Westmore · UDRP DecisionPluggable.com
The three-member Panel denied the Complaint and found Reverse Domain Name Hijacking. Although <pluggable.com> was confusingly similar to the Complainant’s PLUGABLE trademark, the Respondent acquired the dictionary-word domain before the Complainant acquired trademark rights and used it for a business named “Pluggable Ltd.” The Panel found no evidence that the Respondent targeted the Complainant or its later-arising trademark. It rejected the argument that reactivating the domain in 2026 reset the registration date and held that the later offer to sell the domain did not retrospectively create bad-faith registration. The Panel did not definitively decide the rights-or-legitimate-interests element because the Complaint necessarily failed under the third element.
The timeline behind pluggable.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 pluggable.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates the central importance of registration timing in UDRP cases involving dictionary-word domains. Later non-use, reactivation, changed use, or a high-value sale offer did not reset the acquisition date or retrospectively establish bad-faith registration while the registrant remained unchanged. It also demonstrates the RDNH risk of pursuing a complaint where the complainant knows the domain predates its rights and the record supplies a credible, non-targeting reason for acquisition.
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 Leancode, Inc. v. Richard Harrison Case No. D2026-2365 1. The Parties The Complainant is Leancode, Inc., United States of America, represented by Eligon IP LLC, United States o f America. The Respondent is Richard Harrison, United Kingdom, represented by Adlex Solicitors, United Kingdom. 2. The Domain Name and Registrar The disputed domain name <pluggable.com> is registered with DNC Ho ld ing s, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 1, 2026. On June 2, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On June 8, 2026 the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Jewella Privacy, Jewella Privacy LLC Privacy ID# 13566846) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 9, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on June 12, 2026. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on June 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 6, 2026. The Respondent requested an automatic extension of f our days, then the due date was July 10, 2026. The Response was f iled with the Center on July 8, 2026. page 2 The Center appointed Kaya Köklü, Lynda J. Zadra-Symes and Nick J. Gardner as panelists in this matter on July 22, 2026. The Panel f inds that it was properly constituted. Each member of 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 company registered in the United States, active in the f ield of computer accessories and related technology products. The Complainant is the owner of the trademark PLUGABLE. Based on the inf ormation provided in the Complaint, the Complainant’s f irst trademark registration is United States Trademark Registration No. 3,956,966, registered on May 10, 2011, claiming f irst use in commerce on September 18, 2009, f o r PLUGABLE, covering various computer hardware and peripheral goods in class 9. The Complainant also owns and operates its of f icial website at <plugable.com>. The Respondent is located in the United Kingdom. The disputed domain name was initially registered on April 9, 2005. The Respondent acquired the disputed domain name on February 18, 2009. On January 17, 2008, prior to acquiring the disputed domain name, the Respondent had established a consulting company in 2007, which was named “Pluggable Ltd.”. After discontinuing its business activities in 2012, the Respondent retained ownership of the disputed domain name. In 2026, the Respondent reactivated the email account associated with the disputed domain name and started receiving misdirected emails intended f or the Complainant. On March 17 and 19, 2026, the Respondent inf ormed the Complainant of these misdirected emails. During the Parties’ subsequent correspondence, the Respondent indicated that it would be prepared to sell the disputed domain name, without specifying an asking p rice. In return, the Complainant of f ered to purchase the disputed domain name f or USD 5,000. Through its legal counsel, the Respondent declined that offer and stated that its price expectations were “in the mid-six f igure range”. At the time of the Decision, the disputed domain name resolves to a webpage promoting the value of the disputed domain name and indicating that it is available f or purchase. 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 does not dispute that the disputed domain name was registered bef ore the Complainant acquired trademark rights in PLUGABLE. However, the Complainant argues that the relevant point in time for assessing the second and third elements of the Policy, in particular bad f aith registration, should be the Respondent’s reactivation of use of the disputed domain name in 2026 rather than the original registration or acquisition of the disputed domain name. Of f ering the disputed domain name f or sale at a price likely exceeding the Respondent’s out-of-pocket costs related to the disputed domain name is, in view of the Complainant, suf f icient evidence of bad f aith. page 3 B. Respondent The Respondent requests the denial of the Complaint and a f inding of Reverse Domain Name Hijacking (“RDNH”). The Respondent contends that the Complainant has not satisf ied the second and third elements required under the Policy f or a transf er of the disputed domain name. The Respondent particularly submits that the disputed domain name consists of a common English dictionary word, that it was acquired before the Complainant adopted and obtained trademark rights in the deliberately modif ied spelling PLUGABLE, that the Respondent never targeted the Complainant or its PLUGABLE trademark, and that offering the disputed domain name f or sale does not, in itself , constitute evidence of bad faith. The Respondent rather argues that after discontinuing its business under “pluggable” in 2012, it retained ownership of the disputed domain name considering the disputed domain name to have an inherent value as a dictionary word and technology-related domain name. In addition, the Respondent submitted a screenshot of a Reddit post of 2025, in which the f ounder of the Complainant stated, in response to a user’s comment: “Yes! It’s the classic issue of name clash and branding. We’re Plugable because the dictionary word pluggable.com wasn’t available, and can’t be trademarked!”