The Complainant is LEGO Juris A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden.
The Respondents are Domain Administrator, See PrivacyGuardian.org, United States of America (“United States” or “US”), Sara Rhoades, United States, John Munoz, United States, Black Anna, United States, David Sisk, United States, Todd J Sumrall, United States, Hlwa Jennifer, United States, Amanda Lane, United States, Sandra James, United States, Wayne K Wilson, United States, Theresa W Chavez, United States, Rebecca Steele, United States, Andrew Doyle, United States, Judy Lay, United States, Barbara Smith, United States, Theresa Chavez, United States, Pat Weaver, United States, Christopher Morrison, United States, Asa Uribe, United States, Henry Johnson, United States, Timmy Rodriguez, United States, Todd Sumrall, United States, Tiffany Freund, United States, Fred Miles, United States, Samuel Vaughan, United States, Harvey Wells, United States, Joseph Dale, United States, Name Redacted , Joshua Pate, United States, Tina Clark, United States, Judith R Woodard, United States, Giriykei, BB BBC, United States, Tammy Price, United States, Arlene Mora, United States, jingui, Josie Porter, United States, Terry Dunlap, United States, Randy Tardiff, United States, Jesse Smith, United States, Fredrick Gadson, United States, William Daniels, United States, adsfd Sokolowski, United States, dreamhhome.tdl, Mark Funk, United States, Lucienne Labrador, United States, Charlotte Murray, United States, Carolyn Short, United States, Antonia Gasparotto, United States, Roger Vance, United States, Susan Peterson, United States, Margaret Bradley, United States, Howard Diaz, United States, Nancy Hunsaker, United States, Mary C Hobbs, United States, Francesco B Campbell, United States, Adrienne K McNear, United States, Wayne Rieley, United States, Eugene Preston, United States, Nichole Hutsell, United States, Mary Dejesus, United States, Bruce M Martinez, United States, Michelle Verduzco, United States, Lynn Morris, United States, Cheryl Marshall, United States, Lance J Hernandez, United States, Lyman Katie, United States, Candie Deloach, United States, jacy fone, United States, Elva W Rose, United States. 2. The Domain Names and Registrar
The disputed domain names The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 7, 2020. On December 7, 2020, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On December 7, 2020, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Names which differed from the named Respondent and contact information in the Complaint. On December 8 and December 11, 2021, the Complainant submitted amended Complaints adding 6 domain names to the Complaint. On December 27, 2020, the Center transmitted by email to the Registrar a request for registrar verification in connection with the additional Domain Names. On December 28, 2020, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the additional Domain Names which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on January 2, 2021 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 January 7, 2021. The Center verified that the Complaint together with the amended Complaints 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 February 12, 2021. In accordance with the Rules, paragraph 5, the due date for Response was March 4, 2021. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 5, 2021. On March 12, 2021, a third party contacted the Center regarding the claimed unauthorized use of its identity in relation to the Domain Names The Center appointed Karen Fong as the sole panelist in this matter on March 12, 2021. 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 the owner of the trade mark LEGO which is famous for its construction toys. The Complainant has subsidiaries, branches, and licensees throughout the world, and LEGO products are sold in more than 130 countries including China and the United States. The Complainant’s LEGO brand is one of the best known trade marks in the world. In 2014, Time Magazine voted LEGO as the Most Influential Toy of All Time. In 2019, it was recognized by Superbrands UK as the number 1 Consumer Superbrand and number 8 in the Consumer Relevancy Index. The Complainant has an extensive global trade mark portfolio for the LEGO trade mark (the “Trade Mark”). The earliest trade mark submitted in evidence, US Trade Mark Registration No. 1018875, was registered on August 26, 1975. The Complainant also owns the figurative trade mark HOUSE HOME OF THE BRICK, European Union Trade Mark registration No. 015893357, registered on January 31, 2017. The Complainant’s group of companies has expanded its use of the LEGO trade mark to other areas including computer hardware and software, books, videos, and computer controlled robotic construction sets. The Complainant is the owner of close to 5,000 domain names containing the mark LEGO. Its main website is located at the domain name The Complaint involves 79 Domain Names which are registered to multiple Respondents as detailed below: No Domain Names Registrant Date of Registration 1 Sara Rhoades (US) November 11, 2020 2 John Munoz (US) November 10, 2020 3 Black Anna (US) November 11, 2020 4 Black Anna (US) November 11, 2020 5 David Sisk (US) November 11, 2020 6 Todd J Sumrall (US) November 8, 2020 7 Hlwa Jennifer (US) November 11, 2020 8 Hlwa Jennifer (US) November 11, 2020 9 Amanda Lane (US) November 10, 2020 10 Sandra James (US) September 17, 2020 11. Wayne K Wilson (US) November 9, 2020 12 Theresa W Chavez (US) November 8, 2020 13 Rebecca Steele (US) September 17, 2020 14 Theresa W Chavez (US) November 8, 2020 15 Andrew Doyle (US) September 4, 2020 16 Theresa Chavez (US) September 4, 2020 17 Judy Lay (US) September 4, 2020 18 Pat Weaver (US) September 4, 2020 19 Barbara Smith (US) September 4, 2020 20 Christopher Morrison (US) September 14, 2020 21 Asa Uribe (US) September 4, 2020 22 Asa Uribe (US) September 4, 2020 23 