ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LEGO Holding A/S v. Il?ya Kazantsev, Private person Case No. D2025-1591 1. The Parties The Complainant is LEGO Holding A/S, Denmark, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Il?ya Kazantsev, Private person, Russian Federation, self-represented. 2. The Domain Names and Registrar The disputed domain names , , and are registered with Regtime Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on April 18, 2025. On April 22, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On April 29, 2025, 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 April 30, 2025, the Center disclosed the registrant information to the Complainant for its information, and informed the Parties in Russian and English, that the language of the Registration Agreement for the disputed domain names is Russian. On May 1, 2025, the Complainant requested English to be the language of the proceeding by submitting an amended Complaint. The Respondent did not submit any comment on the Complainant’s submission. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in Russian and English of the Complaint, and the proceedings commenced on May 6, 2025. In accordance with the Rules, paragraph 5, the due date for Response was May 26, 2025. The Respondent sent two email
page 2 communications in Russian to the Center on May 8, 2025, express his willingness to transfer the disputed domain name with reimbursement of the registration costs. On May 9, 2025, the Center sent the possible settlement email. On May 19, 2025, the Complainant confirmed that it would not suspend the proceeding. On May 27, 2025, the Center confirmed that it would proceed with panel appointment. The Center appointed Alissia Shchichka as the sole panelist in this matter on June 2, 2025. 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 Danish company engaged in the production and sale of construction toys and related products. The Complainant’s LEGO and LEGOLAND trademarks have been promoted internationally over several decades. These trademarks have also been used in connection with products and services beyond toys, including digital offerings, media, and theme parks. In recent years, the LEGO brand has received recognition in consumer and corporate reputation rankings. The Complainant has evidenced to be the registered owner of numerous trademarks worldwide relating to its trademarks LEGO and LEGOLAND including, but not limited, to the following - International Trademark Registration No. 287932, registered on August 27, 1964, for the word mark LEGO, in class 28 - Russian Federation Trademark registration No. 42932, registered on December 10, 1971, for the word mark LEGO, in class 28. - International Trademark Registration No. 397858, registered on March 30, 1973, for the word mark LEGOLAND, in classes 9 and 28. The Complainant also owns more than 6,000 domain names containing LEGO and LEGOLAND trademarks, including and , which serve as official websites for its products and services. The aforementioned trademarks and domain names were registered decades prior to the registration of the disputed domain names (registered on February 16, 2025), (registered on February 19, 2025), and (registered on February 1, 2025). According to the evidence provided by the Complainant, the disputed domain names previously resolved to websites that reproduced the Complainant’s LEGO and LEGOLAND trademarks and displayed copyrighted images owned by the Complainant. These websites appeared to offer LEGO products at discounted prices. The disputed domain names are currently inactive. According to the disclosed WhoIs information confirmed by the Registrar, the Respondent is located in the Russian Federation. 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 asserts that the LEGO and LEGOLAND trademarks have achieved global recognition and are well-known trademarks.
