Domain disputes
UDRP decisions
Every UDRP argument rests on published decisions. These are the ones we cite most, summarised, with a link to each full text at WIPO.
- World Wrestling Federation Entertainment, Inc. v. Michael Bosman
- Case
- WIPO D1999-0001, 1999
- Domain
- worldwrestlingfederation.com
- Outcome
- Transferred
The first decision ever issued under the UDRP. Offering to sell a domain to the trademark owner for more than the registrant's documented costs is itself bad faith use under policy paragraph 4(b)(i).
- Telstra Corporation Limited v. Nuclear Marshmallows
- Case
- WIPO D2000-0003, 2000
- Domain
- telstra.org
- Outcome
- Transferred
A domain name that hosts nothing at all can still be used in bad faith, where the mark is well known, the registrant concealed their identity and no good faith use is plausible. This is the origin of the passive holding doctrine.
- Excelentisimo Ayuntamiento de Barcelona v. Barcelona.com Inc.
- Case
- WIPO D2000-0505, 2000
- Domain
- barcelona.com
- Outcome
- Transferred
The panel ordered transfer of a geographic name to the city authority.
The transfer was later reversed by the United States Court of Appeals for the Fourth Circuit. A useful reminder that a UDRP decision is not final and can be displaced by a court.
- Wal-Mart Stores, Inc. v. Richard MacLeod d/b/a For Sale
- Case
- WIPO D2000-0662, 2000
- Domain
- wal-martsucks.com
- Outcome
- Transferred
A domain combining a trademark with 'sucks' is still confusingly similar under the policy, because the test asks whether the domain includes the mark, not whether it would confuse anyone. The panel ordered transfer based on the registrant's bad faith attempt to sell the domain, not on any real risk of confusion.
- Chanel, Inc. v. Estco Technology Group
- Case
- WIPO D2000-0413, 2000
- Domain
- chanelstore.com, chanelfashion.com
- Outcome
- Transferred
Adding generic words like 'store' or 'fashion' to a famous mark does not remove the confusing similarity. The panel distinguished between writing about a brand and using its name as the domain itself.
- Lockheed Martin Corporation v. Dan Parisi
- Case
- WIPO D2000-1015, 2000
- Domain
- lockheedsucks.com, lockheedmartinsucks.com
- Outcome
- Complaint denied
A majority of the panel held that adding 'sucks' to a mark can remove confusing similarity entirely, once the added word signals the site is not affiliated with the owner, and denied the complaint. One panelist dissented. Frequently cited against Wal-Mart Stores v. MacLeod, D2000-0662, on the same question with the opposite result.
- Nokia Corporation v. Nokiagirls.com a.k.a IBCC
- Case
- WIPO D2000-0102, 2000
- Domain
- nokiagirls.com
- Outcome
- Cancelled
Adding a generic word to a globally famous mark does not remove the likelihood of confusion. The respondent used the site to sell advertising space, which the panel treated as free riding on Nokia's goodwill.
- Arthur Guinness Son & Co. (Dublin) Limited v. Dejan Macesic
- Case
- WIPO D2000-1698, 2000
- Domain
- guiness.com
- Outcome
- Transferred
A domain one letter short of the mark is confusingly similar, and a disclaimer does not cure the bad faith, because a visitor has already been diverted by the time they read it.
- Julia Fiona Roberts v. Russell Boyd
- Case
- WIPO D2000-0210, 2000
- Domain
- juliaroberts.com
- Outcome
- Transferred
The UDRP does not require a registered trademark. Someone with enough public recognition can hold common law rights in their own name, sufficient to bring a complaint over a domain using it.
- Gordon Sumner, p/k/a Sting v. Michael Urvan
- Case
- WIPO D2000-0596, 2000
- Domain
- sting.com
- Outcome
- Complaint denied
STING was too common an English word to give the complainant exclusive rights against a respondent who had used it as an online handle. The panel also found the alleged $25,000 sale demand unproven, calling the evidence merely consistent with bad faith rather than proof of it.
- Smart Design LLC v. Carolyn Hughes
- Case
- WIPO D2000-0993, 2000
- Domain
- smartdesign.com
- Outcome
- Complaint denied
The panel dismissed the complaint and found reverse domain name hijacking, calling it 'a clear abuse of the Policy designed to deprive the Respondent of her domain name.' The respondent had used the domain for a consulting business before the complaint was filed.
