Westmore · UDRP decision
WIPO · Case No. D2025-2252

Jll-eu.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <jll-eu.com>. It found the domain confusingly similar to the Complainant’s JLL marks, that the Respondent had no rights or legitimate interests, and that the domain was registered and used in bad faith. The bad-faith finding rested on the well-known character of the JLL marks, the domain’s similarity to both those marks and <jll.eu>, passive holding, likely false organizational information, activated MX records, and the absence of any response or plausible good-faith explanation.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-08-07
Panelist(s)
Tsuru, Kiyoshi
Complainant
Jones Lang LaSalle IP, Inc.
Respondent
Douglas Andrews, JLL EU
Disputed domain(s)
jll-eu.com
Citation weightrelies on 34 authorities
Domain history UDRP Intelligence

The timeline behind jll-eu.com

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-eu.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of jll-eu.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a domain combining a well-known mark with a geographic abbreviation can create both confusing similarity and a strong implied-affiliation risk. It also shows that a “coming soon” page does not insulate a respondent from a bad-faith finding where the totality of circumstances includes a well-known mark, no response, likely false registration information, resemblance to the complainant’s existing regional domain, and activated MX records.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-08-07
Panel
Tsuru, Kiyoshi
Full decision
19 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Jones Lang LaSalle IP, Inc. v. Douglas Andrews, JLL EU Case No. D2025-2252 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 Douglas Andrews, JLL EU, Canada. 2. The Domain Name and Registrar The disputed domain name <jll-eu.com> is registered with Squarespace Domains II LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 10, 2025. On June 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 10, 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, JLL EU) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 12, 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 June 16, 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 June 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 8, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 10, 2025. page 2 Due to a technical issue, the Center’s Notification of Complaint and Commencement of Administrative Proceeding was not delivered to the Respondent’s email address on record. On July 11, 2025, the Center resent the Notification of Complaint and Commencement of Administrative Proceeding email and asked the Respondent to indicate whether it wished to participate in the proceeding. The Respondent did not reply to the Center’s email. The Center appointed Kiyoshi Tsuru as the sole panelist in this matter on July 24, 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 a part of the JLL group, a n industry leader in property and corporate facility management and investment services, with more than 106,000 employees in over 80 countries. The Complainant owns, among others, the following trademark registrations: Trademark Registration No. Jurisdiction Date of Registration Class JLL TMA875711 Canada April 15, 2014 35, 36, 37, and 42 JLL 010603447 European Union August 31, 2012 36, 37, and 42 JLL 4564654 United States July 8, 2014 35 , 36, 37, and 42 The Complainant is the owner of more than 400 domain names, such as <jll.com>, <jll.eu>, <joneslanglasalle.com>, <jll.com.co>, <jll.realty> among others. The disputed domain name <jll- eu.com> was registered on March 12, 2025. At the time of writing this Decision, the disputed domain name resolves to a “coming soon” website. 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 names. Notably, the Complainant contends: I. Identical or Confusingly Similar. That by virtue of the registrations that it holds for its JLL trademarks, the Complainant owns exclusive rights to them for purposes of the Policy (citing WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition [“WIPO Overview 3.0 ”] Section 1.2.1). That the Generic Top-Level Domain (“gTLD”) “.com” should be disregarded when comparing the disputed domain name to the Complainant’s JLL trademarks (citing WIPO Overview 3.0 , 1.11.1) page 3 That the Respondent added a hyphen and the letters “eu” to the Complainant’s JLL trademarks in the disputed domain name, making it confusingly similar to the Complainant’s JLL trademarks. That the term “eu” is closely linked to the Complainant’s JLL trademarks, increasing the confusing similarity between the disputed domain name and the Complainant’s JLL trademarks, given that the “eu” term refers to the European Union as a geographic location. That past panels have held that a disputed domain name consisting merely of a trademark and an additional term that closely relates to, and describes a complainant’s business, is confusingly similar to said complainant’s trademarks (citing Inter IKEA Systems B.V. v. Franklin Lavall?e / IkeaCuisine.net, WIPO Case No. D2015-2042 and WIPO Overview 3.0 , 1.8). That the addition of a hyphen does nothing to distinguish the disputed domain name from the Complainant’s JLL trademarks, as it should be disregarded for purposes of determining a confusing similarity between the disputed domain name and the Complainant’s JLL trademarks. That the disputed domain name should be classified as identical to the Complainant’s JLL trademarks. II. Rights or Legitimate Interests That the registrations of the Complainant’s JLL trademarks constitutes prima facie evidence of the validity of the term “jll” as a trademark owned by the Complainant, along with the exclusive right to use said trademark in commerce arising from said registrations, in connection with the offering of goods or services specified in them. 