page 3 According to the Complainant, the disputed domain names are confusingly similar to the Complainant’s trademarks LEGO and LEGOLAND, as they incorporate the Complainant’s trademarks in their entirety. The addition of the suffixes “ltd,” “ia ltd,” and “hub limited” to the Complainant’s trademarks does not prevent a finding of confusing similarity, nor does it alter the overall impression that the disputed domain names are associated with the Complainant. This impression is further reinforced by the Respondent’s prior use of the disputed domain names, during which it impersonated the Complainant. The Complainant also notes that the Top-Level Domain (TLD) “.net”, should be disregarded under the first element, as it is a standard registration requirement and does not affect the analysis of confusing similarity. Furthermore, the Complainant asserts that the Respondent lacks rights or legitimate interests in the disputed domain names for the following reasons: First, the Respondent is not affiliated with, licensed by, or otherwise authorized the Complainant to use the LEGO and LEGOLAND trademarks in connection with the disputed domain names. Second, the Respondent is not commonly known by the disputed domain names, does not hold any registered trademarks or trade names corresponding to them, and has no legitimate rights to them under the common law. Third, the Respondent has not used, nor demonstrated any preparations to use the disputed domain names in connection with a bona fide offering of goods or services. On the contrary, the disputed domain names previously resolved to websites that reproduced the Complainant’s trademarks, displayed copyrighted images, and falsely claimed to offer “officially licensed LEGO products” at discounted prices, thereby impersonating the Complainant. Finally, these websites lacked any disclaimer of affiliation and instead included statements implying endorsement by the Complainant. The Respondent therefore fails to satisfy the criteria of fair use as established by “Oki Data test”. The Complainant further contends that the Respondent has registered and used the disputed domain names in bad faith. First, the Complainant’s well-known LEGO and LEGOLAND trademarks significantly predate the registration of the disputed domain names. Second, the Respondent’s use of the disputed domain names, which featured the Complainant’s LEGO and LEGOLAND trademarks, in connection with unauthorized commercial websites offering the Complainant’s products and displaying the Complainant’s logo, shows that the Respondent clearly knew of and intentionally targeted the Complainant’s prior registered and well-known trademarks at the time of registration. Third, such use was intended to attract Internet users to the websites for commercial gain, by creating a likelihood of confusion with the Complainant’s trademarks as to the source, sponsorship, affiliation or endorsement of the websites. Fourth, the incorporation of well-known trademarks into the disputed domain names by an unaffiliated entity can, by itself, create a presumption of bad faith. Finally, the currently inactive status of both disputed domain names does not prevent a finding of bad faith under the doctrine of passive holding. The Complainant requests that the disputed domain names be transferred to the Complainant.
page 4 B. Respondent The Respondent sent several communications to the Center and the Complainant, in which he proposed to transfer the disputed domain names to the Complainant, subject to reimbursement of the registration costs, as the disputed domain names were used for an educational project - not for any commercial purpose or actual sales, and the website content was immediately removed after approval from a mentor. The Parties did not reach an agreement, and the administrative proceeding continued. 6. Discussion and Findings 6.1. Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Russian. 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. Firstly, the Complainant is not able to communicate in Russian. Requiring a translation of the Complaint and accompanying evidence would impose an undue burden on the Complainant, both financially and procedurally, and would cause unnecessary delay in the resolution of this matter. Secondly, given the abusive nature of the disputed domain names and websites, any additional delay poses a continuing risk to the Complainant and unsuspecting consumers seeking its products. Furthermore, the disputed domain names are composed entirely of Latin characters. Lastly, the websites associated with the disputed domain names contained English-language phrases, including “LEGO Multiverse LTD,” “LEGO PRICE DROPS,” and “Your Ultimate Destination for LEGO Sets,” indicating that the Respondent is capable of understanding and using English in a commercial context. 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. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1. In addition, the Center has communicated with the Respondent in both English and Russian and invited the Respondent to comment on the language of the proceeding. The Respondent has not submitted any response or objection to the Complainant’s request that the proceeding be conducted in English, despite the informal email communications in Russian. The Panel is proficient in both English and Russian, capable of reviewing all the documents and materials in both languages and giving full consideration to the Parties’ respective arguments. 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 Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith.
