Playboy Enterprises Inc. v. Netscape Communications Corp.
Plaintiff, in action alleging that defendant Internet service providers infringe its “Playboy” and “Playmate” trademarks by using “playboy” and “playmate” as “keyword” search terms that trigger appearance of “banner advertisements” on user’s computer screen, may be able to show “initial interest” confusion, since some consumers seeking plaintiff’s Web sites may initially believe that unlabeled banner advertisements are links to plaintiff’s sites or to sites affiliated with plaintiff.