1 Introduction

Since the earliest cybersquatting cases, football clubs have been prime targets. Their reputation, identity, and the wide range of activities developed around their brands—including ticketing, online stores, academies, digital content, and merchandising—provide numerous opportunities for abusive exploitation.

At the same time, technological developments have profoundly transformed cybersquatting practices. AI-powered content generation and website cloning tools now make it possible to replicate the appearance of legitimate websites within minutes and publish content that is sufficiently convincing to deceive Internet users. A domain name is no longer merely a disputed Internet address; it has increasingly become the entry point to more sophisticated fraudulent operations.

Drawing on a dataset of 102 published out-of-court decisions involving 130 domain names targeting football clubs, this article first examines how these domain names are constructed (Section 3), before analysing the ways in which they are used (Section 4). It then considers the central role played by out-of-court dispute resolution mechanisms (Section 5) and concludes by proposing several strategies to strengthen the protection of football clubs, ranging from domain name portfolio management (Section 6) to monitoring their broader digital ecosystem (Section 7).

This dataset is not intended to capture every infringement affecting football clubs. It includes only cases that resulted in a published or otherwise accessible decision. Inevitably, many matches were played behind closed doors. Nevertheless, the available decisions reveal a clear trend: the domain name is no longer merely the object of the abuse—it is increasingly becoming its infrastructure.

2 More Than One Hundred Decisions Involving Football Clubs and Domain Names

We compiled a dataset of 102 out-of-court decisions involving domain names targeting football clubs.

These decisions tell a very different story from that of the earliest domain name disputes. Initially, cybersquatting primarily consisted of registering a football club’s name in the hope of reselling the domain name or generating advertising revenue. Today, however, the domain name has often become the entry point to a much broader ecosystem involving fake ticketing websites, counterfeit online stores, phishing campaigns, identity theft, and traffic diversion. The dispute is no longer simply about a domain name; it is about the entire fraudulent scheme that the domain name makes possible.

3 Anatomy of a Domain Name Targeting a Football Club

Before examining how the disputed domain names are used, it is worth analysing how they are constructed. A domain name consists of two components: the second-level domain (the string preceding the dot) and the top-level domain (the extension). In our dataset, both elements contribute to the message conveyed to Internet users: the second-level domain reproduces, alters, or complements the club’s trademark, while the extension may sometimes reinforce or extend its meaning.

3.1 Reproducing, Altering, or Complementing the Club’s Name

The 102 decisions involve 130 distinct domain names. Their analysis reveals an almost perfectly balanced distribution between two main patterns. Sixty-two domain names, representing 47.7% of the cases, reproduce the club’s name, trademark, acronym, or another distinctive sign either identically or in a standardised form. By contrast, sixty-four domain names, representing 49.2%, combine that distinctive sign with one or more additional elements.

Classic typographical alterations, however, are remarkably uncommon. Only four domain names—3.1% of the cases—primarily rely on a minor modification of the sign, such as the omission, transposition, or substitution of a character, i.e., typosquatting.

This finding deserves particular attention, as any domain name portfolio strategy must take into account the capabilities of modern domain name detection and blocking tools.

Of the 64 domain names incorporating an additional term, 27 include vocabulary associated with merchandising or retail. Terms such as “shop,” “store,” “jersey,” “kit,” “maillot,” “boutique,” and “merchandise” appear in domain names such as <galatasaraystore.com> (WIPO Case No. D2003-0018), <chelseajersey.net> (WIPO Case No. D2015-1242), <spurskit.com> (WIPO Case No. D2025-2937) or <boutique-psg.fr> (WIPO Case No. DFR2009-0022).

Ticketing-related terminology forms another identifiable lexical category. Ten domain names incorporate terms belonging to this semantic field. The word “tickets” alone appears in eight domain names and is frequently combined with the term “official.” As a result, nine domain names make an explicit claim of official status. The domain names <official-arsenal-tickets.com> (WIPO Case No. D2008-0842) and <official-chelsea-tickets.com> (WIPO Case No. D2008-1574) follow exactly the same structure: a claim of official status, the club’s distinctive sign, and a term referring to ticket sales.

Football-related terminology also contributes to the construction of these domain names. Acronyms and terms such as “FC,” “football,” “soccer,” and “foot” appear as additional elements in ten domain names. Examples include <manchestercityfc.com> (WIPO Case No. D2009-0686), <psgfootball.com> (WIPO Case No. D2019-0036), <thebayernmunichsoccershop.com> (WIPO Case No. D2016-0060), and <soccerparissaintgermainshop.com> (WIPO Case No. D2023-3126).

Other lexical categories also emerge. Nine domain names incorporate terms related to digital products, gaming, or tokens, including <tottenhamfantoken.com> (WIPO Case No. D2022-4038), <newcastleunitedtoken.com> (WIPO Case No. D2025-3200), <barcagames.com> (WIPO Case No. D2024-0543) or <juventuscasino.com> (WIPO Case No. D2005-1048). Three combine the club’s distinctive sign with terminology associated with academies or player recruitment, notably <psg-france-academy.com> (WIPO Case No. D2021-1597), <liverpoolfootballclubacademy.com> (WIPO Case No. D2022-1145) and <cfctrials.com> (WIPO Case No. D2023-3698). Finally, four incorporate vocabulary relating to media or content services: <juventusnews.com> (WIPO Case No. D2001-1232), <juventuschannel.com> (WIPO Case No. D2012-2162), <asromaradio.com> (WIPO Case No. D2015-1973) or <juvetv.com> (WIPO Case No. D2001-0583).

