Westmore · UDRP decision
WIPO · Case No. D2025-4581

Leathermanaustralia.com + 21 more domains

Transfer, denied in partWIPO-indexed · informational, not legal advice

The Panel accepted consolidation for 20 domain names after finding sufficient evidence of common control, including similar naming patterns, concentrated registration dates, shared technical characteristics, and substantially identical passing-off websites. It found all three UDRP elements established for those domains and ordered their transfer. The Panel declined consolidation for <leathermanonline.shop> and <leathermandeal.shop> because the evidence did not sufficiently connect them to the commonly controlled group; the Complaint concerning those two domains was dismissed without prejudice rather than decided on the merits.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Transfer, denied in part
Decision date
2026-02-23
Panelist(s)
Wong Wai Man, Deanna
Complainant
Leatherman Tool Group, Inc.
Respondent
杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) 苏科 (ke su, suke, su ke) 林志冰 (linzhibing, lin zhibing) 臧勇 (zang yong, zangyong) 曾发琴 (zengfaqing, zeng faqing) 郑道君 (zheng daojun, zhengdaojun) earl j glancy jiu lin L Adams Timothy, Timothy L Adams Liana De M Albert Jerome, Jerome M Albert McLachlan Krystal, Krystal McLachlan niu youguo
Disputed domain(s)
leathermanaustralia.com, leatherman-canada.com, leathermandeal.shop, leatherman-eu.com + 18 more
Citation weightCited by 2 later decisions · relies on 3 authorities
Domain history UDRP Intelligence

The timeline behind leathermanaustralia.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Westmore reconstructs the full history behind leathermanaustralia.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Outcome by domain

How each disputed name was decided in this proceeding.

leathermanaustralia.comUndetermined
leatherman-canada.comUndetermined
leathermandeal.shopUndetermined
leatherman-eu.comUndetermined
leatherman-europe.shopUndetermined
leatherman-eu.shopUndetermined
leathermaneu.shopUndetermined
leatherman-eu.topUndetermined
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of leathermanaustralia.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that consolidation is domain-specific and evidence-driven. Strong common patterns across names, registration timing, website content, and technical infrastructure justified consolidation and transfer of 20 domains, but did not automatically extend to two domains registered to an identified respondent where one domain showed materially different use and that respondent informally objected. The dismissal without prejudice preserved the distinction between a procedural failure to establish common control and a decision on the UDRP merits.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer, denied in part
Decision date
2026-02-23
Panel
Wong Wai Man, Deanna
Full decision
22 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Leatherman Tool Group, Inc. v. niu youguo; 苏科 (ke su, suke, su ke); 杭州 奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si); earl j glancy; 郑道君 (zheng daojun, zheng daojun); 臧勇 (zang yong, zangyong); 曾发琴 (zengfaqing, zeng faqing); 林志冰 (linzhibing, lin zhibing); jiu lin; Liana De; M Albert Jerome, Jerome M Albert; L Adams Timothy, Timothy L Adams; McLachlan Krystal, Krystal McLachlan Case No. D2025-4581 1. The Parties The Complainant is Leatherman Tool Group, Inc., United States of America (“United States”), represented by SafeNames Ltd., United Kingdom. The Respondents are niu youguo, United States; 苏科 (ke su, suke, su ke), China; 杭州奥深互动科技有限公 司 (hang zhou ao shen hu dong ke ji you xian gong si), China; earl j glancy, Germany; 郑道君 (zheng daojun, zhengdaojun), China; 臧勇 (zang yong, zangyong), China; 曾发琴 (zengfaqing, zeng faqing), China; 林志冰 (linzhibing, lin zhibing), China; jiu lin, China; Liana De, Canada; M Albert Jerome, Jerome M Albert, Germany; L Adams Timothy, Timothy L Adams, Germany; and McLachlan Krystal, Krystal McLachlan, Germany. 2. The Domain Names and Registrars The disputed domain names <leathermanaustralia.com>, and <leatherman-uk.com> are registered with CNOBIN Information Technology Limited. The disputed domain name <leatherman-canada.com> is registered with Web Commerce Communications Limited dba WebNic.cc. The disputed domain names <leathermandeal.shop>, and <leathermanonline.shop> are registered with Alibaba Cloud Computing Limited. The disputed domain names <leatherman-eu.com>, <leathermaneu.shop>, <leatherman-eu.top>, <leatherman-ll.top>, <leatherman-lp.top>, <leatherman-online.shop>, <leatherman-outlet.com>, <leathermansalee.com>, <leathermansell.com>, and <leatherman-svip.top> are registered with Xin Net Technology Corporation. page 2 The disputed domain name <leatherman-europe.shop> is registered with Chengdu West Dimension Digital Technology Co., Ltd. The disputed domain name <leatherman-eu.shop> is registered with PDR Ltd. d/b/a PublicDomainRegistry.com. The disputed domain names <leathermanoutlet-eu.shop>, <leathermansale.com>, and <leathermansale.shop> are registered with West263 International Limited. The disputed domain name <leathermanromania.ro> is registered with ROTLD. The disputed domain name <leathermansales.shop> is registered with Spaceship, Inc. 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on November 4, 2025. 