WWE likes to lock down every possible name they can. Any nickname used on merchandise or elsewhere needs to be owned by the company.
PW Insider reports that WWE has filed for more interesting trademarks for more top wrestlers. Randy Orton and The Undertaker were the subjects this time around.
The company filed copyrights for Apex Predator, The Deadman, and The Phenom. All of these trademarks would allow WWE to use them in the ring and for merchandising purposes.
WWE filed for “The Phenom” in September, 2019 and that trademark is still active.