It is also worth noting that some domain names combine several additional elements. For example, <official-chelsea-tickets.com> combines a claim of official status, the club’s distinctive sign, and the term “tickets.” Similarly, <thebayernmunichsoccershop.com> combines the club’s name with two additional terms: “soccer” and “shop.”

In short, the club’s distinctive sign forms the core of the domain name. Around this core are added elements that contextualise, qualify, or specialise it. Some domain names merely reproduce the club’s identity, whereas others construct a more elaborate expression.

3.2 When the Top-Level Domain Complements the Name

Unsurprisingly, the .com top-level domain remains by far the most prevalent, accounting for 86 of the 130 domain names analysed (66.2%). Nevertheless, the decisions examined feature 27 different top-level domains, including .shop, .club, .futbol, .camp, .email, .soccer, .coach, and .tienda.

Not all top-level domains play the same role in the construction of a domain name. Some are semantically neutral, such as .com, .net, .org, .co, or certain country-code top-level domains. This is the case, for example, with <clubbolivar.com> (Forum FA0911001295131), <juventus.net> (WIPO Case D2001-0260), <realmadrid.org> (WIPO Case D2000-1805), <parissaintgermain.co> (WIPO Case D2021-1321), and <asroma.us> (Forum FA1512001652203). In these examples, the top-level domain conveys little information about the nature or purpose of the website. Its primary function is simply to complete the web address built around the club’s distinctive sign.

By contrast, other top-level domains contribute directly to the overall meaning of the domain name. Thus, <parissaint-germain.club> (Forum FA1406001563159), <blaugrana.club> (Forum FA1406001564810), <realmadrid.club> (WIPO Case D2020-0540), and <liverpoolfc.club> (WIPO Case D2021-3907) reinforce the association with the club’s collective identity. The domain names <barça.futbol> (Forum FA1410001582662), <chelseafc.futbol> (Forum FA2209002010621), and <fcbarcelona.soccer> (WIPO Case D2017-1257) explicitly place the domain within the world of football. Similarly, <realmadrid.tienda> (WIPO Case D2014-1605), <liverpoolfc.shop> (WIPO Case D2021-3903), and <newcastleunited-eu.shop> (WIPO Case D2025-3205) immediately evoke a commercial activity, while <liverpoolfc.coach> (WIPO Case D2021-4132), <parissaintgermain.camp>, and <psg.camp> (WIPO Case D2021-0019) suggest coaching, academy, or training activities. In these cases, the top-level domain is no longer a mere technical suffix; it complements the club’s name and contributes to giving the domain name an appearance of coherence, specialisation, and even official status.

The relatively limited presence of these specialised top-level domains nevertheless deserves attention. This can first be explained by the historical scope of the dataset, which spans more than twenty-five years. A substantial proportion of the decisions analysed predate the 2012 New gTLD Program, with the first new generic top-level domains introduced under that programme only beginning to be delegated from 2013 onwards. For a significant part of the period covered by this study, extensions such as .shop, .futbol, .soccer, and .coach were therefore simply unavailable. In addition, these new top-level domains often involve higher registration or renewal fees than the legacy extensions, particularly for certain specialised strings or for domain names designated as premium. This price differential may have limited their adoption, including by cybersquatters, who generally favour the least expensive options when registering large portfolios of domain names.

4 The Use of the Disputed Domain Names

A domain name may be passively held, offered for sale, monetised, used to divert Internet traffic, or serve as the basis for a commercial activity. The decisions in our dataset reveal a gradual shift: from the mere appropriation of a club’s identity to uses in which the domain name itself contributes directly to creating an appearance of affiliation, supporting a commercial offering, or forming part of a broader commercial infrastructure.

4.1 Appropriating the Club’s Identity

The earliest decisions involving football clubs reveal a relatively straightforward use of the disputed domain names. At that stage, the domain name had not yet become the foundation of a more sophisticated scheme. Rather, it was itself the object of the misappropriation. By registering the club’s name under a prominent top-level domain, the cybersquatter deprived the legitimate rights holder of its natural online identifier while reserving the opportunity to profit from its value through resale, redirection, traffic diversion, or simply by exerting pressure on the club.

The ways in which these domain names were exploited varied. In some cases, the domain name was simply held in the registrant’s portfolio. In others, it was offered for sale or used to divert traffic intended for the club. Thus, in <realmadrid.org> (Real Madrid Club de Fútbol v. Lander W.C.S., WIPO Case No. D2000-1805), the respondent prevented the Real Madrid Foundation from using the corresponding address and offered to sell the domain name for a price far exceeding its registration costs. Yet the cost of acquiring the domain name had been negligible. The cybersquatter was exploiting not so much its intrinsic value as its subjective value—or value in use—that is, the particular importance the domain name held for the trademark owner, the only natural user of that online identifier. This logic lies at the very heart of cybersquatting as it emerged in the late 1990s: acquiring, at minimal cost, a digital asset whose value derives primarily from the legitimate rights holder’s interest in it. Even in the absence of a sophisticated website, the domain name already derived its economic value from the appropriation of the club’s digital identity.