1 On November 6, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. Between November 7 and 26, 2025, the Registrars transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 26, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all disputed domain names are under common control. The Complainant filed an amended Complaint in English on December 11, 2025. On November 26, 2025, the Center informed the Parties in Chinese and English, that the language of the Registration Agreements for certain of the disputed domain names is Chinese. On December 11, 2025, the Complainant requested English to be the language of the proceeding. The Respondents did not submit any comment on the Complainant’s submission. The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents in English and Chinese of the Complaint, and the proceedings commenced on December 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 12, 2026. The Respondent 杭州奥深互动科 技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) sent email communications to the Center on November 7, 27, and 28, 2025. On November 27, 2025, the Center sent an email to the Parties regarding possible settlement. On January 13, 2026, the Center informed the Parties of the commencement of panel appointment process. The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on January 26, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 1 The Complaint was original filed against 25 domain names and three domain names were removed from the proceedings when the Complainant submitted the amended Complaint on December 11, 2025. page 3 On February 17, 2026, the Panel issued Procedural Order No. 1, noting that the disputed domain name <leatherman-canada.com> is registered with Web Commerce Communications Limited dba WebNic.cc, as confirmed by the public WhoIs record and Registrar’s Verification. The Panel further noted that this Registrar had been omitted from paragraph 8 of the amended Complaint and, pursuant to paragraphs 10 and 12 of the Rules, directed the Complainant to include this Registrar in paragraph 8 and submit a newly amended Complaint by February 22, 2026, with the decision due date extended to February 23, 2026. On February 18, 2026, the Complainant submitted a newly amended Complaint in compliance with Procedural Order No. 1. The Panel has taken it into account in reaching this Decision, while disregarding any potential additional changes and evidence not directly related to, or exceeding, the correction required by the Procedural Order. 4. Factual Background The Complainant is a company founded in 1983 in the United States. The Complainant manufactures and markets multi-purpose tools, knives, pocket tools, wearables, and related accessories. Its products are sold in more than 70 countries worldwide, including through online marketplaces such as Amazon. The Complainant maintains an active presence on social media platforms, including X, Facebook, LinkedIn, Instagram, and YouTube, where it has accumulated a substantial following. As a result of this longstanding and widespread commercial use, the Complainant’s brand and products have achieved significant recognition in the global tools market. The Complainant is the owner of an international trademark portfolio comprising numerous trademark registrations for the mark LEATHERMAN, including but not limited to United States Trademark Registration No. 1325473, registered on March 19, 1985, in class 8; United States Trademark Registration No. 2596689, registered on July 23, 2002, in class 25; Canada Trademark Registration No. TMA380140, registered on February 15, 1991, in class 8; and European Union Trademark Registration No. 000041731, registered on March 31, 2004, in classes 18, 25, and 28. The Complainant further owns the domain name <leatherman.com>, registered on October 19, 1995. The disputed domain names were all registered between July 29, 2025 and September 26, 2025 and, according to the Complainant’s submissions, all of the disputed domain names (except for <leathermanonline.shop> and <leatherman-online.shop>) previously resolved at various times to similar websites passing off as the Complainant’s online shops by displaying substantially identical offerings and visual content. The disputed domain name <leathermanonline.shop> previously resolved to a website primarily offering for sale clothing while the disputed domain name <leatherman-online.shop> did not resolve to an active website. The Panel notes that on the date of this Decision all of the disputed domain names direct to inactive webpages. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain names. Notably, the Complainant contends that it has established rights in the LEATHERMAN trademark through long-standing and extensive use, as well as through numerous registered trademarks in multiple jurisdictions and that the disputed domain names each incorporate the LEATHERMAN mark in its entirety, with the addition of only descriptive, geographical, or other non-distinctive terms, as well as hyphens or minor variations. According to the Complainant, such additions do not prevent a finding of confusing similarity, as the LEATHERMAN mark remains clearly recognizable within the disputed domain names. The applicable generic or country code Top-Level Domains are to be disregarded for the purposes of the first element. page 4 Further, the Complainant asserts that the Respondents have no rights or legitimate interests in respect of the disputed domain names. The Respondents are neither licensed nor otherwise authorized to use the LEATHERMAN