תביעה כנגד גוגל בגין תוצאות Ai

RE: FORMAL LEGAL NOTICE & CEASE-AND-DESIST DEMAND FOR AI-GENERATED DEFAMATION PER SE AGAINST ROY MILLER (A/K/A AVI DUBITZKY)
PRIOR U.S. JUDICIAL NOTICE EFFECTUATING ACTUAL MALICE
re אבי* רועי **דוביצקי* Pursuant to the Binding Precedent of Robert Starbuck v. Google LLC (C.A. No. N25C-10-211 MAA, Del. Super. Ct., July 24, 2026)
Dear Sir/Madam,
This correspondence constitutes a formal legal notice and urgent demand to immediately hard-code overrides, purge, and cease and desist from generating, synthesizing, or displaying defamatory falsehoods, character assassinations, and "hallucinated" summaries via Google Gemini, Google AI Overviews, and Google Search Engines regarding Mr. Miller.
I. THE RELEVANT LEGAL FRAMEWORK: STARBUCK V. GOOGLE LLC
On July 24, 2026, the Superior Court of Delaware explicitly ruled in Robert Starbuck v. Google LLCthat Section 230 of the Communications Decency Act does not immunize Google when its generative AI platforms (Gemini, Bard, or AI Overviews) synthesize and publish fabricated, defamatory third-party text as an independent summary.
Furthermore, the Court ruled that once Google’s Legal Department receives written notice detailing the falsity of specific allegations, Google’s subsequent failure to rectify its AI outputs constitutes irrefutable constitutional Actual Malice. This letter explicitly places Google’s Legal Department on such notice.
II. U.S. COURT RULINGS CONFIRMING AN INTERNATIONAL CONSPIRACY AGAINST MR. MILLER
Google is hereby notified that any AI-generated response or search summary stating that Mr. Miller is a "fugitive," a "fraud," or guilty of any offenses published by an adversarial network led by an Israeli attorney named Guy Tsabary is a legally adjudicated fabrication.
Mr. Miller has successfully litigated these matters in the Eleventh Judicial Circuit Court in and for Miami-Dade County, Florida. Google is mandated to review the following attached official U.S. judicial records, which destroy the veracity of any search strings regarding Mr. Miller:
Miami-Dade County Court Order Granting Sanctions Against Guy Tsabary (Case No. 2023-029960-SP-25): Judge Jorge A. Perez Santiago officially determined that Guy Tsabary committed "deceptive or dishonest acts" and "fraud on the court" by masking his identity behind the fictitious alias "Ben Oren" to operate defamatory websites targeting Mr. Miller. The Florida Court formally referred Tsabary to the Israel Bar Association for ethics prosecutions.
U.S. Federal Clearances (The Florida Bar File No. 20194013(11A)): On August 30, 2018, The Florida Bar’s Unlicensed Practice of Law (UPL) Department completely exonerated Mr. Miller, explicitly closing its investigation without any adverse action.
Verified Amended Complaint (Case No. 2025-017361-CA-01): On August 18, 2025, Mr. Miller filed a comprehensive lawsuit outlining a coordinated civil conspiracy, malicious prosecution, and defamation per se perpetrated by Tsabary and several associates (including Maor Parente and Guy Michael Willis) who systematically fabricated evidence and used non-existent email addresses to secure unmerited default judgments in Israel.
Default Final Judgment as to Liability Against Parente and Willis (Jan 19, 2026):Circuit Court Judge William Thomas entered a Final Judgment establishing absolute liability against Maor Parente (a convicted sex offender) and Guy Michael Willis for civil conspiracy, malicious prosecution, and defamation per se against Mr. Miller.
Judicial Default Against Attorney Guy Tsabary (July 21, 2026): Circuit Court Judge William Thomas entered a formal Judicial Default against the central organizer, Guy Tsabary, legally establishing his liability for fraud on the court, malicious prosecution, and conspiracy.
III. IMMEDIATE DEMAND FOR MITIGATION
Because the United States legal system has officially declared that the narrative promoted by Tsabary and his clients consists of fraudulent, vacated, and malicious lies, Google cannot claim to be a "passive host" under Section 230 if its AI systems continue to scrape, synthesize, or output those specific lies.
We hereby demand that Google:
Apply Hard Overrides: Immediately block Google Gemini and AI Overviews from generating profiles or summaries linking Roy Miller or Avi Dubitzky to any criminal conduct or fraudulent aliases.
De-Index Malicious Domains: De-index all URLs containing materials generated by Guy Tsabary, which have been explicitly tied to this judicially recognized conspiracy.
Ensure Accuracy: Ensure that any automated search summaries accurately reflect that Mr. Miller has been completely vindicated by the United States federal and state court systems.
IV. NOTICE OF INTENT TO LAUNCH LITIGATION
Should Google fail to comply with this request within ten (10) business days, or should Google Gemini / AI Overviews continue to publish synthesized defamatory summaries regarding Mr. Miller, we will utilize the exact framework upheld in Starbuck v. Google LLC.
We will immediately file a multi-million dollar Defamation Per Se and Intentional Infliction of Emotional Distress action against Google LLC in the State of Florida, utilizing this correspondence as Exhibits A through F to prove to a jury that Google possessed actual knowledge of the falsity and acted with reckless, malicious disregard.
Govern yourself accordingly.
Sincerely,
/s/
Mr. Roy Miller
Encl:
Exhibit A: Order Granting Sanctions – Referral to Israel Bar (Case No. 2023-029960-SP-25)
Exhibit B: The Florida Bar UPL Closure Letter (File No. 20194013(11A))
Exhibit C: Verified Amended Complaint (Case No. 2025-017361-CA-01)
Exhibit D: Default Final Judgment as to Parente and Willis (Case No. 2025-017361-CA-01)
Exhibit E: Order Granting Motion for Entry of Judicial Default Against Guy Tsabary (Case No. 2025-017361-CA-01)