The case of Liverpool Football Club PLC and Athletic Grounds Limited v. DVM International Limited, WIPO Case No. D2002-0046, concerning <liverpoolfc.com>, also illustrates how respondents sometimes attempted to justify their registration through alternative explanations. The respondent argued that the domain name referred to a purported “Liverpool Fashion Club.” The Panel was unconvinced and ordered the transfer of the domain name. This case illustrates a defence frequently encountered in domain name disputes. Faced with circumstances that are difficult to refute, some respondents attempt to attribute an alternative meaning to the disputed domain name after the fact in order to create an appearance of legitimacy. In both football and domain name disputes, some defences seem to owe more to hope than to genuine legal strategy.

The <culers.com> case (Fútbol Club Barcelona v. Domain Admin, Whois Privacy Corp., WIPO Case No. D2021-1412) illustrates that the age of a domain name registration may constitute a decisive obstacle to a UDRP complaint. The domain name had initially been used for a parking page displaying pay-per-click advertising links before later becoming inactive. Nevertheless, the complaint was denied because the Panel found that the complainant had failed to establish that the respondent had acted in bad faith when the domain name was registered in 2000. Under the UDRP, bad faith must be assessed as of the time of the domain name’s registration. The subsequent development of a sign’s reputation, or of its association with a football club, is not, in itself, sufficient to call into question a registration that was lawful when made.

4.2 From the Club’s Name to the Infrastructure of Abuse

The most significant development becomes apparent when one examines not merely the registered domain name, but the way it is used. Of the 102 decisions in our dataset, 53 primarily concern the appropriation of the club’s identity or the creation of an appearance of affiliation. An increasing proportion of disputes, however, involve domain names designed around a specific purpose, such as ticketing, online retail, football shirts, academies, news, email services, or digital products.

This evolution is consistent with the growing body of research on combosquatting, namely the registration of a domain name combining a recognisable trademark with one or more additional terms. Unlike typosquatting, which relies on a typographical error or minor orthographic alteration, combosquatting generally preserves the trademark intact while adding an additional term intended to enhance the credibility of the domain name. That additional element is not chosen at random. Rather, it evokes a product, a service, a geographical location, a feature, or an activity that Internet users naturally associate with the trademark owner. The resulting confusion therefore stems less from the visual similarity of the signs than from the semantic coherence of the domain name as a whole.

Research on this phenomenon shows that combosquatting is now more widespread than typosquatting and is used in a wide range of contexts, including phishing campaigns, social engineering attacks, malware distribution, affiliate abuse, and trademark infringement. It also demonstrates that the additional terms are generally tailored to the business sector of the targeted trademark in order to increase the plausibility of the domain name and reinforce Internet users’ trust (Kintis et al., Hiding in Plain Sight: A Longitudinal Study of Combosquatting Abuse, CCS 2017).

Football provides a particularly compelling illustration of this phenomenon. Football clubs offer a wide range of readily identifiable services, products, and activities, including ticketing services, official online stores, academies, supporters’ areas, membership programmes, competitions, and branded merchandise. Adding terms such as tickets, shop, store, academy, membership, official, or the name of a competition does not distract from the trademark. On the contrary, it enhances the overall plausibility of the domain name by evoking services that the trademark owner might objectively be expected to provide. Accordingly, this technique is not intended merely to reproduce the distinctive sign, but to exploit the trademark’s essential function as an indicator of origin. By suggesting that the domain name is operated, authorised, or otherwise economically connected with the football club, the cybersquatter seeks to create a likelihood of confusion as to the origin of the services or, at the very least, as to the existence of an economic connection with the trademark owner. The effectiveness of combosquatting therefore lies less in the visual similarity of the signs than in its ability to replicate Internet users’ legitimate expectations and to appropriate both the trademark’s distinctive function and its power of attraction.

The following decisions illustrate the close correspondence between the composition of the domain name and its actual use. In most cases, the additional term appended to the club’s name foreshadows the function of the associated website or service. In others—most notably the Liverpool Academy case—it facilitates a more sophisticated form of identity impersonation through the use of email addresses.

The table highlights a consistent pattern: in almost every case, the additional term foreshadows the intended use of the domain name. Internet users do not discover the purpose of the website only after accessing it; rather, that purpose is already suggested by the domain name itself. The composition of the domain name and its subsequent use therefore form part of the same strategy, reinforcing the appearance of legitimacy while increasing the likelihood of confusion.

This observation reflects an important evolution in cybersquatting practices. Domain names are no longer used merely to capture the value associated with a trademark or to divert Internet traffic. Instead, they have become the infrastructure for more sophisticated forms of abuse, including fraudulent ticket sales, the marketing of counterfeit goods, the impersonation of official academies, the dissemination of misleading information, and the promotion of purported digital products. A domain name is no longer merely a technical address; it has become the first link in a chain of deception that begins with the domain name itself, continues on the associated website, and then unfolds according to the particular form of fraudulent activity.

4.3 Ticketing, Online Stores, and the Appearance of Official Status

Ticketing provides one of the clearest illustrations of this evolution. In Chelsea Football Club Limited v. Official Tickets Ltd (<official-chelsea-tickets.com>) (WIPO Case No. D2008-1574), the disputed domain name was used for a commercial website offering tickets for Chelsea matches. The following year, several English football clubs brought a joint complaint against the domain names <official-fulham-tickets.com>, <official-liverpool-tickets.com>, <official-manchester-tickets.com>, <official-tottenham-tickets.com>, and <official-westham-tickets.com> in Fulham Football Club (1987) Limited et al. v. Domains by Proxy, Inc. / Official Tickets Ltd. (WIPO Case No. D2009-0331). This decision also illustrates the procedural advantages of complaint consolidation under the UDRP. Where the same conduct affects multiple rights holders, or where several domain names appear to be under common control, panels may permit a single complaint to proceed, provided that consolidation is fair and equitable to all parties and promotes procedural efficiency (WIPO Overview 3.0, section 4.11). This mechanism is particularly valuable where coordinated campaigns target several football clubs simultaneously through domain names following the same pattern, thereby avoiding the need for multiple proceedings concerning closely related facts.

