WIPO D2000-1532 · decided 25 January 2001
Bruce Springsteen v. Jeff Burgar and Bruce Springsteen Club
The parties
- Complainant
- Bruce Springsteen
- Respondent
- Jeff Burgar and Bruce Springsteen Club
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The majority assumed, without deciding, that the name Bruce Springsteen is protected as an unregistered trademark, and on that assumption found brucespringsteen.com identical to it. |
| 4(a)(ii) No rights or legitimate interests | The majority found Bruce Springsteen had not proved that Jeff Burgar lacked a legitimate interest, because internet users were not misleadingly diverted to the celebrity1000.com site. |
| 4(a)(iii) Registered and used in bad faith | The majority found none of the paragraph 4(b) circumstances present, and held that registering in the name "Bruce Springsteen Club" did not meet the burden of proving bad faith. |
Why does Springsteen matter for a complaint today?
In Bruce Springsteen v. Jeff Burgar and Bruce Springsteen Club, D2000-1532, a 2-1 majority of a three-member WIPO panel let Jeff Burgar keep brucespringsteen.com. The domain name pointed to his celebrity1000.com site. The majority reasoned that internet users who search for a celebrity do not expect every site carrying the name to be official. It also held that Jeff Burgar had not blocked Bruce Springsteen from "a corresponding domain name", because the official site already ran at brucespringsteen.net. The dissenting panelist found the diversion misleading and would have ordered transfer. For anyone with a famous personal name, the lesson from this decision is about evidence. The majority noted that no evidence of secondary meaning was filed, and only assumed the name was protected. The WIPO Overview 3.1, section 1.5, says merely having a famous name is not likely to be enough without evidence of use as a trademark. Section 2.7 says panels have tended to find that a right to run a fan or informational site does not extend to a domain name identical to the trademark. A complainant in this position today should file trademark use evidence and argue impersonation.
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 2.7: Does a fan (or informational) site support respondent rights or legitimate interests in a domain name? The Overview cites this decision here.
Who decided the case?
A three-member panel decided the case on 25 January 2001: Gordon D. Harris (presiding), A. Michael Froomkin, Richard W. Page (dissenting).
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, who worked at the WIPO Arbitration and Mediation Center from 2018 to 2021 and sits as a domain name panelist at the Czech Arbitration Court. Checked against the published decision on 23 October 2026. Full background.
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