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Google Fonts cease-and-desist letter: what to do?

Since the judgment of the Regional Court of Munich I (20 Jan 2022, case 3 O 17493/20), numerous letters have been sent demanding damages and cease-and-desist over externally loaded Google Fonts — partly automated and in questionable volume.

The Google Fonts warning-letter wave goes back to a single ruling: on 20 January 2022 the Regional Court of Munich I awarded an affected person 100 euros in damages because, on loading the page, their IP address was transmitted to Google without a legal basis. In the aftermath, several law firms and partly dubious “interest groups” sent out thousands of often automatically generated demand letters to website operators whose pages loaded fonts directly from fonts.googleapis.com.

Transmitting an IP address without a valid legal basis may breach the GDPR. According to Germany's Federal Court of Justice (VI ZR 10/24), even a brief loss of control may constitute non-material damage. Whether a Google Fonts integration involves an infringement, damage and the necessary causal link must be assessed individually.

Anyone who receives such a letter should do three things in parallel: fix the technical cause immediately (embed fonts locally, check the source code), document the current state and the letter (screenshots, timestamps) and engage a law firm specialising in IT law before making a payment or signing a cease-and-desist declaration. Pre-formulated cease-and-desist declarations are often drafted too broadly and create a high risk of contractual penalties.

Is this a risk?

Transmitting the IP to Google without a legal basis can give rise to a claim for damages (Art. 82 GDPR). Whether there is a compensable damage in an individual case is disputed; mass letters that are serial and abusive have been rejected by courts. Having the specific letter reviewed by a lawyer is advisable.

What you can do

Häufige Fragen

Do I have to pay the amount demanded?
Not without review. Whether compensable damage exists has to be assessed case by case; where letters are recognisably serial and abusive, courts have rejected the claims. A legal review before any payment makes sense.
Should I sign the enclosed cease-and-desist declaration?
Not in the pre-formulated version. Such declarations are usually drafted too broadly and create a high contractual penalty for every future breach. If at all, a modified declaration should be submitted after a legal review.
How do I fix the cause?
Download the font weights you need, embed them locally via @font-face and remove all calls to fonts.googleapis.com and fonts.gstatic.com from HTML, CSS and plugins. In WordPress, plugins such as OMGF help; afterwards check the source code again.
Can it happen to me again?
Yes, as long as the site loads fonts externally. After localising them you should also check whether other external resources (icon fonts, Maps, embeds) transmit the IP — they are legally comparable.

How consentglass helps

The free scan checks the delivered HTML and shows which services are embedded, whether a cookie banner is detected and whether privacy-policy and legal-notice links are present — with context for each finding. It is not a substitute for legal advice.

Read on

This text is general information to the best of our knowledge, not legal advice. For an individual case, consult a law firm specialising in IT law.