Playboy Enterprises, Inc v. Frena
839 F. Supp. 1552 (1993)
George Frena, owner of an online bulletin board service, allowed subscribers to post copyrighted material belonging to Playboy Enterprises, Inc. He also allowed subscribers to alter the photographs and delete trademarked Playboy content replacing it with advertisements of Frena’s bulletin board. Frena, however, claimed that he had not actually done the posting and altering and was not liable for the actions of his subscribers. Playboy Enterprises, Inc., however, claimed that Frena had engaged in copyright infringement, trademark infringement, practiced unfair competition and "reverse passing off" by his actions. Reverse passing off is the idea of taking an item created by another party and in turn using it as your own without sufficient change to the final product. Frena did not change the photos enough to make them his own creation; rather he just simply changed small details for his own benefit. The court decided in favor of Playboy on copyright infringement, trademark infringement, and unfair competition practices.