Westmore · UDRP DecisionLego-video-games.com
The Panel ordered transfer of <lego-video-games.com> to LEGO Holding A/S. It found the domain confusingly similar to the LEGO trademark because it incorporated the mark in full and the additional terms “video” and “games” did not prevent confusing similarity. The Respondent lacked rights or legitimate interests because there was no authorization, reseller relationship, evidence of being commonly known by the domain, bona fide offering, or legitimate fair use. Bad faith was established from the prior and well-known LEGO rights, the targeting composition of the domain, its use for an online-games website displaying the LEGO mark and logo, the resulting likelihood of confusion for commercial gain, and additional circumstances including use of a privacy service and failure to respond to communications or the proceeding.
The timeline behind lego-video-games.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 lego-video-games.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a direct targeting pattern in which a well-known mark is combined with descriptive terms connected to the content offered at the resulting website. The same facts—the full incorporation of LEGO, the related terms “video” and “games”, and the display of LEGO branding on an online-games site—supported confusing similarity, the absence of legitimate interests, and bad faith.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LEGO Holding A/S v. Xiaolong Hao Case No. D2025-5381 1. The Parties The Complainant is LEGO Holding A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Xiaolong Hao, India. 2. The Domain Name and Registrar The disputed domain name <lego-video-games.com> (the “Disputed Domain Name”) is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 23, 2025. On December 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On December 24, 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 (DT), Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 24, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on December 24, 2025. 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 Respondent of the Complaint and the amended Complaint, and the proceedings commenced on January 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was January 25, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 26, 2026. page 2 The Center appointed Monica Novac as the sole panelist in this matter on January 28, 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. 4. Factual Background The Complainant is a globally renowned Danish company established in 1932, specializing in the design, production, and sale of play materials, while it has also expanded the use of its LEGO mark to, inter alia, computer hardware and software, books, videos and computer controlled robotic construction sets. As per the incorporation documents filed with the Complaint, in January 2025, the Complainant changed its name from LEGO Juris A/S to the current LEGO Holding A/S in order to bring together all LEGO branded and related activities under one governance structure. The Complainant has subsidiaries and branches all over the world, including five main hubs, 37 sales offices, five manufacturing sites, and more than 500 retail stores. The Complainant employs over 28,500 people, while its LEGO branded products are sold in more than 130 countries worldwide. The Complainant (either under its current name LEGO Holding A/S, or the former name LEGO Juris A/S) holds numerous trademark registrations for LEGO internationally, including the following: - India Trademark Registration No. 240430 LEGO (word), registered on February 7, 1967, for goods in class 28; - International Trademark Registration No. 287932 LEGO (word), registered on August 27, 1964, for goods in class 28, designating multiple jurisdictions; and - European Union Trade Mark Registration No. 000039800 LEGO (word), registered on October 5, 1998, for goods and services in classes 3, 9, 14, 16, 20, 24, 25, 28, 38, 41, and 42. Previous UDRP panels have already recognized the well-known character of the LEGO trademarks. The Complainant holds more than 6,000 domain names comprising the LEGO trademark, including the domain name <lego.com> (registered on August 22, 1995), which redirects to the Complainant’s official website. The Respondent is Xiaolong Hao, reportedly located in India. The Respondent registered the Disputed Domain Name on August 4, 2025 through a privacy service. Both at the time of the Complaint, as well as at the date of rendering this Decision, when accessed by the Panel, the Disputed Domain Name resolves to a website offering online games, by also displaying the Complainant’s LEGO mark and logo. As per the evidence filed by the Complainant, on August 29, 2025, the Complainant’s lawyers sent a cease- and-desist letter (via the Registrar’s domain holder contact request form) addressed to the registrant of the Disputed Domain Name, demanding, among others, the voluntary transfer of the Disputed Domain Name to the Complainant and the Complainant would reimburse the costs related to the registration and transfer. In the absence of any reaction from the registrant, the Complainant’s lawyers sent two additional reminders (via the same channel), however no reply was received either. 