WWE has hit another roadblock in its attempt to lock down a trademark for Randy Orton’s signature RKO finishing maneuver. The United States Patent and Trademark Office issued a fresh refusal of the application on November 3, again pointing to the potential for confusion with trademarks already held by RKO Pictures, the storied Hollywood film studio behind classic titles dating back nearly a century.
This marks the latest in a string of denials WWE has faced as it has tried to formally claim ownership of the RKO name for use in wrestling entertainment services. The USPTO’s concern remains consistent: RKO Pictures’ long-standing trademarks covering entertainment and media create a likelihood that consumers could associate WWE’s use of the letters with the film studio, rather than Orton’s finisher.
The RKO has been one of the most recognizable finishing moves in WWE for more than two decades, a cutter variation that Orton has used to end matches — and sometimes ambush unsuspecting opponents out of nowhere — since early in his main roster run. The move’s catchphrase status (“RKO outta nowhere!”) has made it a merchandising and meme-worthy piece of WWE’s intellectual property, which is precisely why the company has pushed to secure exclusive trademark rights to it.
Trademarking a wrestling move’s name isn’t just a formality — it determines how aggressively a company can police unauthorized use of the term on merchandise, in video games, or across social media and advertising. WWE has built an extensive portfolio of trademarks around its performers’ finishers and catchphrases over the years, treating them as core brand assets. A repeated refusal like this one complicates that strategy for one of its most valuable and enduring pieces of in-ring iconography.
It’s worth noting that RKO Pictures, despite not being an active film producer in the way it was during Hollywood’s golden age, still maintains and defends its intellectual property, which is clearly a factor the USPTO is weighing here. WWE will likely have the option to respond to this latest refusal, amend its application, or attempt to argue against the examiner’s reasoning, as companies often do during the trademark prosecution process. Given WWE’s track record of aggressively protecting its branding, it would be a surprise if this was the end of the road for the company’s pursuit of the mark.
For now, though, the RKO remains something WWE can certainly keep using in the ring and in its own programming, even without the trademark locked down — Orton isn’t going to stop hitting it. But the inability to secure broader trademark protection could limit how far WWE can go in cracking down on third-party use of the term in merchandising or other commercial contexts. Expect this fight to continue playing out in the background while Orton keeps delivering the move itself on live television.
Reporting and match coverage produced by the PW Exclusive team. Articles under this byline are drafted with AI assistance and reviewed before publication — see our editorial standards for how we work.
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