LEGO Holding A/S v Sonia Wignall, Perfect Privacy, LLC
WIPO Case No. D2025-3245
•06-10-2025
ARBITRATION
AND
| MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
LEGO Holding A/S v. Sonia Wignall, Perfect Privacy, LLC
Case No. D2025-3245
1. The Parties
The Complainant is LEGO Holding A/S, Denmark, represented by CSC Digital Brand Services Group AB,
Sweden.
The Respondent is Sonia Wignall, United States of America (“United States”).
2. The Domain Names and Registrar
The disputed domain names <learnlegorobotics.com>, <learnlegorobotics.net>, <learnlegorobotics.online>,
<learnlegorobotics.org>, <learnlegorobotics.site>, <legoroboticsclasses.com>, <legoroboticsclasses.net>,
<legoroboticsclasses.online>, <legoroboticsclasses.org>, <legoroboticsclasses.site>,
<legoroboticsforkids.com>, <legoroboticsforkids.net>, <legoroboticsforkids.org>, <legoroboticsforkids.site>,
<legorobotics.net>, <legorobotics.online>, <legoroboticsprograms.com>, <legoroboticsprograms.net>,
<legoroboticsprograms.online>, <legoroboticsprograms.org>, and <legoroboticsprograms.site> are
registered with Network Solutions, LLC (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 13, 2025. connection with the disputed domain names. On August 14, 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.
The Center verified that 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 August 22, 2025. In accordance with the Rules,
paragraph 5, the due date for Response was September 11, 2025. The Respondent did not submit any
response. Accordingly, the Center notified the Respondent’s default on September 15, 2025.
page 2
The Center appointed Rodrigo Azevedo as the sole panelist in this matter on September 22, 2025. the Rules, paragraph 7.
The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and
4. Factual Background
The Complainant is a Danish company that owns the LEGO brand of construction toys.
The Complainant has expanded its use of the LEGO trademark to products such as computer hardware and software, books, videos and computer controlled robotic construction sets.
The Complainant has subsidiaries and branches throughout the world. LEGO products are sold in more than
130 countries, including in the United States.
The Complainant owns several LEGO trademark registrations in multiple jurisdictions, including the United
States registration No. 4395578, filed on January 17, 2013, and registered on September 3, 2013.
The Complainant is also the owner of numerous domain names containing the term “lego”, including its principal domain name <lego.com>, registered since August 22, 1995.
The Respondent registered the disputed domain names on December 18, 2024.
The Complainant brought evidence that all disputed domain names but one resolved to pay-per-click advertisement sites at time of filing of the Complaint. The disputed domain name <legorobotics.net> resolved to a website under construction.
The Panel accessed the disputed domain names on October 2, 2025, the majority of which did not resolve to
any active websites including a website under construction regarding the disputed domain name
<legorobotics.net>, the remaining disputed domain names <learnlegorobotics.com>,
<learnlegorobotics.org>, <legoroboticsclasses.com>, <legoroboticsclasses.net>, <legoroboticsclasses.org>,
<legoroboticsforkids.com>, <legoroboticsprograms.com>, <legoroboticsprograms.net>, and
<legoroboticsprograms.org> were connected to pay-per-click parking pages.
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 contends that:
(i) The disputed domain names are identical or confusingly similar to the Complainant’s trademark.
The dominant part of the disputed domain names comprises the term “lego”, identical to the registered
trademark LEGO, registered by the Complainant as trademarks and domain names in numerous jurisdictions
all over the world. The addition of the terms “learn” and/or “robotics”, “robotics classes”, “robotics for kids”,
“robotics programs”, does not prevent a finding of confusing similarity when paired up with the well-known
LEGO trademark. The addition of the Top-Level Domains (“TLD”s) “.com”, “.net”, “.online”, “.org”, and “.site”
does not have any impact on the overall impression of the dominant portion of the disputed domain names
and is also irrelevant to determine the confusing similarity between the trademark and the disputed domain
names. By using the LEGO trademark as the dominant part of the disputed domain names, the Respondent
exploits the goodwill and the image of the trademark, which may result in dilution and other damage for
the Complainant’s trademark.