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 Name. page 3 Notably, the Complainant contends that: - the Disputed Domain Name is confusingly similar to the Complainant’s LEGO trademark; - the Respondent has no rights or legitimate interests in the Disputed Domain Name; and - the Disputed Domain Name has been registered and it is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 Name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“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 entirety of the LEGO trademark is reproduced within the Disputed Domain Name. The Panel finds that the LEGO trademark is recognizable within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the Complainant’s trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Disputed Domain Name also contains the terms “video” and “games”, both preceded by a hyphen, however, the Panel finds that the addition of these elements does not prevent a finding of confusing similarity between the Disputed Domain Name and the Complainant’s trademark for the purposes of the Policy. According to the WIPO Overview 3.0, section 1.8, where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. According to the WIPO Overview 3.0, section 1.11.1, the generic Top-Level Domain (“gTLD”) “.com” in the Disputed Domain Name is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. Further to all the above, 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 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 page 4 evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, 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 Name. 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 Name such as those enumerated in the Policy or otherwise. It is accepted by the Panel that the Respondent is not related to the Complainant in any way and that the Complainant has not authorized nor licensed the Respondent to use the Complainant’s trademark. The Respondent is not an authorized reseller of the Complainant either. There is also no evidence that the Respondent is commonly known by the Disputed Domain Name. In view of the composition of the Disputed Domain Name, the Panel is of the opinion that the Respondent registered the Disputed Domain Name with the ultimate intent to mislead Internet users and to erroneously make them believe that the Disputed Domain Name is operated by or associated with the Complainant. Moreover, the Disputed Domain Name resolves to a website offering goods which are similar to those of the Complainant (i.e., online/video games), by unlawfully displaying the Complainant’s LEGO mark and logo. In this sense, it has been established that “respondent’s use of a domain name will not be considered ‘fair’ if it falsely suggests affiliation with the trademark owner; the correlation between a domain name and the complainant’s mark is often central to this inquiry”. WIPO Overview 3.0, section 2.5. The Panel considers that the composition of the Disputed Domain Name, coupled with its use (as explained above), signals the Respondent’s intention of taking unfair advantage of the Complainant’s mark. Thus, the Panel is of the opinion that the Respondent does not use the Disputed Domain Name in connection with a bona fide offering of goods or services nor does it make a legitimate noncommercial or fair use of the Disputed Domain Name as per the Policy. The Respondent did not respond to the Complainant’s contentions, thus the Respondent did not present any evidence to rebut the Complainant’s prima facie case. Further to all the above, 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. 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 faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1. In the present case, the Panel notes that the Complainant had registered and used its LEGO trademark long before the Respondent registered the Disputed Domain Name. In view of the worldwide reputation of the Complainant, the well-known character of its trademark, the composition of the Disputed Domain Name, as well as its use (as explained above), it is unlikely that the Respondent was not aware of the Complainant’s trademark and business when registering the Disputed Domain Name. The Panel considers that the Respondent targeted the Complainant when registering the Disputed Domain Name. Moreover, panels have consistently found that the mere registration of a domain name that is confusingly similar (particularly domain names incorporating the mark plus a descriptive term) to a famous or widely- known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4. page 5 The Panel is of the opinion that the Respondent registered the Disputed Domain Name with the intent to mislead Internet users into believing that the website at the Disputed Domain Name is affiliated with or endorsed by the Complainant, which is a clear proof of bad faith. Paragraph 4(b)(iv) of the Policy provides that the use of a domain name to intentionally attempt “to attract, for commercial gain, Internet users to [the respondent’s] web site or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of [the respondent’s] web site or location or of a product or service on [the respondent’s] web site or location” is evidence of registration and use in bad faith. In view of all the above, the Panel considers that the Respondent’s intention was to attract Internet users to the webpage at the Disputed Domain Name, by creating a likelihood of confusion and making them believe that said webpage is held or controlled by or related to the Complainant, for the Respondent’s commercial gain. Finally, the Respondent hid its identity when registering the Disputed Domain Name by using a privacy shield service. As per WIPO Overview 3.0, section 3.6, there are recognized legitimate uses of privacy and proxy registration services; the circumstances in which such services are used, including whether the respondent is operating a commercial and trademark-abusive website, can impact a panel’s assessment of bad faith. The Panel is of the opinion that in view of all circumstances of this case, the Respondent’s use of privacy service constitutes further evidence of bad faith registration and use of the Disputed Domain Name. The Panel also notes the Respondent’s failure to submit a response in the present proceeding, as well as to reply to the cease-and-desist letter and several reminders sent by the Complainant’s lawyers, which may be considered an additional indication of the Respondent’s bad faith. In view of the above, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitute bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. 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 Name <lego-video-games.com> be transferred to the Complainant. /Monica Novac/ Monica Novac Sole Panelist Date: February 11, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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