"In addition to establishing that the defendant was aware of his statement's defamatory meaning, the plaintiff also must show that the defamatory statement is false. The falsity requirement has evolved gradually through a two-step process. Initially, the courts recognized that truth was a defense in a defamation suit. With time, however, the burden of proof on the issue of the statement's truth or falsity shifted to the plaintiff, so that now a statement is not actionable unless it can be proven false."

https://scholarship.law.wm.edu/cgi/viewcontent.cgi?params=/c... (pp. 851ff).

If a typical page can be shown to be prima facie safe to well formed parsers, without obvious shell code. It would require a response if there was additional evidence google was using in their determination.