People for the Ethical Treatment of Animals v. Doughney Case Brief Summary | Law Case Explained

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People for the Ethical Treatment of Animals v. Doughney | 263 F.3d 359 (4th Cir. 2001)

A cybersquatter is a person who registers an internet domain name using a trademark held by someone else. Congress enacted the Anticybersquatting Consumer Protection Act, or ACPA, to crack down on cybersquatters. In People for the Ethical Treatment of Animals versus Doughney, the Fourth Circuit considered whether the ACPA applied to a purported parody website.

In 1995, Michael Doughney registered the domain name peta dot org and created a website for the fictional organization, People Eating Tasty Animals. The site parodied People for the Ethical Treatment of Animals, a well-known animal rights group that had registered the trademark PETA in 1980. Doughney falsely represented to the domain registrar that the domain name didn’t interfere with any third-party rights and that People Eating Tasty Animals was a non-profit educational organization. In 1996, PETA asked Doughney to transfer the domain name to it based on its ownership of the PETA trademark. Doughney refused, instead suggesting that PETA offer him a settlement in exchange for access to the domain name.

PETA sued, alleging that Doughney had violated the ACPA. The district court found that Doughney had violated the ACPA, granted summary judgment in favor of PETA, and ordered Doughney to transfer the domain name. Doughney appealed to the Fourth Circuit, arguing that he had registered the domain name pursuant to a good-faith belief that he was exercising his First Amendment right to parody PETA. Doughney further argued that he had not sought to use PETA’s mark for profit.

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