Undeveloped Domains Like ‘Trumpindia.com’’ Didn’t Entitle Registrant to ACPA Safe Harbor

• Key Holding:
  A person’s registration of domain names such as trumpindia.com without developing them or adding descriptive or critical commentary was not eligible for the fair use safe harbor defense under the Anticybersquatting Consumer Protection Act of 1999.

An individual who registered the domain names trumpbeijing.com, trumpindia.com, trumpmumbai.com, and trumpabudhabi.com, but who barely developed the domains and added only a minimal amount of token content, was not entitled to the “fair use” safe harbor provision of the Anticybersquatting Consumer Protection Act of 1999, the U.S. District Court for the Eastern District of New York ruled Feb. 28 (Web-adviso v. Trump, E.D.N.Y., 1:11-cv-01413-DLI-VVP, 2/28/13