A federal court in California has denied emergency relief in a cybersquatting case involving Vlad Tenev, the co-founder of Robinhood, the popular investment platform. The United States District Court for the Northern District of California declined to issue a temporary restraining order over the domain name vladtenev.com, but ordered the defendants to show cause why a preliminary injunction should not be entered.
Background of the dispute
Plaintiffs Robinhood Markets, Inc. and Vladimir Tenev brought suit against Libin Zhu and Dynadot Inc. after Zhu registered the domain name vladtenev.com and allegedly offered it for sale for $16,800. Plaintiffs asserted claims under the Lanham Act and the Anti-Cybersquatting Consumer Protection Act, along with unfair competition, common law trademark infringement, and violation of California’s right of publicity statute.
Before turning to federal court, Tenev pursued a Uniform Domain Name Dispute Resolution Policy proceeding. That effort was unsuccessful. The UDRP panel denied his claim in February 2026, a fact that influenced the court’s view of the timing of this lawsuit.
Requested relief
Plaintiffs asked the court to enter an ex parte temporary restraining order blocking the alleged cybersquatting conduct, requiring transfer of the disputed domain name, and prohibiting defendants from using or marketing the “VLAD TENEV” name or confusingly similar identifiers. They also sought an order to show cause regarding a preliminary injunction.
The court’s ruling
The court denied the request for a temporary restraining order. At the same time, it granted the request for an order to show cause and set a briefing schedule and hearing on whether a preliminary injunction should issue.
Key reasoning
The court found that plaintiffs had not shown a likelihood of success on their Lanham Act or ACPA claims. Personal names are treated as descriptive under trademark law and are protectable only if they acquire secondary meaning. That requires showing that the public primarily associates the name with a product or service rather than the individual. Here, the court found it implausible that “Vlad Tenev” functions primarily as a source identifier for public speaking services, rather than identifying Tenev himself, particularly given his prominence as a co-founder of Robinhood.
The court did conclude that plaintiffs raised serious questions under California Civil Code section 3344, which governs the right of publicity. But that alone was not enough to justify ex parte relief.
The court also emphasized delay. Plaintiffs were aware of the domain listing in early January 2026, pursued and lost the UDRP proceeding in February, and then waited more than a month after that adverse decision to seek a TRO. That delay undermined any claim of immediate and irreparable harm, which is required for emergency relief.
Takeaways
The decision underscores how difficult it can be to assert trademark rights in a personal name without strong evidence of secondary meaning, even for a well-known figure such as the co-founder of Robinhood. It also highlights a practical point about timing. Pursuing a UDRP proceeding does not eliminate the need to act quickly in court if emergency relief is sought.
Robinhood Markets, Inc. v. Zhu, 2026 WL 915291 (N.D. Cal. Apr. 3, 2026)