Utah Lighthouse Ministry v. Wyatt

The Utah Lighthouse Ministry (UTLM), an organization that publishes information critically analyzing the history and doctrines of the Church of Jesus Christ of Latter-day Saints (LDS), sued Allen Wyatt, his company Discovery Computing, Inc. (DCI), the Foundation for Apologetic Information & Research (FAIR), and one of FAIR's directors, Scott Gordon. UTLM publishes its views and sells books written by its founders, Jerald and Sandra Tanner, on its official website, www.utlm.org. Wyatt, a professional website designer and the Vice President of FAIR, a non-profit organization that responds to criticisms of LDS, created a website which attempted to parody the UTLM official site and linked visitors to pro-LDS sites. Wyatt bought several domain names and redirected them all to his parody website. The domain names included www.utahlighthouse.com, www.sandratanner.com, www.jeraldtanner.com, www.uthahlighthouse.org, plus six other similar names.

In April 2005, UTLM sued Wyatt,DCI, FAIR, and Gordon in Utah federal court for trademark infringement and dilutition, trade dress infringement, cybersquatting, and violation of federal and state unfair competition laws. Among other things, the complaint alleged that the defendants' use of UTLM's trademarks in the domain names associated with the Wyatt website infringed its trademark rights because that site and the official UTLM site were confusingly similar.

In March 2007, the district court granted the defendants' motions for summary judgment and dismissed the lawsuit. The court held that the trademark, trade dress, dilution, and unfair competition claims failed because Wyatt's website did not constitute a "commercial use" of UTLM's marks, but rather a "noninfringing parody of Plaintiff's site." The court further held that there was no evidence that the defendants registered the domain names with a "bad faith intent to profit" from the UTLM marks, as required for a cybersquatting claim.

Update:

5/29/2008 - On appeal, the Tenth Circuit affirmed the district court's judgment.