The ruling was an important early precedent on the nominative use of trademarked terms for self-identification on the World Wide Web.

In the mid-1990s Welles established a personal and promotional website in which she described herself as a former Playboy model and Playmate of the Year, frequently using the magazine's name plus the acronym "PMOY".

The Ninth Circuit affirmed most of the district court's ruling, and found that Welles had not infringed on the Playboy trademarks and could claim the nominative use defense.

That legal doctrine had been defined by the Ninth Circuit precedent Brookfield Communications, Inc. v. West Coast Entertainment Corp. in 1999.

[1] Furthermore, the court held that Welles was entitled to mention the name of the magazine and its related terms like "PMOY" in a basic description of herself for identification and promotion purposes.