Westmore · UDRP decision
WIPO · Case No. D2026-1195

Leathermandeal.shop, Leathermanonline.shop

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <leathermandeal.shop> and <leathermanonline.shop>. It found the LEATHERMAN mark recognizable in both domain names, held that the Respondent had not rebutted the Complainant’s prima facie case on rights or legitimate interests, and concluded that the domains were registered and used to attract Internet users for commercial gain through confusion with the Complainant’s mark. The domains’ non-use at the time of the Complaint and Decision did not prevent a finding of bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-11
Panelist(s)
Chen, Jacob Changjie
Complainant
Leatherman Tool Group, Inc.
Respondent
杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si)
Disputed domain(s)
leathermandeal.shop, leathermanonline.shop
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind leathermandeal.shop

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 leathermandeal.shop — 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
Outcome by domain

How each disputed name was decided in this proceeding.

leathermandeal.shopTransferred
leathermanonline.shopTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of leathermandeal.shop.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how prior commercial website use can establish targeting and bad faith even when disputed domains are inactive by the time a complaint is filed. It also shows that different commercial uses across multiple trademark-formative domains—one involving purported branded products and another involving unrelated goods—may both support findings of implied affiliation and intentional attraction through confusion.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-11
Panel
Chen, Jacob Changjie
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Leatherman Tool Group, Inc. v. 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si) Case No. D2026-1195 1. The Parties The Complainant is Leatherman Tool Group, Inc., United States of America (“United States”), represented by SafeNames Ltd., United Kingdom. The Respondent is 杭州奥深互动科技有限公司 (hang zhou ao shen hu dong ke ji you xian gong si), China. 2. The Domain Names and Registrar The disputed domain names <leathermandeal.shop>, and <leathermanonline.shop> are registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) (the “Registrar”). 3. Procedural History The Complaint was filed in English 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 names. On March 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. On March 20, 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 24, 2026, the Complainant confirmed its request that English be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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 in English and Chinese of the Complaint, and the proceedings commenced on March 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 14, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 15, 2026. page 2 The Center appointed Jacob Changjie Chen as the sole panelist in this matter on April 27, 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, founded in 1983 in the United States, provides multi-purpose tools, wearables, knives, pocket tools and other related accessories, under the LEATHERMAN mark. The Complainant owns LEATHERMAN trademark within several jurisdictions, including but not limited to the followings: - United States Trademark Registration No. 1325473, registered on March 19, 1985, in class 8; - United States Trademark Registration No. 2596689, registered on July 23, 2002, in class 25; - Canada Trademark Registration No. TMA380140, registered on February 15, 1991, in class 8; and - European Union Trademark Registration No. 000041731, registered on March 31, 2004, in classes 18, 25 and 28. In 1995, the Complainant registered the domain name <leatherman.com> and has been using it as its primary business website. The Complainant also owns domain names <leatherman.ca>, <leatherman.be>, <leatherman.cn>, <leatherman.co.uk>, and <leatherman.mx>. The disputed domain name <leathermandeal.shop> was registered on September 15, 2025. At the time of the Complaint and of this Decision, it did not resolve to an active website. According to the record presented by the Complainant, it used to resolve to an online shop displaying the LEATHERMAN trademark and logo, and allegedly selling LEATHERMAN products. The disputed domain name <leathermanonline.shop> was registered on September 8, 2025. At the time of the Complaint and of this Decision, it did not resolve to an active website. According to the record presented by the Complainant, it used to resolve to an online clothing shop titled “LIFE IS GOOD”. 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 names. Notably, the Complainant contends that the domain names are confusingly similar to the LEATHERMAN trademark as the domain names encompass the entirety of the LEATHERMAN mark. The Complainant’s LEATHERMAN mark is the dominant and only distinctive element in the disputed domain names. The addition of the terms “online” and “deal” does not diminish the likelihood of confusion but rather increases it. The Complainant further contends that the Respondent lacks rights or legitimate interests in the disputed domain names. The Complainant claims that the Respondent does not have any trademark nor unregistered rights to the term “Leatherman” nor any similar term. Neither has the Respondent received any license from the Complainant to use a domain name featuring the LEATHERMAN trademark. Furthermore, the Respondent has not used, nor prepared to use, the disputed domain names in connection with a bona fide offering of goods or services. page 3 The Complainant finally contends that the Respondent registered the disputed domain names in bad faith, with the primary intention of taking advantage of the Complainant’s brand. The Respondent had used the disputed domain names in bad faith prior to notice of the Complaint in that it intentionally attempted to attract, for commercial gain, online users by creating a likelihood of confusion with the Complainant’s LEATHERMAN mark and offerings. B. Respondent The Respondent did not reply to the Complainant’s contentions. 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 disputed domain names are solely composed of Latin characters, and the terms “online” and “deal” are in the English language; - the disputed domain names used to host websites that were displayed entirely in English; the Respondent responded in English to the Center during the administrative proceeding of 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, showcasing that it understands English; and - conducting the proceedings in Chinese would cause unnecessary delay of the proceeding. The Respondent did not make any submissions with respect to the language 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 trademark and the disputed domain names. WIPO Overview 3.1, section 1.7. page 4 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. The Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms “deal” and “online” may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names 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 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. 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. The Panel considers that the composition of the disputed domain names carries a risk of implied affiliation with the Complainant. WIPO Overview 3.1, section 2.5.1. The website at the disputed domain name <leathermandeal.shop> was prominently displaying the Complainant’s trademark and providing purported LEATHERMAN products, while the website at the disputed domain name <leathermanonline.shop> was providing clothing products which are irrelevant to the Complainant. Both websites fail to accurately represent that there is no relationship between the Complainant and Respondent, thereby creating an undue association with the Complainant and likely confusing Internet users as to the source of products provided through the website. These facts suggest that the Respondent was using the disputed domain names to confuse and attract Internet visitors. In terms of the website at the disputed domain name <leathermandeal.shop>, panels have held that the use of a domain name for illegitimate activity (here, claimed passing off) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. page 5 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 determines that the Respondents chose the disputed domain names with knowledge of the Complainant, particularly given the offerings of purported LEATHERMAN products via the website associated with the disputed domain name <leathermandeal.shop>. It is thus inconceivable that the Respondent could have registered the disputed domain names without knowledge of the Complainant’s LEATHERMAN trademark. Clearly the Respondents intentionally registered the disputed domain names to exploit reputation of the Complainant and the LEATHRMAN, which indicates registration in bad faith. By choosing the Complainant’s trademark to register the disputed domain names and setting up websites to provide either purported LEATHERMAN products or irrelevant products to the Complainant, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with the Complainant’s marks, which constitutes bad faith under paragraph 4(b)(iv) of the Policy. Particularly in the case of disputed domain name <leathermandeal.shop>, the Respondent is deliberately attempting to misrepresent itself as being affiliated with the Complainant. Such use of the disputed domain names constitutes bad faith under the Policy. The disputed domain names did not resolve to any website at the time of filing the Complaint. This does not prevent a finding of bad faith under the circumstances of this case. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <leathermandeal.shop> and <leathermanonline.shop> be transferred to the Complainant. /Jacob Changjie Chen/ Jacob Changjie Chen Sole Panelist Date: May 11, 2026

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

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