Introduction

In 1978, Michel Platini was promoting a fruit juice called “Fruité” on television. In 2026, Cristiano Ronaldo is selling CR7 online. Between these two eras, football has undergone a profound business transformation: players have evolved from brand ambassadors into trade mark owners. For many years, football stars lent their reputation to advertisers, putting their image at the service of brands they did not own. That reality has not disappeared. However, today’s biggest names in football no longer simply endorse brands, they build their own. Their names, initials, signatures, shirt numbers, personal logos and even their goal celebrations have become intangible assets capable of being registered, commercialised, licensed, assigned and enforced on a global scale.

The examples of David Beckham, Cristiano Ronaldo, Lionel Messi, Neymar Jr., Kylian Mbappé, Sam Kerr, Pelé and Maradona illustrate this transformation. Their trade mark portfolios demonstrate that modern football is now played as much in intellectual property registers, domain name databases and digital platforms as it is on the pitch.

This transformation of athletes’ identities into valuable commercial assets has, however, an immediate consequence: value inevitably attracts misuse. Once an intangible asset acquires economic value, it becomes vulnerable to imitation, misappropriation, registration by third parties, incorporation into abusive domain names, use in the marketing of counterfeit goods, or exploitation for the purposes of online impersonation.

This article therefore pursues a twofold objective. It first examines the main threats affecting players’ intangible assets, including counterfeiting, cybersquatting and online impersonation. It then explores the mechanisms available to protect them through a strategy combining rights governance, trade marks, domain names, digital monitoring, Online Brand Protection and appropriate enforcement procedures.

1. Risks to Players’ Intangible Assets

The media exposure of professional athletes, the globalisation of sport, the growth of the Internet and the proliferation of digital platforms have created an environment particularly conducive to infringements targeting their commercial identity, including counterfeiting (1.1.) and cybersquatting (1.2.).

1.1. Counterfeiting 

The first category of infringement concerns the marketing of products that reproduce or imitate, without authorisation, the intangible assets associated with players: counterfeiting. In professional football, counterfeiting rarely targets a single right in isolation. A single product may simultaneously reproduce several protected elements, including the trade marks of a club or national team, those of the kit manufacturer, as well as a player’s name, shirt number or other distinctive signs associated with their identity.

The economic scale of the phenomenon regularly becomes apparent during major international sporting events. For example, in the lead-up to the 2026 FIFA World Cup, a coordinated operation conducted by the Spanish National Police, with the support of Europol, Interpol, the European Union Intellectual Property Office (EUIPO) and the European Anti-Fraud Office (OLAF), resulted in the seizure of more than 66,000 counterfeit football shirts and kits, representing over sixteen tonnes of goods (EUIPO, More than 66,000 Fake Football Jerseys Seized Ahead of FIFA World Cup 2026, euipo.europa.eu, 17 June 2026). The authorities estimated the potential losses suffered by rights holders at more than EUR 7 million and arrested ninety-five individuals. The seized goods included counterfeit jerseys of several national teams and were intended for sale through markets, social media platforms and e-commerce websites.

Other enforcement operations carried out ahead of the tournament further illustrate the global scale of the phenomenon. In Toronto, for example, authorities seized more than 16,000 counterfeit goods reproducing, among others, the FIFA, Nike, Adidas and Puma trade marks (« Toronto police seize $2.5 million worth of fake soccer gear ahead of World Cup », reuters.com, 1st June 2026). Similarly, Hong Kong Customs seized approximately 230,000 suspected counterfeit items, including nearly 30,000 counterfeit football jerseys, many of which were destined for the North American markets hosting the FIFA World Cup (« Hong Kong customs seize $20 million in fake goods ahead of the World Cup », apnews.com, 11 juin 2026).

For the world’s most high-profile players, counterfeiting extends far beyond the reproduction of official jerseys. It often involves exploiting the economic value attached to their identity. Jerseys bearing the names of Messi, Ronaldo, Mbappé and other international football stars consistently rank among the most sought-after products by supporters and, consequently, among the most attractive targets for counterfeiting networks. A player’s name has clearly become a valuable commercial asset, and its unauthorised use directly contributes to the profitability of counterfeit goods.

