A three-member WIPO panel denied Leancode, Inc.’s attempt to obtain Pluggable.com and found that the company behind the Plugable brand had abused the UDRP process by filing a complaint with no reasonable prospect of success.
Ech’s short answer
Leancode tried to use the UDRP to take Pluggable.com from Richard Harrison. The panel rejected the complaint because Harrison acquired the dictionary-word domain before Leancode had trademark rights and had previously used it for a genuine business. This was an administrative domain decision, not a criminal conviction.
The dispute centred on one missing letter. Leancode sells computer accessories under the brand Plugable, while the contested domain was Pluggable.com—the standard spelling of the English word “pluggable”.
Leancode asked the World Intellectual Property Organization to order a transfer under the Uniform Domain Name Dispute Resolution Policy. The panel not only refused; it ruled that the complaint was brought in bad faith and constituted reverse domain name hijacking.
The company behind Plugable argued that the domain should be transferred despite its owner acquiring it first.
The complainant was Leancode, Inc., a US company that sells docking stations and other computer accessories under the PLUGABLE mark. The respondent was Richard Harrison in the United Kingdom, who had acquired Pluggable.com on 18 February 2009.
Leancode’s first US trademark registration was issued in May 2011 and claimed first commercial use in September 2009. That chronology meant Harrison’s acquisition of the domain came before the rights relied on in the complaint.
Leancode nevertheless asked the panel to treat Harrison’s renewed use of the domain in 2026 as the relevant date for deciding whether it had been registered in bad faith.
Pluggable.com had a documented business history before Plugable’s claimed trademark use began.
Pluggable.com was initially registered on 9 April 2005.
Richard Harrison acquired the domain on 18 February 2009.
Leancode claimed first use in September 2009 and registered its mark in May 2011.
Harrison discontinued Pluggable Ltd but retained the domain.
After reactivating email, Harrison received misdirected messages and approached Leancode.
The panel denied transfer and declared the filing an attempt at RDNH.
During the 2026 discussions, Leancode offered USD 5,000 for the domain. Harrison’s lawyers said his expectations were in the mid-six-figure range. The failure to agree a price was followed by the UDRP complaint filed on 1 June 2026.
The panel said that offering a dictionary-word domain for sale is not, by itself, evidence that it was registered to target a later trademark owner.
A UDRP complainant must prove all three required elements, and the third element was fatal to Leancode’s case.
The panel rejected Leancode’s proposed “reset” of the registration date. A period of non-use, later reactivation or a change in how the same owner uses a domain does not create a new registration for UDRP purposes.
It also found no evidence that Harrison acquired the domain in anticipation of Leancode’s future rights. Instead, the record showed that he had used the ordinary dictionary word for a corresponding business for several years.
Bad-faith use alone is not enough under the UDRP. The complainant must show both bad-faith registration and bad-faith use.
Losing a UDRP case does not automatically mean RDNH. The panel found additional evidence that this complaint abused the process.
Leancode knew Harrison acquired the domain before its trademark rights arose.
Pluggable is the ordinary spelling, while the company deliberately used the modified spelling Plugable.
A 2025 Reddit post showed awareness that the correctly spelt domain was already owned by someone else.
The panel also considered that Leancode had legal representation throughout the proceeding. It concluded that the company either knew, or should have known after reasonable investigation, that it could not establish bad-faith registration.
The complaint was therefore declared to have been filed in bad faith and to constitute an attempt at reverse domain name hijacking under paragraph 15(e) of the UDRP Rules.
It is a finding that a complainant used the administrative process in bad faith to try to obtain a domain. It is not a criminal offence or a damages award, and the panel’s order was simply to deny the complaint.
The policy is designed for abusive domain registrations, not as a substitute for buying a valuable name from its legitimate owner.
For domain owners, the ruling shows why records of acquisition, historical websites, company registrations and earlier business use can be decisive. Harrison’s evidence connected the domain to a real business and a meaning unrelated to Leancode’s later trademark.
For brand owners, it is a reminder to obtain specialist advice before filing. A complaint that ignores an earlier registration date or tries to turn failed purchase talks into a cybersquatting claim can end with a public RDNH finding.
Bottom line
Leancode could not use its later PLUGABLE trademark to establish that a dictionary-word domain acquired in February 2009 was registered in bad faith. The complaint was denied, and the company left the proceeding with a reverse domain name hijacking finding.