page 5 The Respondent’s default to provide any substantive response in the case at hand does not automatically result in a decision in favor of the Complainant, however, paragraph 5(f) of the Rules provides that if the Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel may draw such inferences from the Respondent’s failure to submit a substantive response as it considers appropriate. 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 3.0, section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the LEGO and/or LEGOLAND marks is reproduced within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the marks for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms, here “ltd”, “ia ltd” and “hub limited” 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 name and the mark for the purposes of the Policy. WIPO Overview 3.0, 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 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 3.0, 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 names. Indeed, the Complainant has confirmed that the Respondent is neither affiliated with, nor otherwise authorized or licensed by the Complainant to use the LEGO and LEGOLAND trademarks, nor to seek registration of any domain name incorporating these trademarks. Furthermore, there is no evidence that the Respondent is commonly known by the disputed domain names. WIPO Overview 3.0, section 2.3. The Panel notes that the Respondent alleged in its communication that the disputed domain names “were used for an educational project - not for any commercial purpose or actual sales, and the website content was immediately removed after approval from a mentor.” However, this assertion is clearly contradicted by the evidence submitted by the Complainant. As demonstrated in the supporting materials, the disputed
page 6 domain names previously resolved to commercial websites purporting to be official LEGO webshops, featuring sections such as “AVAILABLE TO PRE-ORDER NOW! LEGO Ferrari SF-24”, “SHOP ALL LEGO PRICE DROPS”, “NEW ARRIVALS”, and “TOP OFFERS”. These elements clearly indicate commercial intent and contradict any claim of noncommercial use. Therefore, based on the available record, the Panel finds that the Respondent is not making a legitimate noncommercial or fair use of the disputed domain names, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. WIPO Overview 3.0, section 2.4. Moreover, the websites associated with the disputed domain names clearly impersonated the Complainant by reproducing its registered LEGO trademarks and copyrighted content, while purporting to sell the Complainant’s products- at discounted prices. The websites gave the false impression of being official LEGO-branded platforms, thereby misleading consumers. Specifically, the websites displayed prominent declarations such as: “LEGO Land Ltd - Your Ultimate Destination for LEGO Sets” and “Welcome to LEGO Land Ltd, your go-to store for an incredible selection of LEGO® sets for kids, adults, and everyone in between!”. The website further included a description of the LEGO brand, falsely suggesting endorsement or official status. Previous panels have consistently held that use of a domain name for illegal activities, such as impersonation or passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. Panels have also found that such use does not constitute a bona fide offering of goods or services, but rather unfairly exploits the reputation and goodwill associated with the Complainant’s trademarks. Accordingly, the Complainant has provided evidence supporting its prima facie claim that the Respondent lacks any rights or legitimate interests in the disputed domain names. 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 names such as those enumerated in the Policy or otherwise. Therefore, the Panel concludes that the Respondent does not have any rights or legitimate interests in the disputed domain names and the Complainant has met its burden under paragraph 4(a)(ii) of the Policy. 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 observes that the Complainant’s trademarks significantly predate the Respondent’s registration of the disputed domain names. Additionally, the incorporation of the Complainant’s trademarks in the disputed domain names, along with the prior use of the Complainant’s trademarks and logo on the websites associated with the disputed domain names, demonstrates that the Respondent was clearly aware of the Complainant’s business and trademarks at the time of registering the disputed domain names. WIPO Overview 3.0, section 3.2.2. Further, the mere registration of the disputed domain names that are confusingly similar to the Complainant’s well-known trademarks by the Respondent, who is unaffiliated with the Complainant, can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4. The Panel further notes that the previous use of the websites impersonated the Complainant, displaying its trademarks and copyrighted content while purporting to offer its products at discounted prices. Panels have consistently held that the use of a domain name for illegitimate activity, such as impersonation or passing off, constitutes bad faith. WIPO Overview 3.0, section 3.4.
page 7 In the Panel’s view, the Respondent has intentionally attempted to attract Internet users to its websites, for commercial gain, by creating a likelihood of confusion with the Complainant’s trademarks regarding the source, sponsorship, affiliation, or endorsement of its websites or the products offered on it. Under paragraph 4(b)(iv) of the Policy, this constitutes evidence of registration and use of a domain name in bad faith. WIPO Overview 3.0, section 3.1.4. Although the disputed domain names are no longer in active use, noting the circumstances of the case, the Panel finds that the current non-use of the disputed domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Based on the available record, 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 , , and be transferred to the Complainant. /Alissia Shchichka/ Alissia Shchichka Sole Panelist Date: June 16, 2025
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