Ninth Circuit Finds Refusal To Transfer Website Domain Registered In Good Faith Can be Bad Faith “Use” For Purposes of the Anti-Cybersquatting Consumer Protection Act

In DSPT Int’l, Inc. v. Nahum, 624 F3d 1213, 97 USPQ2d 1022 (9th Cir. 2010), DSPT International, Inc. (DSPT) is a clothing designer, manufacturer and importer.  Paulo Dorigo, owner and founder of DSPT, hired Lucky Nahum, who was a friend of Dorigo, to help launch EQ, a new brand for DSPT.  Dorigo and Nahum set up a website in 1999 for EQ, and Nahum’s brother was to design and produce the website “” in order to display DSPT clothing under the EQ brand.  Nahum, who exclusively working for DSPT, registered the website domain name under his personal name, for a cost of $25 USD. Continue reading