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Internet Trademark Case Summaries

Zippo Manufacturing Co. v. Zippo Dot Com, Inc.

952 F. Supp. 1119 (W.D. Pa. 1997)

The court held that defendant was subject to jurisdiction in Pennsylvania because it consciously conducted business with forum residents over the Internet.  Defendant used the mark ZIPPO in connection with its Internet subscription news services and as the domain name for its website (“zippo.com”).  Plaintiff, the Pennsylvania-based manufacturer of ZIPPO brand cigarette lighters, sued, alleging trademark dilution, infringement, and false designation of origin under the Lanham Act.  The court held that defendant had actively pursued business opportunities in the forum by entering into arrangements with local ISPs and by willingly processing Pennsylvania residents’ applications and issuing passwords to them.  The transmission of messages into the forum was a foreseeable result of these electronic commercial activities.