Kremen v. Cohen Network Solution, Inc.
United States Court of Appeals for the Ninth Circuit
337 F.3d 1024 (2003)
Kremen (plaintiff) registered the domain name "sex.com" through registrar Network Solutions under his business entity, Online Classifieds. Cohen (defendant), a convicted con artist, forged a letter to Network Solutions claiming Online Classifieds wished to relinquish the domain, prompting Network Solutions to delete the registration, after which Cohen acquired the name and built a profitable internet pornography enterprise around it. Kremen sued Cohen and won at the district court, but had little success actually collecting on the judgment, so he separately sued Network Solutions, including a tort claim of conversion. The district court granted Network Solutions summary judgment on all claims, and Kremen appealed.
Whether an internet domain name is a form of property that is subject to a claim of conversion under California law.