The word “official” is decisive. It does more than reinforce confusion; it makes a promise. The choice is a particularly astute one. A football supporter searching for a ticket to a sold-out or highly anticipated match is unlikely to conduct extensive due diligence on the seller’s legal identity, company registration number, or corporate structure. They simply want a ticket—preferably before someone else gets it. In this context, urgency and scarcity become the fraudster’s greatest allies. This vulnerability explains why football ticketing has become a preferred target for fraudsters. Major international tournaments and high-profile matches regularly give rise to schemes involving counterfeit or non-existent tickets, as well as criminal prosecutions for fraud. In 2025, for example, several individuals in the United Kingdom were convicted for operating a fraudulent Liverpool FC ticket resale scheme, while law enforcement authorities and event organisers continue to warn supporters against counterfeit tickets offered through unauthorised websites (Crown Prosecution Services, 27 August 2024 ; UK Police, 14 January 2025).

The same pattern can be observed in relation to online stores. Domain names such as <galatasaraystore.com> (Galatasaray Spor Kulübü Derneği v. Maksimum İletişim A.Ş., WIPO Case No. D2003-0018), <soccerparissaintgermainshop.com> (Paris Saint-Germain Football v. Name Redacted, WIPO Case No. D2023-3126), <thebayernmunichsoccershop.com> (FC Bayern München AG v. WhoisGuard Protected, WhoisGuard, Inc. / zhangyl, WIPO Case No. D2016-0060), <bayernmunichfcproshop.com> (FC Bayern München AG v. Domain Admin, Whois Privacy Corp. / Name Redacted, WIPO Case No. D2017-0516), <spurskit.com>, <spurskits.com> and <tottenhamhotspurstore.com> (Tottenham Hotspur Football and Athletic Co. Ltd v. Carolina Rodrigues, Fundacion Comercio Electronico, WIPO Case No. D2025-2937) demonstrate that cybersquatting is no longer aimed solely at diverting Internet traffic. It can also be used to create a storefront, establish a commercial presence, and operate what appears to be an official online store.

4.4 The Domain Name as a Storefront for Counterfeit Goods

Counterfeiting represents one of the most significant developments observed in the dataset. Of the 102 decisions identified, 24 concern online stores, merchandising, or other activities relating to the sale of football products. Eight of these cases were more specifically classified as involving counterfeit or otherwise manifestly unlawful goods.

4.4.1 Chelsea

The case of Chelsea FC plc v. chen xiaofei, concerning the domain name <chelseajersey.net> (WIPO Case No. D2015-1242), provides a particularly clear illustration of this evolution. The domain name combined the CHELSEA trademark with the word “jersey”, referring precisely to the product sought by football supporters. The associated website reproduced the club’s official crest and offered numerous Chelsea shirts as though they were sold through an official club store, even though the respondent had never been authorised to use the trademark.

The manner in which counterfeiting was established is also noteworthy. The complainant had not carried out a test purchase. Instead, it submitted a witness statement from its Licensing Manager confirming that the products offered on the respondent’s website were counterfeit: “The Complainant submitted a Witness Statement from its Licensing Manager confirming that the products sold upon the Respondent’s website are counterfeit items” (WIPO Case No. D2015-1242). In the absence of any response from the respondent, the Panel accepted this statement as sufficient evidence that the website was offering counterfeit goods.

The Panel further found that the combined use of the trademark in the domain name, the club’s visual identity on the website, and the offering of counterfeit goods created a clear impression of affiliation with Chelsea FC. The respondent was therefore seeking to attract Internet users for commercial gain by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of the website and the products offered.

This decision demonstrates that, in cases of this kind, the domain name is only one component of a broader fraudulent scheme. The resulting confusion arises from the combination of a suggestive domain name, the reproduction of the trademark and the club’s visual identity, and the marketing of counterfeit goods presented as authentic. The domain name thus serves as the digital storefront for a counterfeiting operation.

4.4.2 Bayern Munich

The case of FC Bayern München AG v. Whoisguard Protected, Whoisguard, Inc. / Name Redacted, concerning the domain name <fcbayernsoccershop.com> (WIPO Case No. D2016-2282), illustrates a comparable strategy. The domain name combined the FC BAYERN trademark with the expression “soccer shop”, suggesting the existence of an official store specialising in club merchandise. The associated website reproduced the FC BAYERN and FC BAYERN MUENCHEN trademarks and offered various items for sale as official club products.

The complainant argued that the goods being sold were counterfeit and that the respondent had never been authorised to use its trademarks. The Panel found that the respondent was exploiting the club’s trademarks both in the domain name and on the associated website in order to create the misleading impression of an official online store. It concluded that such use could neither constitute a bona fide offering of goods or services nor a legitimate non-commercial or fair use of the domain name. Rather, it demonstrated an intention to exploit the reputation of the complainant’s trademarks for commercial gain.

