On March 8, 2011, in Network Automation, Inc. v. Advanced Sys. Concepts, Inc., 2011 WL 815806 (9th Cir. Mar. 8, 2011), the Ninth Circuit provided some insight as to whether using a competitor’s trademark as a search engine keyword constitutes trademark infringement. The dispute surrounds a common practice utilized by various search engines such asGo to Article

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