The Anticybersquatting Protection Act (ACPA) was enacted in the United States to provide trade mark holders with remedies against cyber-squatters. Under the ACPA, a defendant is considered to be a cyber-squatter and liable in a civil action if the plaintiff can demonstrate that: (1) the plaintiff owns a mark that was distinctive or famous at the time of registration of the domain name; (2) the defendant registered, uses, or traffics in a domain name that is identical to or confusingly similar to the distinctive or famous mark; and (3) the defendant had a bad faith intent to profit from the mark. If a trade mark owner can satisfy these requirements, it may be entitled to various forms of relief, namely transfer, forfeiture or cancellation of the domain name and, in certain circumstances, monetary recovery.