For defamatory statements about public figures, "actual malice" is a necessary component of defamation. For private individuals, plaintiffs just have to prove "negligence", that Google didn't act with reasonable care before publishing. It's unclear whether courts would find negligence, but a decent lawyer would argue something like: "By explicitly stating in their disclaimer that Google knows some of the information they are publishing might be inaccurate, they are actively demonstrating that they did not verify the claims - and therefore willfully acted with reckless disregard for the truth."

This is exactly why Google's public comment on this case from the TFA is:

> "AI Overviews frequently improve to show the most helpful information, and we invest significantly in the quality of responses. When issues arise – like if our features misinterpret web content or miss some context – we use those examples to improve our systems and may take action under our policies."

Google's statement is carefully crafted to make the case that they "act with reasonable care" for legal effect, rather than to win any points in the court of public opinion. Courts have yet to determine what passes the reasonable-care test for negligence wrt AI output. Google feels they need to make sure that regardless of anything else that happens in this case, that the decision does not find their publishing was negligent.