Moreover, infringement is no longer confined to physical products. The digitalisation of the sports economy has created new opportunities for the unlawful exploitation of the commercial value associated with players, allowing it to be reproduced, marketed or misappropriated without authorisation. The case of Juventus FC v. Blockeras S.r.l. (Tribunale di Roma, ordonnance du 20 juillet 2022) provides a particularly compelling illustration. The court granted interim relief ordering the cessation of the marketing of non-fungible tokens (NFTs) depicting former player Christian Vieri wearing Juventus colours, holding that the unauthorised use of the club’s trade marks and other distinctive signs was capable of constituting trade mark infringement and acts of unfair competition. In other words, a single digital representation may simultaneously incorporate several categories of intellectual property rights, sometimes belonging to different rights holders. New digital assets, such as NFTs, are therefore subject to the same traditional mechanisms of intellectual property protection.

1.2 Cybersquatting

Trade marks and domain names evolve like twins: distinct in their legal nature, yet closely intertwined in their economic function. A trade mark identifies the commercial origin of goods or services, while a domain name provides access to the digital environment associated with that trade mark.

Among the various forms of infringement affecting players’ intangible assets, cybersquatting occupies a unique position. Unlike traditional counterfeiting, which primarily targets goods or services, cybersquatting directly targets an athlete’s digital identity. A player’s name, having become a distinctive sign and, in many cases, a registered trade mark, is registered as a domain name by third parties seeking to profit from the player’s reputation, public profile or the trust they inspire among consumers.

More than two decades of case law now make it possible to trace the evolution of these practices. Decisions issued in out-of-court domain name dispute resolution proceedings show that abusive uses have gradually diversified over time. Early cases primarily involved speculative domain name registrations intended either to be resold to the player concerned or to generate advertising revenue through parking pages. With the growth of e-commerce, social media and digital technologies, domain names have become gateways to far more sophisticated schemes, including fake websites, unauthorised online stores, traffic diversion, identity theft, the collection of personal data and phishing attacks.

The table below sets out a selection of landmark decisions involving professional football players. Together, these decisions illustrate the wide range of abusive practices that have emerged over time.

An analysis of these decisions illustrates the gradual evolution of cybersquatting targeting professional football players. The earliest disputes primarily involved speculative domain name registrations made in the hope of subsequently selling the domain name to the player concerned or capitalising on the Internet traffic generated by their reputation. The Totti, Joe Cole and Wayne Rooney cases are emblematic of this first generation of cybersquatting, in which the domain name was essentially regarded as a tradable asset. The principal harm lay in the player’s inability to use the domain name corresponding to their identity and the need to initiate proceedings in order to recover it.

More recent decisions, however, reveal a significant evolution in abusive practices. Domain names are now used to create an appearance of legitimacy. The cases involving David Beckham, Lionel Messi and Kylian Mbappé illustrate how a domain name can be used to replicate a player’s digital identity, promote unauthorised products, divert Internet traffic or collect information from the public. This trend has been facilitated by new technologies that enable the creation of convincing websites quickly and with limited resources. As a result, the risk no longer lies solely in the misappropriation of the sign itself, but also in the exploitation of the trust associated with the athlete’s identity.

Case law also highlights a particularly interesting phenomenon: cybersquatting does not target only well-established players. On the contrary, several decisions demonstrate cybersquatters’ ability to anticipate the future creation of commercial value. The Wayne Rooney case is particularly illustrative in this respect. The disputed domain name was registered when the player was still a promising young talent in English football. Similarly, a number of cases show that domain name registrants seek to identify, at a very early stage, athletes who are likely to achieve significant media exposure. Cybersquatting therefore appears to be driven not only by the exploitation of existing reputation, but also by speculation on future fame.

This ability of cybersquatters to anticipate a player’s future commercial value stems from the fact that an athlete’s name may become an economic asset long before a trade mark portfolio has been established. Case law quickly recognised this reality. In Madonna Ciccone p/k/a Madonna v. Dan Parisi and Madonna.com (OMPI, D2000-0847), a three-member Panel held that the name MADONNA constituted a protectable commercial identifier by virtue of its commercial exploitation and widespread reputation. This reasoning is equally relevant to professional athletes, whose names may acquire considerable commercial value from the very early stages of their careers. Nevertheless, once that value becomes significant, trade mark registration remains the most effective means of securing the asset and facilitating its enforcement against cybersquatting and other forms of unauthorised exploitation.

