Westmore · UDRP DecisionWorldcupofhockey.com
The three-member Panel ordered transfer of <worldcupofhockey.com>. It found the domain identical to the Complainant’s registered WORLD CUP OF HOCKEY mark, found no rights or legitimate interests despite the Respondent’s domain-investment and descriptiveness arguments, and found bad-faith registration and use based on targeting and passive holding. The Panel emphasized the exact reproduction of the mark, the mark’s reputation in Canada, the Respondent’s location in Canada, the absence of a demonstrated good-faith use, and the obligation of domain investors to screen registrations for trademark abuse. The Panel expressly rejected the requested finding of Reverse Domain Name Hijacking.
The timeline behind worldcupofhockey.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 worldcupofhockey.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that domain investment in ordinary or descriptive terms is not automatically illegitimate, but an exact match to a registered mark may substantially change the analysis. Here, the Panel treated the complete phrase, exact word order, inclusion of “of,” geographic proximity, sector-specific reputation, and absence of a demonstrated alternative use as collectively persuasive evidence of targeting. It also shows that an inactive domain can satisfy bad-faith use where the passive-holding factors point away from any plausible good-faith use.
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 National Hockey League v. A Mirza Case No. D2026-0718 1. The Parties The Complainant is National Hockey League, United States of America, represented by Greenberg Traurig, LLP, United States. The Respondent is A Mirza, Canada, self-represented. 2. The Domain Name and Registrar The disputed domain name <worldcupofhockey.com> is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 19, 2026. On February 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 20, 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 February 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 17, 2026. The Respondent was granted an extension until March 25, 2026. The Response was filed with the Center on March 25, 2026. The Complainant filed a Supplemental Filing on April 13, 2026. The Respondent sent an email communication to the Center on April 14, 2026. page 2 The Center appointed Luca Barbero, Igor Motsnyi, and Richard W. Page as panelists in this matter on April 30, 2026. The Panel finds that it was properly constituted. Each member of 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. On May 1, 2026, the Respondent filed a Supplemental Filing, requesting additional time to respond to the Complainant’s Supplemental Filing of April 13, 2026. The Complainant sent an email to the Center on May 4, 2026, in which it stated that it did not oppose reasonable leave to be determined by the Panel for the Respondent to file its own additional submission. On May 6, 2026, and May 12, 2026, the Respondent sent further email communications to the Center. On May 18, 2026, the Panel issued an Administrative Panel Procedural Order (Panel Order No. 1), by which it granted the Respondent an opportunity to respond to the Complainant’s Supplemental Filing submitted on April 13, 2026. The deadline for the Respondent’s reply was set for May 25, 2026. The Decision due date was thereby extended to June 1, 2026. On May 25, 2026, the Respondent filed its submission in reply to Panel Order No. 1. 4. Factual Background The Complainant is a professional hockey league and is followed by tens of millions of fans all around the world. Organized in 1917 and composed of 32 teams, 25 of which are located in the United States and seven in Canada, the Complainant ranks consistently among the highest-grossing professional sports leagues in the world. Teams within the Complainant’s league compete annually for the opportunity to win the coveted Stanley Cup championship trophy – the oldest existing trophy to be awarded to a professional sports franchise in North America. The 2025 Stanley Cup Final series averaged an audience size of 4.89 million television viewers in the United States and Canada. Over the years, many millions of fans have attended the Complainant’s games and even more have listened to or viewed NHL games and related news reports on television and radio. During the 2024-2025 regular season, total attendance at the games was over 23 million—the highest attendance in the Complainant’s history. Starting in 1996, the Complainant organized the World Cup of Hockey, an international ice hockey tournament, together with the National Hockey League Players Association (NHLPA). The World Cup of Hockey is the first international hockey championship to allow nations to field their top professional players and was held in 1996, 2004, and 2016. The 2016 World Cup of Hockey included eight teams: Canada (24- and-over players), Czech Republic, Europe (consisting of players from European countries not already represented), Finland, North America (23-and-under players), Russian Federation, Sweden, and United States (24-and-over players). Over 15 million viewers watched the tournament games on television in North America alone. In February 2025, the Complainant announced the return of the World Cup of Hockey for February 2028. The Complainant has provided