263 F.3d 359 (4th Cir. 2001), affirming 113 F. Supp. 2d 915 (E.D. Va. 2000)

In 1995, Doughney registered the domain name peta.org for the fictitious organization "People Eating Tasty Animals." The website contained linkes to over 30 sites including some that promoted the sale of leather goods and meats. At the bottom of the page, the website inquired "Feeling lost? Offended? Perhaps you should, like, exit immediately" and provided a link to the actual People for the Ethical Treatment of Animals website.

PETA requested that Doughney transfer the domain name, but Doughney refused to do so, leading to the lawsuit. PETA asserted claims of service mark infringement, unfair competition, trademark dilution, and cybersquatting.

The United States District Court for the Eastern District of Virginia held that the peta.org site was a used in commerce because it prevented consumers from reaching the People for Ethical Treatment of Animals website and it contained links to commercial sites. A likelihood of confusion was easily proven after Doughney's admission.

The District Court and the Fourth Circuit both rejected Doughney's assertion that the website was a parody of the PETA website. Relying on the Cliffs Notes, Inc. v. Bantam Doubleday Dell Publ'g Group, Inc., both courts ruled that in order to constitute a parody, the peta.org website must simultaneously convey that (1) the site was the PETA site and (2) the site was not the PETA site.