Respondent asserts that Complainant is incorrect in its classification of the word “total” as being “purely descriptive.” Respondent claims it is distinctive and the public is accustomed to seeing nonofficial domain names for NFL teams incorporating the “total” term (e.g., and ). Moreover, including the term “total” at the beginning of the Domain Name differentiates it from other domain names that not only incorporate the words “packer” or “packers,” but also begin with those words – e.g.,compare the domain names (; ; ; ; ; ) and the domain names (; ; ; ; ; ; ; ; ; ; ; ; ; ; and ).
https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2016-1455
WIPO wrote: