infringement. Ultimately, the Court of Justice of the European Union ruled that Google AdWords were “not a breach of EU trademark law, but that the content of some advertisements that are linked by Google keywords may well be in breach depending upon the particular facts of the case.” Additionally, in some American jurisdictions, the use of a person's name as a keyword for advertising or trade purposes without the person's consent has raised Right to Privacy concerns. In 2013, the Tenth Circuit Court of Appeals held in 1-800 Contacts, Inc. v. Lens.com, Inc. that online contact lens seller Lens.com did not commit trademark infringement when it purchased AdWords and other search advertisements using competitor 1-800 Contacts' federally registered 1800 CONTACTS trademark as a keyword. In August 2016, the Federal Trade Commission filed an administrative complaint against 1-800 Contacts alleging that its search advertising trademark enforcement practices have unreasonably restrained competition in violation of the FTC Act. 1-800 Contacts has denied all wrongdoing and is scheduled to appear before an FTC administrative law judge in April 2017. IT support ban In 2018, Google implemented a policy change which restricts the advertising of consumer technical support, including, "troubleshooting, security, virus removal, internet connectivity, online accounts (for example, password resets or login support), or software installation", Google's Director of Global Product Policy, David Graff stated that the policy was intended to "address abuse" and "fraudulent activity" from third-party technical support providers, and that a verification program for legitimate providers would be rolled out "in the coming months". This is yet to manifest, resulting in an effective ban on all IT support and repair related services on the Google Ads platform. Commentators have expressed concerns that this is an attempt by Google to stifle consumers' right to repair electronic devices. Use by fossil fuel companies for greenwashing Fossil fuel companies, funders and public relations agencies including ExxonMobil, Shell, Aramco, McKinsey, and Goldman Sachs are among the largest customers of Google Ads. One in five Google Ads for climate-related terms (e.g. net zero, carbon storage, carbon capture and energy transition) were paid by fossil fuel companies. A study by The Guardian and InfluenceMap found that Shell's ads appeared on 86% of searches for "net zero". Over half of users in a 2020 survey could not tell the difference between a normal Google result and a Google Ad. One of the study's authors, InfluenceMap stated "Google