I've heard of people getting "cease and desist" _letters_ (i.e., from the competitor's lawyer) for this behavior, but never an actual C&D order, which is a cour

I've heard of people getting "cease and desist" _letters_ (i.e., from the competitor's lawyer) for this behavior, but never an actual C&D order, which is a court order. The general approach seems to be, unless the trademark holder specifically complains, you can place ads on their keywords, and even use their trademark in your ad, as long as you're not pretending to be them. "We're better than X", for example. And if the trademark holder does take issue with it, they're at least as likely to take it up with Google as they are to take it to court.