm should face judicial scrutiny. Submission page 31, retrieved 10 August 2026.
• Decision-makers should assess proportionality instead of automatically converting rightsholder demands into orders. Submission page 31, retrieved 10 August 2026.
• Decisions, reasons, and routes to challenge a block should be transparent to affected users, third parties, and intermediaries. Submission pages 31-32, retrieved 10 August 2026.
• Injunctions should be limited in time, with extensions subject to judicial review of effect and efficacy. Submission page 32, retrieved 10 August 2026.
• Compliance should not require an intermediary to monitor its traffic, and implementation costs should be shared. Submission pages 31-32, retrieved 10 August 2026.

Current status

The Commission initiative page remains a closed call for evidence. Google's filed response provides a specific safeguard proposal for any later measure; it is not the later measure. Commission initiative record, retrieved 10 August 2026; Google feedback record, retrieved 10 August 2026.

Sources

• European Commission feedback record F33504634, retrieved 10 August 2026.
• Google submission attachment 090166e52ff2de8c, retrieved 10 August 2026.
• European Commission targeted-copyright initiative, retrieved 10 August 2026.