2. Protecting Players’ Intangible Assets

Enhancing the commercial value of a player’s identity is only the first step. It is equally important to establish an effective framework for the protection, management and commercial exploitation of the intangible assets that now form part of the player’s economic estate. This process begins with a clear allocation of rights and responsibilities among the various stakeholders involved in the player’s ecosystem (2.1.). It also requires the development of appropriate intellectual property portfolios, including trade marks protecting the player’s name, logos, celebrations and other distinctive signs (2.2.), as well as domain names securing the player’s digital identity (2.3.). In addition, it calls for continuous monitoring of the digital environment in order to detect infringements at an early stage (2.4.). Finally, whenever an infringement is identified, the most appropriate enforcement mechanisms must be deployed, whether through takedown procedures, alternative dispute resolution proceedings, administrative actions or judicial remedies (2.5.).

2.1. Governance of Players’ Intangible Assets

The protection of a player’s intangible assets depends on the coordinated involvement of several professionals, each acting within their own area of expertise. This allocation of responsibilities is essential, as an athlete’s personal brand lies at the intersection of law, marketing, technology, cybersecurity and commercial management. The table below identifies the principal stakeholders and summarises their respective roles within this ecosystem.

This mapping illustrates that protecting a personal brand extends far beyond filing a trade mark or occasionally recovering a domain name. It requires a comprehensive governance framework for the player’s intangible assets. It is essential to determine who owns the rights, who exploits them, who monitors infringements, who decides when to take action, who gathers the evidence and who oversees the enforcement proceedings.

Without such an organisational framework, the risks multiply: forgotten domain names, trade marks that are not renewed, undetected fraudulent accounts, poorly structured licensing agreements, insufficient evidence, or enforcement action taken too late. In professional football, the value of a personal brand therefore depends as much on the quality of the registered rights as on the ability of the various stakeholders to act swiftly and in a coordinated manner.

2.2. Building a Trade Mark Portfolio

Trade mark registration is generally one of the first steps in protecting a player’s intangible assets. While the player’s name remains the sign most naturally associated with their identity (2.2.1.), it is by no means the only element capable of benefiting from trade mark protection. As an athlete’s reputation grows, other distinctive signs may also acquire independent economic value and become part of a broader branding strategy. Certain iconic celebrations (2.2.2.), for example, may evolve into distinctive signs in their own right. More broadly, trade mark law now makes it possible to protect a wide range of elements contributing to a player’s commercial identity, including logos, monograms, signatures, slogans, silhouettes, three-dimensional shapes, sound marks and other forms of non-traditional trade marks (2.2.3.). Taken together, these assets form a portfolio of rights designed to protect, structure and enhance the economic value of the athlete’s identity.

2.2.1. The Player’s Name

 A name is, first and foremost, an attribute of personality. It identifies a natural person and traditionally falls within the scope of civil law, personality rights and, in certain respects, image rights. For many years, this analysis appeared sufficient to address the legal position of professional athletes. A player’s name was primarily regarded as an element of civil status, a vehicle of reputation and, for the most talented players, a familiar reference for supporters and commentators. However, the evolution of professional football over recent decades has fundamentally transformed this perception.

An increasing share of the value created within the sports industry now derives from intangible assets. The economic development of sport depends to a large extent on the protection and exploitation of intellectual property rights, including trade marks, copyright, broadcasting rights, licensing arrangements and sponsorship agreements (Jacques de Werra (ed.), Reference Guide to Sustaining Sport and its Development through Intellectual Property Rights, World Intellectual Property Organization, 2022, in particular pp. 3–9 and 17–24). Competitions, clubs, broadcasters, sports equipment manufacturers and athletes now organise their commercial activities around portfolios of rights that constitute valuable economic assets in their own right. In this context, trade marks, copyright, designs, broadcasting rights and other intellectual property rights have become fundamental components of the sports economy.

