Dluhos v. Strasberg
United States Court of Appeals for the Third Circuit
321 F.3d 365 (2003)

- Written by Sean Carroll, JD
Facts
Eric Dluhos (defendant) registered the domain name www.leestrasberg.com. Lee Strasberg’s widow, Anna Strasberg (Strasberg) (plaintiff), brought a complaint under the Internet Corporation for Assigned Names and Numbers’ Uniform Domain Name Dispute Resolution Policy (UDRP) before the National Arbitration Forum (NAF). The complaint alleged that the domain name was identical or confusingly similar to Strasberg’s trademarks, that Dluhos had no rights or legitimate interests in the name, and that he registered the domain name in bad faith. The NAF ordered transfer of the domain name to Strasberg. Dluhos filed suit in federal district court, challenging the legitimacy and constitutionality of the dispute-resolution process. The district court applied the extremely deferential appellate standard under the Federal Arbitration Act (FAA) and dismissed Dluhos’s complaint. Dluhos appealed.
Rule of Law
Issue
Holding and Reasoning (Aldisert, J.)
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