Westmore · UDRP DecisionLinc0lnelectric.com
The Panel ordered transfer of <linc0lnelectric.com>. It found the domain confusingly similar to the LINCOLN ELECTRIC mark because it replaced the letter “o” with the visually similar number “0.” The Complainant established a prima facie case that the Respondent lacked rights or legitimate interests, which the defaulting Respondent did not rebut. Bad faith was found from the typosquatting composition, the mark’s reputation, registration long after the Complainant acquired rights, passive holding through a website-builder landing page, email configuration, the absence of any credible good-faith explanation, and the Panel’s finding that the Respondent used a false name and apparently false contact details.
The timeline behind linc0lnelectric.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 linc0lnelectric.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a single visually deceptive character substitution can satisfy confusing similarity and contribute strongly to findings on the other UDRP elements. It also shows that passive holding may support bad faith where a domain is an obvious typo of a widely known mark, the respondent offers no explanation, email functionality is configured, and the registration information appears false.
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 Lincoln Global, Inc., The Lincoln Electric Company v. Lincoln AR, linc0lnelectric Case No. D2026-2216 1. The Parties The Complainants are Lincoln Global, Inc., United States of America (“United States”) and The Lincoln Electric Company, United States, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Lincoln AR, linc0lnelectric 1 , United States. 2. The Domain Name and Registrar The disputed domain name <linc0lnelectric.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 22, 2026. On May 22, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 22, 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 Complainants on June 1, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainants to submit an amendment to the Complaint. The Complainants filed an amended Complaint on June 2, 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”). 1 Due to the similarity in names between the Respondent and the Complainant, the Complainant requested the Panel to redact the name of the Respondent in order to prevent the publication of a decision against what might appear to be the Complainant and the Complainant’s representative. Despite the request, the Panel declines to redact the name of the Respondent. The decision is clear that the Respondent appears to be using false names in an attempt to hide their true identity. Therefore, it is in the interest of potential future abusive registrations by the same Respondent that their alleged identity remains a public record. page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 22, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 23, 2026. The Center appointed Gary Saposnik as the sole panelist in this matter on June 29, 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 Complainants, Lincoln Electric Company and Lincoln Global, Inc. (collectively “Complainant”) are sister companies owned by Lincoln Electric Holdings Inc. Lincoln Electric was founded in 1895 in the United States, and in 1936 started to expand globally, starting in Australia. Today, the Complainant designs, develops, and manufactures welding products, robotic arc welding systems, plasma and oxy-fuel cutting equipment, and is also in the brazing and soldering alloys market. Headquartered in Ohio, United States, the Complainant operates 71 manufacturing and automation system integration locations across 21 countries and maintains a worldwide network of distributors and sales offices serving customers in over 160 countries. The Complainant employs over 12,000 employees worldwide, and had reported sales of USD 4.0 billion in 2024. The Complainant is the owner of a number of trademark registrations for LINCOLN ELECTRIC, including the following: • LINCOLN ELECTRIC, United States Reg. No. 2350082, registered May 16, 2000, in class 9; • LINCOLN ELECTRIC, United States Reg. No. 2420805, registered January16, 2001, in class 35; • LINCOLN ELECTRIC, United States Reg. No. 3114157, registered July 11, 2006, in class 6. Additionally, the Complainant has a large internet presence and is the owner of over 270 domain names which incorporate LINCOLN ELECTRIC and its variations, including its primary domain name <lincolnelectric.com>, where it hosts its website that received an average of 482K hits in March 2026. The Complainant also has a social media presence through the use of its Facebook, X and YouTube pages. The disputed domain name was registered on April 2, 2026, with the alleged Respondent being Lincoln AR, linc0lnelectric, located in California, United States. The disputed domain name resolves to a website builder landing page. 