LinkedIn Corporation v Ludjon Roshi

WIPO Case No. DIO2025-0026

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

LinkedIn Corporation v. Ludjon Roshi

Case No. DIO2025-0026

1. The Parties

The Complainant is LinkedIn Corporation, United States of America (“United States”), represented by The

GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States.

The Respondent is Ludjon Roshi, Albania.

2. The Domain Name and Registrar

The disputed domain name <zipgame.io> is registered with NameCheap, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 15, 2025. On connection with the disputed domain name. On July 16, 2025, 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 (REDACTED, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 17, 2025, 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 July 21, 2025.

The Center verified that the Complaint together with the amendment to the Complaint satisfied the formal requirements of the .IO Domain Name Dispute Resolution Policy (the “Policy”), the Rules for .IO Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for .IO 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 July 22, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 11, 2025. The Respondent sent informal email communications to the Center on August 8 and 12, 2025. On August 8 and 12, 2025, the Center informed the Parties that if they wish to explore settlement options, the Complainant should submit a request for suspension of the proceeding. On August 22, 2025, the Complainant informed the Center that it did not intend to request a suspension of the proceedings. The Center informed the Parties of the commencement of the panel

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appointment process on August 22, 2025.

The Center appointed Assen Alexiev as the sole panelist in this matter on August 27, 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 was founded in 2003. It is one of the world’s largest professional networks on the Internet with more than one billion members in more than 200 countries and regions, including executives from every Fortune 500 company. The Complainant has 18,400 full-time employees in 38 offices around the world and operates websites in 36 languages. Its official website is located at the domain name <linkedin.com>,

registered on November 2, 2002.

The Complainant offers a number of games on its website, including a game called “Zip”, a visual logic game
where you need to plot a path through the grid while passing through each number in order. The Zip game
was announced by the Complainant on March 18, 2025. It is available at “

and its LinkedIn page has 15 million followers.

The Complainant is the owner of the following trademark registrations for ZIP (the “ZIP trademark”):

- the International trademark ZIP with registration No. 1872750, registered on April 3, 2025 for goods and

services in International Classes 9, 41 and 42, with priority as of February 27, 2025; and

- the United Kingdom trademark ZIP with registration No. UK00004182938, registered on June 27, 2025, for
services in International Classes 9, 41 and 42, with priority as of February 27, 2025.

The disputed domain name was registered on March 21, 2025. At the time of filing of the Complaint, it resolved to a website that offered a game called “Zip”. Below the game, there was the text: “Zip Game - Play Unlimited | Zip Game is an unlimited path-building puzzle game inspired by LinkedIn. Connect numbered cells in sequence to create a single continuous path that fills the entire grid.” The Respondent’s website also included advertising links and banners.

The disputed domain name currently redirects to the website at a different domain name, which has identical content, and the only difference is that the name of the game offered on it is changed to “Ziply”. The text below the game, which refers to “Zip Game” and to “LinkedIn”, has not been modified.

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.

The Complainant states that the disputed domain name is confusingly similar to its ZIP trademark. It notes that the second-level portion of the disputed domain name contains the ZIP trademark and the dictionary word “game”. According to the Complainant, the inclusion of the word “game”, which describes the Complainant’s services associated with the ZIP trademark, does not alleviate the confusing similarity of the disputed domain name with the trademark, but may actually increase it.

The Complainant maintains that the Respondent has no rights or legitimate interests in respect of the disputed domain name, because the Complainant has never authorized it to register or use the ZIP trademark, and it is not commonly known by the disputed domain name and has never acquired any relevant

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trademark rights. The Complainant points out that the Respondent offers visitors of its website to play
“unlimited” versions of the Zip game “inspired by LinkedIn”, and the website displays multiple
advertisements. According to the Complainant, this shows that the Respondent is not using the disputed
domain name in connection with a bona fide offering of goods or services and is not carrying out a legitimate
noncommercial or fair use of it.

The Complainant contends that the disputed domain name was registered and is being used in bad faith. its customers or potential customers and to attempt to attract Internet users for potential gain.

The Complainant points out that the disputed domain name is obviously connected with the Complainant because it is a combination of the ZIP trademark and the word “game”, which is associated with the services described by the ZIP trademark, and is being used in connection with a website offering the same services offered by the Complainant. According to the Complainant, this shows that the Respondent knew of the Complainant’s ZIP trademark when registering the disputed domain name and sought to obtain a commercial benefit by attracting Internet users based on the likelihood of confusion between it and the Complainant’s trademark. The Complainant adds that the Respondent is publishing without permission copies or derivative works based on the Complainant’s game, which represents copyright infringement.

The Complainant maintains that, although the disputed domain name was created on March 21, 2025, which is prior to April 3, 2025, when the Complainant obtained rights in the ZIP trademark, this does not prevent a finding of bad faith, because the Complainant had announced its Zip game on March 18, 2025 – three days prior to the date on which the disputed domain name was registered.

