And the Court granted defendants summary judgment as to plaintiff's federal and state constitutional claims, and plaintiff's laches defense. Plaintiff registered the Chicago2016.com domain in 2004, and after the sale, the domain registrar maintained a parking page on the site which included advertising links. Revenues for the links went to the registrar, not plaintiff.
The Court held that the parking page was commercial. But there was a question of fact as to whether plaintiff "used" the trademark, in this case the domain, for commercial purposes as required by the Stevens Act. Plaintiff did not receive revenues from the parking page and it was even unclear whether plaintiff knew of the parking page or consented to the registrar's use of the parking page.

To read the entire article check out : http://www.chicagoiplitigation.com/2009/10/articles/lanham-act-1/chicago-2016-is-a-trademark-but-not-all-cityplusolympicyear-marks-are/