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Conflicts over Domain Names Program of Instruction for Lawyers William Fisher June 25, 2004 © 2004. All rights reserved.

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Presentation on theme: "Conflicts over Domain Names Program of Instruction for Lawyers William Fisher June 25, 2004 © 2004. All rights reserved."— Presentation transcript:

1 Conflicts over Domain Names Program of Instruction for Lawyers William Fisher June 25, 2004 © All rights reserved

2 Types of Domain-Name Disputes

3 Cybersquatting Joshua Quittner registers “mcdonalds.com”

4 Typosquatting Misrosoft.com

5 Conflicts between Competitors Kaplan.com

6 Conflicts between Noncompetitors Howard Johnson registers “howardjohnson.com”

7 Retailers weber.com

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9 Retailers weber.com webergrills.com

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14 Commerical v. Noncommerical Users (Reverse Domain Name Hijacking) pokey.org Prima Toy Company

15 (December 2, 2000)

16 Fan Sites

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25 Parody and Commentary

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36 Initial Legal Responses

37 Types of Trademark Infringement

38 Identical Marks on Competitive Products

39 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products

40 Axes and Factors in Assessing Likelihood of Confusion §Similarity of Appearance  SQUIRT / QUIRST (for soft drinks) §Similarity of Sound  Huggies / Dougies (for disposable diapers) §Similarity of Meaning  Apple / Pineapple (for computer products)  Good Morning / Buenos Dias (for bath products) §Marketing Environment

41 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products

42 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products Similar Marks on Noncompetitive Products

43 Polaroid/McGregor Factors for Noncompetitive Products Ultimate issue: likelihood of confusion §Strength of the plaintiff’s mark §Similarity of the two marks §Proximity of the two products §Quality of the defendant’s product §Likelihood of the plaintiff “bridging the gap” §Actual confusion §Defendant’s “good faith” §Sophistication of buyers of the products §General equities

44 Varieties of “Consumer Confusion” §Source §Endorsement (e.g., Rolls Royce Radio Tubes) §Post-sale (e.g., Ferrari) §Initial Interest (e.g., Brookfield)

45 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products Similar Marks on Noncompetitive Products

46 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products Similar Marks on Noncompetitive Products Dilution

47 Forms of Dilution (Clinique 1996) §“Dilution by blurring occurs where ‘the defendant uses or modifies the plaintiff's trademark to identify the defendant's goods and services, raising the possibility that the mark will lose its ability to serve as a unique identifier of the plaintiff's product.’ Like tarnishment, blurring is concerned with an injury to the mark's selling power and ‘need not involve any confusion as to source or sponsorship.’” §“Tarnishment may occur when the plaintiff's mark is used by the defendant in association with unwholesome or shoddy goods or services. Tarnishment may also result from an association with obscenity, or sexual or illegal activity, but is not limited to seamy conduct.”

48 International Development of Dilution Doctrine §Originates in Germany, (Odol 1925) §Gradually expands in United States l Schecter, 1927 l State anti-dilution statutes, 1947-present l Federal Trademark Dilution Act, 1996 §Slow introduction elsewhere l Benelux countries, Germany adopt expansive doctrines l EC Harmonization Directive (1988) and EC Community TM Regulation (1993) are ambiguous Benelux countries and France favor generous reading England and ECJ resist

49 Types of Trademark Infringement Identical Marks on Competitive Products Similar Marks on Competitive Products Similar Marks on Noncompetitive Products Dilution

50 Applications of TM Infringement Doctrine to Domain Names §Amadeus Marketing (Italy 1997): TM owner must prove operation of similar DN is directly confusing or damaging to TM §British Telecommunications (UK 1998): A DN incorporating a TM “shows an inherent tendency to confuse” consumers §Champagne Céréales (France 1998): A DN mimicking an unregistered TM creates excessive likelihood of confusion §Braunschweig (Germany 1997): DN incorporating name of a city creates likelihood of confusion

51 Problems 1)“Use in Commerce”? 2)Consumer Confusion? 3)Federal Dilution Doctrine only applies to “famous” marks 4)Judicial proceedings are slow and expensive

52 The New Legal Regime

53 Dispute-Resolution Systems 1)UDRP 2)Anticybersquatting Consumer Protection Act

54 UDRP governs “Abusive Registrations and Use” of DNs §the domain name is identical or misleadingly similar to a trademark in which someone else has rights. §the holder of the domain name has no rights or legitimate interests in that domain name §the domain name has been registered and is used in bad faith.

55 UDRP governs “Abusive Registrations and Use” of DNs §the domain name is identical or misleadingly similar to a trademark in which someone else has rights. §the holder of the domain name has no rights or legitimate interests in that domain name §the domain name has been registered and is used in bad faith.

56 Examples of “Bad Faith” §Circumstances indicate that defendant’s main purpose was to sell DN to TM owner for more than the direct costs of registration §History of registering DNs to prevent TM owners from registering §Registering a DN in order to disrupt the business of a competitor §attempting to divert Internet users to Defendant’s site for commercial gain by creating confusion concerning source or sponsorship

57 Examples of “Legitimate Interests” Pre-dispute use or demonstrable preparations to use the DN in bona fide offering of goods or services Defendant was commonly known by the name Legitimate, noncommercial or fair use of the DN without intent to misleadingly divert or tarnish

58 Coverage §All gTLDs §Aprx. 1/3 of ccTLDs

59 Procedure §Complainant picks forum §Respondents have 20 days to respond §No additional submissions typically are permitted §Decision within 14 days of appointment of panelist(s) §Respondents default 50% of the time §Remedies: l Cancellation of the registration l Transfer of the DN to the complainant §Losing respondent can postpone remedy by filing suit within 20 days

60 UDRP Usage §As of May, 2004, 9377 proceedings l Roughly 15,000 domain names l (out of a total of aprx. 60,000,000 DNs of all sorts) §Rates of filing are declining gradually §Most of the DNs challenged under UDRP were registered during the boom of early 2000 §WIPO is the most popular provider, and becoming more so – aprx. 70% of the cases Plaintiffs win 71% of the time See Convergence Center Database: Mueller Report (6/24/2002):

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62 The End of the “Land Rush”? From:

63 The End of the “Land Rush”? From: But registration of country-code TLDs continue to rise

64 Mueller Report (6/24/2002):

65 UDRP Usage §As of May, 2004, 9377 proceedings l Roughly 15,000 domain names l (out of a total of aprx. 60,000,000 DNs of all sorts) §Rates of filing are declining gradually §Most of the DNs challenged under UDRP were registered during the boom of early 2000 §WIPO is the most popular provider, and becoming more so – aprx. 70% of the cases Plaintiffs win 71% of the time See Convergence Center Database: Mueller Report (6/24/2002):

66 Examples of “Bad Faith” §Circumstances indicate that defendant’s main purpose was to sell DN to TM owner for more than the direct costs of registration §History of registering DNs to prevent TM owners from registering §Registering a DN in order to disrupt the business of a competitor §attempting to divert Internet users to Defendant’s site for commercial gain by creating confusion concerning source or sponsorship

67 Examples of “Bad Faith” §Circumstances indicate that defendant’s main purpose was to sell DN to TM owner for more than the direct costs of registration §History of registering DNs to prevent TM owners from registering §Registering a DN in order to disrupt the business of a competitor §attempting to divert Internet users to Defendant’s site for commercial gain by creating confusion concerning source or sponsorship §Other forms of bad faith §No bad faith 30% 14% 9% 39% 15% 14% Source:

68 Dispute-Resolution Systems 1)UDRP 2)Anticybersquatting Consumer Protection Act

69 Dispute-Resolution Systems 1)UDRP 2)Anticybersquatting Consumer Protection Act (UDRP on Steroids)

70 ACPA, 15 U.S.C. sec (d) §TM owners have civil cause of action against defendants who, with bad faith intent to profit from the goodwill of a TM, register or use a DN that is: l identical or confusingly similar to a distinctive mark, l or dilutive of a famous mark