evidence of ownership of the following trademark registrations: - Canada trademark registration No. TMA623384 for WORLD CUP OF HOCKEY (word mark), filed on November 26, 2001, and registered on October 25, 2004, in International Class 41, with the following disclaimer: “The right to the exclusive use of the word HOCKEY is disclaimed apart from the trademark”; - Canada trademark registration No. TMA511556 for WORLD CUP OF HOCKEY C C (figurative mark), filed on May 27, 1996, and registered on May 05, 1999, in International Class 41, with the same disclaimer as above; page 3 - United States trademark registration No. 2900202 for WORLD CUP OF HOCKEY (word mark), filed on November 26, 2001, and registered on November 2, 2004, in International Class 41, with a similar disclaimer on the term “HOCKEY” as above. The disputed domain name was registered on April 16, 2016, and at the time of filing of the Complaint, did not resolve to an active website. 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 contends that the disputed domain name is identical to the trademark WORLD CUP OF HOCKEY in which the Complainant has rights as it reproduces the trademark in its entirety with the mere addition of the generic Top-Level Domain (“gTLD”) “.com”. The Complainant submits that the Respondent has no rights or legitimate interests in respect of the disputed domain name since: i) the Respondent is not commonly known by the disputed domain name; ii) the Respondent has never operated any bona fide or legitimate business under the disputed domain name; iii) the use of the disputed domain name does not constitute a legitimate noncommercial or fair use of the domain name; iv) the Respondent is preventing the Complainant from registering or using the disputed domain name and v) the Complainant has not authorized, licensed, or consented to the Respondent’s registration and use of a domain name incorporating the Complainant’s WORLD CUP OF HOCKEY mark, or any confusingly similar variation thereof. The Complainant submits that the Respondent registered and is using the disputed domain name in bad faith since: i) the Complainant is not aware of any use of the Complainant’s trademark WORLD CUP OF HOCKEY, other than in connection with the hockey tournaments that the Complainant organizes together with the NHLPA; ii) the disputed domain name has never been used in relation to active websites and is therefore being passively held by the Respondent; and iii) in addition to the Respondent’s actual and inferred knowledge of the Complainant’s WORLD CUP OF HOCKEY mark, the Respondent had constructive knowledge of the WORLD CUP OF HOCKEY mark because of the Complainant’s prior trademark registrations. The Complainant further points out that, on August 20, 2025, the Complainant’s counsel initiated contact with the Respondent via phone using the Respondent’s phone number obtained through a Registration Data Service Request (RDRS), and subsequently via email. The Complainant asserts that, between August 19 and October 9, 2025, the Complainant’s counsel and the Respondent exchanged a number of emails, in which the Complainant’s counsel outlined the Complainant’s prior rights in the WORLD CUP OF HOCKEY mark, the abusive nature of the disputed domain name, and requested that the Respondent relinquish the disputed domain name or the Complainant would take further legal action including filing the Complaint. The Complainant states that, while the Respondent technically responded to the Complainant’s counsel, its responses have been far from substantive or helpful for purposes of settling the matter without the need for this proceeding and did not provide evidence of any rights or legitimate interests in the disputed domain name or that the disputed domain name was not registered or used in bad faith. B. Respondent. The Respondent rebuts the Complainant’s allegations and requests a denial of the relief sought by the Complainant, for the following reasons. page 4 The Respondent contends that the disputed domain name was acquired via expired auctions on GoDaddy as part of its domain investment activity, not hand-registered or targeted at the Complainant, and emphasizes that the disputed domain name was acquired in the past other four times and by different registrants in 2000, 2012, 2014, and 2016. The Complainant also states that his portfolio includes similar descriptive domains (e.g., <worldballhockey.com>). The Respondent further contends that the Complainant’s use of the WORLD CUP OF HOCKEY mark has been irregular, as the WORLD CUP OF HOCKEY events were held only in 1996, 2004, and 2016, plans were made for 2020, the 2020 and 2024 events were abandoned, and only in 2025 the Complainant officially announced a 2028 event. The Respondent therefore states that the Complainant’s mark was abandoned due to non-use between 2016 and 2025. Moreover, the Respondent claims that: i) the term “world cup” is generic and could be widely used for many sports or as a name for video games, competitions, or fiction from literature to video/TV; ii) there is a large number of non-targeted potential buyers and end-users for the disputed domain name; iii) Field Hockey’s “Hockey World Cup” (FIH) has longer, continuous use and greater global audience, which diminishes the Complainant’s claim for exclusive rights on WORLD CUP