Network Solutions, Inc. v. Umbro International, Inc. case brief

529 S.E.2d 80 (Va. Sup. Ct. 2000)

FACTS
-Network Solutions was garnishee and sought to garnish 38 domain names that debtor registered with NSI.
-NSI claimed domain names not garnishable.

PROCEDURAL HISTORY
-Circuit Court held that domain names were "valuable intangible property subject to garnishment."

ISSUE

Can a contractual right to use an Internet domain name be garnished?

HOLDING

No, domain name registrations are not garnishable.  

ANALYSIS

Here we are dealing with contractual rights.  A contract for services is not a liability and is not subject to garnishment.

-Some contractual rights can be garnished, however.  For example, fire insurance policy held to be garnishable.