Westmore · UDRP decision
WIPO · Case No. D2026-1189

Seaofthievesshop.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <seaofthievesshop.com> to Microsoft Corporation. It found the domain confusingly similar to Microsoft’s SEA OF THIEVES mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. Although the associated commercial website included a fan-store disclosure, the Panel found that the disclosure did not dispel the false impression of an authorized commercial relationship created by the domain, trademark use, franchise content, authenticity claims, and sale of merchandise and third-party goods.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-20
Panelist(s)
Weston, Nicholas
Complainant
Microsoft Corporation
Respondent
Hello World
Disputed domain(s)
seaofthievesshop.com
Domain history UDRP Intelligence

The timeline behind seaofthievesshop.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 seaofthievesshop.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 seaofthievesshop.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that labeling a commercial merchandise website as a fan store does not itself establish legitimate fan-site use. The Panel assessed the entire presentation, including the trademark-containing domain, sale of merchandise and third-party goods, use of franchise content, and claims of authenticity and a franchise creative team. On that record, the disclaimer could not cure the broader impression of official affiliation.

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
2026-05-20
Panel
Weston, Nicholas
Full decision
14 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Microsoft Corporation v. Hello World Case No. D2026-1189 1. The Parties The Complainant is Microsoft Corporation, United States of America (“United States”), represented by Edward Nathan Sonnenbergs Inc., South Africa. The Respondent is Hello World, Viet Nam. 2. The Domain Name and Registrar The disputed domain name <seaofthievesshop.com> (the “Disputed Domain Name”) is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 19, 2026. On March 19, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On March 20, 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, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 23, 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 on March 24, 2026. 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 of the Complaint, and the proceedings commenced on March 31, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 20, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 4, 2026. page 2 The Center appointed Nicholas Weston as the sole panelist in this matter on May 6, 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 a well-known software company with subsidiaries in over 120 countries and an employee headcount of 228,000 globally. The Complainant holds a portfolio of businesses that include a number of game development and publishing labels and studios, one of which, Xbox Game Studios, developed a popular video game franchise, SEA OF THIEVES. The Complainant holds trade mark registrations for the name SEA OF THIEVES, and variations of it, in numerous countries. Examples include United States Registration No. 5492586 SEA OF THIEVES (word) registered on November 6, 2015; United Kingdom Registration No. UK00801278052 SEA OF THIEVES (word) registered on October 24, 2016; and International Registration No. 1278052 SEA OF THIEVES (word) registered on November 10, 2015. The Complainant owns the domain name <seaofthieves.com>. The Disputed Domain Name <seaofthievesshop.com> was registered on June 25, 2025. The Disputed Domain Name resolves to a webpage that offers unauthorized third party products, digital goods and accessories for sale and displays content and trade marks related to the SEA OF THIEVES franchise. 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 cites its trademark registrations for the mark SEA OF THIEVES and variations of it, in numerous countries, as prima facie evidence of ownership. The Complainant contends that its rights in the mark SEA OF THIEVES mark predate the Respondent’s registration of the Disputed Domain Name. It submits that the Disputed Domain Name is confusingly similar to its trademark, because it is comprised of the SEA OF THIEVES trademark along with the term “shop”, under the generic Top-Level Domain (“gTLD”) “.com”, and that these variables are not sufficient to avoid the confusing similarity. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because the “Respondent is ... not known or in any way related to the Complainant and is not authorized to use the SEA OF THIEVES trademark” and that none of the circumstances set out in paragraph 4(c) of the Policy apply. Finally, the Complainant alleges that the registration and use of the Disputed Domain Name was, and currently is, in bad faith, contrary to the Policy and the Rules having regard to the prior use and distinctive nature of the Complainant’s trademark. On the issue of registration, the Complainant states that “the term SEA OF THIEVES is purely an imaginative term and is unique to the Complainant. The term SEA OF THIEVES is not commonly used to refer to video games”. The Complainant also contends that “[i]t is therefore beyond the realm of reasonable coincidence that the Respondent chose the Disputed Domain Name, without the intention of invoking a misleading association with the Complainant”. page 3 On the issue of use the Complainant contends that the Respondent’s website “describes itself as ‘Sea Of Thieves Merchandise Store For Fans’” and is “selling and offering third party products and accessories of other commercial origin (referred to as the ‘unauthorised third party products’) which not only infringes the Complainant’s SEA OF THIEVES trademark but also the Complainant’s copyright protected content appearing in or emanating to and/or from the SEA OF THIEVES video game franchise (referred to as the ‘SEA OF THIEVES Content’). The Website is prominently using the Complainant’s registered SEA OF THIEVES trademark at the top of the Website and within the tab interface and Website banner (as illustrated below), being the locations where users / relevant consumers usually expect to find the name of the online shop and/or the name of the provider of the Website. The landing page of the website describes itself as ‘Sea Of Thieves Merchandise Store For Fans’”. It also contends that “[t]he Respondent, though claiming to be ‘created by fans for fans’ is using the Complainant’s SEA OF THIEVES trademark to redirect users to a competing site”, and displays a “copyright notice ‘Copyright 2026 © Sea of Thieves Merch. All Rights Reserved’ appearing at the bottom of the Website”. The Complainant discloses that “[t]he Website contains a ‘Fans Store Disclosure’ Page, which states that ‘Sea Of Thieves Merch is not an Official Merchandise, It is a store created by fans, for fans. We understand the deep connection and enthusiasm that comes with being a devoted fan. Our mission is to provide you with high-quality merchandise that reflects your love and dedication.’ However, [the Complainant contends] the Website is evidently not a mere fan site as it is clearly making commercial use of the Complainant’s SEA OF THIEVES trademark and Content in a manner that is not distinct from the Complainant’s official offerings and SEA OF THIEVES Content” and that these facts amount to use in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant has the burden of proving the following: (i) that the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (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. 