OF HOCKEY; and iv) the Complainant’s trademark registrations are insufficient to establish exclusive rights given abandonment and non-continuous use. With reference to the Complainant’s assertions on bad faith registration and use, the Respondent denies all allegations, stating that: i) it had no knowledge of the Complainant’s trademark at the time of the acquisition of the disputed domain name and until he was contacted by the Complainant in 2025; ii) the Respondent acquired the disputed domain name only after the Complainant openly abandoned usage of its mark; iii) the disputed domain name has been passively held and has never been offered for sale, nor was there ever an intent to target the Complainant’s mark; iv) the Complainant had opportunities to acquire the disputed domain name earlier from prior owners of the disputed domain name, but failed to act; and v) the disputed domain name was in no way intended to be misused or used in bad faith, but on the contrary was registered for a bona fide business purpose as it could be used for other sectors (such as games and literature) and different types of hockey as well as for fair use in other regions. The Respondent also claims that he has been a part-time domain investor for 9 years with 5,000 domain names yet has never been involved in a proceeding under the Policy. Lastly, the Respondent requests a finding of Reverse Domain Name Hijacking (RDNH) against the Complainant. C. Complainant’s Supplemental Filing On April 13, 2026, the Complainant sent the Center a Supplemental Filing to address certain statements and information contained in the Response. Regarding the Respondent’s asserted descriptiveness of the WORLD CUP OF HOCKEY mark for international hockey tournament, the Complainant asserts that the WORLD CUP OF HOCKEY trademark is presumptively valid and incontestable under United States law due to federal registration since 2004 and submits that the WORLD CUP OF HOCKEY marks in the United States and Canada were registered without any claim of descriptiveness or genericness by the United States Patent and Trademark Office (USPTO) or Canadian Intellectual Property Office (CIPO), implying inherent distinctiveness. The Complainant also states that third-party trademarks, such as HOCKEY WORLD CUP owned by the FIH, are separate and nationally registered but do not conflict with the Complainant’s trademark, and that precedents confirm that combining generic terms can generate a distinctive expression. page 5 With reference to the Respondent’s claim that the Complainant abandoned its mark, the Complainant denies such allegation stating that: i) the Complainant’s trademark registrations have been continuously maintained and renewed for over two decades; ii) during this time, the use of the trademark has been continuous via merchandise, broadcasts, and licensed products, even during years without a physical tournament. In this regard, the Complainant submits publicly available evidence including: licensed jersey sales (dated 2016, 2017, 2026) on the website “www.nhlshop.com” and network and YouTube broadcasts of past tournaments and events (e.g., 1996, 2016) as well as public statements and media reports confirming the intent to continue the tournament. The Complainant maintains that its WORLD CUP OF HOCKEY mark has a strong reputation and is well- known in the Complainant’s field and in Canada. The Complainant also submits that, considering: i) its worldwide key audience metrics; ii) the 2016 tournament revenue nearing USD 100 million; iii) the fact that in Canada only it has a reach of over 15.5 million Canadian viewers out of a 35.1 million population; iv) the Complainant’s largest fan activation in history attracted 100,000+ visitors; v) the 750,000+ live streams in Canada; vi) the 9.75 million website visits during the 2016 tournament, of which 3.5 million were from Canada and vii) its global broadcast viewership exceeds 130 million, the Respondent’s argument that the fame of a mark must reach global brand rankings is inaccurate and submits that Panels routinely recognize marks as well-known for UDRP purposes if they have a strong market presence in their sector and geography. The Complainant also states that the Respondent’s allegations appear to be conflicting, since the Respondent stated that (i) he “was not aware of the [Complainant’s] mark” and “had zero knowledge [of] Complainant’s claim to [the] mark” and that (ii) the disputed domain name was “Not Hand Registered” - implying registration was automated -, but then asserts that (iii) registration and use by the Respondent were legitimate based on perceived abandonment and descriptiveness. The Complainant further submits that, given the widely known character of its mark, the Respondent was or should have been aware of the mark and anyway, had he performed any sort of due diligence and checked for existing trademark registrations, as he regularly counsels others to do on a forum, then he would have immediately discovered the Complainant’s identical trademark registrations, including within the Respondent’s own country of residence. The Complainant also addresses the issue of the date of registration of the disputed domain name by the Respondent, highlighting that the Respondent claimed that it acquired the disputed domain name after the Complainant’s