Trademark Registrations on the 'Supplemental Register' Don't Count (in Domain Name Disputes)

Trademark Registrations on the 'Supplemental Register' Don't Count (in Domain Name Disputes)

The UDRP has never required that a complainant own any trademark registrations to succeed in a domain name dispute, given that common law trademark rights (if properly established) are sufficient. But, as a pair of recent UDRP decisions reminds us, even some registrations are insufficient, such as those on the "Supplemental Register" at the U.S. Patent and Trademark Office (USPTO).