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 JLL trademarks in any manner, including the registration of domain names. That the Respondent is not commonly known by the disputed domain name, which in fact evidences a lack of rights or legitimate interests according to the Policy (citing World Natural Bodybuilding Federation, Inc. v. Daniel Jones TheDotCafe, WIPO Case No. D2008-0642 ). That the Complainant has not licensed, authorized or permitted the Respondent to register domain names incorporating the Complainant’s JLL trademarks, and that therefore no bona fide or legitimate use of the disputed domain name can be claimed by the said Respondent (citing Sportswear Company S.P.A. v. Tang Hong, WIPO Case No. D2014-1875 ). That the Respondent listed “JLL EU” as his organization when registering the disputed domain name, which is a clear sign that the Respondent chose to impersonate the Complainant in the WhoIs record of the disputed domain name, in an attempt to pass off as the Complainant in the registration details of the disputed domain name. That there are no entities registered in the Canadian business registry under the term “JLL EU”. That the Respondent is using the disputed domain name to attract Internet users to a blank page website which lacks any content, by merely stating “We're under construction. Please check back for an update soon”, which shows that the Respondent has failed to make a legitimate use of the disputed domain name, which in turn evidences a lack of rights or legitimate interests in the disputed domain name (citing LeadsMarket.com LLC v. Privacy Protect, LLC (PrivacyProtect.org) / Oscar Dominguez, WIPO Case No. D2019-1363 ). That the Respondent registered the disputed domain name significantly after the filing dates of the Complainant’s trademark applications that matured into the registrations for its JLL trademarks, and significantly after date of registration of the Complainant’s <jll.com> and <jll.eu> domain names. page 4 III. Registered and Used in Bad Faith That the Complainant and its JLL trademarks are known internationally. That the disputed domain name is confusingly similar to the Complainant’s JLL trademarks and <jll.eu> domain name, which shows that the Respondent had knowledge of the Complainant’s JLL trademarks and business at the time of registration of the disputed domain name, which makes it impossible to conceive of a plausible situation in which the Respondent would have been unaware of the Complainant’s JLL trademarks when registering the disputed domain name (citing Telstra Corp. Ltd. v. Nuclear Marshmallows, WIPO Case No. D2000-0003 ). That the term “JLL” is so closely associated to the Complainant that the Respondent’s use of the Complainant’s JLL trademarks or any variation thereof strongly implies bad faith (citing Parfums Christian Dior v. Javier Garcia Quintas, WIPO Case No. D2000-0226 ). That the disputed domain name is closely similar to the Complainant’s JLL Trademarks, for which reason it could not have been coincidentally registered by the Respondent without knowledge of the Complainant’s JLL trademarks (citing Asian World of Martial Arts Inc. v. Texas International Property Associates, WIPO Case No. D2007-1415 ). That the WIPO Overview 3.0 , 3.1.4 states that “previous panels have held that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by unaffiliated entities can by itself, create the presumption of bad faith”, which is so in the present case because the disputed domain name is closely similar to the Complainant’s JLL trademarks. That previous panels have held that the selection of a domain name which is obviously connected to a complainant’s trademark strongly suggests opportunistic bad faith, particularly when the respondent has no affiliation with the complainant (citing Singapore Airlines Ltd. V. European Travel Network, WIPO Case No. D2000-0641 and Wikimedia Foundation Inc. v. Kevo Ouz a/k/a Online Marketing Realty, WIPO Case No. D2009-0798). That, when searching for the term “jll eu” in search engines, multiple results refer to the Complainant and its business, and thus the Respondent should have been aware of the Complainant’s JLL trademarks prior to the registration of the disputed domain name (citing Caesar World, Inc. v. Forum LLC, WIPO Case No. D2005-0517 ). That the disputed domain name resolves to an inactive website and is not being used, and that passive holding can constitute a factor for finding bad faith under the Policy (citing Telstra Corp. v. Nuclear Marshmallows, supra; and Alitalia-Linee Aeree Italiane S.p.A v. Colour Digital, WIPO Case