Network Solutions, Inc. v. Umbro International, Inc. (2000)
Citation: 259 Va. 759 · Court: Supreme Court of Virginia · Decided: Apr. 21, 2000 · Opinion: Kinser, J.; Compton, Senior J., dissenting.
Source note (2026-10-18):
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Case page. Legal information, not legal advice. Last verified: 2026-10-16.
Facts
Umbro held a federal judgment against a debtor and, using a writ of fieri facias from the Fairfax County Circuit Court, sought to garnish 38 Internet domain names the debtor had registered with Network Solutions (NSI). NSI answered that it held no garnishable property, characterizing the registrations as “standardized, executory service contracts.” The circuit court held the registrations garnishable. (Source: https://static.case.law/va/259/cases/0759-01.json , retrieved 2026-10-16.)
Holding
“In this case of first impression, we address the issue whether a contractual right to use an Internet domain name can be garnished,” and conclude “that such a contractual right is ‘the product of a contract for services’ … and hence is not subject to garnishment.” “[W]e will reverse the judgment of the circuit court, dismiss the garnishment summons, and enter final judgment in favor of NSI.”
Practical impact
In Virginia a judgment creditor cannot reach a debtor’s domain names by garnishing the registrar. Domain names nonetheless pass in negotiated and court-supervised sales of a business (bankruptcy, receivership, ABC) through the owner’s or estate representative’s transfer. Contrast kremen-v-cohen-2003 (California; domain name is property).
Good-law status
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Applies in →
intellectual-property-and-licenses, virginia
Legal information, not legal advice. Verify against the current primary source before relying on this summary.