71 ACPA, 15 U.S.C. sec (d) §TM owners have civil cause of action against defendants who, with bad faith intent to profit from the goodwill of a TM, register or use a DN that is: l identical or confusingly similar to a distinctive mark, l or dilutive of a famous mark

72 ACPA Factors 1. Does  have IP rights in the DN? 2. Is the DN  ’s legal or customary name? 3.  ’s prior use of DN to offer goods/services 4.  ’s prior noncommercial or fair use of DN 5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion 6.  ‘s offer to sell DN – or habit of doing so 7. Did  provide false contact information 8. Did  acquire multiple DNs similar to TMs 9. How distinctive or famous is  ’s mark?

73 Safe Harbor: §“Bad faith intent” shall not be found where the defendant “believed and had reasonable grounds to believe that the use of the domain name was a fair use or otherwise lawful”

74 Remedies §Injunctive Relief (retroactive) §Damages (nonretroactive) §Statutory Damages (nonretroactive) l $ $100,000 per domain name §In rem jurisdiction §Registrars may sua sponte refuse to register marks that they deem to violate the rules

75 Application of ACPA §People for Ethical Treatment of Animals v. Doughney (EDVa 2000): peta.org used for parody site: “People eating tasty animals” l Links to leather-goods and meat websites

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77 ACPA Factors 1. Does  have IP rights in the DN? 2. Is the DN  ’s legal or customary name? 3.  ’s prior use of DN to offer goods/services 4.  ’s prior noncommercial or fair use of DN 5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion 6.  ‘s offer to sell DN – or habit of doing so 7. Did  provide false contact information 8. Did  acquire multiple DNs similar to TMs 9. How distinctive or famous is  ’s mark?

78 PETA 1. Does  have IP rights in the DN?  2. Is the DN  ’s legal or customary name?  3.  ’s prior use of DN to offer goods/services  4.  ’s prior noncommercial or fair use of DN  5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion  6.  ‘s offer to sell DN – or habit of doing so  7. Did  provide false contact information  8. Did  acquire multiple DNs similar to TMs  9. How distinctive or famous is  ’s mark? 

79 PETA 1. Does  have IP rights in the DN?  2. Is the DN  ’s legal or customary name?  3.  ’s prior use of DN to offer goods/services  ? ? 4.  ’s prior noncommercial or fair use of DN  ? ? 5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion  ? ? 6.  ‘s offer to sell DN – or habit of doing so  7. Did  provide false contact information  ? ? 8. Did  acquire multiple DNs similar to TMs  9. How distinctive or famous is  ’s mark? 

80 Applications of ACPA §People for Ethical Treatment of Animals v. Doughney (EDVa 2000): peta.org used for parody site: “People eating tasty animals” l Links to leather-goods and meat websites §Mattel v. Schiff (SDNY 2000): barbiesplaypen.com for commercial porn club

81 ACPA Factors 1. Does  have IP rights in the DN? 2. Is the DN  ’s legal or customary name? 3.  ’s prior use of DN to offer goods/services 4.  ’s prior noncommercial or fair use of DN 5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion 6.  ‘s offer to sell DN – or habit of doing so 7. Did  provide false contact information 8. Did  acquire multiple DNs similar to TMs 9. How distinctive or famous is  ’s mark?

82 Mattel 1. Does  have IP rights in the DN?  2. Is the DN  ’s legal or customary name?  3.  ’s prior use of DN to offer goods/services  4.  ’s prior noncommercial or fair use of DN  5.  ‘s intent to divert business from  and harm good will by causing likelihood of confusion  6.  ‘s offer to sell DN – or habit of doing so  7. Did  provide false contact information  8. Did  acquire multiple DNs similar to TMs  9. How distinctive or famous is  ’s mark? 