mark was abandoned, without however providing the specific date. The Complainant therefore maintains that the disputed domain name was registered by the Respondent: (i) in the immediate lead-up to or shortly after the 2016 World Cup of Hockey in September 2016, when interest in the tournament in was at its height, particularly in Canada where it was hosted; or (ii) in conjunction with the Complainant’s press releases or announcements regarding plans for subsequent WORLD CUP OF HOCKEY tournaments; or (iii) automatically upon expiry by a prior registrant who realized that the disputed domain name violated the Complainant’s rights in its WORLD CUP OF HOCKEY mark. Lastly, the Complainant addresses the issue of the relevance of prior opportunities that the Complainant allegedly had to acquire the disputed domain name before it was registered by the Respondent and of third- party prior use of the disputed domain name, stating that whom and when to sue or commence an administrative proceeding against are the exclusive prerogative of the trademark owner. D. Respondent’s Supplemental Filing The Respondent criticizes the Complainant’s Supplemental Filing as excessive and abusive, highlighting the enormous volume of the Complainant’s materials exceeding 1,000 pages (including citations and annexes), which far surpasses typical standards under the Policy. page 6 With regards to the nature and timing of the Complainant’s submissions, the Respondent submits that the Complainant delayed submitting its Supplemental Filing by almost three weeks after the Respondent’s original Response, which the Respondent interprets as an attempt to increase the Respondent’s burden. Moreover, the Respondent finds the timing of the original Complaint deliberately planned to follow the Complainant’s media campaign promoting a 2028 event, potentially skewing public perception (e.g., Google search results) about the mark’s active use and argues this timing and the excessive submission volume collectively exhibit bad faith and attempts to manipulate the Panel’s view. In addition, the Respondent states that the Complainant falsely claimed that the Respondent has submitted false statements and information as an excuse to unfairly add new additional arguments to their original claim. With regard to the date of acquisition of the disputed domain name by the Respondent, the Respondent states that it has held the disputed domain name prior to at least 2021. The further submissions in the Supplemental Filing offer rebuttal to the Complainant’s contentions and comments on citations included in the Complainant’s Supplemental Filing, besides reiterating arguments already included in the Response. 6. Discussion and Findings According to 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”. Paragraph 4(a) of the Policy directs that the Complainant must prove each of the following: (i) that the disputed domain name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. 6.1 Preliminary procedural issue: the Parties’ Supplemental Filings Before entering into the merits of the case, the Panel addresses the issue of the unsolicited supplemental filings submitted by the Parties to the Center. No provision concerning supplemental filings are made in the Rules or Supplemental Rules, except at the request of the panel according to paragraph 12 of the Rules, which states the panel, in its sole discretion, may request any further statements or documents from the parties it may deem necessary to decide the case. According to paragraph 10 of the Rules, the Panel has the authority to determine the admissibility, relevance, materiality and weight of the evidence, and also to conduct the proceedings with due expedition, ensuring that the Parties are treated with equality and that each Party is given a fair opportunity to present its case. As stated in section 4.6 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), unsolicited supplemental filings are generally discouraged - unless specifically requested by the panel - and the party submitting an unsolicited supplemental filing should clearly show its relevance to the case and why it was unable to provide the information contained therein in its complaint or response. page 7 Accordingly, UDRP panels generally accept supplemental filings only when they provide material new evidence or a fair opportunity to respond to arguments that could not reasonably have been anticipated. See, along these lines, Welcomemat Services, Inc. v. Michael Plummer Jr., MLP Enterprises Inc., WIPO Case No. D2017-0481. As highlighted in the Procedural History and in section 5 above, the Complainant initially submitted its Supplemental Filing to address statements in the Response that the Complainant claimed could not have been anticipated by the Complainant at the time of the filing of the Complaint. The Respondent then requested the Panel’s permission to submit his additional submission in response to the Complainant’s Supplemental Filing. The Panel granted such permission, also taking into account the fact that the Respondent is not professionally represented. The Panel accepts the unsolicited supplemental filing of the Complainant to the extent that it addresses some arguments of the Response that the Complainant could not have anticipated at the time of the filing of its original Complaint (such as the alleged abandonment of the trademark by the Complainant) and the Panel expressly granted leave to the Respondent to respond to the Complainant’s supplemental submission. The Panel notes though that the Respondent’ Supplemental Filing titled as “Additional Response” (consisting of over 19,000 words) exceeds the word limit set in rule 11(b) of WIPO Supplemental Rules. Given the nature of this dispute and the numerous conflicting statements of both Parties, the Panel accepts the Supplemental Filings for the sake of completeness, in order to grant both Parties equal rights to provide their arguments and to reach a fair decision. 