LinkedIn Corporation v meme cha, R

WIPO Case No. D2025-2777

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

LinkedIn Corporation v. meme cha, R

Case No. D2025-2777

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 meme cha, R, Singapore.

2. The Domain Name and Registrar

The disputed domain name <zip-game.online> is registered with Dynadot Inc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 15, 2025, regarding the disputed domain name and another domain name. On July 15, 2025, the Center transmitted by email to the Registrars a request for registrar verification in connection with the disputed domain name and another domain name. On July 16, 2025, the Registrars transmitted by email to the Center their verification response disclosing registrant and contact information for the disputed domain name and another domain name which differed from the named Respondent (Redacted for Privacy, Super Privacy Service LTD c/o Dynadot / Redacted for Privacy, 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 16, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on July 19, 2025, requesting to withdraw its Complaint for the other domain name. On July 29, 2025, the Center informed the Parties and the Registrar that the other domain name had been withdrawn from the current proceeding.

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”).

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In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the
Complaint, and the proceedings commenced on July 24, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was August 13, 2025. The Respondent did not submit any response.

Accordingly, the Center notified the Respondent’s default on August 14, 2025.

The Center appointed Knud Wallberg as the sole panelist in this matter on August 18, 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 states that it became a public company on May 18, 2011, and was traded on the New York
Stock Exchange under the symbol “LNKD” until the Complainant was acquired by Microsoft Corp.

Presently, the Complainant has 18,400 full-time employees with 38 offices in cities around the world and operates websites in 36 languages.

Founded in 2003, the Complainant connects the world’s professionals to make them more productive and successful. With more than one billion members in more than 200 countries and territories, including executives from every Fortune 500 company, the Complainant is one of the world’s largest professional networks on the Internet.

The Complainant is the registrant of numerous domain names, including <linkedin.com>, which it registered on November 2, 2002, and which it uses in connection with its primary website. The Complainant offers a number of games on its website, which it announced on April 30, 2024. On March 18, 2025 – two months before the Respondent registered the disputed domain name – the Complainant announced a game called “Zip.”

The Complainant’s Zip game is available at the URL “ which now has 15 million followers.

The Complainant is the owner of the United Kingdom Trademark reg. No. UK00004182938 (filed for April 2,
2025, registered June 27, 2025) for the mark ZIP in classes 9, 41 and 42, inter alia in connection with,
recreational purposes”. “providing temporary use of Online non-downloadable software for playing a logic and puzzle game for

The Respondent registered the disputed domain name on May 24, 2025. The Respondent is using the disputed domain name in connection with a website that offers a game called “Zip Unlimited,” which it describes as “The LinkedIn Puzzle Game That Broke The Internet, Now Without Limits”.

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 that the disputed domain name is identical or confusingly similar to the ZIP trademark. It is thus well-established that the Top-Level Domain (“TLD”) (i.e. “.online”) may be disregarded, just as the inclusion of the word “game”, which is descriptive of the Complainant’s goods and services marketed in relation to the mark, and the inclusion of a hyphen in the disputed domain name is irrelevant for the purposes of establishing confusing similarity under the Policy.

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The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has never assigned, granted, licensed, sold, transferred or in any way authorized the Respondent to register or use the ZIP trademark in any manner, and to the Complainant’s knowledge the

Respondent does not have any rights corresponding to the disputed domain name nor has the Respondent used the disputed domain name in connection with a bona fide offering of goods or services.

The Complainant finally contends that the Respondent has registered and used the disputed domain name in bad faith. The disputed domain name is thus obviously connected with the Complainant since the disputed domain name includes the ZIP trademark plus the word “game”, just as the disputed domain name is used in connection with a website that offers the same online services that is offered by the Complainant under the ZIP trademark.

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 Selected UDRP Questions, Third Edition, (“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 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 3.0, section 1.7.

Although the addition of other terms, here the generic term “-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 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.

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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 evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise.

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.

Where a respondent registers a domain name before the complainant’s trademark rights accrue, panels will
not normally find bad faith on the part of the respondent. As an exception to the general proposition, in
certain limited circumstances where the facts of the case establish that the respondent’s intent in registering
the domain name was to unfairly capitalize on the complainant’s nascent trademark rights, panels have been
prepared to find that the respondent has acted in bad faith. In this case, the Respondent registered the
disputed domain name two months after the Complainant announced launch of its game “Zip” and filed for its
trademark application. Therefore, the Panel finds that the Respondent registered the disputed domain name
in bad faith to unfairly capitalize on the Complainant’s nascent trademark rights. WIPO Overview 3.0,
section 3.8.2.

In the present case, the Panel notes that the Respondent intentionally attempts to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark, and by using the disputed domain name, to host a website that provides a game that claims to be an “improved” and “unlimited” version of the one that is offered by the Complainant.

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 <zip-game.online> be transferred to the Complainant.

/Knud Wallberg/
Knud Wallberg
Sole Panelist
Date: September 1, 2025