WIPO D2000-0210 · decided 29 May 2000
Julia Fiona Roberts v. Russell Boyd
The parties
- Complainant
- Julia Fiona Roberts
- Respondent
- Russell Boyd
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel held that Julia Roberts had common law trademark rights in her name without any registration, and that juliaroberts.com was identical to that name. |
| 4(a)(ii) No rights or legitimate interests | Russell Boyd had no permission from Julia Roberts, and the site had little to do with her until the dispute arose, so the panel found no rights or legitimate interests. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith under paragraph 4(b)(ii), because Russell Boyd had registered other celebrity names, and treated his eBay auction of juliaroberts.com as additional evidence. |
Why does Julia Roberts matter for a complaint today?
In Julia Fiona Roberts v. Russell Boyd, WIPO Case No. D2000-0210, a three-member WIPO panel ordered juliaroberts.com transferred to the actress. Julia Roberts held no registered trademark in her name. The panel held that the UDRP does not require one, and that her name had enough secondary association with her under United States law to create common law trademark rights. The panel cited Jeanette Winterson v. Mark Hogarth, WIPO Case No. D2000-0235, for the point that unregistered rights are enough. Bad faith followed from Russell Boyd's registration of more than 50 other domain names, including other film stars' names, and from his eBay auction of juliaroberts.com, where the decision records a US$2,550 offer. Anyone relying on an unregistered personal name should read section 1.5.2 of the WIPO Overview 3.1 before filing. It says that merely having a famous name would not likely establish common law rights. The name must be used in commerce as a distinctive identifier of goods or services. The Julia Roberts panel based its finding on her film career, her press coverage and her two Academy Award nominations. A complainant today should put evidence of trade use of the name into the complaint itself.
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 1.5: Can a complainant show UDRP-relevant rights in a personal name? The Overview cites this decision here.
- Section 1.3: What does a complainant need to show to successfully assert unregistered or common law trademark rights? The Overview cites this decision here.
- Section 3.1.2: What constitutes a pattern of conduct of preventing a trademark holder from reflecting its mark in a domain name? The Overview cites this decision here.
Who decided the case?
A three-member panel decided the case on 29 May 2000: Richard W. Page (presiding), Sally M. Abel, James Bridgeman.
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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