## Facts

- World Wrestling Federation Entertainment, Inc. owned U.S. trademark and service-mark registrations for “WORLD WRESTLING FEDERATION” used in professional wrestling entertainment.
- On October 7, 1999, Michael Bosman registered the domain name `<worldwrestlingfederation.com>` with Melbourne IT.
- The domain name incorporated the mark in its entirety, differing only by removal of spaces and the “.com” suffix.
- Bosman did not develop a website or use the domain for a bona fide offering of goods or services.
- Within three days of registration, Bosman contacted WWF and offered to “sell or rent” the domain name for an amount exceeding his out-of-pocket registration costs.
- WWF filed a UDRP complaint with WIPO on December 2, 1999 seeking transfer of the domain name.
- WIPO commenced the proceeding on December 9, 1999; a single-member panel was appointed, and no settlement was reached.

## Issues

1. Whether `<worldwrestlingfederation.com>` was identical or confusingly similar to a mark in which WWF had rights under UDRP ¶ 4(a)(i).
2. Whether Bosman had any rights or legitimate interests in the domain name under UDRP ¶ 4(a)(ii).
3. Whether the domain name was registered and used in bad faith under UDRP ¶ 4(a)(iii), including whether an offer to sell at a premium constitutes bad-faith “use” without an active website.

## Decision

- The panel found WWF proved all three elements of UDRP ¶ 4(a).
- The panel concluded the domain name was identical or confusingly similar to WWF’s registered mark.
- The panel found Bosman had no rights or legitimate interests in the domain name.
- The panel found the domain name was registered and used in bad faith, based chiefly on registration for resale to WWF for more than out-of-pocket costs.
- The panel ordered transfer of `<worldwrestlingfederation.com>` to WWF.

## Legal Principles

- Under UDRP ¶ 4(a), a complainant must prove: (1) identical or confusing similarity to a mark; (2) respondent’s lack of rights or legitimate interests; and (3) bad-faith registration and bad-faith use.
- A domain name that fully incorporates a protected mark is typically identical or confusingly similar; the “.com” suffix and removal of spaces do not materially distinguish the domain name.
- Lack of authorization, lack of a bona fide offering, and absence of legitimate noncommercial or fair use support a finding of no rights or legitimate interests.
- Bad faith may be shown where the domain was registered primarily to sell or rent it to the mark owner for consideration exceeding documented out-of-pocket costs (UDRP ¶ 4(b)(i)).
- An offer to sell a domain name to the mark owner at a premium can constitute bad-faith “use” even if the domain is not developed into an active website.

## Conclusion

The panel applied the UDRP’s three-part test to a classic cybersquatting pattern and ordered transfer because the domain was effectively the trademark, the registrant had no legitimate interest, and the rapid offer to sell at a premium established bad-faith registration and use.


World Wrestling Fed’n Ent., Inc. v. Bosman, No. D99-0001 (WIPO Arb. & Mediation Ctr. Jan. 14, 2000)