4.4.3 Manchester United

Two decisions issued in 2020 concerning Manchester United likewise illustrate this evolution. In Manchester United Football Club Limited v. Domain Admin, Whois Privacy Corp. / Name Redacted (WIPO Case Nos. D2020-1848 and D2020-1849), the respondents had registered the domain names <manutdfcteamshop.com>, <soccermanchesterunitedjersey.com>, <cheapjerseysmanchesterunited.com>, and <cheapmanchesterunitedshop.com>. Their composition left little doubt as to their intended purpose. Each combined the MANCHESTER UNITED trademark with terms such as team shop, jersey, or cheap, all directly suggestive of an online store specialising in Manchester United merchandise.

The associated websites reproduced the complainant’s trademarks, adopted Manchester United’s visual identity, and offered for sale products presented as official club merchandise. The Panel found that these elements demonstrated a deliberate intention to create the appearance of affiliation with the club in order to attract Internet users for commercial gain. Such use could neither constitute a bona fide offering of goods or services nor a legitimate non-commercial or fair use of the domain names.

These two decisions also show that counterfeiters increasingly think in terms of domain name portfolios rather than isolated registrations. Multiple domain names are registered around the same trademark, each targeting a particular Internet search query (team shop, jersey, cheap shop, and so forth), thereby multiplying the entry points to the same unlawful commercial operation. The domain name thus becomes both a search engine optimisation tool and a means of capturing Internet traffic in furtherance of a genuine commercial strategy.

4.4.4 Paris Saint-Germain

Paris Saint-Germain has likewise been confronted with several series of domain names constructed around the very product sought by its supporters. The cases Paris Saint-Germain v. HJ concerning <maillotfootpsg.com>, <maillotfootpsgpascher.com>, and <maillotpsgpascher.com> (WIPO Case No. D2015-0126), followed by Paris Saint-Germain v. Whois Privacy Protection Service, Inc. / Domain Admin concerning <psgmaillot.com>, <psgmaillots.com>, <maillotspsg.com>, and <psgjerseys.com> (WIPO Case No. D2015-1396), illustrate this lexical specialisation centred on football shirts.

The additional terms were not chosen at random. They correspond to the search queries most likely to be entered by Internet users looking for a Paris Saint-Germain shirt: maillot, maillots, jersey, or “pas cher” (“cheap”). The cybersquatter therefore does more than merely reproduce the PSG trademark. Rather, it anticipates supporters’ search behaviour and constructs the domain name accordingly. The domain name thus performs a dual function: it identifies the targeted trademark while capturing Internet users precisely at the moment they are searching for a specific product.

4.4.5 The Domain Name as the Cornerstone of the Counterfeiting Strategy

The decisions examined show that a domain name is no longer designed merely to reproduce a trademark. Instead, it is constructed around the terms that Internet users are likely to enter when searching for a specific product, such as jersey, maillot, shop, store, or tickets. In doing so, the cybersquatter simultaneously exploits the reputation of the trademark, consumers’ search behaviour, and search engine optimisation mechanisms in order to increase the website’s visibility while reinforcing the likelihood of confusion.

The domain name therefore performs a role that extends far beyond that of a mere technical address. It constitutes the first component of the commercial strategy by signalling the nature of the products being offered and suggesting the existence of an official or authorised online store. The presentation of the website, the reproduction of the club’s trademarks and visual identity, and the offering of counterfeit goods merely reinforce the impression initially created by the domain name.

Counterfeiting is therefore no longer confined to the goods being sold. It forms part of a broader digital infrastructure in which the domain name serves as the first point of contact with consumers and underpins an overall strategy of traffic acquisition, the creation of an appearance of official status, and the marketing of counterfeit goods.

4.4.6 Arsenal v. Reed: Football Shirts, Supporters, and the Function of the Trademark

Any analysis of counterfeiting, particularly in the context of football, almost inevitably begins with the judgment in Arsenal Football Club plc v. Matthew Reed, C-206/01, delivered by the Court of Justice of the European Communities on 12 November 2002.

The case did not concern a domain name. For several years, Matthew Reed had been selling scarves and other merchandise bearing, among other things, the ARSENAL signs in the vicinity of Arsenal’s stadium. Notices displayed at the stall stated that the goods were unofficial. One of the central legal issues concerned the way in which supporters perceived those signs. The club’s name and emblems could be understood as expressions of support, loyalty, or affiliation rather than as indicators of the commercial origin of the goods.

The Court nevertheless reaffirmed that the essential function of a trademark is to guarantee to consumers the identity of origin of the goods or services. Accordingly, the proprietor must be able to prevent the use of an identical sign where such use affects, or is liable to affect, that essential function. In the circumstances of the case, the Court held that the use of signs identical to Arsenal’s trademarks was liable to undermine that guarantee of origin. It was therefore immaterial that those signs might also be perceived as expressions of support, loyalty, or affiliation with the club.

More than twenty years later, the setting has changed, but the legal contest remains remarkably familiar. A supporter may search for a football shirt because they wish to express their attachment to a club. That motivation does not negate the trademark function performed by the sign affixed to the product. Nor does it diminish the signals of origin or affiliation conveyed by the name of an online store, its content, and its domain name.

The out-of-court decisions examined in this article demonstrate precisely how those signals can be combined. <chelseajersey.net> associates the club’s name with the product being sought. <thebayernmunichsoccershop.com> and <bayernmunichfcproshop.com> present themselves as specialist online stores. <soccerparissaintgermainshop.com> follows the same pattern. In this context, the domain name forms part of the commercial environment in which consumers assess the origin of the goods or their affiliation with the club.

