The first trademark application for UGG in the United States was filed by Brian Smith's company in 1984. In the 1990s, Smith and then Deckers secured additional registrations in the U.S. and other countries. In 1999, Deckers began asserting its new trademark and sent out cease and desist letters to Australian manufacturers that were selling sheepskin boots outside of Australia via the internet. By the early 2000s, demand for UGG boots was soaring with Australian and U.S.-based manufacturers selling sheepskin boots over the Internet. There was confusion among consumers between generic ugg boots made in Australia and Deckers' UGG brand boots. Deckers' law firm Middletons of Melbourne began a serious effort to halt the Australian companies' sales by sending cease and desist letters to a number of Australian and U.S.-based manufacturers, preventing them from selling sheepskin boots using the UGG trademark on eBay or from using the word in their registered business names or domain names. Deckers initiated numerous domain name actions under the UDRP.