Westmore · UDRP DecisionJll.amsterdam
The Panel ordered transfer of <jll.amsterdam>. It found the domain identical to the Complainant’s registered JLL mark, concluded that the Respondent had no rights or legitimate interests in an unauthorized domain redirecting to the Complainant’s official website, and found bad-faith registration and use based on the exact reproduction of the JLL mark, the geographic targeting suggested by the “.amsterdam” extension, the parties’ connections to the Netherlands, the domain’s recent registration long after the trademark registrations, the unauthorized redirection, and active MX records. The Respondent did not file a response.
The timeline behind jll.amsterdam
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind jll.amsterdam — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates that redirecting an exact-match trademark domain to the trademark owner’s own website does not necessarily demonstrate legitimacy. In this record, the redirection instead reinforced implied affiliation and bad faith because it was unauthorized. The case also shows how a geographically meaningful gTLD and active MX records may contribute to a targeting and deception analysis when combined with an exact trademark match and other supporting circumstances.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBI TRATI O N AND MEDI ATI ON CENTER ADMINISTRATIVE PANEL DECISION Jones Lang LaSalle IP, Inc v. Silvio Da Costa Case No. D2025-0353 1. The Parties The Complainant is Jones Lang LaSalle IP, Inc, United States of America (“USA”), represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Silvio Da Costa, Netherlands (Kingdom of the) (“the Netherlands”). 2. The Domain Name and Registrar The disputed domain name <jll.amsterdam> is registered with Cronon GmbH (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 29, 2025. On January 29, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 31, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 3, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on February 4, 2025. The Center verified that the Complaint together with the amended 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 February 6, 2025. In accordance with the Rules, paragraph 5, the due date for Response was February 26, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 7, 2025. page 2 The Center appointed Vincent Denoyelle as the sole panelist in this matter on March 14, 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 by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is part of the JLL group, which is a professional services and investment management firm specializing in real estate with its headquarters in Chicago, Illinois, USA. The JLL group has operations in over 80 countries, including the Netherlands. The Complainant is the owner of several JLL trade marks including the following: - European Union Trade Mark JLL registration number 010603447, registered on August 31, 2012; and - USPTO (USA) Trade Mark JLL registration number 4564654, registered on July 8, 2014. The Complainant has registered several domain names reflecting its JLL trade mark including <jll.com> and <jll.nl> and it operates the generic Top Level Domain (“gTLD”) <.jll>. The disputed domain name was registered on December 29, 2024, and it points to the Complainant's website at <jll.com> or local websites such as <jll.nl> depending on the IP address of the Internet user. The only information available to the Complainant about the Respondent is as provided by the Registrar. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends that the disputed domain name is identical to the Complainant's JLL trade mark. The Complainant contends that the Respondent is not sponsored by or affiliated with the Complainant in any way and that the Complainant has not given the Respondent permission to use the Complainant’s trade mark in any manner, including in domain names. The Complainant adds that based on the available information there is nothing suggesting that the Respondent is commonly known by the disputed domain name. The Complainant highlights the fact that the disputed domain name merely redirects to the Complainant's main website and that such use cannot confer any rights or legitimate interest in the disputed domain name. Turning to the issue of bad faith, the Complainant asserts that it is not possible to conceive of a plausible situation in which the Respondent would have been unaware of the Complainant’s JLL trade mark at the time the disputed domain name was registered. The Complainant also considers that the disputed domain name can only be taken as intending to cause confusion among Internet users as to the source of the disputed domain name, and thus, it must be considered as having been registered and used in bad faith pursuant to paragraph 4(b)(iv) of the Policy, with no good faith use possible. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 6.1 Preliminary Issue: Language of Proceedings Pursuant to paragraph 11(a) of the Rules, “unless otherwise agreed by the Parties, or specified otherwise in the Registration Agreement, the language of the administrative proceeding shall be the language of the Registration Agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the administrative proceeding”. In the present case, the Registration Agreement appears to be in Dutch as confirmed by the Registrar, and the Complaint was submitted in English. The Complainant submitted arguments in order to request that the Proceedings be in English. The Respondent did not comment or respond. The Respondent was given an opportunity to comment on or to oppose the Complainant’s arguments. The Panel is satisfied that the Respondent reasonably understands the nature of the proceedings and finds that to request the Complainant to translate the Complaint would cause potential unfairness and unwarranted costs and delay in light of the overall circumstances including (i) the fact that the Respondent's use of the disputed domain name is clearly in bad faith and poses a potential threat to the Complainant and its customers, (ii) the complete lack of reaction of the Respondent after having been given a fair chance to comment and (iii) the fact that the disputed domain name is identical to the Complainant's JLL trade mark. In light of these circumstances, the Panel finds that it would not be unfair to proceed in a language other than that of the Registration Agreement, and the Panel is satisfied that the language of proceedings should be English. A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trade mark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0 ”), section 1.7. The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.2.1. The entirety of the JLL trade mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the JLL trade mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.7. 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. Although 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 difficult 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 in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0 , section 2.1. page 4 Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Complainant has stated that it does not know the Respondent and that it has not licensed or otherwise authorized the Respondent to make any use of its trade mark JLL. There is no indication that the Respondent is commonly known by the disputed domain name. The current use of the disputed domain name to redirect to the Complainant’s official website, with no authorization, can only serve to increase confusion that the disputed domain name is somehow affiliated with or authorized by the Complainant and is therefore misleading, and cannot be considered bona fide, legitimate or fair. Furthermore, the nature of the disputed domain name, which is identical to the Complainant’s trade mark, carries a significant risk of implied affiliation. See section 2.5.1 of the WIPO Overview 3.0 . 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. Given the circumstances described in the Complaint and the documentary evidence provided by the Complainant, the Panel finds that the disputed domain name was registered in bad faith. The disputed domain name reproduces the exact JLL trade mark of the Complainant and this cannot be a coincidence given the overall circumstances of the present case, including (i) the reputation of the Complainant and its JLL trade mark, (ii) the fact that the Respondent appears to be based in the Netherlands where the Complainant has operations and a local Dutch version of its website, (iii) the fact that the disputed domain name is registered under the gTLD “.amsterdam”, clearly suggesting an intention to target the Complainant's business and customers in the city of Amsterdam, where the Complainant operates, and (iv) the fact that the disputed domain name was registered very recently and many years after the registration of the trade mark JLL. Thus, the Panel finds that the disputed domain name was registered in bad faith. As for use of the disputed domain name in bad faith, given the circumstances described in the Complaint, the evidence provided by the Complainant, the Panel considers that the disputed domain name is used in bad faith. The use of the disputed domain name to redirect to the Complainant’s official website, with no authorization, can only serve to increase confusion that the disputed domain name is somehow affiliated with or authorized by the Complainant (See PayPal Inc. v. Jon Shanks, WIPO Case No. D2014-0888 and AXA S.A., AXA Investment Managers S.A. v. Domains By Proxy, Inc. / Adam Long, WIPO Case No. D2009-0452). This circumstance, along with the DNS setup of the disputed domain name (with active MX records) and the composition of the disputed domain name, lead the Panel to consider that the disputed domain name could be used to deceive Internet users. The fact that the Respondent chose not to object to the Complainant’s assertions can only reinforce the Panel’s view that the disputed domain name is used in bad faith. page 5 The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <jll.amsterdam> be transferred to the Complainant. /Vincent Denoyelle/ Vincent Denoyelle Sole Panelist Date: March 28, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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