The Complainant also submits that the Respondent is a repeat cybersquatter against whom the Complainant filed and settled a previous complaint under the UDRP, and has engaged in a pattern of bad faith conduct under the Policy. The Complainant also notes that the Respondent is a member of the Complainant’s LinkedIn service, so he has agreed to abide by the Complainant’s User Agreement, which includes an undertaking not to violate the intellectual property or other rights of the Complainant. The Complainant maintains that, by registering and using the disputed domain name, the Respondent has violated this requirement.

B. Respondent

The Respondent did not submit a formal Response. In its informal communications to the Center, the

Respondent made the following statements:

“I want to clarify that I have never had any intention to mislead users or create confusion with LinkedIn's
services. The domain was registered and used in good faith for my own gaming project.

In the interest of resolving this matter amicably and avoiding any potential confusion, I am willing to voluntarily transfer the <zipgame.io> domain to LinkedIn. I understand your concerns about brand protection and respect your trademark rights.

To ensure a smooth transition for my existing users, I migrated my game to a new domain: […]. This new domain will have no connection to LinkedIn’s Zip game and will clearly represent my independent gaming project.

Please let me know the preferred process for completing this domain transfer. I am committed to resolving this matter cooperatively and professionally.”

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6. Discussion and Findings

Paragraph 4(a) of the Policy directs that the Complainant must prove each of the following:

(i) that the disputed domain name registered by the Respondent is identical or confusingly similar to a

trademark or service mark in which the Complainant has rights;

(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 or is being used in bad faith.

Given the similarities between the Policy and the Uniform Domain Name Resolution Policy (“UDRP”), the
Panel finds it appropriate to refer to UDRP jurisprudence, including reference to the WIPO Overview of

WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”).

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 the ZIP trademark for the purposes of the Policy. WIPO

Overview 3.0, section 1.2.1.

The Panel finds the ZIP trademark is recognizable within the disputed domain name. Accordingly, the
disputed domain name is confusingly similar to the ZIP trademark for the purposes of the Policy. WIPO
Overview 3.0, section 1.7.

Although the addition of other terms (here, “game”) 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 ZIP trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.

It has also long been held that country code Top-Level Domains (“ccTLDs”) are generally disregarded when evaluating the confusing similarity of a domain name. WIPO Overview 3.0, section 1.11.

The Panel therefore finds 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 ioDRP 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 name. The Respondent has

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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.

The disputed domain name is confusingly similar to the Complainant’s ZIP trademark and includes the dictionary word “game” which describes the online game for which the Complainant uses its trademark. It has been associated to a website that offered to visitors to play an identical game and contained references to the Complainant and its Zip game alongside third-party advertising links and banners. After the submission of the Complaint, the Respondent made the disputed domain name redirect to the website at a different domain name, which offers the same game under the name “Ziply” and displays the same reference to the Complainant and its Zip game that was previously included on the website at the disputed domain name - “Zip Game - Play Unlimited | Zip Game is an unlimited path-building puzzle game inspired by LinkedIn.” This change contradicts the statements made by the Respondent in this proceeding, i.e., that it will migrate its game to a new domain name that will have no connection to the Complainant’s Zip game and will represent an independent gaming project. Considering also the previous content of the website at the disputed domain name at the time of filing of the Complaint, the Panel is not convinced by the Respondent’s statements that the disputed domain name was registered and used for its own independent gaming project and that it never intended to mislead users or create confusion with the Complainant’s services.

On the basis of the above, the Panel finds that the Respondent has registered and used the disputed domain
name to confuse and attract Internet users looking for the Complainant’s ZIP game for commercial gain.

Such conduct cannot give rise to rights or legitimate interests in the disputed domain name.

The Panel therefore finds the second element of the Policy has been established.

C. Registered or Used in Bad Faith

Unlike the UDRP, which requires that Complainant prove both bad faith registration and use, under the 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.

As discussed in the section on rights and legitimate interests, the evidence in the case and the Respondent’s conduct following the submission of the Complaint support a conclusion that it has registered and used the disputed domain name targeting the Complainant’s ZIP trademark.

The disputed domain name was registered 13 days before the Complainant first registered its ZIP trademark. This however does not preclude a finding of bad faith registration of the disputed domain name, because the Complainant has submitted evidence that it had announced its Zip game three days before the Respondent registered the disputed domain name, and the Respondent’s website clearly shows its knowledge and

targeting of the Complainant and of its yet unregistered trademark rights. WIPO Overview 3.0, section 3.8.2.

On this basis, the Panel finds that, by registering and using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s ZIP trademark as to the origin or endorsement by the Complainant of the

Respondent’s website and of the content on it. This supports a finding of bad faith registration and use of the disputed domain name under Paragraph 4(b)(iv) of the Policy.

The Panel therefore finds that the Complainant has established the third element of the Policy.

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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 <zipgame.io> be transferred to the Complainant.

/Assen Alexiev/
Assen Alexiev
Sole Panelist
Date: September 8, 2025