Westmore · UDRP DecisionLegominifigs.net
The Panel ordered transfer of <legominifigs.net>. It found the domain confusingly similar because it reproduced the LEGO mark and combined it with “minifigs,” a misspelling of the MINIFIGURES mark. The Respondent did not rebut the Complainant’s prima facie case on rights or legitimate interests. Bad faith was established from the targeting of the well-known LEGO mark, the domain’s initial commercial use for unrelated children’s health supplements or gummies, and its later passive holding.
The timeline behind legominifigs.net
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 legominifigs.net — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how combining a famous house mark with a shortened misspelling of a related product mark can support all three UDRP elements. It also shows that unrelated commercial use followed by inactivity may still establish bad faith when the domain’s composition demonstrates targeting and the earlier use sought to capitalize on likely confusion.
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. peng yan yan Case No. D2026-1020 1. The Parties The Complainant is LEGO Holding A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is peng yan yan, China. 2. The Domain Name and Registrar The disputed domain name <legominifigs.net> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on March 10, 2026. On March 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 11, 2026, 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 information in the Complaint. The Center sent an email communication to the Complainant on March 11, 2026, 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 in English on March 12, 2026. On March 11, 2026 the Center informed the parties in Chinese and English, that the language of the registration agreement for the disputed domain name is Chinese. On March 12, 2026, the Complainant requested English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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 in Chinese and English of the Complaint, and the proceedings commenced on March 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 2, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 10, 2026. page 2 The Center appointed Karen Fong as the sole panelist in this matter on April 16, 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 the owner of the LEGO trade mark, and all other trade marks used in connection with the LEGO brand of construction toys and other products. Founded in 1932, the Complainant has subsidiaries and branches all over the world which includes five manufacturing sites and over 500 retail stores. The Complainant employs more than 28, 500 individuals all over the world and LEGO products are sold in more than 130 countries. The Complainant has consistently been listed in various brand rankings, indices and directories as one of the top brands in the world and it has won many awards including Global Toy Manufacturer of the Year for 2022- 2024. The LEGO brand is registered as a trade mark in many jurisdictions around the world. The LEGO trade mark registrations include the following: - United States of America Trade Mark Registration No. 1018875 for LEGO registered on August 26, 1975; - Chinese Trade Mark Registration No. 10176415 for LEGO registered on January 14, 2013; (individually and collectively, the “Trade Mark”). One of the many products sold by the Complainant under the Trade Mark includes LEGO Minifigures. The Complainant has trade mark registrations for the mark MINIFIGURES including Chinese Trade Mark Registration No. 16190649 for “minifigures” (stylised) registered on March 21, 2016 (the “Additional Trade Mark”). The Complainant owns an extensive portfolio of more than 6,000 domain names incorporating the Trade Mark. Its main websites are at the domain names <lego.com>, and <legoland.com>. The Respondent, who appears to be based in China, registered the disputed domain name on November 1, 2025. The disputed domain name initially resolved to a website which offered for sale children’s health supplements or gummies. At the time of the filing of the complaint the disputed domain name was inactive (the “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 confusingly similar to the Trade Mark and/or the Trade Mark and Additional Trade Mark combined, that the Respondent has no rights or legitimate interests with respect to the disputed domain name, and that the disputed domain name was registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 6.1 Preliminary Issue: Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that: - The Complainant is unable to communicate in Chinese and translation of the Complaint would unfairly disadvantage and burden the Complainant in terms of cost and delay the proceedings and adjudication of this matter; - Such additional delay, given the abusive nature of the disputed domain name and the Website poses a continuing risk to the Complainant and unsuspecting consumers; - The disputed domain name is composed of Latin characters; and - The term “lego” which is the dominant portion of the disputed domain name does not carry any specific meaning in the Chinese language. The Respondent has not challenged the Complainant’s language request and in fact has failed to file a response in either English or Chinese despite being duly notified by the Center in both English and Chinese of the language of the proceeding and of the commencement of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 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 trade mark and the disputed domain name. WIPO Overview 3.1, section 1.7. Based on the available record, the Panel finds the Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the entirety of the Trade Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical or confusingly similar to the Trade Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. The Panel also notes that the disputed domain name includes a misspelling of the Additional Trade Mark with the letters “u” “r” and “e” missing from the word “minifigures”. Common, obvious, or intentional misspellings of a trade mark are considered by panels to be confusingly similar to the relevant mark for the purposes of the first element. WIPO Overview 3.1, section 1.9 The Panel finds the Additional Trade Mark is recognizable within the disputed domain name which is in fact comprised of the combination of the Trade Mark and a misspelling of the Additional Trade Mark. Accordingly, under this reasoning, the disputed page 4 domain name is also confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Based on the available record, 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 often impossible 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. 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 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. Based on the available record, the Panel finds the second element of the Policy has been established. 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. 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 fully incorporated the Trade Mark and a misspelling of the Additional Trade Mark. The combination of these two elements indicates that the Respondent had actual knowledge of and was targeting the Complainant and the Trade Mark when registering the disputed domain name particularly given the well-known nature of the Trade Mark. The Panel further notes that the clear absence of any rights or legitimate interests on the part of the Respondent, coupled with the Respondent’s selection of the disputed domain name without any explanation, constitutes an additional factor supporting a finding of bad-faith registration (see WIPO Overview 3.1, section 3.2.1). In the Panel’s view, the disputed domain name falls squarely within the category of cases described therein. Accordingly, the Panel finds that the disputed domain name was registered in bad faith. The Panel also finds that the disputed domain name is being used in bad faith. The disputed domain name initially resolved to a commercial website selling products which are completely unrelated to the Complainant and established for the Respondent’s commercial benefit. It is highly likely that Internet users typing the disputed domain name into their browser, or encountering it via a search engine, would be expecting to reach a website operated by, or affiliated with, the Complainant. The disputed domain name is therefore inherently misleading and likely to cause confusion among Internet users, particularly as it incorporates the Complainant’s distinctive Trade Mark. page 5 The Panel finds that the Respondent is seeking to exploit the reputation of the Trade Mark in order to mislead Internet users into visiting the Respondent’s Website. On the basis of the record, the Panel concludes that the Respondent has intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of the Website, within the meaning of paragraph 4(b)(iv) of the Policy. The fact that the Website was inactive when the complaint was filed does not affect the Panel’s bad faith finding. Panels have found that the non-use of a domain name 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 the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Based on the available record, the Panel finds the third element of the Policy has been established. 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 <legominifigs.net> be transferred to the Complainant. /Karen Fong/ Karen Fong Sole Panelist Date: May 12, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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