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CRS Recovery, Inc. v. Laxton
United States Court of Appeals for the Ninth Circuit
600 F.3d 1138 (2010)
Dale Mayberry (plaintiff), a Virginia citizen, registered a domain name, rl.com, and controlled rl.com through another domain and website, mat.net. At some point, Mayberry lost control of mat.net and accordingly also lost control of rl.com. Subsequently, Li Qiang (defendant) was able to register mat.net and transfer ownership of rl.com to himself. Qiang sold rl.com to John Laxton (defendant), who was a California citizen. Meanwhile, Mayberry discovered that he had lost control of both rl.com and mat.net. Mayberry assigned his interest in rl.com to CRS Recovery, Inc. (CRS) (plaintiff), a Virginia corporation. CRS and Mayberry sued Laxton, Qiang, and others in California district court, alleging theft of the two domain names. On summary judgment, Laxton urged the court to apply Virginia law, which assertedly did not recognize domain names as a form of intellectual property. Mayberry claimed that California law governed the matter. It was undisputed that California law recognized domain names as intangible personal property. The district court found that California law applied. Laxton appealed.
Rule of Law
Holding and Reasoning (Hawkins, J.)
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