Wargaming.net Limited v Tram Tran, Kim Bao and maurice frisby

WIPO Case No. D2025-2689

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Wargaming.net Limited v. Tram Tran, Kim Bao and maurice frisby

Case No. D2025-2689

1. The Parties

The Complainant is Wargaming.net Limited, Cyprus, represented by Malvika Dasani, Cyprus.

The Respondents are Tram Tran, Kim Bao, United States of America (“United States”) and maurice frisby,

United States.

2. The Domain Names and Registrars

The disputed domain name <worldoftanksstore.shop> is registered with Sav.com, LLC (the “Registrar”).

The disputed domain name <worldoftanksstoreeu.shop> is registered with Web Commerce Communications

Limited dba WebNic.cc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 8, 2025. On
July 9, 2025, the Center transmitted by email to the Registrars a request for registrar verification in
connection with the disputed domain names. On July 9, 2025, the Registrars transmitted by email to the
Center their verification response disclosing registrant and contact information for the disputed domain
names which differed from the named Respondent (REDACTED FOR PRIVACY / Domain Admin,
Whoisprotection.cc) and contact information in the Complaint.

The Center sent an email communication to the Complainant on July 11, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint 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 15, 2025.

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 of the
Complaint, and the proceedings commenced on July 21, 2025. In accordance with the Rules, paragraph 5,

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the due date for Response was August 10, 2025. The Respondent did not submit any response.

Accordingly, the Center notified the Respondent’s default on August 19, 2025.

The Center appointed Pablo A. Palazzi as the sole panelist in this matter on August 25, 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 video game company and part of the Wargaming group, headquartered in Cyprus. The group operates across the world via more than 20 offices globally and includes a number of related subsidiary game development studios.

The Complainant has various award-winning games within its portfolio, including free-to-play multiplayer online action games, such as its military themed game WORLD OF TANKS.

The Complainant is the owner of several trademark registrations for WORLD OF TANKS: including the following:

- European Union Trade Mark (“EUTM”) No. 011623071 for WORLD OF TANKS (word mark), filed March 4, 2013, registered June 11, 2015, covering Class 35 services;

- EUTM No. 13255765 for WORLD OF TANKS (word mark), filed March 4, 2013, registered September
12, 2014, covering an extensive range of goods and services in Classes 9, 12, 13, 16, 18, 20, 25, 28, 32, 33,
34, 41, 43, and 45;

- EUTM No. 009033879 for WORLD OF TANKS (word mark), filed April 16, 2010, registered September 14, 2010, covering Classes 9, 16, 28, and 41;
- EUTM No. 18432677 for the WORLD OF TANKS (logo mark), filed March 18, 2021, registered July 15, 2021, covering Classes 9, 28, and 41;
- EUTM No. 011140308 for WORLD OF TANKS (logo mark), filed August 24, 2012, registered January 22, 2013, covering Classes 9, 16, 28, and 41; and

- EUTM No. 011870144 for WORLD OF TANKS (logo mark), filed June 4, 2013, registered December 9, 2013, covering Classes 12, 14, 18, 25, 29, 30, 32, 34, 35, 43, and 45.

The disputed domain name <worldoftanksstore.shop> was registered on June 9, 2024.

The disputed domain name <worldoftanksstoreeu.shop> was registered on March 15, 2025.

According to the Complaint, the Respondents are using the disputed domain names to sell counterfeit merchandise goods featuring the Complainant trademarks, including for example, clothing and related accessories (e.g., hoodies, t-shirts, caps, gaming sleeves, socks), mugs and water bottles, games and puzzles, computer peripherals (e.g., computer mouses), bags and model tanks etc. On the website resolving

from the disputed domain names, there are 9 pages featuring 36 purportedly counterfeit product listings on

each page when searching for “World of Tanks”.

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.

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B. Respondent

The Respondent did not reply to the Complainant’s contentions.

6. Discussion and Findings

6.1. Consolidation: Multiple Respondents

The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules and based on the following facts:

- Redirection Behavior: Both disputed domain names resolve to the same website at

“ indicating centralized technical control and administration.

- Both disputed domain names resolve to the same website at “ The

disputed domain name <worldoftanksstore.shop> redirects to disputed domain name domain names.
<worldoftanksstoreeu.shop> with the exact same content. This indicates centralized use and administration.

