Are the courts set to lock the door on keyword advertising?

Google announced last month that it would no longer grant requests
from US and Canadian trademark owners to stop selling their trademarks as keywords
that trigger advertising. The policy is consistent with the latest Ninth Circuit
decision on the subject. However, Carla Oakley of Morgan Lewis & Bockius
LLP in San Francisco explains that keyword advertising litigation is far from
over, as mark owners and courts in the United States and Europe continue to
grapple with the topic and other similar trademark uses in internet advertising.