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 or confusingly similar to the LINCOLN ELECTRIC trademark or service mark in which the Complainant has rights. The disputed domain name is a purposeful misspelling of the Complainant’s mark and must be considered confusingly similar to the Complainant’s trademark. The disputed domain name varies from the Complainant’s trademark by substituting the letter “o” with the number “0” in the trademark term “LINCOLN”. A domain name which consists of an obvious, or intentional misspelling of a trademark is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. This includes the substitution of similar- appearing characters (e.g., upper vs lower-case letter or numbers used to look like letters), as an example of page 3 typosquatting. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.9. The Complainant argues that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not sponsored by or affiliated with the Complainant in any way. The Complainant has not given the Respondent permission to use the Complainant’s trademarks in any manner, including in domain names. The Respondent is not commonly known by the disputed domain name, which evinces a lack of rights or legitimate interests. Furthermore, the Complainant has not licensed, authorized, or permitted the Respondent to register domain names incorporating the Complainant’s trademark. The Complainant contends that the Respondent has falsely identified itself in the contact details to lend legitimacy to the registration, and the Respondent should still not be regarded as commonly known by the disputed domain name. There is no evidence to show that the Respondent has ever been known by the moniker “Lincoln Electric”, apart from the disputed domain name. The Complainant has not found that the Respondent has any registered trademarks corresponding to the disputed domain name, nor any registered business by the same name. The disputed domain name currently resolves to a parked page. The Respondent has failed to make use of the disputed domain name’s website and has not demonstrated any attempt to make legitimate use of the domain name and website, which evinces a lack of rights or legitimate interests in the disputed domain name. While there is no evidence that the disputed domain name was actively used as part of a fraud, the presence of Mail Exchanger (“MX”) records on the domain name, whilst resolving to an unused parking page, strongly implies that the disputed domain name could be used as part of an email phishing scheme in the future. Lastly, the Complainant avers that the disputed domain name was registered and is being used in bad faith. The Complainant has marketed and sold its goods and services using the LINCOLN ELECTRIC mark since 1915, which is well before the Respondent’s registration of the disputed domain name. By registering a domain name that is a one letter typo from the Complainant’s trademark, the Respondent has created a domain name that is confusingly similar to the Complainant’s trademark, as well as its <lincolnelectric.com> domain name. The composition of the disputed domain name makes it illogical to believe that the Respondent registered the disputed domain name without specifically targeting the Complainant. Based on the facts of the case, it is “not possible to conceive of a plausible situation in which the Respondent would have been unaware of” the Complainant’s brands at the time the disputed domain name was registered. See Telstra Corporation Limited. v. Nuclear Marshmallows, WIPO Case No. D2000-0003. The LINCOLN ELECTRIC mark is so closely linked and associated with the Complainant that the Respondent’s use of this mark, or any minor variation of it, strongly implies bad faith. Numerous panels have found that registering a domain name to take advantage of traffic generated by typing errors committed by another’s customers, as here, is evidence of bad faith registration and use pursuant to Policy 4(a)(iii). See WIPO Overview 3.1, section 3.1.4. The disputed domain name currently resolves to a holding page and is not being used, but rather is being passively held, which can constitute a factor in finding bad faith registration and use. See Telsta, supra. The disputed domain name is confusingly similar to the Complainant’s trademarks, and the Respondent has made no use of the disputed domain name, factors which should be duly considered in assessing bad faith registration and use. The disputed domain name can only be taken as intending to cause confusion among internet users as to the source of the disputed domain name, and thus, the disputed domain name must be considered as having been registered and used in bad faith pursuant to Policy 4(b)(iv), with no good faith use possible. Although the disputed domain name is not being used to host active content, the Complainant submits that it has been set up with MX records. The disputed domain name may be actively used for email purposes. Emails deriving from the disputed domain name could not reasonably be used for any good faith purpose given the close similarity of the disputed domain name with the Complainant’s trademark that would be page 4 difficult to discern in an email. Therefore, it is more likely that the disputed domain name may be actively used to facilitate fraudulent activity such as phishing, impersonating or passing off as the Complainant. Additionally, by falsely using the name of the Complainant, the Respondent is attempting