Westmore · UDRP DecisionLeathermaneu-store.com
The Panel ordered transfer of <leathermaneu-store.com>. It found the domain confusingly similar to the LEATHERMAN mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The findings relied principally on the incorporation of LEATHERMAN with the terms “eu” and “store,” the former website mimicking the Complainant’s official site and offering purported LEATHERMAN products, the collection of payment information, the risk of implied affiliation, and evidence of the Respondent’s prior and broader abusive registration conduct.
The timeline behind leathermaneu-store.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 leathermaneu-store.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a trademark combined with geographic and retail wording can strengthen, rather than reduce, an implication of official affiliation. The case also shows that a domain’s deactivation after a registrar abuse complaint does not remove the significance of its earlier use. Prior disputes involving the same respondent, together with evidence linking the respondent’s email to other trademark-bearing domains, materially reinforced the Panel’s findings of knowledge, targeting, and patterned conduct.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Leatherman Tool Group, Inc v. 郑道君 (zhengdaojun, zheng daojun) Case No. D2026-1098 1. The Parties The Complainant is Leatherman Tool Group, Inc, United States of America, represented by SafeNames Ltd., United Kingdom. The Respondent is 郑道君 (zhengdaojun, zheng daojun), China. 2. The Domain Name and Registrar The disputed domain name <leathermaneu-store.com> is registered with Xin Net Technology Corp. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on March 13, 2026. On March 16, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On March 17, 2026, 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 for Privacy) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on March 17, 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 17, 2026. On March 17, 2026, the Center inf ormed the parties in Chinese and English, that the language of the registration agreement f or the disputed domain name is Chinese. On March 17, 2026, the Complainant conf irmed its request that English be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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” o r “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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notif ied the Respondent in Chinese and English of the Complaint, and the proceedings commenced on March 19, 2026. In accordance with the Rules, paragraph 5, the due date f or Response was April 8, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on April 10, 2026. The Center appointed Linda Chang as the sole panelist in this matter on April 16, 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, founded in 1983 in the United States of America, is a company providing multi-purpose tools, wearables, knives, pocket tools and other related accessories. At present, the Complainant’s products are sold in approximately 90 countries across the globe, including via the popular eCommerce platf orm Amazon. The Complainant is active on social media platforms (i.e., X, Facebook, LinkedIn, Instagram, and YouTube), where it gathered thousands of f ollowers. Further to the extensive exposure of its brand and products, the Complainant has obtained national and international recognition in the tool market. The Complainant owns numerous trademark registrations f or LEATHERMAN, including: - The United States of America trademark LEATHERMAN Registration No. 1325473, registered on March 19, 1985, in class 8; - The Canada trademark LEATHERMAN Registration No. TMA380140, registered on February 15, 1991, in class 8; and - The European Union trademark LEATHERMAN Registration No. 000041731, registered on March 31, 2004, in classes 18, 25, and 28. The Complainant registered the domain name <leatherman.com> on October 19, 1995, and has been using it as the Complainant’s official website. This website is reported to receive an average of 1.1 million monthly user visits. In addition to <leatherman.com>, the Complainant also owns other domain names incorporating its LEATHERMAN trademark, including <leatherman.ca>, <leatherman.be>, <leatherman.co.uk>, and <leatherman.mx>, which redirect to the Complainant’s of f icial website. The Respondent is reportedly based in China. The disputed domain name was registered on February 3, 2026. Presently, the disputed domain name resolves to an inactive webpage as a result of the Complainant’s earlier abuse complaint to the Registrar. According to the Complainant’s evidence, the disputed domain name previously resolved to a website displaying the Complainant’s LEATHERMAN trademark and allegedly selling and of f ering the Complainant’s LEATHERMAN products at discounted prices. 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: i) the disputed domain name encompasses the entirety of the Complainant’s LEATHERMAN trademark with the addition of the geographical term “eu” (denoting the abbreviation of European Union), the hyphen and the page 3 term “sto re”. The Complainant’s LEATHERMAN tradem ark is the dominant and only distinctive element in the disputed domain name. The addition of the terms “eu” and “sto re” do not prevent the likelihood of conf usion. On the contrary, it only reinforces the connection to the Complainant, since the terms conveys the impression that the disputed domain name is used to of f er the Complainant’s of f icial store in Europe where the Complainant’s products are sold. The generic top-level domain (“g TLD”) “.com” is a standard registration requirement and, as such, is disregarded under the f irst element conf using similarity test. Theref ore, the disputed domain name is confusingly similar to the Complainant’s