The judgment in Arsenal v. Reed concerned a market stall located outside a football stadium. Contemporary cases have simply moved that stall onto the Internet. The seller is no longer necessarily positioned along the route to the match. Instead, it may operate thousands of kilometres away from the supporter while remaining open twenty-four hours a day. Yet the underlying mechanism remains essentially the same: using the club’s signs to incorporate unauthorised goods into its commercial universe. The domain name merely adds another dimension. It can create the appearance of official status before the consumer has even seen the first football shirt. In that sense, cybersquatting can be said to prepare the ground for counterfeiting.

5 Disputes Resolved Almost Exclusively Through Out-of-Court Proceedings

The prominent role played by out-of-court proceedings is no coincidence. Disputes involving domain names targeting football clubs appear relatively rarely before national courts or, at the very least, seldom result in published decisions that are readily accessible.

This situation is partly explained by the effectiveness of specialised dispute resolution mechanisms. The UDRP and comparable procedures generally enable the transfer or cancellation of a domain name to be obtained more quickly and at a more predictable cost than court proceedings. Where a club’s primary objective is simply to regain control of the disputed domain name as swiftly as possible, there may be little practical advantage in pursuing lengthier judicial proceedings.

A small number of cases have nevertheless been brought before the courts.

The dispute concerning <corinthians.com> provides an important illustration. After losing the UDRP proceeding initiated by the Brazilian club Corinthians Licenciamentos Ltda. (WIPO Case No. D2000-0461), the domain name registrant commenced proceedings before the United States federal courts. In Sallen v. Corinthians Licenciamentos Ltda., 273 F.3d 14 (1st Cir. 2001), the United States Court of Appeals for the First Circuit held that a registrant who has been unsuccessful in a UDRP proceeding may seek an independent judicial determination of its rights under the Anticybersquatting Consumer Protection Act (ACPA). The Court did not, however, decide the merits of the dispute. Instead, it remanded the case to the District Court for consideration of the registrant’s claims. No subsequent published decision appears to have finally resolved the dispute.

This case highlights an important distinction. A UDRP decision does not bind the competent courts. Although UDRP proceedings are adjudicative in nature—in that the dispute is determined by one or more independent decision-makers applying legal principles and issuing a binding decision as to the disposition of the domain name—the resulting decision does not possess the finality of a judicial judgment or an arbitral award. Paragraph 4(k) of the UDRP provides that either party may submit the dispute to a court of competent jurisdiction, which conducts an independent review of the case without being bound by the findings of the administrative panel.

In Germany, the dispute concerning the domain name <fc.de> illustrates the application of the right to a name outside the framework of out-of-court proceedings. In a judgment delivered on 9 August 2016 (LG Köln, Urteil vom 9. August 2016, Az. 33 O 250/15), the Court held that, in the particular circumstances of the case, the initials “FC” were sufficiently associated in the public mind with 1. FC Köln to benefit from the protection afforded by Section 12 of the German Civil Code (Bürgerliches Gesetzbuch (BGB)). Finding that the registration of <fc.de> created a likelihood of misattribution of the name, the Court ordered the domain name registrant to cease using the domain name and to consent to its deletion by DENIC. The dispute was subsequently settled on appeal, however, with the result that the judgment was never affirmed by a higher court.

That said, caution is warranted. Some disputes may have been resolved through settlement agreements, unpublished court orders, interim measures, or judgments that are insufficiently indexed and therefore difficult to identify. Others may have been resolved before any hearing through a cease-and-desist letter, registrar suspension, or an out-of-court proceeding.

The relative scarcity of judicial decisions nevertheless remains significant. For more than twenty-five years, specialised mechanisms, including the UDRP, have absorbed a substantial proportion of cybersquatting disputes. For football clubs, they have become the natural—and unquestionably the fastest—avenue where the principal objective is to recover control of the disputed domain name.

That specialisation, however, also has its limits. A UDRP proceeding cannot award damages, seize counterfeit goods, identify all the actors involved in a fraudulent campaign, or order broader measures designed to prevent the re-emergence of infringing variants. The UDRP may win back the ball, but it cannot dismantle the opposing team.

6 Optimising Domain Name Portfolio Management

The findings drawn from our dataset invite a re-examination of defensive domain name management. Faced with the ever-growing number of possible combinations, the systematic registration of variants is no longer a realistic strategy. Effective portfolio protection now requires identifying priority domain names, assessing the risks associated with different top-level domains, making use of available blocking mechanisms, and strengthening the detection of registrations that may serve as vehicles for abusive activities.

6.1 Building Multiple Layers of Defence

Defensive portfolio management must take account of these developments. It is no longer sufficient to register the club’s exact name under a handful of top-level domains. Nor is it realistic to register every conceivable variation. Attempting to cover every inch of the pitch usually means leaving gaps everywhere.

The decisions analysed highlight the importance of certain keywords. “FC” appears frequently. Terms such as “official”, “tickets”, “shop”, “store”, “jersey”, “kit”, “academy”, “news”, and “token” also play an obvious role. Their significance must be assessed in light of the club’s business model. A club whose online store is a core commercial asset does not face the same risk profile as one whose international activities rely more heavily on academies, ticket sales, or digital content.

A rational strategy should distinguish between several layers of defence. The first consists of the domain names actually used by the club: its official name, principal trademarks, and distinctive acronyms. These are the undisputed starters: they must always be in the starting line-up and renewed without fail.

The second layer concerns critical combinations, particularly those combining the trademark with high-risk terms such as “official”, “tickets”, “shop”, “store”, “jersey”, or “academy”. Their relevance depends on the club’s business profile and commercial activities.

