Westmore · UDRP DecisionLeathermanmultitool.com
The Panel ordered transfer of <leathermanmultitool.com>. It found the domain confusingly similar to the LEATHERMAN mark because it reproduced the mark in full and added the descriptive term “multitool.” The Respondent failed to rebut the Complainant’s prima facie case concerning rights or legitimate interests, while the domain’s composition and prior use for a website displaying the mark and purporting to sell the Complainant’s goods indicated targeting. The Panel also found bad-faith registration and use based on the Complainant’s longstanding trademark rights, the domain’s reference to its business, and the prior website use.
The timeline behind leathermanmultitool.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 leathermanmultitool.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an established trademark with a term describing the trademark owner’s core product can support findings not only of confusing similarity but also of deliberate targeting. Prior use for a website displaying the mark and purporting to sell branded goods was especially significant, even though the domain had become inactive by the time of the proceeding.
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 Leatherman Tool Group, Inc. v. Thompsona SylviaR Case No. D2026-0178 1. The Parties The Complainant is Leatherman Tool Group, Inc., United States of America (“United States”), represented by SafeNames Ltd., United Kingdom. The Respondent is Thompsona SylviaR, United States. 2. The Domain Name and Registrar The disputed domain name <leathermanmultitool.com> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 16, 2026. On January 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 19, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that the 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 proceedings commenced on January 21, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 10, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Parties of the Respondent’s default on February 11, 2026. The Center appointed Ingrīda Kariņa-Bērziņa as the sole panelist in this matter on February 12, 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. page 2 4. Factual Background The Complainant, headquartered in Oregon, United States, manufactures and markets a multi-function pocket tool under the LEATHERMAN mark, for which it has registered several trademarks, including the following: - United States Trademark Registration No. 1325473 for LEATHERMAN (word mark), registered on March 19, 1985 for goods in class 8; - United States Trademark Registration No. 2596689 for LEATHERMAN (word mark), registered on July 23, 2002 for goods in class 25; - European Union Trade mark No. 000041731 for LEATHERMAN (word mark), registered on March 31, 2004 for goods in classes 18, 25 and 28. In 1995, the Complainant registered the domain name <leatherman.com>, which it uses for its primary business website. It has also registered several other domain names under various top-level domains reflecting the LEATHERMAN mark that redirects users to its primary website. The disputed domain name was registered on August 18, 2025. At the time of the Complaint and of this Decision, it did not resolve to an active website. The record contains evidence that it previously resolved to a website displaying the Complainant’s mark and purportedly offering for sale the Complainant’s goods. 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. Notably, the Complainant states it was founded in 1983 in the United States by Timothy Leatherman and Steve Berliner. The Complainant markets multi-purpose tools under the LEATHERMAN mark in the United States and internationally, and has actively promoted its mark through social media and events. The Complainant contends that the disputed domain name reflects the Complainant’s LEATHERMAN mark in its entirety, with the addition of the term “multitool,” which only strengthens the association with the Complainant. The Respondent is not authorized by the Complainant to use its mark and is not commonly known by the disputed domain name. The disputed domain name was used to redirect to a website displaying the Complainant’s mark and allegedly offering the Complainant’s products for sale. This website required Internet users to submit their personal information, including credit card numbers. It is likely that the Respondent was using the disputed domain to collect personal data from Internet users to carry out fraudulent activity. The disputed domain name, which no longer resolves to an active website, is now being passively held in bad faith. The Complainant requests transfer of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the UDRP requires the Complainant to make out all three of the following: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; page 3 (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the Respondent has registered and is using the disputed domain name in bad faith. Under paragraph 15(a) of the Rules, “[a] Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. 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 Complainant’s LEATHERMAN mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms (here, “multitool”) may bear on assessment of the second and third elements, t he Panel finds the addition of such a term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, 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 3.0, 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. There is no evidence that the Respondent is commonly known by the disputed domain name, nor that there are any circumstances or activities that would establish the Respondent’s rights therein. The disputed domain name comprises the Complainant’s LEATHERMAN mark (and as such is similar to the Complainant’s own domain name <leatherman.com>), adding “multitool”, referring to the Complainant’s business. The Panel finds that such composition indicates targeting of the Complainant. WIPO Overview 3.0, section 2.5.1. page 4 The record indicates that the disputed domain name was previously used to resolve to a website displaying the Complainant’s mark and purporting to offer for sale the Complainant’s goods. Panels have held that the use of a domain name for illegitimate activity (here, claimed impersonation/passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. 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 has intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. The Complainant’s rights in its LEATHERMAN mark predate by at least 40 years the registration of the disputed domain name. The disputed domain name contains the Complainant’s LEATHERMAN mark together with the term “multitool,” referring directly to the Complainant’s business. Under such circumstances, the Panel finds that the disputed domain name was registered in bad faith. The record indicates that the disputed domain name previously resolved to a website purporting to offer “Leatherman” branded goods for sale. Panels have held that the use of a domain name for illegitimate activity (here, claimed impersonation/passing off, or other types of fraud) constitutes bad faith. WIPO Overview 3.0, section 3.4. In light of the finding that the Respondent has no rights in the disputed domain name, 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. 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 <leathermanmultitool.com> be transferred to the Complainant. /Ingrīda Kariņa-Bērziņa/ Ingrīda Kariņa-Bērziņa Sole Panelist Date: February 17, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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