Historically, domain name registrars have not been held liable for contributory infringement under the common law concerning trademark infringement. Since courts have held that a registrar's registration of a domain name on behalf of a third-party does not constitute "commercial use" because the registrar has no "knowledge of how a registrant will use a domain name," registrars have remained relatively unscathed in modern cybersquatting lawsuits, eg, Acad. of Motion Picture Arts & Sciences v Network Solutions Inc., 989 F. Supp. 1276, 1281 (CD. Cal. 1997).
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