The third layer comprises variants that do not necessarily warrant defensive registration but should nevertheless be actively monitored. These may include combinations of the trademark with generic terms (“tickets”, “shop”, “academy”, “streaming”, “fan”, “jersey”), geographical indicators (“uk”, “paris”, “usa”), descriptive qualifiers (“official”, “vip”, “live”), or common typographical errors and letter transpositions. As the possible combinations are virtually limitless, a policy of registering each of these variants proactively would be both unrealistic and economically unjustifiable. In this category, an active monitoring strategy—enabling potentially abusive registrations to be detected quickly and action to be taken once they become genuinely problematic—is generally more effective than an approach based on the continual accumulation of domain names.

This approach makes it possible to distinguish between what should be registered, what can be blocked, and what should be monitored.

6.2 When the Top-Level Domain Comes into Play

Top-level domains also play a more important role than might initially appear. Although .com remains the dominant extension in our dataset, several decisions involving specialised top-level domains are particularly revealing, including <parissaint-germain.club>, <blaugrana.club>, <chelseafc.futbol>, <barça.futbol>, and <fcb.email>.

These top-level domains are not neutral from the perspective of user perception. The .club extension naturally reinforces the impression of a sports organisation or a community space. .futbol immediately places the sign within the world of football. .email may create a particular risk where the domain name is used—or is simply capable of being used—for deceptive communications.

Not all top-level domains present the same level of risk. Since the introduction of the new gTLDs in 2012, it has no longer been realistic to register a trademark systematically under every available extension. An effective strategy instead requires prioritising registrations according to the degree of credibility that a particular top-level domain lends to the domain name, the club’s business activities, and the types of abuse observed in practice. For football clubs, that hierarchy may be summarised as follows.

This classification is, of course, not absolute and must be adapted to each club’s strategy. A club with a strong international profile will naturally attach particular importance to the principal ccTLDs corresponding to its key markets, while a club expanding its online store or ticketing operations may choose to strengthen protection for the top-level domains most closely associated with those activities. The essential point, however, lies elsewhere: not all top-level domains are created equal. The more a top-level domain enhances the credibility of a domain name in the eyes of supporters, the stronger the case for including it in a defensive registration strategy. Conversely, for the hundreds of remaining top-level domains, blocking mechanisms, active monitoring, and rapid recovery procedures will generally provide a more efficient response than a policy of systematic defensive registration.

6.3 GlobalBlock and GlobalBlock Plus: “Parking the Bus” Is No Longer Enough

For many years, defensive registrations were one of the cornerstones of domain name portfolio protection. To borrow a football expression: “Park the bus!” The idea remains sound. But the attackers have clearly done their homework. They no longer seek merely to break through the defence; they now exploit the spaces that it cannot realistically cover. As the number of top-level domains, lexical variations, and cybersquatting techniques continues to grow, a strategy based exclusively on defensive registrations inevitably becomes insufficient.

Defensive blocking services, such as GlobalBlock and GlobalBlock Plus, have changed part of the equation. Rather than defensively registering large numbers of domain names across multiple top-level domains, rights holders can block strings corresponding to their trademarks across participating top-level domains. GlobalBlock Plus extends this approach to certain variants, including strings that are visually or typographically similar.

For football clubs, these tools can be particularly valuable. Clubs often own well-established trademarks, distinctive acronyms, and highly exposed signs. A blocking mechanism can reduce administrative costs, minimise the risk of accidentally allowing defensive registrations to lapse, and prevent certain abusive registrations before any website is even launched.

Our dataset of decisions nevertheless suggests that it is too early to celebrate after the opening goal. A significant proportion of the abusive registrations identified do not rely on a simple typographical error or a homograph. Instead, they consist of adding a term that gives the domain name a plausible function: official-chelsea-tickets, liverpoolfootballclubacademy, tottenhamfantoken, or soccerparissaintgermainshop.

The issue, therefore, is not merely formal similarity to the trademark. It lies in the semantic combination of the trademark with a plausible service. Blocking should therefore be regarded as an additional layer of protection rather than a complete solution. A robust strategy may be summarised as follows: register what is actually used, block what can effectively be blocked, monitor what remains, and prioritise enforcement according to the domain name’s actual use.

6.4 Detecting Risky Domains

The objective is no longer merely to react once a fraudulent website is online, but to identify high-risk domain names as soon as they are registered. New domain registration monitoring services can now generate alerts within minutes—or at most a few hours—of the registration of a domain name reproducing a trademark, one of its variants, or predefined keywords. This early detection provides a decisive advantage: it enables a rapid assessment and, where appropriate, prompt action before the domain name is put to use.

Monitoring services now make it possible to identify a domain name as soon as it is registered if it reproduces a trademark or one of its variants. Newly registered domain names are generally compiled into reports delivered at predefined intervals—daily, weekly, or monthly—allowing trademark owners to identify potentially infringing registrations at an early stage.

The reporting frequency can, however, be adapted to the club’s level of exposure. Transfer windows, the semi-finals and finals of European competitions, major international tournaments, the launch of new kits, season-ticket campaigns, and high-profile player signings are all periods during which the risk of cybersquatting increases significantly. A monitoring programme that normally relies on monthly reports may therefore be supplemented, on a temporary basis, by weekly or even daily reports.

