Madonna Ciccone v. Dan Parisi & "Madonna.com"

A defining case on celebrity name protection in domain disputes and bad-faith cybersquatting.

Summary

This case addressed whether the famous pop artist Madonna could recover the domain name madonna.com, which had been registered by Dan Parisi. Madonna argued that the registration exploited her global reputation and misled internet users. The panel confirmed that celebrities enjoy strong protection against domain registrations made in bad faith.

Facts of the Case

Madonna is a world-renowned singer and performer whose name has acquired strong trademark-like recognition. Dan Parisi, unrelated to her, registered madonna.com and used it to host adult content links and advertisements. Madonna filed a complaint under the UDRP claiming:

⦁ The domain was identical to her well-known name

⦁ Parisi had no legitimate interest

⦁ The registration was made to profit from her fame

Parisi argued that “Madonna” was also a religious term and that he had free-speech rights to use the name.

Findings

The panel held that:

⦁ The name “Madonna” had become strongly associated with the singer, giving her protectable rights.

⦁ Hosting adult content on a domain identical to a celebrity name misled users and damaged reputation.

⦁ Parisi registered and used the domain in bad faith to attract traffic and advertising revenue.

⦁ Free-speech arguments were invalid because the site was commercial, not informational.

Suggestions

The ruling highlighted:

⦁ Celebrities must act quickly to protect their online identity.

⦁ Domain registrants should avoid famous personal names unless they have a legitimate, non-commercial reason.

⦁ Bad-faith exploitation of fame will result in transfer of the domain.

Judgment

The panel ordered the transfer of madonna.com to Madonna, strengthening protection of famous personal names in cyberspace.