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 Select UDRP Questions (“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. The requirements of the first element for purposes of the Policy may be satisfied by a trademark registered in any jurisdiction. WIPO Overview 3.1, section 1.2.1. The Complainant has produced sufficient evidence to demonstrate that it has registered trademark rights in the mark SEA OF THIEVES in several countries. Turning to whether the Disputed Domain Name is identical or confusingly similar to the SEA OF THIEVES trademark, the Panel observes that the Disputed Domain Name <seaofthievesshop.com> is comprised of: (a) the Complainant’s trademark; (b) followed by the term “shop”; (c) followed by the gTLD “.com”. page 4 It is well established that the gTLD used as part of a domain name is generally disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. The relevant comparison to be made is with the second-level portion of the Disputed Domain Name, specifically: “seaofthievesshop”. The Panel finds the mark is recognizable within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the mark for the purposes of the Policy also. WIPO Overview 3.1, section 1.7. Although, the addition of the term “shop” may bear on assessment of the second and third elements in relation to the Disputed Domain Name, the Panel finds the addition of that 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 3.1, 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 Disputed 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. The Panel finds that there is no indication that the Respondent was commonly known by the term “SEA OF THIEVES” prior to registration of the Disputed Domain Name. The Complainant has not licensed, permitted, or authorized the Respondent to use the trademark SEA OF THIEVES. The Panel also notes that the composition of the Disputed Domain Name carries a risk of implied affiliation (see WIPO Overview 3.1, section 2.5.1). The Panel notes that the Complainant has not licensed or otherwise authorized the Respondent to use its trademark and that there is no relationship between the Complainant and the Respondent. The Panel finds that while there is prominent disclosure of the “fan” relationship on its website, the disclosure is neither accurate nor sufficient to dispel the false impression of an authorized commercial relationship. The use of the Complainant’s trademark and content, the nature of the products which include third party goods displayed on the Respondent’s website suggests that the Respondent has targeted the Complainant. The Panel finds that the Respondent’s activities do not represent a bona fide offering of goods or services, or a legitimate noncommercial or fair use, given the substantial reputation and goodwill of the Complainant’s mark or capacity to otherwise mislead Internet users. Panels have held that the use of a domain name for illegitimate activity such as impersonation, passing off, or other types of fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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. page 5 The Panel observes that the Disputed Domain Name is not identical to the complainant’s trademark but adds the term “shop”. Where such a “fan” site is noncommercial in nature, an extra descriptive word may tend to support a finding that the use is a fair one. Some panels have also found in such cases that a degree of commercial activity may be permissible. However, the commercial content of the website in this case is egregious evidence the Disputed Domain Name has been registered and is being used for illegitimate purposes and as a pretext for commercial gain and may be misunderstood by Internet users as being somehow sponsored or endorsed by the trademark owner. The Panel finds that this is not fair use by a legitimate “fan” site. WIPO Overview 3.1, sections 2.5.2 and 2.7. The Panel finds the second element of the Policy has been established for the 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. 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 faith. WIPO Overview 3.1, section 3.2.1. In the present case, the Panel finds that the evidence in the case shows the Respondent registered and has used the Disputed Domain Name in bad faith. On the issue of registration, taking into account the composition of the Disputed Domain Name and the Complainant’s distinctive trademark, the Panel is satisfied that the Respondent deliberately targeted the Complainant’s trademark SEA OF THIEVES when it registered the Disputed Domain Name. This Panel finds that there is no reason for the Respondent to have registered the Disputed Domain Name other than to trade off the reputation and goodwill of the Complainant’s trademark. WIPO Overview 3.1, section 3.1.4. Further, a gap of several years between registration of a complainant’s trademark and respondent’s registration of a disputed domain name (containing the trademark) may indicate bad faith registration. In this case, the Respondent registered the Disputed Domain Name nearly 10 years after the Complainant established registered trademark rights in the SEA OF THIEVES mark. The Respondent has not come forward to rebut the Complainant’s allegations or to offer an alternative explanation. On the issue of use, the Complainant’s evidence is that the Disputed Domain Name was used to host a website that displays the Complainant’s actual trademark, copyright content and displaying products that offer for sale merchandise and other commercial products, including third party goods, that target the Complainant’s SEA OF THIEVES video game franchise. Targeting of this nature is a common example of bad faith as referred to in paragraph 4(b)(iv) of the Policy and identified in many previous UDRP decisions. WIPO Overview 3.1, sections 3.1.4 and 3.2.1. Panels have held that the use of a domain name for unlawful activity here, alleged impersonation or passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. The Complainant supplied evidence of the misleading website. In the circumstances, having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under paragraph 4(b)(iv) of the Policy. page 6 The Panel notes that some of the content displayed on the Respondent’s website includes the following: a statement that “All of our products are designed by the Sea Of Thieves Creative Team and have high-quality standards”. The website also displays the words: “Why Choose Sea of Thieves Merch? Authenticity: Immerse yourself in the world of Sea of Thieves with merchandise crafted with an unwavering commitment to authenticity.” The Panel finds that notwithstanding the Respondent’s disclaimer that this is a fan site, the overall impression created is one of an affiliation with the Complainant which does not in fact exist (WIPO Overview 3.1, section 3.7). 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 <seaofthievesshop.com> be transferred to the Complainant. /Nicholas Weston/ Nicholas Weston Sole Panelist Date: May 20, 2026.

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

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