Henry Johnson (US) September 7, 2020 24 Timmy Rodriguez (US) September 4, 2020 25 Todd Sumrall (US) September 4, 2020 26 Fred Miles (US) September 4, 2020 27 Tiffany Freund (US) September 4, 2020 28 jacy fone (US) September 11, 2020 29 Samuel Vaughan (US) November 11, 2020 30 Harvey Wells (US) September 4, 2020 31 Lyman Katie (US) November 23, 2020 32 Joseph Dale (US) October 9, 2020 33 Name Redacted November 11, 2020 34 Name Redacted November 11, 2020 35 Joshua Pate (US) November 10, 2020 36 Tina Clark (US) November 11, 2020 37 Giriykei (US) September 23, 2020 38 Judith R Woodard (US) September 3, 2020 39 Theresa Chavez (US) September 4, 2020 40 Tammy Price (US) September 18, 2020 41 Theresa Chavez (US) September 4, 2020 42 Arlene Mora (US) October 22, 2020 43 Jingui (US) November 26, 2020 44 Jingui (US) November 26, 2020 45 Jingui (US) November 26, 2020 46 Jingui (US) November 26, 2020 47 Terry Dunlap (US) September 4, 2020 48 Randy Tardiff (US) September 18, 2020 49 Theresa W Chavez (US) November 6, 2020 50 Jesse Smith (US) September 4, 2020 51 Frerick Gadson (US) October 26, 2020 52 William Daniels (US) November 8, 2020 53 Theresa W Chavez (US) November 6, 2020 54 William Daniels (US) November 9, 2020 55 Adsfd Sokolwski (US) November 7, 2020 56 Dreamhhome.tdl (US) July 15, 2020 57 Domain Administrator, See PrivacyGuardian.org (US) October 9, 2020 58 Lucienne Labrador (US) September 15, 2020 59 Charlotte Murray (US) November 10, 2020 60 Carolyn Short (US) September 17, 2020 61 Antonia Gasparotto (US) November 10, 2020 62 Roger Vance (US) November 10, 2020 63 Susan Peterson (US) November 10, 2020 64 Margaret Bradley (US) September 17, 2020 65 Howard Diaz (US) September 17, 2020 66 Candice Deloach (US) November 15, 2020 67 Nancy Hunsaker (US) November 10, 2020 68 Mary C Hobbs (US) November 8, 2020 69 Francesco B Campbell (US) September 3, 2020 70 Adrienne K McNear (US) November 4, 2020 71 Wayne Rieley (US) November 10, 2020 72 Eugene Preston (US) November 9, 2020 73 Mary Dejesus (US) October 28, 2020 74 Nichole Hutsell (US) November 9, 2020 75 Bruce m Martinez (US) November 9, 2020 76 Michelle Verduzco (US) November 7, 2020 77 Lynn Morris (US) November 11, 2020 78 Cheryl Marshall (US) November 8, 2020 79 Lance J Hernandez (US) November 8, 2020 71 of the Domain Names used to resolve to websites titled “LEGO House Home of Bricks” which closely resembled the Complainant’s website and prominently displayed the Complainant’s trade marks (Domain Names 2-17, 20-36, 39-42, 44-68, 70-77 and 79). Domain Names 1, 18, 19, 37, 38, 43, 69 and 78 were inactive. The Complainant sent cease and desist letters to the registrants but did not receive any response. At the time of the filing of the Complaint, all the Domain Names were inactive. 5. Parties’ Contentions A. Complainant The Complainant contends that the Domain Names are identical or confusingly similar to the Trade Mark, the Respondents have no rights or legitimate interests with respect to the Domain Names, and that the Domain Names were registered and are being used in bad faith. The Complainant requests transfer of the Domain Names, all of which it believes are related and under management and common control of a single entity or network. The basis of its belief that the registrants are related and under management and common control of a single network are as follows: 1. All 79 Domain names are registered with the Registrar and 78 use Cloudfare as its host, a pass through network. The only one that does not is Domain Name 43. 2. Domain Name 43 has the same registrant as Domain Names 44, 45 and 46. 3. 71 of the Domain Names used to resolve to websites which mimicked the Complainant’s website. 4. These websites all featured the same contact information at the top right hand corner of each home page. 5. The remaining 8 Domain Names resolved to inactive websites but have string similarities with the other Domain Names which did display content. 6. All 79 Domain Names were registered by individuals located in the United States, 48 of whom use Outlook email addresses, which are seemingly auto generated addresses, while 31 of them use either Gmail, Hotmail or GMX email addresses. 7. 77 of the 79 Domain Names are within the same IP address ranges. B. Respondent The Respondent did not reply to the Complainant’s contentions. However, the Center received an email from a third party regarding the Domain Names 33 and 34 on March 12, 2021 denying any involvement in the registration of the Domain Names. The third party alleged identity theft after trying to buy some LEGO toys from “www.legotoys.com”. 6. Discussion and Findings 6.1 Consolidation of Proceedings The Complainant has filed a single complaint in relation to 79 Domain Names against multiple respondents. In relation to the position of a complaint being filed against multiple respondents, section 4.11.2 of WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) provides that in such cases, panels look at whether (i) the domain names or corresponding websites are subject to common control, and (ii) the consolidation would be fair and equitable to all parties. Procedural efficiency would also underpin panel consideration of such a consolidation scenario. UDRP panels have considered a range of factors, typically present in some combination, as useful to determining whether such consolidation is appropriate, such as similarities in or relevant aspects of (i) the registrants’ identity(ies) including pseudonyms, (ii) the registrants’ contact information including email address(es), postal address(es), or phone number(s), including any pattern of irregularities, (iii) relevant IP addresses, name servers, or webhost(s), (iv) the content or layout of websites corresponding to the disputed domain names, (v) the nature of the marks at issue (e.g., where a registrant targets a specific sector), (vi) any naming patterns in the disputed domain names (e.g.,