83 Doctrines

84 §UDRP §ACPA §Trademark Infringement -- Likelihood of Confusion §Trademark Dilution §Unfair Competition

85 DoctrinesTypes of Conflict §UDRP §ACPA §Trademark Infringement -- Likelihood of Confusion §Trademark Dilution §Unfair Competition §Cybersquatting §Typosquatting §Competing Use §Noncompeting Use §Reverse Domain Name Hijacking §Retailers §Fan Sites §Parody and Commentary

86 DoctrinesTypes of Conflict §UDRP §ACPA §Trademark Infringement -- Likelihood of Confusion §Trademark Dilution §Unfair Competition §Cybersquatting §Typosquatting §Competing Use §Noncompeting Use §Reverse Domain Name Hijacking §Retailers §Fan Sites §Parody and Commentary { }

87 DoctrinesTypes of Conflict §UDRP §ACPA §Trademark Infringement -- Likelihood of Confusion §Trademark Dilution §Unfair Competition §Cybersquatting §Typosquatting §Competing Use §Noncompeting Use §Reverse Domain Name Hijacking §Retailers §Fan Sites §Parody and Commentary { }

88 DoctrinesTypes of Conflict §UDRP §ACPA §Trademark Infringement -- Likelihood of Confusion §Trademark Dilution §Unfair Competition §Cybersquatting §Typosquatting §Competing Use §Noncompeting Use §Reverse Domain Name Hijacking §Retailers §Fan Sites §Parody and Commentary { }

89 Defects of UDRP §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy

90 General Problems §Unnecessarily complex §Unpredictable outcomes §Trademark owners have too much power; domain-name owners too little §Excessive Impediments to Freedom of Speech

91 Alternatives to the Current Legal Regime

92 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

93 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

94 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults

95 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies

96 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or

97 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller)

98 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller) §Establish internal appellate process (loser pays)

99 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller) §Establish internal appellate process (loser pays) §Add discovery system, or

100 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller) §Establish internal appellate process (loser pays) §Add discovery system, or §Reduce jurisdiction

101 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller) §Establish internal appellate process (loser pays) §Add discovery system, or §Reduce jurisdiction

102 Improved UDRP Defects: §Complainant picks forum §No appellate process §Simplified procedures ill suited to complex cases §Arbitrators reach cases not intended by the policy §Innocent defaults Possible Remedies §Disputes assigned randomly to licensed providers, or §Registrars pick providers (Mueller) §Establish internal appellate process (loser pays) §Add discovery system, or §Reduce jurisdiction §$1000 bond (Mueller)

103 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

104 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

105 Major gTLDs §.com and.net: 30,400,000

106 More gTLDs Operator.aeroAviationSITA.bizBusinessesNeuLevel.coopCooperativesdotCoop.infoUnrestrictedAfilias.museumMuseumsMuseDoma.namePersonal names Global Name Registry.proProfessionalsRegistryPro

107 Reducing Scarcity? §See Zittrain & Edelman at

108 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

109 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

110 Trademark Doctrine: No protection for generic marks §Inherently generic marks l E.g., Alaska Salmon; Convenience Store §Marks that become generic through use l E.g., thermos, kleenex; lite beer Basis of the rule: excessive threat to competition

111 Domain-Name practice currently deviates from this rule

112 §Trademark owners are sometimes able to control generic domain names l E.g., crew.com

113 Domain-Name practice currently deviates from this rule §Trademark owners are sometimes able to control generic domain names l E.g., crew.com §Generic domain names are protected (by law) against “confusingly similar” domain names l E.g., E-cards.com vs. Ecards.com

114 Domain-Name practice currently deviates from this rule §Trademark owners are sometimes able to control generic domain names l E.g., crew.com §Generic domain names are protected (by law) against “confusingly similar” domain names l E.g., E-cards.com vs. Ecards.com §Generic domain names are protected (by code) against identical domain names l Only one firm can use sex.com

