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 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 advertisement with the other results from the keyword “law” search, clearly marked as an ad. The 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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