Lucas Nursery and Landscaping, Inc., sued Michelle Grosse under the Anti-Cybersquatting Protection Act (ACPA) for the domain name lucasnursery.com. Grosse used the Web page to document poor service by Lucas Nursery in landscaping her yard.

In Lucas Nursery v. Michelle Grosse, the court held that the ACPA was inapplicable because Grosse's complaint site was a "bona fide noncommercial use".
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