In this context, competitions, clubs, broadcasters, sports equipment manufacturers and athletes all develop strategies built around intellectual property rights. The International Trademark Association (INTA) shares this view, recognising athletes as genuine owners of personal brands that should be managed and protected as valuable commercial assets in their own right (« International Trademark Association Releases Trademark and IP Toolkit for Football Organizations », inta.org, 18 November 2022).

In a digital and globalised environment, an athlete’s name often serves as the gateway to their entire commercial ecosystem. It gradually ceases to be merely an attribute of personality and becomes an intangible asset capable of being protected, exploited and enhanced. In this respect, the evolution reflected in trade mark registers is particularly revealing.

One of the most emblematic examples is that of David Beckham. Long before the rise of social media and participatory digital platforms, the player’s name was already the subject of a structured trade mark protection strategy through multiple trade mark registrations. Searches of trade mark registers reveal, in particular, the European Union trade mark DAVID BECKHAM No. 001796721, registered in 2002, together with registrations such as DAVID BECKHAM CLASSIC BLUE No. 012110003 and THE DAVID BECKHAM ACADEMY No. 004310835. These registrations cover a wide range of sectors, including perfumes, accessories, clothing, sporting goods, educational services and entertainment services. They illustrate how the player’s name progressively evolved beyond its function as a personal identifier to become the foundation of diversified commercial activities and a genuine strategy for creating economic value. Indeed, several leading works on sports business and personal branding regard David Beckham as one of the most accomplished examples of a personal brand in professional football, built around commercial partnerships, licensing programmes and intellectual property assets extending well beyond his sporting career (Simon  Chadwick and Nick Burton, “From Beckham to Ronaldo: Assessing the Nature of Football Player Brands”, Journal of Sponsorship, Vol. 1, No. 4, 2008, pp. 307–317; John Vincent, John S. Hill and Jason W. Lee, “The Multiple Brand Personalities of David Beckham: A Case Study of the Beckham Brand”, Sport Marketing Quarterly, Vol. 18, No. 3, 2009, pp. 173–180; Irving J. Rein, Philip Kotler and Ben Shields, The Elusive Fan: Reinventing Sports in a Crowded Marketplace, New York, McGraw-Hill, 2006).

Cristiano Ronaldo has adopted a similar approach. By way of illustration, searches of the EUIPO trade mark registers reveal a relatively extensive and diversified trade mark portfolio. It includes, in particular, the European Union trade mark CRISTIANO RONALDO No. 016809485, together with several CR7 CRISTIANO RONALDO trade marks, including registrations No. 018156737 and No. 018204263. These registrations cover a broad range of sectors, including clothing, commercial services, entertainment services, software and digital content, as well as various consumer products. As in the case of David Beckham, the objective is not merely to prevent unauthorised use of the player’s name, but also to build a portfolio of rights capable of supporting commercial partnerships, licensing programmes and other forms of commercial exploitation.

Similarly, Kylian Mbappé has developed a trade mark portfolio centred on his first name, surname and the KM sign. Searches of the trade mark registers reveal, in particular, the European Union trade marks MBAPPÉ No. 018984423, KYLIAN MBAPPE Nos. 017157363 and 018025777, as well as KM KYLIAN MBAPPE No. 018025780. These registrations cover a broad range of sectors, including cosmetics, software and digital content, jewellery, printed matter, leather goods, textiles, clothing and sporting goods. They illustrate a deliberate strategy to protect not only the player’s name but also the various signs capable of being associated with his commercial identity. As with David Beckham, Cristiano Ronaldo and Neymar Jr., the objective is not merely to prevent the unauthorised use of these signs. It is also to build a portfolio of rights capable of supporting commercial partnerships, licensing programmes, merchandising and other forms of commercial exploitation. The player’s name thus becomes the cornerstone of a value creation strategy deployed on an international scale.

