Westmore · UDRP DecisionThelinkedinstrategist.com
The Panel ordered transfer of <thelinkedinstrategist.com> to LinkedIn Corporation. It found the domain confusingly similar to the LINKEDIN mark because it incorporated the mark in its entirety, with the additional terms “the” and “strategist.” The Respondent failed to establish rights or legitimate interests, and the domain’s composition and prior use for prospecting services involving LinkedIn created a risk of confusion. The Panel further found bad-faith registration and use under paragraph 4(b)(iv) of the Policy because the Respondent intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s mark.
The timeline behind thelinkedinstrategist.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 thelinkedinstrategist.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an entire well-established platform mark with terms suggesting expertise or services relating to that platform can satisfy all three UDRP elements when the associated website commercially references the platform and the respondent supplies no substantive explanation. The case also shows that a later maintenance page does not erase the significance of documented prior website use.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LinkedIn Corporation v. Paul Jensen, Astral Business Solutions Case No. D2025-5269 1. The Parties The Complainant is LinkedIn Corporation, United States of America (“United States”), represented by The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States. The Respondent is Paul Jensen, Astral Business Solutions, South Af rica. 2. The Domain Name and Registrar The disputed domain name <thelinkedinstrategist.com> is registered with Tucows Domains Inc. (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 17, 2025. On December 17, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On December 17, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Redacted for Privacy) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on December 18, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on December 18, 2025. The Center verif ied that the Complaint together with the amendment to the Complaint, satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on December 19, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was January 8, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 13, 2026. The Respondent page 2 sent an email communication to the Center on January 15, 2026, which the Center acknowledged on the same day. The Center appointed Uwa Ohiku as the sole panelist in this matter on January 20, 2026. The Panel f inds 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. 4. Factual Background The Complainant was founded in 2003 and is one of the world’s largest professional networking platforms on the Internet, with over one billion members in more than 200 countries and regions, including executives f ro m every Fortune 500 company. The Complainant owns more than 700 trademarks comprising the term LINKED IN in over 71 jurisdictions worldwide, including: -United States Trademark No . 3074241 f or LINKEDIN, registered on March 28, 2006; -European Union Trademark No . 004183893 f or LINKEDIN, registered on July 24, 2006; and -International Trademark No . 1368414 LINKEDIN, registered on April 27, 2017. The Complainant’s domain name, <linkedin.com>, which was registered on November 2, 2002, hosts the Complainant’s primary website. The disputed domain name was registered on M arc h 12, 2020, and at the time of the Complaint, resolved to a website offering Internet visitors “Exp ert Prospecting Services” to help them “f ind the LinkedIn opportunities” they want, among several other services. The disputed domain name presently resolves to an inactive page, displaying the following message: “Maintenance Mode. This site is undergoing scheduled maintenance. Please check back soon.” 5. Parties’ Contentions A. Complainant The Complainant contends that all the three elements required for a transfer of the disputed domain name under paragraph 4(a) of the Policy have been satisf ied. Notably, the Complainant contends t hat the disputed domain name is confusingly similar to a trademark or service mark in which the Complainant has rights as it contains the Complainant’s LINKEDIN trademark in its entirety, with the addition of the words “the” and “strategist”, which do not diminish the conf using similarity between the disputed domain name and the Complainant’s mark. The Complainant further contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name; that the Respondent has never been granted any rights or authorization, to reg ister or use the disputed domain name; that the Respondent has not been commonly known as “linkedin” and has not acquired any trademark or service mark rights in the mark. The Complainant further asserts that the Respondent’s use of the disputed domain name is not in connection with a bona fide off ering of goods and services and that the Respondent is not making a legitimate noncommercial or f air use of the disputed domain name, given the circumstances of the Respondent’s use of the disputed domain name. The Complainant also ref ers to previous UDRP panel decisions to buttress its contentions in this regard. The Complainant asserts further that the disputed domain name was registered and is being used in bad f aith by the Respondent; that the motive of the Respondent in registering and using the disputed domain name is to disrupt the Complainant’s business and to attract Internet users f or gain, both acts which page 3 constitute bad faith registration and use. Further, that the use of the disputed domain name (Annex 8 of the Complaint) by the Respondent clearly shows that the Respondent was aware of the Complainant’s LINKED IN trademark which has a strong reputation and is globally well kno wn, and creating a website that appears to be a website of the Complainant is “likely fraudulent” and “indicates an intent to deceive or at a minimum, act in bad faith with the intent for commercial gain”. The Complainant also asserts that given that the disputed domain name is “so obviously connected with ‘the Complainant, the Respondent’s actions suggest ‘opportunistic bad faith’ in violation of the Policy”. (LinkedIn Corporation v. David Naranjo, All Play Media, WIPO Case No . D2019-2784). B. Respondent The Respondent did not f ile a f ormal response to the Complainant’s contentions, but sent an email communication to the Center, on January 15, 2026, well after the deadline to respond to the Complaint had expired, copying in the Complainant’s representatives and the Registrar of the disputed domain name. The Respondent contended that t he communication from the Center appeared to be invalid; that the identities of the recipients could not be verified in the absence of any names or specific email addresses; that he did not know who he was addressing, etc. The Panel addresses the email communications in the Panel’s f indings below. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs the Panel to “decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any other rules and principles of law that it deems applicable”. The Respondent did not file a formal response to the Complainant’s assertions. Ho wever, as stated above, the Respondent sent an email communication on January 15, 2026, after the deadline to file a Response had lapsed, to the Center, (copying in the Complainant’s representatives and the Registrar of the disputed domain name) contending that the identities of the recipients were unclear; that he did not know who he was addressing and requested valid and verif ied addresses. The email did not responded, or ref ute the Complainant’s assertions, b ut was sent on top of the email of December 19, 2025, sent by the Center to notif y the Respondent of the Complaint and of the formal commencement of the UDRP proceeding, which included information on the steps the Respondent could take and the timeline f or a response, etc. The Center acknowledged receipt of the Respondent’s email of January 15, 2026, f urther clarif ying to the Respondent that the Complaint had been filed in accordance with the UDRP incorporated in the Registration Agreement binding on the Respondent. Taking into consideration the facts and available evidence theref ore, this Panel regards the Respondent’s communication after the deadline to file a response, as mere subterfuge and by virtue of the Panel powers under paragraph 10 (d) of the Rules, f inds the same immaterial and attaches no weight to them. The lack of a f ormal response f rom the Respondent, however, does not automatically mean that the Complainant has established the three elements in paragraph 4(a) of the Policy for a transfer of the disputed domain name. The Panel has a responsibility to review all the relevant evidence and annexed materials provided in the Complaint to verify that all three elements are indeed established. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 4.3. Under paragraph 5(f) of the Rules, barring exceptional circumstances, in the absence of a response, the Panel shall decide the dispute based on the Complaint. Under paragraph 14(b) of the Rules, in the absence of exceptional circumstances, the Panel may also draw inferences as it considers appropriate from any non- compliance b y a p arty , with any provision or requirement under the Rules. Limited independent research may also be conducted by the Panel by virtue of paragraph 10 of the Rules. page 4 A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 name. WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel f inds that the entirety of the Complainant’s mark is reproduced and immediately recognizable within the disputed domain name. Accordingly, the disputed domain name is conf usingly similar to the Complainant’s mark f or the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Panel also finds that the addition of other terms, here, the words “the” and “strategist”, does not prevent a f inding of confusing similarity between the disputed domain name and the mark f or the purposes of the Policy. WIPO Overview 3.0, section 1.8. Further, the generic Top-Level Domain (“gTLD”) “.com” may be disregarded for the purposes of assessing conf using similarity as this is a standard registration requirement. The Panel f inds the f irst element of the Policy has been established. B. Rights or Legitimate Interests The second element requires the Panel to examine whether the Respondent has any rights or legitimate interests in the disputed domain name and paragraph 4(c) of the Policy provides a list of circumstances by which a respondent may demonstrate such rights or legitimate interests. The Complainant has provided copious and uncontested evidence that its rights in the LINKEDIN trademark are extensive and well-established. 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 of ten primarily within the knowledge or control of the respondent. Thus, where a complainant makes out a prima f acie case that the respondent lacks rights or legitimate interests, the burden of production on this element then shifts to the respondent to come f orward 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 f ails to come f orward with such relevant evidence, as in this case, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. The Panel f inds that the previous website content and the composition of the disputed domain name together create a risk of Internet user conf usion as to who is behind the disputed domain name and website. Accordingly, having reviewed the available record, the Complainant’s p rior and well-established rights in the LINKEDIN trademark, the unrebutted assertions, the preponderance of evidence submitted as annexes to the Complaint and the f ailure of the Respondent to come f orward to establish any rights or legitimate interests in the disputed domain name, such as those enumerated in paragraph 4(c) of the Policy or otherwise, the Panel finds that the Complainant has established the second element of the Policy that the Respondent lacks rights or legitimate interests in the disputed domain name. page 5 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 sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad f aith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad f aith. WIPO Overview 3.0, section 3.2.1. Given all the f oregoing, and taking into consideration the unrebutted contentions of the Complainant, (some of which are reproduced above), the preponderance of evidence by way of several annexes, and the composition and the use of the disputed domain name, the Panel concludes that the disputed domain name was registered and being used by the Respondent (who appears to trade as Astral Business Solutions) in bad f aith, all acts falling particularly within paragraph 4(b)(iv) of the Policy, that is, intentionally attempting to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <thelinkedinstrategist.com> be transf erred to the Complainant. /Uwa Ohiku/ Uwa Ohiku Sole Panelist Date: January 27, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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