page 3
(ii) The Respondent has no rights or legitimate interests in the disputed domain names. The Complainant disputed domain name, which evinces a lack of rights or legitimate interests, as confirmed by numerous past panels. The remaining disputed domain names redirect Internet users to websites featuring links to third- party websites. Prior UDRP decisions have consistently held that respondents that monetize domain names using pay-per-click links have not made a bona fide offering of goods or services that would give rise to rights or legitimate interests in the disputed domain names.
has not licensed or otherwise authorized the Respondent to use the LEGO mark. There is no indication that
the Respondent is commonly known by any of the disputed domain names, nor is there evidence of any
bona fide offering of goods or services or legitimate noncommercial use. On the contrary, it is clear that
the Respondent was aware of the Complainant’s legal rights in the name LEGO at the time of
the registrations of the disputed domain names and it is rather obvious that it is the fame of the trademark
that has motivated the Respondent to register the disputed domain names. One of the disputed domain
names (<legorobotics.net>) redirects Internet users to a website that is under construction and lacks content.
| LEGO has the status of a well-known and reputable trademark with a substantial and widespread goodwill | (iii) The disputed domain names were registered and are being used in bad faith. The Complainant’s brand plausible explanation for doing so may be, in and of itself, an indication of bad faith. | |||||
| B. Respondent | ||||||
| The Respondent did not reply to the Complainant’s contentions. However, the Respondent replied to the Complainant’s cease and desist letter prior to the proceeding, indicating that her “intent was not to falsely use the LEGO name for commercial services”, “[we are an organization that teaches LEGO Robotics and have worked with over 1000 students over the past years teaching LEGO Robotics. LEGO Robotics is the flagship program that we offer as part of our STEM initiatives”, and she does not “know how the referenced domain name(s) are available for sale if they are not authorized to be used by the general public.”. The Complainant replied to the Respondent’s email and sent several reminders. The Respondent did not reply to the Complainant’s follow-up emails. | ||||||
| 6. Discussion and Findings | ||||||
| Paragraph 4(a) of the Policy provides that in order to be entitled to a transfer of the disputed domain names, the Complainant shall prove the following three elements: | ||||||
|
page 4
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 names. WIPO Overview of WIPO Panel
Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7.
Annex 3 to the Complaint shows numerous trademark registrations for LEGO. Based on the available record, the Panel finds 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 disputed domain names incorporate the Complainant’s trademark LEGO, with the addition of the terms
“learn”, “robotics”, “classes”, “for kids” and/or “programs”. Although the addition of terms 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 names and the mark for the purposes of
the Policy. WIPO Overview 3.0, section 1.8.
It is also well established that the addition of TLDs, such as “.com”, “.net”, “.online”, “.org”, and “.site”, is typically disregarded when determining whether a domain name is confusingly similar to a complainant’s trademark as such is viewed as a standard registration requirement. WIPO Overview 3.0, section 1.11.1.
Therefore, the Panel finds the disputed domain names are confusingly similar to the Complainant’s trademark and that 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. 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.
The Panel finds no evidence showing that the Respondent is commonly known by the disputed domain names.
The Complainant has asserted that the Respondent is not an authorized representative, nor has obtained any permission to use the trademark LEGO and to register the disputed domain names. The Respondent claimed to offer LEGO Robotics program as part of their STEM initiatives in her reply to the Complainant’s cease and desist letter. However, the Panel notes that except for the disputed domain name
<legorobotics.net> resolving to a website under construction, at the time of filing of the Complaint,
the remaining 20 disputed domain names resolved to pay-per-click websites. Such use of the disputed
domain names does not constitute a bona fide of offering of goods or services nor a legitimate
noncommercial or fair use.