. All in all, the Respondent argues that all this demonstrates that the Complainant, represented by a counsel apparently familiar with UDRP, must have been fully aware that the Complaint could not succeed under the Policy, but nevertheless chose to commence this administrative proceeding. 6. Discussion and Findings According to paragraph 15(a) of the Rules, the Panel shall decide the Complaint in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three following elements is satisf ied: (i) the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad f aith. It is stated that the Panel has taken note of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1“) and, where appropriate, will decide consistently with the consensus views captured therein. 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 of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1“), section 1.7. The Complainant has shown rights in respect of the PLUGABLE trademark f or the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. page 4 The disputed domain name consists of the correctly spelled English dictionary word “pluggable”, whereas the Complainant’s trademark PLUGABLE omits one of the two letters “g”. Despite this minor dif f erence in spelling, the Panel considers that the Complainant’s PLUGABLE trademark remains recognizable f or the purposes of the f irst element of the Policy. The Panel already here notes that the disputed domain name corresponds to the ordinary spelling of a common English dictionary term, whereas the Complainant’s trademark consists of a slightly modified spelling of that term. However, these considerations concern the nature of the term and the Respondent’s registration and use of the disputed domain name, and, hence, are more appropriately addressed under the second and third elements of the Policy rather than under the standing test f or conf using similarity. Accordingly, the Panel f inds that the disputed domain name is conf usingly similar to the Complainant’s PLUGABLE trademark for the purposes of paragraph 4(a)(i) of the Policy. WIPO Overview 3.1, section 1.7. The Panel f inds the f irst element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(a)(ii) of the Policy provides that the Complainant must establish that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Panel considers that there are substantial grounds f or f inding that the Respondent has rights or legitimate interests in respect of the disputed domain name. The Panel notes that the disputed domain name consists of the common English dictionary term “pluggable”, which the Respondent registered as the disputed domain name before the Complainant acquired any trademark rights. The record further shows that the Respondent subsequently used the disputed domain name f or a number of years in connection with a business operating under the corresponding company name. There is nothing in the record suggesting that this use by the Respondent was not bona f ide or otherwise illegitimate. The Panel f urther notes that the registration of a domain name consisting of a dictionary word or descriptive term is generally regarded as a legitimate activity under the Policy, provided that such registration is not intended to target a complainant’s trademark rights. As numerous UDRP panels have observed, the Policy does not prevent domain name registrants from registering and holding dictionary terms on a “first come, first served” basis. In this regard, the Complainant does not dispute that the disputed domain name may initially have been used by the Respondent legitimately but argues that the Respondent’s business was discontinued for many years and that the disputed domain name is currently being of f ered f or sale at a price that likely exceeds the Respondent’s o ut-of-pocket costs related to the disputed domain name. Ho wever, the Panel f inds that the mere discontinuation of a business or the subsequent offering of a domain name f or sale does not, without more, negate rights or legitimate interests that arose from an originally legitimate registration and use of a dictionary term within a domain name. Hence, the Panel considers that the Respondent has raised a credible basis for rights or legitimate interests in the disputed domain name under the Policy. Nonetheless, the Panel does not find it necessary to reach a definitive conclusion on this element, since the Complaint in any event f ails under the third element of the Policy f or the reasons set out below. C. Registered and Used in Bad Faith Under paragraph 4(a)(iii) of the Policy, the Complainant must establish that the disputed domain name was registered and is being used in bad f aith. Both requirements must be satisf ied. page 5 In the present case, the Panel f inds that the Complaint f ails because there is no basis whatsoever f or concluding that the disputed domain name was registered in bad f aith. According to the case record, the Respondent registered the disputed domain name before the Complainant acquired any trademark rights in PLUGABLE. At the time of registration, the disputed domain name consisted of an ordinary English dictionary term, and there is no evidence that the Respondent could have had the Complainant, its subsequently acquired trademark, or