For example, Respondent might select a domain name that contains Complainant s name combined with other terms to avoid any initial confusion about the nature of the site. Others would find this view an unwarranted restriction on free speech over the Internet, and would allow domain names to make a direct nominative reference to the subject of the message, just as the title of a biography may make direct reference to its subject. This is an important and critical issue that may turn on the nature of the speech involved, so that the result could be different depending on whether the underlying use were commercial or noncommercial speech. See, for example, Cliff s Notes Inc. v. Bantam Doubleday Dell Pub. For the reasons discussed below, we do not need to resolve this difficult issue here.
None seem applicable here.
There is no evidence that Respondent has registered and used the domain name for the purpose of selling it for profit. Respondent is not engaged in a pattern of conduct that prevents the owners of trademarks from reflecting the mark as a domain name. Respondent did not register the domain name to disrupt the business of a competitor. Finally, there is no indication that the Respondent has intentionally attempted to attract Internet users to its site for commercial gain based on confusion with Complainant. As stated above, the element of commercial gain, in our view, is not satisfied by a public attempt to recover on a personal debt.