St. John's Law Review

Intellectual Property Law and Competitive Internet Advertising Technologies: Why "legitimate" Pop-Up Advertising Practices Should be Protected

By: James Suh

Internet advertising has become a growing source of frustration for Internet users. The main source of this frustration seems to stem from “spam,” or unsolicited “junk” e-mail advertisements.  The phrase “Internet advertising” immediately conjures up thoughts of closing annoying pop-up advertisements and sorting through countless unsolicited e-mail advertisements.  These negative connotations often overshadow the increasing value of the Internet as a free, extensive source of information.  In fact, the Internet has created a more informed consumer.  Using their home computers, Internet consumers can quickly research comparable products and compare prices of several vendors before making a purchase.  In this way, the Internet has advanced consumer education and choice.  Before the Internet, consumers looking for snow tires might peruse a few catalogs or travel to an automotive parts store to inquire about what types of tires were available.  Their access to information about products would clearly be limited to the brands of tires sold in those catalogs or stores.  Using the Internet, they can find information on every single manufacturer of snow tires, read product reviews of all competing brands, and find the best price among several retailers.  While reading a review of one brand, they might see an ad directing them to information about a competing brand.  This type of advertising exposes consumers to alternatives that they may not have considered.  As such, advertising has played an integral part in making the Internet a valuable consumer tool.

The practices of one of the first pop-up advertising vendors, Gator Corporation, have been the subject of recent litigation.  The plaintiffs, owners and operators of Internet websites, have argued that Gator’s practice of causing pop-up ads to appear over their websites violated their intellectual property rights.  This Note evaluates existing trademark, unfair competition, and copyright standards and applies them to Gator’s pop-up advertising scheme.  It also evaluates some of the earliest federal cases concerning pop-up advertising and their disparate outcomes.