[2] Richard Bucci was an anti-abortion activist who operated a daily Catholic radio program in Syracuse, New York.

[2] Bucci used the domain name for his own website, the homepage of which stated "Welcome to the PLANNED PARENTHOOD HOME PAGE!"

[2] Bucci argued that his website was intended as a parody of the true Planned Parenthood organization and its beliefs, so his use of the domain name constituted free speech that was protected under the First Amendment.

The court found that due to the confusion likely to be caused by his use of "plannedparenthood" in the domain name, his free speech defense was untenable.

[2] Per the Lanham Act, American trademark law makes it a violation for a party to "use in commerce any reproduction, counterfeit, copy, or colorable imitation of a registered mark in connection with the sale, offering for sale, distribution, or advertising of any goods or services on or in connection with which such use is likely to cause confusion, or to cause mistake, or to deceive.

Accordingly, even though Bucci was not selling anything on his website, the court held that he was in violation of the Lanham Act because he was helping Roberge "plug" his book.