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Volokh said: "In context, nobody is going to be confused. Playboy Enterprises recently sued Welles in U.

Defendant was a Playboy model and Playmate of the Year who used these trademarked terms to describe herself via her personal website. None of the cases which Brookfield discusses involved fair use defense or a use of trademarks in the metatags which accurately and fairly described the contents of the web page or web site.

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