Westmore · UDRP decision
WIPO · Case No. D2026-3769

Tmlegalzoom.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <tmlegalzoom.com> to LegalZoom.com, Inc. It found the domain confusingly similar to the LEGALZOOM mark because it reproduced the mark in its entirety, with the addition of “tm” not preventing confusing similarity. The Respondent failed to rebut the Complainant’s prima facie case regarding rights or legitimate interests, and the domain had been used for a website presenting itself as “TM Legal Zoom” and offering overlapping services. The Panel also found that the Respondent targeted the Complainant, its services, and its well-known mark to attract Internet users for commercial gain through likely confusion.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-30
Panelist(s)
Willem J. H. Leppink
Complainant
LegalZoom.com, Inc.
Respondent
Shabbir Abid
Counsel
Zacco Sweden AB
Disputed domain(s)
tmlegalzoom.com
Domain history UDRP Intelligence

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

The case illustrates how combining an established mark with a short term directly associated with the complainant’s services can reinforce a targeting inference rather than distinguish the domain. The website’s corresponding branding and overlapping trademark services linked the composition of the domain to its commercial use.

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
2026-09-30
Panel
Willem J. H. Leppink
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LegalZoom.com, Inc. v. Shabbir Abid Case No. D2026-3769 1. The Parties The Complainant is LegalZoom.com, Inc., United States of America (“United States”), represented by Zacco Sweden AB, Sweden. The Respondent is Shabbir Abid, Pakistan. 2. The Domain Name and Registrar The disputed domain name <tmlegalzoom.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 24, 2026. On August 24, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 25, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 26, 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 amendment to the Complaint on August 26, 2026. The Center verified that the Complaint together with the amendment to 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 of the Complaint, and the proceedings commenced on September 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 21, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 22, 2026. page 2 The Center appointed Willem J. H. Leppink as the sole panelist in this matter on September 24, 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 technology company founded in 2001 and headquartered in the United States. The Complainant provides a comprehensive suite of online services designed to support businesses throughout their lifecycle. These services include intellectual property services, notably trademark registration, business entity formation and registration, legal document preparation, attorney listings, electronic signature solutions, virtual mail services, tax and accounting services, compliance services, and registered agent services. In addition, the Complainant offers general legal services and informational resources aimed at helping businesses meet their operational and regulatory needs. The Complainant is listed on the Nasdaq Stock Market and is included in the S&P 600. The Complainant is the owner of various trademark registrations including the word element LEGALZOOM, including the United States registration for the combined word / device mark LEGALZOOM, with registration number 2540549, registered on February 19, 2002, for services in class 42 and the European Union trademark registration for the word mark LEGALZOOM, with registration number 011044476, registered on December 12, 2012, registered for services in class 35 and 45, as well as numerous other trademark registrations in the United States and other countries around the world. The Complainant has continuously used its LEGALZOOM Trademark and has maintained an active online presence since at least as early as 2001. The Complainant owns several domain names that incorporate its LEGALZOOM trademark and operates its official website at the domain name <legalzoom.com>. The disputed domain name was registered on July 7, 2026 and resolved at the time of filing the Complaint to a website displaying a logo including the words TM LEGAL ZOOM while purportedly offering trademark registration services. At the time of rendering this Decision the disputed domain name does not resolve to an active website. 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 the following. Since its inception, the Complainant has assisted in the formation of over five million businesses and has delivered more than 4.4 million estate planning solutions. The Complainant currently maintains approximately 1.9 million active subscriptions and reported an annual revenue of USD 756 million in 2025. As of the date of this Complaint, the Complainant employs nearly 1,200 individuals worldwide and engages approximately 700 additional contractors and consultants globally. The Complainant’s legal and trademark services include, inter alia, trademark searches, legal advice, trademark monitoring, and the preparation and filing of trademark applications. Since 2017, the Complainant has filed over 400,000 trademark applications, and its legal services division, LZ Legal Services, is currently the largest law firm filer by volume for United States-based businesses at the United States Patent and page 3 Trademark Office. These figures underscore the Complainant’s significant presence and reputation in the legal services industry, particularly in the field of trademark services. The disputed domain name is identical or confusingly similar to the LEGALZOOM trademark since it incorporates the trademark in its entirety. The addition of the term “TM” as a prefix does not prevent a finding of confusing similarity, as “TM” is a universally recognized abbreviation for “trademark”. The use of the LEGALZOOM trademark as a prefix does not create a new or distinct mark, instead, it references the very service category in which the Complainant is a major provider, thereby heightening rather than eliminating confusion. This is particularly compelling because the website to which the disputed domain name resolves is primarily devoted to trademark registration services, one of the same primary services for which the Complainant is recognized by consumers. No license, authorization, or permission of any kind has been granted by the Complainant to the Respondent to register or use the LEGALZOOM trademark as a domain name or in any other manner. Furthermore, the Complainant has found no information indicating that the Respondent trades under a company name corresponding to the disputed domain name or that the Respondent holds any other rights or legitimate interests in the name. The Respondent is not an authorized representative of the Complainant, nor has the Respondent ever had any business relationship with the Complainant. There is a considerable risk that the relevant public will perceive the disputed domain name as being owned by or affiliated with the Complainant, or that there exists some form of commercial relationship between the Respondent and the Complainant. The Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services. Instead, the Respondent has intentionally selected the disputed domain name to trade on the Complainant’s business, trademark, and reputation. The website accessible to which the disputed domain name resolves is used to generate traffic and revenue by exploiting the Complainant’s LEGALZOOM trademark. The LEGALZOOM trademark is prominently and repeatedly displayed throughout the website, which promotes a broad range of services that directly overlap and compete with those offered by the Complainant, including trademark registration, trademark searches, and trademark renewal, among others. The Respondent is actively attempting to create the false impression that the disputed domain name and the associated website are connected to or operated by the Complainant. This is further supported by the fact that the website contains no genuine information about the Respondent, nor does it feature any disclaimer accurately and prominently disclosing the Respondent’s lack of affiliation with the Complainant. On the contrary, the information provided on the website appears to be false or, at a minimum, misleading. Moreover, the registrant information does not correspond with the information which is displayed on the website to which the disputed domain name resolves forming an additional circumstance indicating a lack of legitimate interest on part of the Respondent. Given the confusing similarity between the disputed domain name and the LEGALZOOM trademark and the widespread recognition of the LEGALZOOM trademark and its associated services, it is evident that the Respondent was fully aware of the Complainant and its rights at the time of registration. It is equally clear that it was the Complainant’s business, in particular its legal and trademark services, and the LEGALZOOM trademark that motivated the Respondent to register and use the disputed domain name. Accordingly, the Respondent cannot credibly claim to have been using the trademark without knowledge of the Complainant’s rights. The Complainant can only presume that the Respondent’s purpose with the website to which the disputed domain name resolved, is to intentionally create the false impression that the disputed domain name and Website are affiliated with or operated by the Complainant, for either commercial, illicit or fraudulent purposes. page 4 Finally, on August 12, 2026, the Complainant sent a cease-and-desist letter to the Respondent. As of the date of filing of this Complaint, the Complainant has not received any response to its letter. It therefore appears that the Respondent was made aware of the Complainant’s concerns regarding the registration and use of the disputed domain name, yet has chosen to ignore, or at the very least failed to respond to, the Complainant’s attempts to resolve the matter. 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 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. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced 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. Although the addition of the term “tm” may bear on assessment of the second and third elements, the Panel finds the addition of such 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 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 record indicates that the Respondent used the disputed domain name for a website presenting itself as ‘TM Legal Zoom’ and offering services overlapping with those of the Complainant. Panels have held that the use of a domain name for illegal activity here, claimed passing off, impersonation 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 refers to its considerations under 6.A and 6.B. 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 was clearly targeting the Complainant, its services and its well-known mark and thus intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. Moreover, panels have held that the use of a domain name for illegal activity here, claimed passing off or impersonation constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name 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 name <tmlegalzoom.com> be transferred to the Complainant. /Willem J. H. Leppink/ Willem J. H. Leppink Sole Panelist Date: September 30, 2026

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

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