page 5
Further, the Panel finds that the nature of the disputed domain names comprising the Complainant’s well- known trademark with the addition of terms related to the Complainant’s products (“robotics”, “for kids”) or with possible lessons (“learn”, “classes”, “programs”), forming the expressions “learnlegorobotics”,
“legoroboticsclasses”, “legoroboticsforkids”, “legorobotics” and “legoroboticsprograms”, indicates an
awareness of the Complainant and its trademark and intent to take unfair advantage of such, which does not
support a finding of any rights or legitimate interests. The nature of the disputed domain names also carries
a risk of implied affiliation as if it effectively impersonates or suggests sponsorship or endorsement by
the Complainant. WIPO Overview 3.0, section 2.5.1.
Based on the available record, 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.
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 3.0, section 3.2.1.
The disputed domain names include the trademark LEGO in its entirety. According to the WIPO Overview 3.0, section 3.1.4, UDRP panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith.
Also, when the disputed domain names were registered in 2024, the LEGO trademark was already notorious and directly connected with the Complainant’s toys and additional products and services worldwide. In addition, the Respondent claimed that “LEGO Robotics is the flagship program that we offer as part of our STEM initiatives”.
Therefore, the Panel concludes that the Respondent was aware of the Complainant’s trademark and that
the registration of the disputed domain names was not a mere coincidence. Actually, the choice of words to
compose the disputed domain names (“learn”, “robotics”, “classes”, “for kids” and “programs”) also shows
that the Respondent most likely knew of the Complainant. The use of 20 out of 21 disputed domain names
to host pay-per-click advertisement schemes demonstrates, more likely than not, the intent of
the Respondent for intentionally attempting to attract, for commercial gain, Internet users to her own
websites by creating a likelihood of confusion with the Complainant’s trademark as to the source, affiliation,
or endorsement of the Respondent’s websites, for commercial gain.
The disputed domain name <legorobotics.net> has never been actively used. At the time of the Decision, some of the other disputed domain names do not resolve to any active websites either. However, UDRP panels have frequently found that the apparent lack of so-called active use of the domain name (passive holding) does not prevent a finding of bad faith. See WIPO Overview 3.0, section 3.3; Telstra Corporation
Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003; and Polaroid Corporation v. Jay Strommen,
WIPO Case No. D2005-1005. The non-collaborative posture of the Respondent during the proceeding, i.e.,
(a) not indicating any intention to use the disputed domain name, and (b) not at least providing justifications
for the use of a famous trademark, when being notified of the Complaint during the present proceeding,
certainly cannot be used in benefit of the Respondent in this Panel’s opinion, which circumstances, together
with (c) the fame of the Complainant’s trademark, and (d) the lack of any plausible justification for
the adoption of the terms “learnlegorobotics”, “legoroboticsclasses”, “legoroboticsforkids”, “legorobotics”, and
“legoroboticsprograms” closely related to the Complainant and its well-known trademark, are enough in this
Panel’s view to characterize bad faith registration and use in the present case.
Consequently, having reviewed the record, the Panel finds the registration and use of the disputed domain names constitute bad faith under the Policy.
page 6
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 <learnlegorobotics.com>, <learnlegorobotics.net>,
<learnlegorobotics.online>, <learnlegorobotics.org>, <learnlegorobotics.site>, <legoroboticsclasses.com>,
<legoroboticsclasses.net>, <legoroboticsclasses.online>, <legoroboticsclasses.org>,
<legoroboticsclasses.site>, <legoroboticsforkids.com>, <legoroboticsforkids.net>, <legoroboticsforkids.org>,
<legoroboticsforkids.site>, <legorobotics.net>, <legorobotics.online>, <legoroboticsprograms.com>,
<legoroboticsprograms.net>, <legoroboticsprograms.online>, <legoroboticsprograms.org>, and
<legoroboticsprograms.site> be transferred to the Complainant.
/Rodrigo Azevedo/
Rodrigo Azevedo
Sole Panelist
Date: October 6, 2025
0
0
0