TM/SM in non-commercial contexts?

I'm interested in precedent and/or caselaw for use of trademark or service marks in non-commercial contexts. Most applicable would be publications or free-of-charge media services under a trademarked or service-mark protected name, logo, or brand.

My understanding of trademark law is that use is restricted to "use in commerce" (15 USC 1051(a)(3)(C). However I don't find a definition of "commerce".

There are numerous organizations which maintain identities but don't have commercial activities per se. And while I'm not sure if any of these use trademark or service mark protection, I suspect some do.

Guidance is appreciated.

-- 
Karsten M. Self <kmself@ix.netcom.com>        http://kmself.home.netcom.com/
 What Part of "Gestalt" don't you understand?
  I was never no good after that night, Charlie.
  - M. Brando





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