Lionel Messi’s case is of particular legal interest. Searches of the trade mark registers reveal, in particular, the existence of several European Union MESSI trade marks, including the figurative marks No. 010181154 and No. 013475264, which combine the player’s name with a distinctive logo. These registrations cover, among other things, software and digital content, clothing, sporting goods, cosmetics, jewellery and printed matter. As with other leading football players, this strategy is intended to protect and enhance the commercial value of the athlete’s identity through a coherent portfolio of intellectual property rights. Lionel Messi’s case is noteworthy, however, primarily because of the landmark case law associated with it. In the dispute between MESSI and MASSI, the Court of Justice of the European Union held that the player’s exceptional reputation could be taken into account when assessing the likelihood of confusion between the signs at issue (CJUE, 17 septembre 2020, EUIPO v. Messi Cuccittini, C-449/18 P). This judgment provides a remarkable illustration of the transformation of a player’s name into a valuable commercial asset. Whereas most trade mark disputes are based primarily on the prior existence of registered intellectual property rights, the Court recognised that reputation acquired on the football pitch could itself influence the legal assessment of a sign. The player’s name thus emerges not only as an attribute of personality, but also as an economic asset possessing distinctive value in its own right.

The phenomenon is not confined to men’s football. Searches of trade mark registers reveal the emergence of comparable strategies in women’s football. In this respect, the case of Sam Kerr is particularly illustrative. The Australian player has structured her branding strategy around SKFootball Pty Ltd, which owns, among other rights, the Australian trade mark SAM KERR FOOTBALL No. 2382214 and the International Registration SAM KERR FOOTBALL No. 1788947, designating, in particular, the United Kingdom and the United States. These registrations cover Classes 25, 28, 35 and 41, including clothing, sporting goods, commercial services and entertainment services. As with the examples of David Beckham, Cristiano Ronaldo and Kylian Mbappé, this strategy reflects a deliberate effort to structure and protect an economic asset built around the athlete’s identity. Through these registrations, the player’s name likewise becomes the foundation of commercial activities capable of being exploited independently of her sporting career. Although such examples remain fewer in number and, for the time being, less prominent than those found in men’s football, the trend is clearly underway. As media exposure, commercial revenues and investment continue to grow, female footballers are likewise becoming the owners and managers of genuine portfolios of intangible assets.

These strategies share a common foundation: they are based on recognising a player’s name as an intangible asset capable of being protected, exploited and enhanced. This development forms part of a broader trend identified in the academic literature on personal branding and athlete branding. Specialist scholarship describes the modern athlete as an economic actor who develops a personal brand capable of being managed, protected and commercially exploited independently of their sporting career alone (Chadwick, S., & Burton, N. (2008). “From Beckham to Ronaldo: Assessing the Nature of Football Player Brands”, Journal of Sponsorship, 1(4), 307–317; Parmentier, M.-A., & Fischer, E. (2012) “How Athletes Build Their Brands”, International Journal of Sport Management and Marketing, 11(1/2), 106–124). According to this body of research, today’s athletes no longer commercialise only their sporting performances. They progressively develop a personal brand, with their name serving as its primary identifier.

Finally, the examples of Pelé and Maradona demonstrate that the economic value attached to a player’s name may endure long after the end of their sporting career. Searches of trade mark registers reveal, in particular, the existence of several PELÉ trade marks owned by Pele Brand LLC, including European Union trade marks No. 010208064, No. 013100061 and No. 012934931. Similarly, several MARADONA trade marks are registered in the name of SATTVICA S.A., including European Union trade mark No. 014960141 (notwithstanding the various disputes surrounding the management of the rights relating to Maradona’s name and image). These registrations cover a broad range of sectors, including clothing, sporting goods, commercial services, entertainment services, restaurant services and various categories of consumer products. They illustrate how an athlete’s name can become an autonomous economic asset, managed and commercially exploited by dedicated entities many years after the end of the player’s career. A player’s name thus becomes a genuine intangible asset, capable of being licensed, commercially exploited and, subject to the applicable legal rules, passed on to future generations.

In summary, a player’s name is no longer merely an attribute of personality. In contemporary football, it has often become a strategic intangible asset capable of being protected through trade mark law, commercially exploited and incorporated into a broader portfolio of intellectual property rights. The strategies adopted by numerous male and female players illustrate how a name has evolved into a genuine vehicle for commercial value creation, one whose economic significance may endure well beyond the athlete’s playing career.