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  1. Defendant's practices giving rise to this action involve his use of the World Wide Web and the Internet. Defendant redirects unsuspecting consumers to his Web sites and then traps them in a barrage of Web pages and pop-up browser windows. Defendant places web pages on the World Wide Web with domain names that are misspellings of other domain names; transpose or invert words, terms, or phtrases in other domain names; or are confusingly similar to others' famous trademarks, service marks, or names. When consumers type one of Defendant's domain names into their browser's address bar, they are immediately redirected to Defendant's Web sites.
  2. Once Defendant redirects consumers to his Web sites, he traps them there using a variety of tactics that obstruct consumers' ability to exit Defendant's sites. These practices force consumers, including children, to navigate through multiple windows displaying solicitations for online gambling and casinos, sweepstakes, lotteries, psychics, instant credit, or pornography.
  3. Defendant has registered thousands of domain names which are similar to others' domain names, famous trademarks, service marks, business names, or personal names.
  4. For example, Defendant has registered 15 spelling variations of the domain name, an entertainment Web site designed to provide children information and images about cartoon characters on the cable television channel Cartoon Network. Defendant's variations on the Cartoon Network domain name include:;;;;;; and
  5. Additional examples of domain names registered by Defendant that are misspellings of other domain names are:
  6. Defendant has also registered domain names that, although not typographical errors, incorporate famous trademarks, service marks, company names, or celebirty names (such as,, and or transpose or invert words, terms, or phrases in other domain names (such as, and inversion of the words in the domain name
  7. Defendant registers his domian names in anticipation of consumers mistakenly entering his domain names in a browser address bar, usually as a typographical error or a spelling error.
  8. Nearly all of Defendant's domain names are associated with Web pages that contain no content. Rather, these Web pages are simply blank "bridge" pages that instantaneously and invisibly redirect consumers to Defendant's commercial Web sites, which display advertisements for various goods and services, including online gambling and casinos, sweepstakes, lotteries, psychics, instant credit, or pornography.
  9. The domain name or URL actually entered by consumers, e.g.,, does not appear in any of the browser windows that display Defendant's commercial Web sites.
  10. After Defendant directs conusmers to his Web sites, Defendant traps them in a series of advertising Web pages. Defendant obstructs consumers' efforts to extricate themselves from his advertising Web pages by employing a variety of tactices.
  11. For example, Defendant uses an intervening bridge page,, as the launch pad for many of Defendant's Web sites. Once consumers are directed to Defendant's "launch pad" Web page, Defendant, without the users' knowledge or consent, launches a rapid series of new and separate browser windows, each containing advertisements.
  12. On many of Defendant's Web sites, simply clicking on the "Close" or "X" button in the top right hand corner of the screen, a common way to close a browser window, will not allow consumers to exit. Rather, when consumers attempt this standard function, they find themselves in yet another new window and viewing yet another of Defendant's advertisements - a practice commonly referred to as "mousetrapping."
  13. On at least one of Defendant's Web pages, if consumers click on the "Back" button, at least five new browser windows are launched, each displaying yet another one of Defendant's advertisements.
  14. One of Defendant's "windows," which appears on consumers' take bars as an icon, is hidden from view. This "stealth Web page" in fact contains no viewable content, but is set to periodically launch several additional browser windows that contain additional advertisements.
  15. Defendant obstructs consumers' ability to view this "stealth Web page" on the computer's display screen by using commands inserted in the page's source code. For example, consumers cannot maximize this window.
  16. If consumers should extricate themselves from all of Defendant's browser windows but fail to close the "stealth Web page," that Web page may continue to launch new browser windows without any action on the part of consumers, even after consumers have moved on to new Web sites.
  17. Defendant's use of these tactics can force consumers to navigate through dozens of unwanted advertising windows.
  18. In many instances, Defendant launches the authentic Web site his domain name mimics in addition to his advertising Web sites, thereby leading consumers to believe that the products and services advertised on his Web sites are affiliated with the authentic Web site. For example, when consumers type the URL in the address bar of their browsers, numerous browser windows are launched on consumers' display screens, one of which displays, the official Colege Board Web site.
  19. In many instances, the Web pages and advertisements that are automatically launched include sexually-explicit material. For example, the domain names and redirect consumers to Defendant's pornographic Web site,[...]htm, which immediately launches another pornographic site. Instantly redirected to these sexually-explicit Web pages, consumers are trapped in a series of browser windows displaying graphic advertisements. In some cases, consumers who stumbled upon these sexually-explicit Web pages have to click through 30 or more separate windows or shut off the computer to escape from these pornographic pages.
  20. Defendant earns substantial advertising revenue from his practices of redirecting consumers to his Web sites and subjecting them to window after window of advertisements.
  21. It is highly likely that Defendant's practices cause unsuspecting consumers to incur substantial injury in the form of transaction costs, including Internet connection fees, lost time, and lost data. These practice also expose children to successive solicitations for gambling, casinos, psychic services, or pornography.
  22. Defendant's practices also are likely to cause hardship to employees who unintentionally violate company policies against visiting sexually explicit sites and/or gambling sites on the job. More generally, these practices prevent consumers from locating the Web sites they desire to visit, and impair the growth of the Internet as a commercial medium.

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Revision r1.1 - 21 Feb 2005 - 04:09 by EliMantel web search for EliMantel
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