- K2r Produkte AG v. Jeremie Trigano
- Case
- WIPO D2000-0622, 2000
- Domain
- k2r.com
- Outcome
- Complaint denied
The complainant had already ascertained facts establishing the respondent's legitimate interest in the domain before filing anyway, on unsupported cybersquatting allegations, which a majority of the panel found to be reverse domain name hijacking. One panelist dissented.
- Bridgestone Firestone, Inc. v. Jack Myers
- Case
- WIPO D2000-0190, 2000
- Domain
- bridgestone-firestone.net
- Outcome
- Complaint denied
A critic does not have to add a word like 'sucks' to a domain to signal a criticism site. Disclaimers and the choice of a different extension from the trademark owner's were enough to establish a legitimate interest.
- Madonna Ciccone, p/k/a Madonna v. Dan Parisi and "Madonna.com"
- Case
- WIPO D2000-0847, 2000
- Domain
- madonna.com
- Outcome
- Transferred
A disclaimer does not fix a domain registered in bad faith. The panel found no plausible reason for choosing the name Madonna other than to trade on the performer's fame.
- Encyclopaedia Britannica, Inc. v. John Zuccarini, The Cupcake Patrol
- Case
- WIPO D2000-0330, 2000
- Domain
- encyclopediabrittanica.com, brtannica.com, bitannica.com, britannca.com
- Outcome
- Transferred
A documented history of registering misspellings of well known marks, plus a prior injunction for the same conduct, is treated as clear evidence of bad faith rather than coincidence.
- Wal-Mart Stores, Inc. v. Walsucks and Walmarket Puerto Rico
- Case
- WIPO D2000-0477, 2000
- Domain
- walmartcanadasucks.com, wal-martcanadasucks.com, walmartuksucks.com, walmartpuertorico.com, walmartpuertoricosucks.com
- Outcome
- Transferred
The respondent registered five domains within days of losing an earlier Wal-Mart dispute, then demanded payment for 'domain name consultant' services. The panel called it a blatant abuse of the registration process.
- Do The Hustle, LLC v. Tropic Web
- Case
- WIPO D2000-0624, 2000
- Domain
- pollyester.com, pollyesters.com
- Outcome
- Complaint denied
The panel found the domains confusingly similar but denied the complaint anyway, because the complainant could not prove bad faith. Dictionary-adjacent misspellings without any offer to sell were not enough.
- Oki Data Americas, Inc. v. ASD, Inc.
- Case
- WIPO D2001-0903, 2001
- Domain
- okidataparts.com
- Outcome
- Complaint denied
Sets the conditions under which a reseller has a legitimate interest in a domain containing the manufacturer's mark: it actually sells the goods, the site sells only those goods, it accurately discloses the relationship, and it does not corner the domain market. The complaint was denied.
- Bruce Springsteen v. Jeff Burgar and Bruce Springsteen Club
- Case
- WIPO D2000-1532, 2001
- Domain
- brucespringsteen.com
- Outcome
- Complaint denied
The domain was identical to the complainant's unregistered mark, but the registrant showed some rights or legitimate interests and bad faith registration and use was not made out. The complaint failed on the second and third elements.
- Milwaukee Electric Tool Corporation v. Bay Verte Machinery, Inc.
- Case
- WIPO D2002-0774, 2002
- Domain
- milwaukeetool.com
- Outcome
- Complaint denied
An authorized distributor who registers the manufacturer's mark in a domain, in good faith and before being told to stop, has a legitimate interest in it. The respondent sold Milwaukee's tools alongside other brands, matching Milwaukee's usual distribution model.
- Croatia Airlines d.d. v. Modern Empire Internet Ltd.
- Case
- WIPO D2003-0455, 2003
- Domain
- croatiaairlines.com
- Outcome
- Transferred
Frequently cited on how a complainant makes out a prima facie case under the second element, after which the burden shifts to the registrant.
- Tom Cruise v. Network Operations Center / Alberta Hot Rods
- Case
- WIPO D2006-0560, 2006
- Domain
- tomcruise.com
- Outcome
- Transferred
Delay in bringing a complaint is not a defence under the UDRP. Without evidence that the complainant consented to the use, or that the registrant changed its position because of the delay, a 10-year wait does not stop a transfer. Using celebrity names to send traffic to an advertising site is not fair use.