to conceal its true identity. Such falsified information is another indication of the Respondent’s bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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. The Panel finds the LINCOLN ELECTRIC 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. WIPO Overview 3.1, section 1.7. A domain name which consists of a variation of a trademark (typically a common, obvious or intentional misspelling, referred to as typosquatting) is considered by panels to be confusing similar to the relevant mark for purposes of the first element. The substitution of the number “0” for the letter “O” in LINCOLN ELECTRIC is considered an intentional misspelling of the Complainant’s mark, and the disputed domain name is therefore confusingly similar to the Complainant’s mark. WIPO Overview 3.1, section 1.9. 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. page 5 The Panel notes the uncontroverted contentions that the Respondent is not sponsored by or affiliated with the Complainant in any way, nor has the Complainant given the Respondent permission to use the Complainant’s trademarks in any manner, including in domain names. The Complainant has not licensed, authorized, or permitted the Respondent to register domain names incorporating the Complainant’s trademark. Additionally, the Respondent is not commonly known by the disputed domain name. Although the Respondent’s names appear to contain the same names as the Complainant, the disputed domain name is clearly based on the LINCOLN ELECTRIC widely-known name and mark, which does not seem coincidental, as it is simply a typo of the Complainant’s mark. Such typosquatting in and of itself, is evidence that the Respondent lacks rights or legitimate interests. See Lincoln Global, Inc., The Lincoln Electric Company v. Susan Webbing, WIPO Case No. D2025-4357. The disputed domain name carries a risk of Internet confusion as it is likely to be mistakenly seen by consumers as related to the Complainant. The Respondent has failed to come forward with any credible evidence that it is commonly known by the disputed domain name or its alleged corporate identifier, apart from the disputed domain name or the WhoIs details. Respondents are expected to produce specific credible evidence, but the Respondent has failed to respond or provide any evidence of their rights or legitimate interests. 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. In the present case, the Panel notes that the Respondent registered the disputed domain name decades after the Complainant acquired rights in its widely-known LINCOLN ELECTRIC mark. The Respondent’s registration and use of the disputed domain name, which is a typo domain name clearly based on the Complainant’s mark, has been done opportunistically and in bad faith for the benefit or profit of the Respondent. The disputed domain name, on its face, suggests a connection to the Complainant and its products, when no such connection exists. Although the disputed domain name does not resolve to an active website other than a landing page, the Respondent has set up the disputed domain name for email purposes, and has failed to respond to the Complaint to justify its actions. This suggests that the disputed domain name was registered for some purpose to benefit the Respondent and perhaps for a nefarious purpose. See Lincoln Global, Inc., The Lincoln Electric Company v. Susan Webbing, supra. Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a well-known trademark can by itself create a presumption of bad faith. WIPO Overview 3.1, section 3.1.4. 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. These circumstances include the nature of the domain name being a typo of a widely known mark. The evidence presented reflects that the Complainant’s mark is widely known and the disputed domain name is clearly a typo of the Complainant’s mark. Other factors of bad faith registration are a clear absence of rights or legitimate interests coupled with no credible explanation for the Respondent’s choice of the domain name. As previously determined, the Respondent has a clear absence of rights or legitimate interests and has failed to respond to the Complaint with any credible explanation for the choice of the disputed domain name. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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 page 6 reviewed the available record, the Panel notes the reputation of the Complainant’s trademark, and the composition of the disputed domain name being a typo of the Complainant’s well-known mark, the failure of the Respondent to submit a response or to provide any evidence of actual or contemplated good-faith use beyond a web site builder landing page, the Respondent’s use of a false name and apparent false contact details in its address in an attempt to conceal its identity, 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. 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 <linc0lnelectric.com> be transferred to the Complainant. /Gary Saposnik/ Gary Saposnik Sole Panelist Date: July 13, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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