6.2 Substantive issues 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 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. Indeed, the Complainant has provided evidence of ownership of valid trademark registrations for WORLD CUP OF HOCKEY (both word and figurative marks) in the United States and Canada. Ownership of national trademark registrations prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case. WIPO Overview 3.1, section 1.2.1. With regards to the Respondent’s allegation about the abandonment of the trademark due to its irregular use by the Complainant, the Panel notes that a UDRP proceeding is limited in scope and is not an appropriate forum for resolution of the trademark defense of abandonment (which the Panel does not opine on but may be heard in a United States District Court or the USPTO’s Trademark Trial and Appeal Board (TTAB) or a court of competent jurisdiction in Canada). The Panel further notes that the Respondent’s allegations regarding the asserted abandonment of the mark are not persuasive to the Panel and are rebutted by the Complainant’s evidence. The Complainant’s trademarks were duly renewed and are valid. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. As to the gTLD “.com”, it is a standard registration requirement and can be disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. Therefore, the Panel finds the first element of the Policy has been established. page 8 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 that 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 name and that the Respondent has not come forward with relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Panel notes that there is no relation, disclosed to the Panel or otherwise apparent from the record, between the Respondent and the Complainant. The Respondent is not a licensee of the Complainant, nor has the Respondent otherwise obtained an authorization to use the Complainant’s trademark. Moreover, there is no element from which the Panel could infer a Respondent’s right over the disputed domain name, or that the Respondent might be commonly known by the disputed domain name. Furthermore, there is no evidence of use of the disputed domain name by the Respondent in connection with a bona fide offering of goods of services or of a legitimate noncommercial or fair use without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s trademark. The Respondent argues his legitimate interest in the disputed domain name as a domain investor who acquires generic and descriptive domains and has a portfolio of descriptive/generic domain names. The Respondent also states that he has never received a UDRP complaint before. The Panel notes that aggregating and holding domain names consisting of dictionary words, common phrases or unique/catchy or memorable terms (alone or in combination) can be bona fide and is not per se illegitimate under the Policy where the respondent can show that the purpose of the registration was not to target a trademark, as reflected in WIPO Overview 3.1, section 2.1. In the case at hand, while the Respondent has provided examples of other domain names that he registered following a similar pattern and possible explanations for the choice of the disputed domain name and its potentially legitimate uses, the disputed domain name is an exact match of the Complainant’s WORLD CUP OF HOCKEY mark . The disputed domain name is different from the other domain names that the Respondent registered (e.g., <worldballhockey.com> or <worldclasssupport.com>). The Respondent is from Canada, where the Complainant is very active and where the international competition under the exact same WORLD CUP OF HOCKEY mark is very popular as evidenced by Complainant. The fact that the disputed domain name does not include only the words “hockey”, “world”, or “cup”, but identically reproduces the name of Complainant’s tournament and trademark (including with the preposition “of”) suggests that the Respondent, on balance of probabilities, registered the disputed domain name to target the Complainant and, therefore, cannot claim legitimate interests in the disputed domain name. WIPO Overview 3.1, section 2.5.1. Website visitors are likely to associate the disputed domain name with the Complainant’s tournament. In view of the foregoing, the Panel finds the second element of the Policy has been established. page 9 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. Consensus view reflected in WIPO Overview 3.1, section 3.1, states that bad faith under the Policy is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark. The essence of bad faith is targeting and targeting can be established by either direct