We believe this trend will continue as keyword targeted advertising has become a key medium for small business ad campaigns, and economic recoveries are a time when many small businesses get off the ground.
As I mentioned in this post, consumer surveys suggest that consumers conduct do those keyword search for a variety of reasons that may have nothing to do with finding the trademark owner (a point I also stressed in my 2005 Deregulating Relevancy article).
Although the propriety of keyword advertising on a third party trademark has been hotly contested since at least 2004, I believe this is the first ruling addressing the publicity rights issue.