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Internet growth has exacerbated the uncertainty and conflicts related to U.S. trademark law. The issue of domain names and trademarks has been especially contentious. In July 2011, Facebook filed a U.S. District Court lawsuit against cybersquatting domains, including Facebook, Inc. v. Cyber2Media, Inc., alleging trademark violations per the Lanham Act. In this and similar cases, defendants from around the world surrendered dozens of domains. In February 2011, the Central District of California determined in Binder v. Disability Group Inc. that purchasing a competitor's trademark through Google AdWords is trademark infringement under the Lanham Act's use in commerce requirement.
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