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For example, one court has held that an anti-abortion activist who registered domain names incorporating the names and nicknames of his ideological rivals had misappropriated their names for his own benefit. See Faegre & Benson, LLP v. Purdy, 367 F. Supp. 2d 1238 (D. Minn. 2005). The court also held that the defendant had committed misappropriation through a form of sock puppetry -- namely, he posted comments on his own bulletin board pretending to be lawyers from a law firm that fought for abortion rights; in these comments, he expressed opinions and views that were favorable to his own position that abortion is immoral. See Faegre & Benson, LLP v. Purdy, 447 F. Supp. 2d 1008 (D. Minn. 2006). In another case, a professor created non-commercial websites and email accounts containing portions of the names of several of his former colleagues. Using these email accounts, the professor then sent emails to a number of universities, pretending to nominate these former colleagues for university positions and directing readers back to his websites, which contained critical posts about the nominated individuals. When the University and his former colleagues sued, an Indiana state court found that he had committed misappropriation. The Supreme Court of Indiana affirmed the lower court's decision, holding that the professor had exploited the plaintiffs' names for his own benefit "in that [the misappropriation] enabled him to pursue a personal vendetta." Felsher v. Univ. of Evansville, 755 589, 600 (Ind. 2001).

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