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Internet search engine providers allow advertisers to sponsor search terms known as keywords. When a particular keyword is used in a search request by an Internet search engine user, that particular keyword sponsor’s ad will appear near to the search results. When properly employed, trademarks may be lawfully used as keywords; when improperly used, valid infringement claims arise.

Google, Yahoo, MSN Search and others offer keyword-related advertisement placement services. For example, if Bicklaw.com purchases the “law” keyword from Google, and a Google user enters the term “law” in the Google search box and hits “Search,” that user would receive a Bicklaw.com advertisement with the other results from the keyword “law” search, clearly marked as an ad. The Bicklaw.com advertisement might appear within the search results, as well as at the top and/or bottom of the page, sandwiching the actual search results.

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