mark and are not commonly known by any of the disputed domain names. The Complainant contends that the disputed domain names have been used to resolve to websites passing off as the Complainant by displaying its trademark, logo, and copyrighted content, and by purporting to sell the Complainant’s products, which does not constitute a bona fide offering of goods or services. To the extent that any disputed domain names resolve to inactive pages or to websites offering unrelated products, the Complainant submits that such use likewise fails to give rise to rights or legitimate interests. The Complainant therefore maintains that it has established a prima facie case under paragraph 4(a)(ii) of the Policy. As to bad faith, the Complainant contends that the disputed domain names were registered and are being used in bad faith. The LEATHERMAN trademark predates the registration of the disputed domain names by several decades and is widely known, making it implausible that the Respondents registered the disputed domain names without knowledge of the Complainant and its rights. The Complainant submits that the Respondents intentionally targeted the Complainant’s mark by registering multiple domain names incorporating it together with terms related to the Complainant’s business and geographical markets, and by using them to operate impersonating online shops for commercial gain. The Complainant further relies on the Respondents’ pattern of conduct, including the registration of multiple similar domain names, the use of false or inconsistent registrant details, the failure to respond to a cease-and-desist letter sent to some of the Respondents, and the passive holding of certain disputed domain names, which, taken together, are said to support a finding of bad faith under paragraph 4(a)(iii) of the Policy. B. Respondents The Respondents did not formally reply to the Complainant’s contentions. However, the Respondent 杭州奥 深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) sent email communications to the Center on November 7, 27, and 28, 2025, but for the reasons set out under section 6.1 below, the Panel will not consider these further. 6. Discussion and Findings 6.1 First Preliminary Issue: Consolidation of Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request. Nevertheless, the Respondent杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) sent various email communications to the Center on November 7, 27, and 28, 2025, in which this Respondent informally contests the arguments presented by the Complainant, and specifically indicated that their company is the registrant for the disputed domain names <leathermandeal.shop> and <leathermanonline.shop>. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions (“WIPO Overview 3.1”), section 4.11.2. page 5 As regards common control, the Panel notes that the Complainant essentially contends that the disputed domain names are all under common control based on the following elements: the highly similar lexical composition of the disputed domain names, all of which incorporate the LEATHERMAN mark together with mainly comparable descriptive or geographical terms, the fact that all of the disputed domain names (except for <leathermanonline.shop> and <leatherman-online.shop>) have resolved at various times to similar websites passing off as the Complainant’s online shops by displaying substantially identical content and images, the use of the same hosting provider and closely related IP addresses, and the registration of the disputed domain names within a short, concentrated time period. The Complainant further submits that, although the disputed domain names appear under different registrant names and Registrars, they fall into identifiable registration groupings mainly based in Germany and China that each country group displays internal consistencies in registration details, timing, technical infrastructure, and website use, and that these groupings are themselves linked by shared website content, hosting provider, IP ranges, and registration periods. According to the Complainant, the remaining disputed domain names outside these two country groups can also be connected to these groupings through similar technical and registration characteristics and shared website content. Taken together, the Complainant submits that these factors demonstrate a coordinated pattern of conduct amounting to common control, and that consolidation would therefore be fair, equitable, and procedurally efficient. Having reviewed the facts, arguments and the evidence submitted, the Panel finds that the abovementioned factors and arguments are sufficient to, on a balance of probabilities, establish that the disputed domain names <leathermanaustralia.com>, <leatherman-canada.com>, <leatherman-eu.com>, <leatherman-europe.shop>, <leatherman-eu.shop>, <leathermaneu.shop>, <leatherman-eu.top>, <leatherman-ll.top>, <leatherman-lp.top>, <leatherman-outlet.com>, <leathermanoutlet-eu.shop>, <leathermanromania.ro>, <leathermansale.com>, <leathermansalee.com>, <leathermansale.shop>, <leathermansales.shop>, <leathermansell.com>, <leatherman-svip.top>, and <leatherman-uk.com> are subject to common control. In this regard, the Panel attaches particular importance to the similar naming patterns, to the fact that they were all used at a time to host passing off online shops displaying substantially identical or highly similar offerings and visual content and also