The most advanced monitoring tools do more than simply identify newly registered domain names. They also prioritise them according to their level of risk. This assessment may take into account a range of factors, including the composition of the domain name (for example, the combination of the trademark with terms such as official, tickets, shop, academy, or fan token), the top-level domain used, the activation of DNS services, the presence of MX records, the issuance of a TLS certificate, or the appearance of accessible website content. This prioritisation enables legal teams to focus their efforts on the domain names presenting the highest level of risk.

Monitoring should not end with registration. A domain name registered today may remain inactive for weeks or even months before being put to use. It is therefore equally important to track its subsequent evolution, including changes of registrant, registrar, or DNS servers, the creation of MX records, the issuance of a TLS certificate, the activation of a website or email service, or the appearance of fraudulent content. Continuous monitoring enables rights holders to intervene as soon as the risk becomes real, while preserving a technical history that may later constitute valuable evidence.

7 Detecting Infringements Beyond the Domain Name

A domain name is often only the first indication of a broader infringement of trademark rights. The same actors frequently exploit multiple digital channels to maximise the visibility of their offerings, including websites, online marketplaces, social media platforms, sponsored advertising, messaging applications, and video-sharing platforms. An effective brand protection strategy can therefore no longer be limited to monitoring domain names alone. It requires comprehensive monitoring of the brand’s entire digital environment.

In practice, such monitoring now extends to a wide range of sources. It enables the identification of newly registered domain names, fraudulent websites, listings for counterfeit goods on major online marketplaces, advertising campaigns distributed through services such as Google Ads and social media advertising platforms, as well as accounts making unauthorised use of the trademark across the principal social media platforms. The same approach can also be applied to mobile applications, app stores, video content, and specialised online marketplaces.

The sheer volume of available information, however, makes exclusively manual monitoring impracticable. Millions of new domain names are registered every month, while advertisements, social media posts, and sponsored content are constantly being created and updated. Artificial intelligence tools can automate part of this process by identifying textual and visual similarities, recognising logos and products, and prioritising results according to their level of risk. Their purpose is not to replace human expertise, but to enable it to focus on the infringements most likely to cause harm to the trademark owner.

The real innovation, however, lies in the ability of these tools to correlate information originating from different sources. A recently registered domain name may be associated with a Google Ads campaign, redirect users to a storefront hosted on an online marketplace, be promoted by multiple social media accounts, and advertise products identical to those already offered by another seller. Considered in isolation, each of these elements provides only a clue. Taken together, they make it possible to reconstruct an entire fraud or counterfeiting operation.

Brand protection is therefore evolving towards a 360-degree monitoring approach, in which the domain name is no longer the sole focus, but merely one entry point among many. The objective is no longer simply to detect isolated infringements, but to map the entire digital ecosystem used to exploit a trademark unlawfully and to take prompt action against each of its components.

Identifying an infringement is not, however, an end in itself. It has value only if it enables a swift response. Depending on the platform concerned, that response may take the form of a content takedown, an account suspension, the removal of a listing, an out-of-court domain name proceeding, or, where appropriate, judicial action. Brand protection therefore depends not only on the ability to detect infringements, but also on the capacity to deploy, in a coordinated manner, the various enforcement mechanisms available to bring them to an end.

This evolution also confirms the changing role of the domain name. Long regarded as the primary object of the infringement, it is now better understood as one component of a much broader digital infrastructure, combining websites, online marketplaces, social media platforms, advertising campaigns, and other online services. Protecting football clubs therefore no longer consists merely of recovering an infringing domain name. It requires understanding and monitoring the entire digital ecosystem in which that domain name operates.

8 Conclusion

The decisions examined in this study show that cybersquatting targeting football clubs has fundamentally changed in nature. In the earliest cases, the domain name was often the very object of the misappropriation. It was registered, retained, offered for sale, or used to divert traffic intended for the club. Gradually, however, it has become something more. By combining the club’s name with terms such as official, tickets, shop, jersey, or academy, cybersquatters no longer merely reproduce a trademark. They signal a service, create an appearance of legitimacy, and lay the groundwork for the use that will follow. The domain name thus becomes the digital storefront for a ticketing platform, an online store, an academy, or a counterfeiting operation.

This evolution requires moving beyond a brand protection strategy based solely on defensive registrations. It remains essential to register key domain names, block certain variants, and monitor high-risk registrations. More importantly, however, it requires monitoring how those domain names are actually used and connecting information emerging across multiple channels, including websites, online marketplaces, social media platforms, sponsored advertising, mobile applications, and messaging services. Considered individually, each reveals only part of the infringement. Taken together, they reveal its underlying architecture.

Out-of-court proceedings often enable rights holders to regain control of a domain name quickly. They do not, however, resolve the broader problem, since the transfer of a domain name does not remove the advertisements, social media accounts, online listings, or other channels through which the fraudulent operation continues.

The question is therefore no longer simply which domain names a football club should register or recover. It is to understand what those domain names make possible and the digital ecosystem of which they form part.

The domain name remains the entry point of the abuse. Increasingly, however, it is only the kick-off.

9 About IP Twins

IP Twins assists trademark owners in protecting their brands and digital assets. Its services include strategic domain name portfolio management, new domain registration monitoring, the detection of cybersquatting, phishing, impersonation, and online counterfeiting, as well as the implementation of takedown and domain name recovery procedures.

By combining legal expertise, technical analysis, and advanced monitoring technologies, IP Twins helps companies, public institutions, and sports organisations identify infringements, prioritise risks, and coordinate enforcement actions across domain names, websites, online marketplaces, social media platforms, advertising platforms, and other digital services.