WIPO D2000-0596 · decided 24 July 2000
Gordon Sumner, p/k/a Sting v. Michael Urvan
The parties
- Complainant
- Gordon Sumner, p/k/a Sting
- Respondent
- Michael Urvan
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel did not formally decide this element. It doubted that STING, a common English word, was a trademark under paragraph 4(a)(i), but found a ruling unnecessary because bad faith failed. |
| 4(a)(ii) No rights or legitimate interests | The panel found that Michael Urvan had no rights or legitimate interests, because using "sting" as an online gaming nickname gave him anonymity and did not make him commonly known by it. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith unproven. Gordon Sumner filed no evidence of the alleged $25,000 sale demand, and Michael Urvan made his offer only after the complainant solicited it. |
Why does Sting matter for a complaint today?
In Gordon Sumner, p/k/a Sting v. Michael Urvan, WIPO Case No. D2000-0596, the panel refused to transfer sting.com. The singer lost on bad faith, the third element. Gordon Sumner said Michael Urvan had demanded $25,000 for the domain name but filed no correspondence to prove it. Michael Urvan admitted making an offer, but only after the singer's attorney had contacted him. The panel held that this was as consistent with good faith registration in 1995 as with bad faith. The panel also distinguished Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003, because TELSTRA was an invented word and "sting" has several dictionary meanings. On the first element, the panel doubted that a famous name which is also a common word is a trademark under the UDRP, but left the point undecided. On the second, the gaming nickname was too weak to give Michael Urvan a legitimate interest. The lesson for a complainant is to file the evidence. Section 3.1.1 of the WIPO Overview 3.1 says an offer to sell above the respondent's costs must target the trademark owner, and section 1.5 asks for proof that a personal name is used as a trademark.
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 1.5: Can a complainant show UDRP-relevant rights in a personal name? The Overview cites this decision here.
- Section 2.3: How would a respondent show that it is commonly known by the domain name or a name corresponding to the domain name? The Overview cites this decision here.
Who decided the case?
A single panelist, Andrew F. Christie, decided the case on 24 July 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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