## Facts

- A U.S. precious-metals and coins company owned a federal trademark registration for “GOLDLINE” for precious-metal ingots and gold and silver coins.
- A consultant doing business as “Gold Line Internet” registered and used the domain name **goldline.com** in connection with a business involving vanity toll-free numbers, domain names, and related services.
- The trademark owner demanded transfer of **goldline.com**; the registrant refused and warned that pursuing a UDRP claim would be abusive and constitute reverse domain name hijacking.
- The trademark owner filed a UDRP complaint seeking transfer, alleging confusing similarity, lack of the registrant’s rights or legitimate interests, and bad-faith registration and use.
- The registrant asserted the term “Goldline/Gold Line” was widely used by third parties and that his domain use reflected a bona fide business not aimed at the trademark owner.
- After the complainant filed an unsolicited reply, the panel struck it and disregarded it because additional submissions were not requested by the panel.

## Issues

1. Whether **goldline.com** is identical or confusingly similar to a trademark in which the complainant has rights (UDRP ¶ 4(a)(i)).
2. Whether the registrant lacks rights or legitimate interests in **goldline.com** (UDRP ¶ 4(a)(ii)).
3. Whether **goldline.com** was registered and is being used in bad faith (UDRP ¶ 4(a)(iii)).
4. Whether the complainant engaged in **reverse domain name hijacking** by misusing the UDRP process.

## Decision

- The panel denied the complaint and refused to order transfer or cancellation of **goldline.com**.
- The panel concluded the complainant failed to prove **bad-faith registration and use** under UDRP ¶ 4(a)(iii).
- The panel found the complainant engaged in **reverse domain name hijacking**.
- The panel struck and disregarded the complainant’s unsolicited reply submission.

## Legal Principles

- Under the UDRP, a complainant must prove all three elements of ¶ 4(a); failure to prove **bad faith** defeats the request for transfer even where the domain is identical or confusingly similar to a mark.
- The “.com” generic top-level domain is generally disregarded in assessing identity or confusing similarity.
- Evidence of a respondent’s bona fide business use of a domain name, coupled with the common commercial use of a disputed term, may support **rights or legitimate interests** and weigh against an inference of targeting.
- Bad faith commonly requires proof that the domain was registered to exploit the complainant’s mark (e.g., to sell to the complainant for profit, block the mark holder, disrupt a competitor, or attract users by confusion); absence of such proof defeats ¶ 4(a)(iii).
- Reverse domain name hijacking may be found where, under any fair view of the facts, the respondent’s conduct could not constitute bad faith and a reasonable pre-filing investigation would have revealed the complaint’s deficiencies.

## Conclusion

The panel denied transfer of **goldline.com** because the complainant did not establish bad-faith registration and use, and it declared reverse domain name hijacking based on the objective weakness of the complaint and the complainant’s decision to proceed despite readily apparent obstacles under the UDRP.


Goldline Int’l, Inc. v. Gold Line (Loren C. Stocker d/b/a Gold Line Internet), WIPO Case No. D2000-1151 (2001)