Westmore · UDRP DecisionJll.business
The Panel ordered transfer of <jll.business>. It found the Domain Name identical to the Complainant’s JLL trademark, found no rights or legitimate interests because the Respondent was unaffiliated and used the Domain Name for phishing rather than a bona fide offering, and found bad-faith registration and use based principally on the Respondent’s apparent awareness of the Complainant and use of the Domain Name to impersonate the Complainant in deceptive emails. The use of a privacy service and possible use of a Complainant employee’s or analyst’s name also supported bad faith.
The timeline behind jll.business
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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The case illustrates a straightforward exact-match trademark dispute strengthened by evidence of email-based impersonation. The phishing use was relevant across both the second and third elements: it defeated any claim to bona fide use and provided direct evidence of bad faith. The case also demonstrates the procedural treatment of possible identity theft, including respondent-name redaction and a non-public transfer annex.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Jones Lang LaSalle IP, Inc. v. Name Redacted Case No. D2024-5232 1. The Parties The Complainant is Jones Lang LaSalle IP, Inc., United States of America (“United States”), represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Name Redacted 1 . 2. The Domain Name and Registrar The disputed domain name <jll.business> (the “Domain Name”) is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 19, 2024. On December 19, 2024, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On December 19, 2024, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Not available (privacy protection enabled)) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 20, 2024, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. On January 17, 2025, the Complainant submitted a supplemental filing request to amend annexes to the Complaint. 1 The Respondent appears to have used the name of a third party when registering the Domain Name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the Domain Name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding, and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on January 3, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 23, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 24, 2025. The Center appointed Mathias Lilleengen as the sole panelist in this matter on January 31, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is a subsidiary of Jones Lang LaSalle Incorporated. Jones Lang LaSalle Incorporated and all of its consolidated subsidiaries comprise the JLL group. The JLL group is a services and investment management firm specializing in real estate. The JLL group has approximately 91,000 employees with clients in over 80 countries. The JLL group has received numerous awards. It has strong social media and internet presence. It is the owner of numerous domain names that incorporate the JLL trademark, for example <jll.com> and <jll.eu>. The Complainant owns numerous trademark registrations that include JLL, for example European Union trademark EUTM 010603447 for JLL (registered on August 31, 2012) and United States trademark registration number 4709457 for JLL (registered on March 24, 2015). The Respondent registered the Domain Name on November 4, 2024. The Complainant has documented that the Domain Name has redirected to the Complainant’s website. The Respondent has used the Domian Name to set up an email account, purporting to be an employee of the Complainant, to deceive clients of the Complainant. At the time of drafting the Decision, the Domain Name resolved to an error page. 5. Parties’ Contentions A. Complainant The Complainant provides evidence of trademark registrations and argues that the Domain Name is identical to the Complainant’s trademark. The Respondent’s use of the Domain Name contributes to the confusion. The Complainant argues that the Respondent has no rights or legitimate interests in respect of the Domain Name. The Respondent is not sponsored by or affiliated with the Complainant in any way. The Complainant has not given the Respondent permission to use the Complainant’s trademark. The Respondent is not using the Domain Name to provide a bona fide offering of goods or services as allowed under Policy. To pass off as the Complainant in a phishing scheme, does not confer a right or legitimate interest. The Complainant argues that by registering the Domain Name, the Respondent intentionally created a likelihood of confusion with the Complainant’s trademark as to source, sponsorship, affiliation, or endorsement. The Respondent has registered a domain name that is identical to the Complainant’s trademark. As such, the Respondent has demonstrated a knowledge of the Complainant’s brand. The Respondent’s use of the Domain Name reinforces the Respondent’s knowledge of the Complainant’s trademark. It is not possible to conceive of a plausible situation in which the Respondent would have been unaware of the Complainant at the time the Domain Name was registered. The Respondent’s use of the page 3 Domain Name to fraudulently pose as the Complainant for launching a phishing attack, is evidence of bad faith. The use of a privacy service to hide its identity is further evidence of bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the Domain Name. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0 ”), section 1.7. The Complainant has established that it has rights in the trademark JLL. The Domain Name is identical to the Complainant’s trademark. For the purpose of assessing the confusing similarity under paragraph 4(a)(i) of the Policy, the Panel may ignore the generic Top-Level-Domain (gTLD). See WIPO Overview 3.0 , section 1.11.1. Based on the available record, the Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. While the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the often impossible task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests. If the respondent fails to come forward with relevant evidence, the complainant is deemed to have satisfied the second element. See WIPO Overview 3.0 , section 2.1. Having reviewed the record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the Domain Name. The Respondent has not rebutted the Complainant’s showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the Domain Name. Based on the record, the Respondent is not affiliated with or related to the Complainant. There is no evidence that the Respondent has registered the Domain Name as a trademark or has acquired trademark rights. There is no evidence of the Respondent’s use of, or demonstrable preparations to use, the Domain Name in connection with a bona fide offering of goods or services. The Respondent’s use of the Domain Name for phishing, as described above, is not bona fide, but rather evidence of bad faith. Based on the available record, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular but without limitation, that if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. The Domain Name is identical to the Complainant’s prior registered trademark, coupled with the Respondent’s use of the Domain Name, makes it probable that the Respondent was aware of the page 4 Complainant when the Respondent registered the Domain Name. The use of the Domain Name for phishing purposes is clear evidence of bad faith. See WIPO Overview 3.0 , section 3.4. The Respondent’s use of a privacy service is under the circumstances of the case a further indication of bad faith. See WIPO Overview 3.0, section 3.6. Noting in particular the general powers of a panel articulated inter alia in paragraphs 10 and 12 of the Rules, the Panel undertook a limited factual research online to obtain more information about the Respondent. The Panel, found Internet results indicating that the Respondent may have used an employee or an analyst’s name of the Complainant when registering the disputed domain name, which further supports a finding of bad faith. For the reasons set out above, the Panel concludes that the Domain Name was registered and is being used in bad faith, within the meaning of paragraph 4(a)(iii) of the Policy. The third element of the Policy has been established. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders the Domain Name <jll.business> transferred to the Complainant. /Mathias Lilleengen/ Mathias Lilleengen Sole Panelist Date: February 7, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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