LEATHERMAN trademark; ii) the Respondent has no af f iliation with the Complainant, and the Complainant has not authorized the Respondent to use the LEATHERMAN trademark f or any reason or in any manner. To the best of the Complainant’s knowledge, the Respondent does not have any trademark rights or unregistered trademark rights corresponding to the disputed domain name, and has not been commonly known by the disputed domain name; iii) the disputed domain name previously resolved to a website impersonating the Complainant’s of f icial website, displaying the Complainant’s LEATHERMAN trademark and allegedly selling and of f ering the Complainant’s LEATHERMAN products at discounted prices, without any clear disclosure that it has no af f iliation and relationship with the Complainant. Given the discounted prices promoted on the previous web site associated with the disputed domain name, it is unlikely that the purportedly of f ered products were genuine. Such use of the disputed domain name indicates that the Respondent intended to misleadingly divert the Complainant’s customers to the website associated with the disputed domain name for commercial gain, and theref ore does not constitute a bona f ide of f ering of goods or services or a legitimate noncommercial or fair use of the disputed domain name, nor does it support any claim to legitimate reseller use; iv) the previous website associated with the disputed domain name collected Internet users’ sensitive payment inf ormation when purchasing the purported products. This conduct raises a risk of phishing; v) the disputed domain name was registered long af ter the Complainant’s LEATHERMAN trademark and given the previous use of the disputed domain name, it is implausible that the Respondent was unaware of the Complainant and its LEATHERMAN trademark when registering the disputed domain name; vi) the Respondent’s previous use of the disputed domain name indicates that the Respondent has intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of conf usion with the Complainant and its LEATHERMAN trademark and products. The collection of Internet users’ sensitive payment information, together with the absence of any clear disclaimer of non-af f iliation with the Complainant on the previous website associated with the disputed domain name, is further indicative of bad f aith; vii) the Respondent’s current passive holding of the disputed domain name constitutes bad f aith; and viii) the Respondent has been involved in a prior domain name dispute with the Complainant, in which the relevant panel f ound that the Respondent’s registration and use of a domain name incorporating the Complainant’s LEATHERMAN trademark was in bad faith. See Leatherman Tool Group, Inc. v. niu youguo; 苏科 (ke su, suke, su ke); 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si); earl j glancy; 郑道君 (zheng daojun, zheng daojun); 臧勇 (zang yong, zangyong); 曾发琴 (zengfaqing, zeng faqing); 林志冰 (linzhibing, lin zhibing); jiu lin; Liana De; M Albert Jerome, Jerome M Albert; L Adams Timothy, Timothy L Adams; McLachlan Krystal, Krystal McLachlan, WIPO Case No . D2025-4581; ix) the Respondent’s email address is associated with other domain names that incorporate third-p arty trademarks, which indicates that the Respondent has engaged in a pattern of abusive conduct by registering domain names that incorporate third-party trademarks. page 4 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Procedural Issue - Language of the Proceedings The language of the Registration Agreement f or the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specif ied otherwise in the registration agreement, the language of the administrative proceedings shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceedings be English for several reasons, including the fact that 1) the disputed domain name consists of Latin characters and English word; 2) the previous content on the website associated with the disputed domain name was in English, which indicate that the Respondent is able to understand English; 3) using Chinese as language of the proceedings would unfairly disadvantage and burden the Complainant and delay the proceedings and adjudication of this matter. The Respondent did not make any submissions with respect to the language of the proceedings. 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. 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 proceedings shall be English. 6.2 Substantive Issues 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 3.1, section 1.7. The Complainant has shown rights in respect of the LEATHERMAN trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The gTLD “.com” as a standard registration requirement should be disregarded in the assessment of conf using similarity under the Policy. WIPO Overview 3.1, section 1.11.1. The entirety of the Complainant’s LEATHERMAN trademark is reproduced within the disputed domain name. While the hyphen “-” and the terms “eu” and “sto re” are included, the LEATHERMAN trademark remains clearly recognizable in the disputed domain name. The Panel f inds that the extra hyphen and terms do not prevent a f inding of conf using similarity between the disputed domain name and the LEATHERMAN trademark. Accordingly, the disputed domain name is confusingly similar to the LEATHERMAN trademark f or the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.8. The Panel f inds the f irst element of the Policy has been established. page 5 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 dif f icult 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 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 3.1, section 2.1. The available record shows that: - the Respondent is not affiliated with the Complainant and has not been authorized to use the Complainant’s LEATHERMAN trademark in any f orm; - there is no evidence proving that the Respondent