any corresponding rights in mind. On the contrary, the Respondent has demonstrated that it subsequently used the disputed domain name in connection with a business operating under the same dictionary name f or a number of years. The Panel f inds no evidence in the case record that the Respondent acquired the disputed domain name with the intention of targeting the Complainant or any trademark rights that did not even exist at that time. The Complainant has not even argued, and there is nothing in the record suggesting that the Respondent registered the disputed domain name in anticipation of the Complainant’s f uture PLUGABLE trademark rig hts. The Panel does not overlook the Complainant’s argument that the Respondent’s discontinuation of its business, followed many years later by the resumption of use of the disputed domain name and the of f ering f or sale, should ef f ectively be treated as the relevant point in time f or assessing bad f aith registration. The Panel is unable to accept this argument. The Policy contains no provision suggesting that a domain name registrant’s subsequent decision to resume use of a domain name, while remaining the same registrant throughout, constitutes a new registration or otherwise resets the date f or assessing bad f aith registration. The Panel is also not aware of any established UDRP consensus supporting any such argument. Instead, the relevant point in time remains the original registration (or, where applicable, a subsequent acquisition by a different registrant). Neither a period of non-use nor a later change in a way in which the domain name is used can retrospectively convert an originally good-f aith registration into a bad-f aith registration. Also, the Respondent’s decision to offer the disputed domain name for sale does not alter this conclusion. The Panel f inds that the mere of f er f or sale of the disputed domain name is not, in itself , suf f icient to establish cybersquatting or bad faith. The circumstances of the present case rather demonstrate that there is insufficient evidence to conclude that the disputed domain name was registered primarily f or the purpose of selling it to the Complainant (or any other party), rather than because of its inherent value as a dictionary term. In this regard, the Panel notes that the Policy does not prohibit the acquisition, ownership, or sale of a domain name consisting of a dictionary term as such. Particularly significant in the present case is the additional evidence produced by the Respondent showing that in 2025, about a year before commencing this administrative proceeding, the Complainant’s f ounder himself publicly acknowledged in a Reddit post that the disputed domain name had already been registered by another party and further expressed the view that the dictionary term in question was not capable of exclusive trademark protection. While these statements were made outside the present administrative proceeding, they are not consistent with the position taken by the Complainant in the present administrative proceeding, asserting the Respondent’s registration of the disputed domain name was abusive under the Policy. All in all, the Panel f inds that the Respondent neither registered nor is using the disputed domain name in bad f aith within the meaning of paragraph 4(a)(iii) of the Policy. Consequently, the Panel f inds that the third element of the Policy has not been established. page 6 D. Reverse Domain Name Hijacking Paragraph 15(e) of the Rules provides that, if af ter considering the submissions, the Panel f inds that the Complaint was brought in bad f aith, f or example in an attempt of RDNH or to harass the domain name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint is not, on its own, suf f icient to constitute RDNH. WIPO Overview 3.1, section 4.16. In the circumstances of this case, the Panel considers that the Complaint had no reasonable prospect of success and should never have been f iled. Based on the case record, the Complainant knew that the disputed domain name had been registered before the Complainant acquired any trademark rights. The Complainant was also fully aware that the disputed domain name corresponds to a common dictionary English term. Even more, the Respondent produced evidence that the Complainant itself had publicly acknowledged in 2025 in a Reddit post that the disputed domain name was already registered by another party and that the descriptive term “pluggable” itself was not capable of trademark protection, which is why the Complainant instead opted f or the dif f erent spelling PLUGABLE as its trademark. Notwithstanding these circumstances, the Complainant asked the Panel to find bad f aith registration based essentially on the Respondent’s later resumption of use of the disputed domain name and its subsequent attempt to sell the disputed domain name. However, the Policy provides no basis for treating a later conduct as creating a new registration date. The Panel also takes into account that the Complainant was represented by legal counsel throughout this administrative proceeding. The Panel considers that under these circumstances the Complainant either knew, or should have known af ter reasonable investigation, that the essential requirement of bad f aith registration could not be established on the facts of this case. Despite these circumstances, the Complainant chose to pursue this administrative proceeding. Consequently, and in line with the Respondent’s request, the Panel concludes that the Complaint was filed in bad f aith and therefore constitutes an attempt of RDNH within the meaning of paragraph 15(e) of the Rules. 7. Decision For the f oregoing reasons, the Complaint is denied. /Kaya Köklü/ Kaya Köklü Presiding Panelist /Lynda J. Zadra-Symes/ Lynda J. Zadra-Symes Panelist /Nick J. Gardner/ Nick J. Gardner Panelist Date: August 3, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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