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ADORAIntellectual Property

WIPO D2000-0102 · decided 18 April 2000

Nokia Corporation v. Nokiagirls.com a.k.a IBCC

Cancellednokiagirls.com
In Nokia Corporation v. Nokiagirls.com a.k.a IBCC, D2000-0102 (WIPO, 2000), the panel held that adding a generic word to a globally famous mark does not remove the likelihood of confusion. The respondent sold advertising space on the site, which the panel treated as free riding on Nokia's goodwill, and cancelled the registration.

The parties

Complainant
Nokia Corporation
Respondent
Nokiagirls.com a.k.a IBCC

What did the panel find on each element?

Policy paragraphFinding
4(a)(i) Identical or confusingly similarThe panel found nokiagirls.com confusingly similar to the registered NOKIA trademark, because adding the general noun "girls" did little to distinguish the domain name from the trademark.
4(a)(ii) No rights or legitimate interestsNokia had never licensed the respondent to use NOKIA, and the respondent filed no response showing any right or legitimate interest, so the panel found this element proved.
4(a)(iii) Registered and used in bad faithThe panel found bad faith because NOKIA was so famous that the respondent must have known of it, and the site existed mainly to earn money from banner advertising.

Why does Nokiagirls matter for a complaint today?

In Nokia Corporation v. Nokiagirls.com a.k.a IBCC, WIPO Case No. D2000-0102, the panel ordered the registration of nokiagirls.com cancelled. The panel treated the added word "girls" as a neutral noun that did little to separate the domain name from the NOKIA trademark. Section 1.8 of the WIPO Overview 3.1 now states the rule more broadly: where the trademark is recognizable in the domain name, an added descriptive, pejorative or meaningless term does not prevent confusing similarity. The bad faith finding rested on evidence. The site had almost no content apart from rotating banner advertisements, and the panel presumed the respondent earned money from visitors' clicks. The same entity, IBCC, had registered dellgirls.com for an identical site. If someone has added a word to your trademark, that addition will not save them at the first element. But the first element only gives you standing. Nokia still had to prove bad faith, and it did so with the advertising evidence and the dellgirls.com registration. Nokia asked for cancellation, not transfer, and cancellation is what the panel ordered.

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 1.8: Is a domain name consisting of a trademark and a descriptive or geographical term confusingly similar to a complainant's trademark? The Overview cites this decision here.
  • Section 3.1.4: How does a complainant prove that a respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant's mark? The Overview cites this decision here.

Who decided the case?

A single panelist, Geert Glas, decided the case on 18 April 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.

WIPO decision D2000-0102

Summarised by Gergana Dimitrova. Checked against the published decision on 23 October 2026.

Someone has taken a domain that uses your brand?

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