Westmore · UDRP decision
WIPO · Case No. D2025-5382

Legoesales.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <legoesales.com> to LEGO Holding A/S. It found the domain confusingly similar because it incorporated the LEGO mark in its entirety with the additional term “esales.” The Respondent lacked rights or legitimate interests because it was unauthorized, was not commonly known by the domain, and had used it for a commercial website displaying LEGO branding and offering LEGO-branded products without a prominent disclaimer. Bad faith was established from the targeting of the well-known LEGO mark, the likelihood of confusion for commercial gain, the website’s prior use, and the circumstances surrounding subsequent passive holding and use of a privacy service.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-09
Panelist(s)
Novac, Monica
Complainant
LEGO Holding A/S
Respondent
Wuchong Zhou, HK Hongyun International Business Limited
Disputed domain(s)
legoesales.com
Domain history UDRP Intelligence

The timeline behind legoesales.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 legoesales.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
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of legoesales.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining a famous mark with an online-sales term can reinforce, rather than reduce, an inference of targeting when it is used for a branded retail website. It also shows that uncertainty over whether products are genuine or counterfeit is not necessarily decisive where an unauthorized reseller fails to disclose its lack of affiliation and does not satisfy established reseller-use criteria. A transition from active commercial use to inactivity did not cure the earlier conduct or prevent application of passive-holding principles.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-09
Panel
Novac, Monica
Full decision
14 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LEGO Holding A/S v. Wuchong Zhou, HK Hongyun International Business Limited Case No. D2025-5382 1. The Parties The Complainant is LEGO Holding A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Wuchong Zhou, HK Hongyun International Business Limited, China. 2. The Domain Name and Registrar The disputed domain name <legoesales.com> (the “Disputed Domain Name”) is registered with Dynadot Inc. (the “Reg istrar”). 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 f or registrar verif ication 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 inf ormation f or the Disputed Domain Name which differed from the named Respondent (Redacted f or Privacy (D T), Super Privacy Service LTD c/o Dynadot) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on December 24, 2025, providing the registrant and contact inf ormation disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on December 24, 2025. The Center verif ied that the Complaint together with the amended 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 amended Complaint, and the proceedings commenced on December 29, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was January 18, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on January 21, 2026. page 2 The Center appointed Monica Novac as the sole panelist in this matter on January 26, 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 is a globally renowned Danish company established in 1932, specializing in the design, production, and sale of play materials. The Complainant has subsidiaries and branches all over the world, including five main hubs, 37 sales off ices, f ive manuf acturing 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 holds several trademark registrations f or LEGO in various jurisdictions, including the f ollowing: - China Trademark Registration No. 10176429 LEGO (word), registered on January 14, 2013, for goods in class 28; - Hong Kong, China, Trademark Registration No. 302517660 LEGO (word), registered on February 6, 2013, f or goods and services in classes 9, 28 and 41; and - Hong Kong, China, Trademark Registration No. 19801105 LEGO (word), registered on February 17, 1979, f or goods in classes 16 and 28. 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 of f icial website. The Respondent is Wuchong Zhou, HK Hongyun International Business Limited, reportedly located in China. The Respondent registered the Disputed Domain Name on November 7, 2025 through a privacy service. According to the evidence in the Complaint, the Disputed Domain Name used to resolve to a commercial website that featured a color scheme similar to that used by the Complainant on its own webpage, displayed the Complainant’s LEGO mark and logo (also as a f avicon), and offered f or sale LEGO branded products. The Complainant contends that it has not been able to establish whether the goods sold on the webpage at the Disputed Domain Name were genuine or counterfeit. As shown by the Complainant, the “Contact Us” section of the website at the Disputed Domain Name provided the name and contact details of a company headquartered in the United Kingdom, which dif f er f rom those of the Respondent. The web site at the Disputed Domain Name did not prominently display any disclaimer or any inf ormation regarding the relationship between the Respondent/the website operator and the Complainant. The Respondent is not an authorized reseller of the Complainant. At the date of rendering this Decision, when accessed by the Panel, the Disputed Domain Name resolves to an inactive website. page 3 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the Disputed Domain Name. Notably, the Complainant contends that: - the Disputed Domain Name is conf usingly 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 f aith. 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 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 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. 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 term “esales”, which most likely represents a variation of the term “e-sales”, ref erring to online sales. However, the Panel finds that the addition of this element does not p revent a f inding of conf using 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 f inding of conf using similarity under the f irst 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 f irst element conf using similarity test. Further to all the above, the Panel f inds the f irst 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. page 4 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. 