WIPO D2015-1113 · decided 14 August 2015
Khloe Kardashian, Whalerock Celebrity Subscription, LLC, Khlomoney, Inc. v. Private Registrations Aktien Gesellschaft / Privacy Protection Service Inc. d/b/a Privacyprotect.Org
The parties
- Complainant
- Khloe Kardashian, Whalerock Celebrity Subscription, LLC, Khlomoney, Inc.
- Respondent
- Private Registrations Aktien Gesellschaft / Privacy Protection Service Inc. d/b/a Privacyprotect.Org
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found khloekardashian.com identical to the KHLOE KARDASHIAN trademark, because once the .com suffix is ignored the domain consists of the entire mark registered in the United States. |
| 4(a)(ii) No rights or legitimate interests | The panel found the respondent had no rights or legitimate interests, since a parking page inviting offers to buy the domain shows none and the respondent filed no response. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith because the domain was registered two weeks after Khloe Kardashian's television debut to profit from her prospective fame, and was then offered for sale. |
Why does Khloe Kardashian matter for a complaint today?
The domain khloekardashian.com was registered on 29 October 2007, two weeks after Khloe Kardashian first appeared on Keeping Up with the Kardashians. Her company, Khlomoney, Inc., registered KHLOE KARDASHIAN as a US service mark only in April 2014. The panel still ordered a transfer. The panel drew the "overwhelming inference" that the domain was registered to profit from her prospective fame, and held that a parking page inviting purchase offers was bad faith use. The WIPO Overview 3.1 cites this case at section 3.8.2, the exception for domains registered in anticipation of trademark rights, for example after significant media attention. For a business owner, the point is that a domain registered before your trademark is not always out of reach. You need evidence that the registrant had your name in mind on the day it registered, such as timing that matches a launch or a first broadcast. The limit is real. Section 3.8.1 of the Overview says panels will not normally find bad faith where the domain was registered before the complainant's trademark rights accrued. The respondent here filed no response, so the panel's inference went unchallenged.
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 3.8.2: Domain names registered in anticipation of trademark rights The Overview cites this decision here.
- Section 1.5.1: Can a complainant show UDRP-relevant rights in a personal name? The Overview cites this decision here.
Who decided the case?
A single panelist, Ian Lowe, decided the case on 14 August 2015.
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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