115 Domain-Name practice currently deviates from this rule §Trademark owners are sometimes able to control generic domain names l E.g., crew.com §Generic domain names are protected (by law) against “confusingly similar” domain names l E.g., E-cards.com vs. Ecards.com §Generic domain names are protected (by code) against identical domain names l Only one firm can use sex.com Reverse this rule

116 Domain-Name practice currently deviates from this rule §Trademark owners are sometimes able to control generic domain names l E.g., crew.com §Generic domain names are protected (by law) against “confusingly similar” domain names l E.g., E-cards.com vs. Ecards.com §Generic domain names are protected (by code) against identical domain names l Only one firm can use sex.com Reverse this rule Reverse this rule

117 Domain-Name practice currently deviates from this rule §Trademark owners are sometimes able to control generic domain names l E.g., crew.com §Generic domain names are protected (by law) against “confusingly similar” domain names l E.g., E-cards.com vs. Ecards.com §Generic domain names are protected (by code) against identical domain names l Only one firm can use sex.com Reverse this rule Reverse this rule Either: (a) Refuse registration, or (b) Mandatory index page (cf. Mattel v. Hasbro)

118 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

119 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

120 Increased Latitude for Criticism and Parody §Permit registration of all DNs whose critical purpose is apparent on their face l E.g., verizonsucks.com; yahooka.com l Doctrinal basis: not “confusingly similar” §Recognize criticism as a legitimate use under UDRP, ACPA, and dilution doctrine l E.g., PETA case and Jews for Jesus case would be decided differently

121 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

122 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

123 Return to first-come, first-served §Analogy to buying up rights to newly discovered valuable resource l E.g., Edison and bamboo §Rely on the market to get DNs into the hands of firms best able to use them §Limit relief to the conduct of a website in a fashion likely to cause consumer confusion l Cf. Amadeus

124 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

125 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

126 Repudiate Domain Names §DNs are not essential to navigation of the Internet §Dispense with the system in favor of IP Addresses §Consumers will rely on search engines, links, and bookmarks

127 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

128 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

129 Domain Names Atrophy §Value of domain names may diminish naturally as search engines become more powerful and ubiquitous

130 Alternatives 1)Improved UDRP 2)More GTLDs 3)Eliminate protection for generic domain names 4)Increased latitude for criticism and parody 5)Return to first-come, first-served 6)Repudiate domain names altogether 7)Domain names naturally atrophy

131 Who Won?

132 Who Should be Awarded These DNs? RegistrantComplainant3 rd party Webergrill.comBBQ PitWeber Crew.comNat CohenJ.Crew Peta.comPeople Eating Tasty Animals People for the Ethical Treatment of Animals Kumbhmela.comJagaGovernment of India Southafrica.comVirtual Countries, Inc. Government of South Africa BruceSpringsteen.comJeff BurgarBruce Springsteen Verizonreallysucks.com2600 Magazine Verizon IntroducingMonday.co.ukB3TAPrice Waterhouse Cooper Consulting

133 Actual Winners RegistrantComplainant3 rd party Webergrill.comBBQ PitWeber Crew.comNat CohenJ.Crew Peta.comPeople Eating Tasty Animals People for the Ethical Treatment of Animals Kumbhmela.comJagaGovernment of India Southafrica.comVirtual Countries, Inc. Government of South Africa BruceSpringsteen.comJeff BurgarBruce Springsteen Verizonreallysucks.com2600 MagazinVerizon IntroducingMonday.co.ukB3TAPrice Waterhouse Cooper Consulting

134 Typical Winners in Cases of this Sort RegistrantComplainant3 rd party Webergrill.comBBQ PitWeber Crew.comNat CohenJ.Crew Peta.comPeople Eating Tasty Animals People for the Ethical Treatment of Animals Kumbhmela.comJagaGovernment of India Southafrica.comVirtual Countries Government of South Africa BruceSpringsteen.comJeff BurgarBruce Springsteen Verizonreallysucks.com2600 Magazine Verizon IntroducingMonday.co.ukB3TAPrice Waterhouse Cooper Consulting


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