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 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, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward 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. Although at the time of this Decision, the Disputed Domain Name resolves to an inactive webpage, as per the evidence f iled by the Complainant, it seems that the Disputed Domain Name used to resolve to a commercial webs it e that f eatured a color scheme similar to that used by the Complainant on its of f icial webpage, displayed the Complainant’s LEGO mark and logo (also as a f avicon), and offered f or sale LEGO branded products, without any prominent disclaimer regarding the lack of relationship between the Respondent and the Complainant. The Complainant contends that it has not been able to establish whether the goods sold on the webpage at the Disputed Domain Name were genuine or counterfeit. However, even if the Respondent was offering genuine LEGO branded products, the Respondent would not make fair use of the Complainant’s trademark in the Disputed Domain Name. UDRP panels have recognized resellers or distributors may have a legitimate interest to nominally use a trademark f or its source-identif ying f unction under certain circumstances, and such fair use is qualified under the so-called “Oki Data test” as per section 2.8.1 of the WIPO Overview 3.0. Nevertheless, in the present matter, there is no evidence that the Respondent would meet the requirements of the “Oki Data test”. The Panel considers that the composition of the Disputed Domain Name, coupled with its f o rmer use f or a website that offered for sale LEGO branded products, while displaying the Complainant’s trademark and visuals, signals the Respondent’s intention of taking unfair advantage of the Complainant’s mark. Moreover, the Panel considers that the Respondent registered the Disputed Domain Name with the ultimate intent to mislead the Internet users and to erroneously make them believe that the Disputed Domain Name is operated by or associated with the Complainant. It has been established that “respondent’s use of a domain name will not be considered “f air” if it f alsely suggests affiliation with the trademark owner; the correlation between a domain name and the complainant’s mark is of ten central to this inquiry”. WIPO Overview 3.0, section 2.5. Also, panels have held that the use of a domain name f or illegitimate activity (here, claimed impersonation/passing off), can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. In view of the above, the Panel is of the opinion that the Respondent does not use the Disputed Domain Name in connection with a bona f ide of f ering of goods or services, nor does it make a legitimate noncommercial or f air use of the Disputed Domain Name as per the Policy. page 5 The Respondent did not respond to the Complainant’s contentions, thus the Respondent did not present any evidence f or supporting any rights or legitimate interests in the Disputed Domain Name. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel ref ers to its considerations under section 6.B. above. The Panel notes that, f or 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 f aith. 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 f aith. WIPO Overview 3.0, section 3.2.1. In the present case, the Panel notes that the Complainant registered and used its LEGO trademark long bef ore 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 previous 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 conf usingly similar (particularly domain names incorporating the mark plus a descriptive term) to a f amous or widely- known trademark by an unaffiliated entity can by itself create a presumption of bad f aith. WIPO Overview 3.0, section 3.1.4. The Panel is of the opinion that the Respondent registered the Disputed Domain Name with the intent to mislead the Internet users into believing that the website at the Disputed Domain Name is af f iliated with or endorsed by the Complainant, which is a clear proof of bad f aith. 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 f aith. 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, controlled or related to the Complainant, f or the Respondent’s commercial gain. Panels have held that the use of a domain name for illegitimate activity (here, claimed impersonation/passing of f ) constitutes bad f aith. WIPO Overview 3.0, section 3.4. At the time of this Decision, the Disputed Domain Name does not resolve to an active webpage. However, panels have found that the non-use of a domain name would not prevent a f inding of bad f aith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and worldwide reputation of the Complainant’s trademark, as well as the composition and prior use of the Disputed Domain Name, and finds that in the circumstances of this case, the current passive holding of the Disputed Domain Name does not prevent a finding of bad f aith under the Policy. page 6 Finally, the Respondent hid its identity when registering the Disputed Domain Name by using a privacy s hield 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 f aith. The Panel is of the opinion that in view of all circumstances of this case, the Respondent’s use of privacy service constitutes f urther evidence of bad f aith registration and use of the Disputed Domain Name. The Panel also notes the Respondent’s failure to submit a response in the present proceeding, which may be considered an additional indication of the Respondent’s bad f aith. In view of the above, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitute bad f aith under the Policy. 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 <legoesales.com> be transf erred to the Complainant. /Monica Novac/ Monica Novac Sole Panelist Date: February 9, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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