Planned Parenthood Federation of America, Inc. v. Bucci, 42 U.S.P.Q.2d 1430 (S.D.N.Y. 1997), an early Internet domain trademark infringement case heard in the United States District Court for the Southern District of New York, established the theory that hosting a site under a domain name that was the registered trademark of a third party constituted trademark infringement. The case was also important in determining what constitutes "Use in Commerce" under the Lanham Act in cyberspace. Although these holdings were modified and overruled by various American courts following the decision, Bucci stands as a seminal case for being one of the first cases to address these issues.