holds any trademark rights corresponding to the disputed domain name, or has been commonly known by the disputed domain name; - the disputed domain name previously resolved to a website mimicking the Complainant’s of f icial website, displaying the Complainant’s LEATHERMAN trademark and allegedly selling and offering the Complainant’s LEATHERMAN products at discounted prices, without any prominent and accurate explanation of the relationship (or lack thereof) between the Parties. Such use of the disputed domain name indicates the Respondent’s intention to divert Internet traffic to the website associated with the disputed domain name by misleading Internet users into believing that the website associated with the disputed domain name is operated or endorsed by the Complainant, which cannot be deemed as a bona f ide of f ering of goods or services or a legitimate noncommercial or f air use; - the nature of the disputed domain name, incorporating the Complainant’s LEATHERMAN trademark, together with the terms “eu” (ref erring to the abbreviation of European Union where the Complainant operates business) and “s tore” (suggesting a retail platform or website through which the Complainant off ers its products), carries a risk of implied af f iliation with the Complainant. When considered alongside the Respondent’s previous use of the disputed domain name, it supports to affirm the Respondent’s intention of taking unf air advantage of the likelihood of conf usion between the disputed domain name and the Complainant as to the origin or af f iliation of the website associated with the dispute domain name; and - no other factors demonstrate any rights or legitimate interests of the Respondent in the disputed domain name. 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. The Panel f inds the second element of the Policy has been established. page 6 C. Registered and Used in Bad Faith 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. In the present case, the Panel notes that the Complainant obtained the trademark registration f or LEATHERMAN as early as March 19, 1985, which significantly predates the registration date of the disputed domain name (February 3, 2026). According to the Complainant’s evidence, the Panel accepts that the Complainant and its LEATHERMAN trademark have gained a certain degree of reputation and recognition in relevant markets through its extensive use and advertising. The Respondent registered the disputed domain name that f ully incorporates the Complainant’s LEATHERMAN trademark and resolved it to a website mimicking the Complainant’s official website, displaying the Complainant’s LEATHERMAN trademark and allegedly selling and offering the Complainant’s LEATHERMAN products at discounted prices. Furthermore, the Respondent registered a domain name that incorporates the Complainant’s LEATHERMAN trademark. In a prior domain name dispute, the relevant panel determined that this domain name had been registered and was being used by the Respondent in bad faith. See Leatherman Tool Group, Inc. v. niu youguo; 苏科 (ke su, suke, su ke); 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si); earl j glancy; 郑道君 (zheng daojun, zheng daojun); 臧勇 (zang yong, zangyong); 曾发琴 (zengfaqing, zeng faqing); 林志冰 (linzhibing, lin zhibing); jiu lin; Liana De; M Albert Jerome, Jerome M Albert; L Adams Timothy, Timothy L Adams; McLachlan Krystal, Krystal McLachlan, WIPO Case No . D2025-4581. Given these circumstances, the Panel determines that the Respondent had actual knowledge of the Complainant and its LEATHERMAN trademark at the time of registering the disputed domain name, and bad f aith is f ound. 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 3.1, section 3.2.1. The disputed domain name resolves to an inactive webpage at the time of the Decision as a result of the Complainant’s earlier abuse complaint to the Registrar. Bef ore the Complainant’s abuse complaint, the disputed domain name was used to host a website mimicking the Complainant’s official website, displaying the Complainant’s LEATHERMAN trademark and allegedly selling and of f ering the Complainant’s LEATHERMAN products at discounted prices. The Panel holds that by selecting a domain name confusingly similar to the Complainant’s LEATHERMAN trademark, and using it in the manner as described, the Respondent obviously has intended to attract, for commercial gain, Internet users to the disputed domain name and the associated website by creating a likelihood of conf usion with the Complainant’s LEATHERMAN trademark as to the source, sponsorship, af f iliation, or endorsement of the website associated with the disputed domain name, which constitutes bad f aith within the meaning of paragraph 4(b )(iv) o f the Policy. In addition, the previous website associated with the disputed domain name collected Internet users’ sensitive payment information when purchasing the purportedly offered products, which is of risk of resulting in the leakage of personal inf ormation of Internet users. Given the Respondent’s previous use of the disputed domain name, the current non-use of the disputed domain name does not prevent the Panel’s f inding of the Respondent’s bad f aith. In addition, according to the Complainant’s evidence, the Respondent’s email address is associated with other domain names that incorporate third-party trademarks. The Panel views that the Respondent constitutes a pattern of conduct of preventing a trademark holder from ref lecting its trad emark in a domain name. The Panel f inds that the Complainant has established the third element of the Policy. page 7 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 <leathermaneu-store.com> be transf erred to the Complainant. /Linda Chang/ Linda Chang Sole Panelist Date: April 30, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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