evidence (e.g., copycat website) or indirect (circumstantial evidence) such as strength of the mark and nature of the disputed domain name, timing of the domain name registration vs. timing of trademark registration and geographic proximity of the parties. In the present case, the Panel notes that, even though there is a dispute as to the date of registration / acquisition of the disputed domain name by the Respondent, the Respondent does not question that he registered the disputed domain name after the Complainant had started its competitions under the name “World Cup of Hockey” and obtained its trademark registrations for WORLD CUP OF HOCKEY in Canada and the United States. The Respondent claims that the Complainant abandoned its trademark WORLD CUP OF HOCKEY and its competition between 2016 and 2025. However, notwithstanding numerous publications provided by both Parties which demonstrate that the Complainant’s tournament was not held for a number of years due to various reasons, there is no information that the competition was permanently cancelled or abandoned. The mere circumstance that the competition is irregular does not affect its reputation and its fame in countries where ice hockey is popular, including Canada, where the Respondent is based. Further, the Complainant’s trademark registrations remained valid and active during this period, and the Complainant introduced evidence of the trademarks’ continued use in various fashions outside of hosting the tournament during this period as well. Indeed, considering the Complainant and its mark is widely known, the Panel finds that the Respondent cannot plausibly claim that its believed its registration would not be identical to and therefore target the Complainant’s trademark at the time of registration. WIPO Overview 3.1, section 3.2.2. The Respondent alleges that the genericness of the Complainant’s mark excludes targeting. The strength of the mark and its composition clearly play a role in bad faith analysis. The Panel notes that the Respondent’s position could have made sense in a different set of facts, including different domain name composition (i.e., a combination that did not identically include all of the words in the same order, that make up the Complainant’s mark). However, in the present case, the disputed domain name is an exact match of the Complainant’s mark and the Panel has verified that, according to the information displayed in public trademark databases, the Complainant appears to be the only entity in the world that owns WORLD CUP OF HOCKEY trademarks. 1 The Panel acknowledges that there are numerous other hockey tournaments and other types of hockey (e.g., field hockey), but notes that the disputed domain name does not consist of only the words “hockey” and “cup” or “world”, as it fully replicates the Complainant’s mark, thereby suggesting the Respondent’s knowledge of and intent to target the Complainant. It is noted that the ice hockey tournament run by the International Ice Hockey Federation is referred to as the “Ice Hockey World Championships”, and as discussed above, the FIH field hockey tournament is referred to as the “Hockey World Cup”. In addition to the above, as established in prior decisions and in WIPO Overview 3.1, section 3.2.3, respondents, especially domainers undertaking bulk purchases or automated registrations, have an affirmative obligation to avoid the registration of trademark-abusive domain names. Moreover, noting the 1 Noting in particular the general powers of a panel articulated inter alia in paragraphs 10 and 12 of the UDRP Rules, it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision, in particular to affirm or corroborate a party’s contention. WIPO Overview 3.1, section 4.8. page 10 registrant obligations under paragraph 2 of the Policy, panels have found that respondents who deliberately fail to search and/or screen registrations against available online databases would be responsible for any resulting abusive registrations under the concept of willful blindness. The disputed domain name does not resolve to an active website. Panels have found that the non-use of a domain name, including redirection to blank or coming soon pages, would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes i) the reputation of the Complainant’s trademark, especially in the Respondent’s country, ii) the composition of the disputed domain name, which fully replicates the Complainant’s mark and the name of the Complainant’s international competition, and iii) the implausibility of any good faith use to which the disputed domain name may be put under the circumstances, and finds that the passive holding of the disputed domain name in this case does not prevent a finding of bad faith under the Policy. Therefore, the Panel finds that the Complainant also has established the third element of the Policy. Considering the three substantive requirements set out in the Policy have been met, the Panel does not find RDNH. 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 <worldcupofhockey.com> be transferred to the Complainant. /Luca Barbero/ Luca Barbero Presiding Panelist /Igor Motsnyi/ Igor Motsnyi Panelist /Richard W. Page/ Richard W. Page Panelist Date: June 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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