The respondent's president, Jeff Burgar, had won Bruce Springsteen v. Jeff Burgar, D2000-1532, in 2001 on similar facts. The Tom Cruise panel instead followed the decisions brought against him by Celine Dion, Kevin Spacey and Michael Crichton, which rejected the same celebrity portal defence.
- Karen Millen Fashions Limited v. Danny Cullen
- Case
- WIPO D2011-1134, 2011
- Domain
- karenmillenoutletonline.com
- Outcome
- Complaint denied
A complainant that alleges counterfeits has to prove it. Without evidence, the panel treated the site as a possible seller of genuine or grey-market goods under the Oki Data test, and the complaint failed on the second element despite the respondent's default.
- Wirecard AG v. Telepathy Inc., Development Services
- Case
- WIPO D2015-0703, 2015
- Domain
- boon.com
- Outcome
- Complaint denied
A domain registered before the complainant's trademark rights existed cannot have been registered in bad faith. A domain investor may ask any price in reply to an unsolicited offer. A represented complainant that files anyway, knowing of a 16-year gap, abuses the proceeding.
- Khloe Kardashian, Whalerock Celebrity Subscription, LLC, Khlomoney, Inc. v. Private Registrations Aktien Gesellschaft / Privacy Protection Service Inc. d/b/a Privacyprotect.Org
- Case
- WIPO D2015-1113, 2015
- Domain
- khloekardashian.com
- Outcome
- Transferred
A domain registered in anticipation of fame can be registered in bad faith before any trademark is registered. Registering a personal name two weeks after the person's television debut, then parking it with an invitation to buy, showed the registrant had her in mind.
- Philip Morris USA Inc. v. Borut Bezjak, A Domains Limited
- Case
- WIPO D2015-1128, 2015
- Domain
- marlboro.party
- Outcome
- Complaint denied
A famous mark is not enough where the domain also matches a place name and the registrant has a pre-dispute pattern of registering geographic names. The complainant has to prove the registrant targeted its mark. The panel added that bulk registrants carry some responsibility to keep trademarks out of their algorithms.
- LinkedIn Corporation v. Daphne Reynolds
- Case
- WIPO D2015-1679, 2015
- Domain
- linkedlnjobs.com
- Outcome
- Transferred
Swapping one letter for a lookalike does not avoid confusing similarity, and typosquatting is itself evidence of bad faith registration. Using the domain as the sender address for fraudulent job offers was bad faith use, even though the website only redirected to linkedin.com.
- Accenture Global Services Limited v. Patel Holdings
- Case
- WIPO D2016-0367, 2016
- Domain
- accenturejobs.com
- Outcome
- Transferred
A domain does not need a website to be used in bad faith. An email address on the domain used to pose as the complainant's recruitment team was illegitimate use, and adding 'jobs' to a well-known mark made the confusion worse.
- Virgin Enterprises Limited v. Cesar Alvarez
- Case
- WIPO D2016-2140, 2016
- Domain
- virginmedia.shop
- Outcome
- Transferred
A new gTLD gives no cover. A registrant who picks a famous mark because people search for it, leaves the domain unused and asks the owner for more than out-of-pocket costs registers and uses it in bad faith. The trademark owner's failure to register in the sunrise period is irrelevant.
- Fédération Internationale de Football Association ('FIFA') v. Whois Privacy Shield Services / Winsum Wong
- Case
- WIPO D2016-2310, 2017
- Domain
- fifa.net
- Outcome
- Transferred
A world-famous mark registered under a different top-level domain from the owner's own site, fifa.com, supports an inference of bad faith. Three prior adverse decisions showed a pattern under paragraph 4(b)(ii), and a privacy service used by such a registrant weighs against it.
- Allianz SE v. IP Legal, Allianz Bank Limited
- Case
- WIPO D2017-0287, 2017
- Domain
- allianzkenya.com
- Outcome
- Transferred
Adding a country name to a famous mark does not avoid confusing similarity. Registering under a fictitious company name breaches the registration agreement, and with a well-known mark and no plausible good faith use, passive holding is bad faith under the Telstra test.
Summaries are ours. The decisions themselves are the authority, and each page links to the full text published by the WIPO Arbitration and Mediation Center.
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