http://arbiter.wipo.int/domains/decisions/html/d2000-0071.html

     CSA International (a.k.a. Canadian Standards Association) v.
     John O. Shannon and Care Tech Industries, Inc.

In this case, a firm named Care Tech Industries sought to obtain
certification of an ozone generator from the Canadian Standards
Association (CSA).  The CSA has a trademark on CSA and CSA
International, and owns the domain CSA-International.org.  Care
Tech then registered csa-canada.com and csa-international.net,
which it used to criticize CSA, for its decision not the certify
the Care Tech production.

According to the WIPO panel:

     Respondents maintain websites at each of these
     addresses. At each website, Respondents attack and
     criticise the Complainant and its staff in relation,
     inter alia, to its failure to certify Respondents'
     Odatus generator. The content of each site is
     substantially identical, and each directs viewers to
     see "our homepage". Following that link leads to the
     "odatus.com" homepage which includes promotion of the
     Odatus ozone generator.
     
     . . . they are not using the domain names in connection
     with a bona fide offering of goods or services and they
     do not claim to be commonly known by either of the
     domain names. Examination of Respondents' web pages
     clearly show that they are using their domain names to
     attract persons to their sites for the purpose of
     publicly attacking the Complainant and members of its
     staff and pleading its case in relation to a dispute
     between themselves and the Complainant in relation to a
     product which Respondents offer under the trade mark
     Odatus. Persons attracted to the site are likely to be
     persons seeking contact with Complainant, not persons
     seeking contact with Respondents.

     Respondents claim to rights and legitimate interests is
     essentially based on a claim to freedom of speech and,
     expression of opinion, but that right does not require
     the use of Complainant's trade marks in the domain
     names for that purpose.
                              
The WIPO panel concluded that Care Tech did not have rights or
legitimate interests in respect of the domain names, that they
were registered and were used in bad faith, and ordered the
domain names transferred to the Canadian Standards Organization.

CPT Comment:

1.   This decision was wrong.  The right of a person or a firm to
     criticize a standards body or a government organization is a
     legitimate interest.  There was no suggestion that the
     domains were used to confuse the public as to the identity
     of the CSA. 

2.   The use of the trademarked name in the domain name was
     appropriate, just as would be the use of the trademarked
     name in the title of a book or the title of a web page.  As
     the decision notes, the web sites were clearly attacks on
     the CSA by an aggrieved party, and would not have been
     confused as an official CSA web page. 

3.   The fact that the interest of Care Tech was commercial did
     not mean that Care Tech did not have a legitimate free
     speech right to criticize the CSA.