WIPO D1999-0001 · decided 14 January 2000
World Wrestling Federation Entertainment, Inc. v. Michael Bosman
The parties
- Complainant
- World Wrestling Federation Entertainment, Inc.
- Respondent
- Michael Bosman
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found that worldwrestlingfederation.com is identical or confusingly similar to the WORLD WRESTLING FEDERATION trademark and service mark that World Wrestling Federation Entertainment, Inc. registered with the USPTO. |
| 4(a)(ii) No rights or legitimate interests | The panel found that Michael Bosman had no rights or legitimate interests, because he was not a licensee, had built no website and had no other connection to the name. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith registration because Michael Bosman offered the domain to the complainant three days after registering it, and bad faith use because his US$1,000 offer exceeded his out-of-pocket costs. |
Why does WWF matter for a complaint today?
The panel in World Wrestling Federation Entertainment, Inc. v. Michael Bosman had to decide whether a domain with no website can be used in bad faith. The UDRP requires both bad faith registration and bad faith use, and Michael Bosman never put up a site. The panel held that offering the domain to the trademark owner for more than the registrant's out-of-pocket costs is bad faith use under Policy paragraph 4(b)(i). Michael Bosman registered worldwrestlingfederation.com on October 7, 1999. Three days later he told World Wrestling Federation Entertainment that his primary purpose was to sell it to them, and on December 3, 1999 he asked for US$1,000. For a business owner today, an email offering to sell you a domain that matches your trademark can be evidence of bad faith use, even if the domain shows nothing. Keep it. The limit is that the offer has to target you as the trademark owner. Section 3.1.1 of the WIPO Overview 3.1 says registering a domain for resale is not bad faith by itself, and an offer to sell is not bad faith where the registrant has its own legitimate interest. Michael Bosman had none, and he filed no response.
What does the WIPO Overview 3.1 say?
The WIPO Overview 3.1 summarises how WIPO panels decide each issue. These sections cover the same point of law.
- Section 3.1.1: How does a complainant prove that a respondent has registered or acquired a domain name primarily to sell the domain name to the complainant (or its competitor) for valuable consideration in excess of the respondent's costs related to the domain name? The Overview cites this decision here.
- Section 3.3: Can the "passive holding" of a domain name support a finding of bad faith? The Overview cites this decision here.
Who decided the case?
A single panelist, M. Scott Donahey, decided the case on 14 January 2000.
Read the decision
The full text is published by the WIPO Arbitration and Mediation Center. We summarise it here; the decision itself is the authority.
Summarised by Gergana Dimitrova. Checked against the published decision on 23 October 2026.
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