- Naming Pattern: The disputed domain names are nearly identical, with <worldoftanksstoreeu.shop> representing a slight variation of <worldoftanksstore.shop>, suggesting intentional coordination.

- Content/Use: The disputed domain names serve identical or nearly identical content, which supports a finding of unified operational control.

- Hosting Infrastructure: the disputed domain names have nearly identical IP Addresses, the same Host, and Host registration country, as well as identical ASN details.

The disputed domain name registrants did not comment on the Complainant’s request.

Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.

In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or
corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable
to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition
(“WIPO Overview 3.0”), section 4.11.2.

As regards common control, the Panel notes that the technical evidence demonstrates unified control over both disputed domain names through: (i) identical hosting infrastructure including matching IP addresses, hosting, and registration jurisdiction; (ii) coordinated redirect behavior where <worldoftanksstore.shop>

automatically forwards to <worldoftanksstoreeu.shop> with identical content; (iii) strategic naming pattern
suggesting intentional registration of trademark variations; and (iv) centralized content management across
both disputed domain names. These technical indicators collectively establish that a single respondent
maintains administrative, technical, and operational control over both disputed domain names.

As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party.

Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding.

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6.2. Status of the Disputed Domain Name <worldoftanksstore.shop>

As a preliminary matter, the Panel will address the status of the disputed domain name and confirmed the Complainant was unable to renew the disputed domain name directly, but was able to redeem it for a fee. On July 25, 2025, the Complainant confirmed that it has paid the Registrar the redemption fee (at a higher cost than initially confirmed by the Registrar). On August 8, 2025, the Complainant sought confirmation from the Center if the Registrar had confirmed redemption. On August 20, 2025, the Complainant again confirmed numerous unsuccessful attempts to contact the Registrar regarding the status of the disputed domain name.

<worldoftanksstore.shop>. The disputed domain name expired on June 9, 2025. On July 18, 2025, the

It appears the registration of the disputed domain name <worldoftanksstore.shop> may no longer be active. Complainant’s purported redemption payment and good faith attempts to engage with the unresponsive Registrar Sav.com, LLC, the Panel declines to formally dismiss the Complaint regarding the disputed domain name <worldoftanksstore.shop>. However, noting the scope of this proceeding, the Panel confirms that the implementation of the decision is limited to the present registration to the extent it may become active, and is not directed to future potential registrations.

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.

Although the addition of other terms, here “store”, and “eu”, 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.

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. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence

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demonstrating rights or legitimate interests in the disputed domain names such as those enumerated in the

Policy or otherwise.

Panels have held that the use of a domain name for illegal activity, as applicable to this case: the sale of
purportedly counterfeit goods, can never confer rights or legitimate interests on a respondent. WIPO
Overview 3.0, section 2.13.1.

Moreover, the Panel finds that the composition of the disputed domain names carries a risk of implied affiliation with the Complainant, which cannot constitute fair use. WIPO Overview 3.0, section 2.5.1.

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 notes that:

- the Respondent registered the disputed domain names in 2024 and 2025 respectively while the

Complainant registered and has been using the trademark WORLD OF TANKS at least since 2010.
- The Complainant owns extensive trademark registrations for WORLD OF TANKS across multiple
jurisdictions worldwide, including registered trademark rights for the associated logo which is being
unlawfully used by the Respondent in one of the disputed domain names.

- the listings on the website hosted by the disputed domain names are selling goods at significantly

discounted prices when compared to the Complainant’s legitimate merchandise listings. According to the featuring the Complainant trademarks. The Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad faith under paragraph 4(b)(iv).

Panels have held that the use of a domain name for illegal activity, here, as applicable to this case: sale of purportedly counterfeit goods, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes bad

faith under the Policy.

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 <worldoftanksstoreeu.shop> and <worldoftanksstore.shop> be transferred to the Complainant. [1]

[1]As provided in section 6.2, the order of transfer of the disputed domain name <worldoftanksstore.shop> is limited to the current

/Pablo A. Palazzi/
Pablo A. Palazzi
Sole Panelist
Date: September 4, 2025

registration, to the extent it may become active.