to the fact that they were all registered in a relatively short period of time, i.e., between July 29, 2025 and September 26, 2025. As to the disputed domain name <leatherman-online.shop>, although this disputed domain name never resolved to a passing off website, the Panel finds that there are still sufficient indicia to establish common control on the balance of probabilities. These include, inter alia: (i) a consistent naming pattern; (ii) a proximate registration date; (iii) use of the same IP address as other disputed domain names and the same hosting provider; and (iv) the use of an email service which was also associated with certain abovementioned disputed domain names. The Panel also notes that the registrants of these disputed domain names did not reply and did not object to the Complainant’s consolidation request. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. However, the Panel finds that the foregoing arguments and factual indicia do not equally apply to the disputed domain names <leathermanonline.shop> and <leathermandeal.shop>, which are both registered in the name of the Respondent 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si). First, the Panel notes that, as admitted by the Complainant in its own arguments, the disputed domain name <leathermanonline.shop> does not currently and has never resolved in the past to websites passing off as the Complainant’s LEATHERMAN mark, thereby significantly departing from the most persuasive pattern relied upon by the Complainant to establish common control in respect of the other disputed domain names. Upon review of the evidence on record, the Panel further observes that <leathermanonline.shop> resolved to a website offering clothing under the name “LIFE IS GOOD”. Additionally, the Panel also takes into account that the Respondent 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) submitted several informal email communications (of November 7, 27, and 28, 2025) contesting the Complaint but only relating to the two disputed domain names <leathermanonline.shop> and <leathermandeal.shop>, thereby, in the Panel’s view, at least implicitly objecting to the consolidation. Considering the above, the Panel finds that the Complainant has not established, in respect of these two disputed domain names, <leathermanonline.shop> and <leathermandeal.shop>, sufficient indicia of common control. Accordingly, the Panel concludes that the evidence does not support a finding that common control is being exercised over these two disputed domain names. page 6 Accordingly, having regard to the above circumstances, the Panel accepts the consolidation as regards the disputed domain names <leathermanaustralia.com>, <leatherman-canada.com>, <leatherman-eu.com>, <leatherman-europe.shop>, <leatherman-eu.shop>, <leathermaneu.shop>, <leatherman-eu.top>, <leatherman-ll.top>, <leatherman-lp.top>, <leatherman-outlet.com>, <leathermanoutlet-eu.shop>, <leathermanromania.ro>, <leathermansale.com>, <leathermansalee.com>, <leathermansale.shop>, <leathermansales.shop>, <leathermansell.com>, <leatherman-svip.top>, <leatherman-online.shop>, and <leatherman-uk.com>. However, the Panel does not accept the consolidation as regards the disputed domain names <leathermanonline.shop> and<leathermandeal.shop>. Nevertheless, the Panel notes that the Complainant remains at liberty to file a new complaint/new complaints in respect of these disputed domain names and this Decision is made without prejudice to the possibility of refiling a complaint/complaints regarding these disputed domain names, which are hereby excluded from this proceeding. All further references in this Decision to the Respondent and the disputed domain names refer collectively to the consolidated parties and disputed domain names, as explained above. 6.2 Second Preliminary Issue: Language of the Proceeding The language of the Registration Agreements for some of the disputed domain names is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant has requested that the language of the proceeding be English for several reasons, including that the Complainant is based in the United States and that the Respondent has used, or previously used, the disputed domain names to host websites passing off as the Complainant’s offerings, which were wholly displayed in English. The Complainant submits that this demonstrates the Respondent’s familiarity with the English language and awareness of the Complainant’s English-speaking market. The Complainant further notes that the disputed domain names are composed solely of Latin characters and incorporate the Complainant’s LEATHERMAN trademark together with English terms, such as “outlet”, and English generic Top-Level Domains, such as “.shop”. In addition, the Complainant contends that the disputed domain names are under common control and that the Respondent has registered other disputed domain names subject to Registration Agreements drafted in English, indicating an ability to understand English for domain name registration purposes. The Complainant also observes that the Respondent did not reply to the Complainant’s cease-and-desist letter to indicate any lack of understanding of English. Finally, the Complainant submits that its representatives are based in the United Kingdom and that requiring translation would impose additional cost and delay. The Respondent did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview 3.1, section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. page 7 6.3 Findings on the Merits A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain names. WIPO Overview 3.1, section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within each of the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, including geographical terms such as “europe”, “australia”, “canada”, as well as additional elements such as letters, or misspellings of descriptive terms including “outlet”, “salee”, “sale”, “ll”, and “lp”, may bear on assessment of the second and third elements, the Panel finds that the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy (see WIPO Overview 3.1, section 1.8). The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain names. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the Policy or otherwise. Based on the evidence provided, the Panel notes that the Respondent is not licensed by the Complainant in any way, is not commonly known by the disputed domain names, and that there are no elements in the record indicating that the Respondent has made any reasonable or demonstrable preparations to use the disputed domain names in connection with a bona fide offering of goods or services. Instead, the Panel finds that the disputed domain names previously resolved, at various times, to similar websites passing off as the Complainant’s online shops by displaying substantially similar offerings and visual content. Panels have consistently held that the use of domain names for illegitimate activity, including passing off, can never confer rights or legitimate interests on a respondent (see WIPO Overview 3.1, section 2.13.1). page 8 Additionally, the Panel notes that, as of the date of this Decision, the disputed domain names direct to inactive or blank webpages. In these circumstances, the Panel finds that the passive holding of the disputed domain names, without any active use, likewise does not confer rights or legitimate interests on the Respondent (see, e.g., Bollore SE v. 赵竹飞 (Zhao Zhu Fei), WIPO Case No. D2020-0691; and Vente- Privee.Com and Vente-Privee.com IP S.à.r.l. v. 崔郡 (Jun Cui), WIPO Case No. D2021-1685). The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. In the present case, the Panel notes that the Respondent registered the disputed domain names well after the Complainant had established rights in, and made extensive use of, its LEATHERMAN trademarks. Given the reputation and recognition of the Complainant’s marks (see also prior decisions applying the Policy such as Leatherman Tool Group, Inc. v. zhang qiang, WIPO Case No. D2025-3233), and the composition of the disputed domain names, which incorporate the mark in its entirety, the Panel finds it implausible that the Respondent was unaware of the Complainant and its trademark at the time of registration. This conclusion is further reinforced by the fact that the disputed domain names previously resolved to similar websites passing off as the Complainant’s official web shops by reproducing the Complainant’s branding and visual content. Taken together, these circumstances support a finding that the Respondent deliberately targeted the Complainant and its trademark when registering the disputed domain names. As to use of the disputed domain names in bad faith, the Panel notes that the disputed domain names each previously resolved to active websites passing off as the Complainant by use of its marks, website content and visual materials. The overall presentation of these websites was such as to give the clear impression of passing off as the Complainant. The Panel therefore finds that the Respondent has used the disputed domain names to intentionally attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s LEATHERMAN trademark as to the source, sponsorship, affiliation, or endorsement of the websites and the goods offered thereon. Such conduct constitutes direct evidence of bad faith within the meaning of paragraph 4(b)(iv) of the Policy. Additionally, panels have held that the use of a domain name for illegitimate activity here, claimed passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. As to the fact that certain disputed domain names directed, and the disputed domain names currently direct to inactive websites, panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the reputation of the Complainant’s trademark, and the composition of the disputed domain names, and finds that in the circumstances of this case, the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 9 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <leathermanaustralia.com>, <leatherman-canada.com>, <leatherman-eu.com>, <leatherman-europe.shop>, <leatherman-eu.shop>, <leathermaneu.shop>, <leatherman-eu.top>, <leatherman-ll.top>, <leatherman-lp.top>, <leatherman-outlet.com>, <leathermanoutlet-eu.shop>, <leathermanromania.ro>, <leathermansale.com>, <leathermansalee.com>, <leathermansale.shop>, <leathermansales.shop>, <leathermansell.com>, <leatherman-svip.top>, <leatherman-online.shop>, and <leatherman-uk.com> be transferred to the Complainant. The Complaint is dismissed without prejudice as regards the disputed domain names <leathermanonline.shop>, and <leathermandeal.shop>. /Deanna Wong Wai Man/ Deanna Wong Wai Man Sole Panelist Date: February 23, 2026

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Westmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

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