No. D2000-1260 ). That the disputed domain name is confusingly similar to the Complainant’s JLL Trademarks, and that the Respondent has not used the disputed domain name, which fact should be duly considered by the Panel when assesing bad faith (citing DCI S.A. v. Link Commercial Corp., WIPO Case No. D2000-1232 and Clerical Med. Inv. Group Ltd. v. Clericalmedical.com, WIPO Case No. D2000-1228). That the disputed domain name can only be taken as a means for confusing Internet users as to the source of the disputed domain name, and that therefore the disputed domain name must be considered as registered and used in bad faith. That the disputed domain name is composed of the Complainant’s JLL trademarks in their entirety, and so that there is no plausible good faith reason or logic for the Respondent to register the disputed domain name, which indicates the Respondent’s intention of holding the disputed domain name for a future use which could be competitive with or detrimental to the Complainant (citing Jupiters Limited v. Aaron Hall, WIPO Case No. D2000-0574 ). page 5 That any use of the disputed domain name, whether actual or theoretical, would have taken place in bad faith, because it is unconceivable that the disputed domain name would not have been used for conducts such as impersonation or passing off, infringement of consumer protection laws, or infringing the Complainant’s JLL trademarks (citing Telstra Corp. v. Nuclear Marshmallows, supra). That the Respondent’s registration information available through the disputed domain name’s WhoIs record lists “JLL EU” as his organization, intentionally providing those false details to avoid detection and appearing legitimate, and that using false information is another indication of the Respondent’s bad faith (citing KT Intellectual Property Holding Company, LLC v. Henry Findstein et. al., WIPO Case No. D2017-2047 ). That the disputed domain name is set up with mail exchanger (MX) records, which implies that the disputed domain name could be used to send emails. That emails emanating from the disputed domain name could not be used for good faith purposes, and that it is likely that the Respondent could use said emails for fraudulent activities, including phishing, impersonation, or passing off as the Complainant, which conducts have been considered to be indicators of bad faith by previous Panels (citing Alain Afflelou Franchiseur v. Lihongbo, Lihongbo, WIPO Case No. D2020-2075 ). That it is more likely than not that the Respondent knew of and targeted the Complainant’s JLL trademarks (citing Tudor Games, Inc. v. Domain Hostmaster, Customer ID No. 09382953107339 dba Whois Privacy Services Pty Ltd / Domain Administrator, Vertical Axis Inc., WIPO Case No. D2014-1754 ). B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy sets out the three requirements that the Complainant must prove in order to successfully request remedies: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark to which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in connection to the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. Given the Respondent’s default and therefore failure to specifically address the case merits as they relate to the three UDRP elements, the Panel may decide this proceeding based on the Complainant’s undisputed factual allegations under paragraphs 5(f), 14(a), and 15(a) of the Rules (see Joseph Phelps Vineyards LLC v. NOLDC, Inc., Alternative Identity, Inc., and Kentech, WIPO Case No. D2006-0292 ; Encyclopaedia Britannica, Inc. v. null John Zuccarini, Country Walk, supra; see also WIPO Overview 3.0, section 4.3). 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 trademark and the disputed domain names. WIPO Overview 3.0 , section 1.7. The Complainant has shown rights in respect of its JLL trademarks for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The disputed domain name is confusingly similar to the Complainant’s JLL trademarks because it reproduces said trademarks entirely (see WIPO Overview 3.0 , section 1.7). The incorporation of a hyphen followed by a term such as “eu”, indicative of the geographical denomination for the “European Union” does not prevent a finding of confusing similarity. The Complainant’s JLL trademarks are recognizable in the page 6 disputed domain name (see WIPO Overview 3.0, section 1.8; see Playboy Enterprises International, Inc. v. Zeynel Demirtas, WIPO Case No. D2007-0768; InfoSpace.com, Inc. v. Hari Prakash, WIPO Case No. D2000-0076; AT&T Corp. v. WorldclassMedia.com, WIPO Case No. D2000-0553 and Six Continents Hotels, Inc., Inter-Continental Hotels Corporation v. South East Asia Tours, WIPO Case No. D2004-0388). The addition of the gTLD “.com” to the disputed domain name constitutes a technical requirement of the Domain Name System (“DNS”). Thus, it has no legal significance in assessing identity or confusing similarity in the present case (see CARACOLITO S SAS v. Nelson Brown, OXM.CO, WIPO Case No. D2020-0268 ; SAP SE v. Mohammed Aziz Sheikh, Sapteq Global Consulting Services, WIPO Case No. D2015-0565; Bentley Motors Limited v. Domain Admin / Kyle Rocheleau, Privacy Hero Inc., WIPO Case No. D2014-1919 and WIPO Overview 3.0, section 1.11.1). The disputed domain name is also confusingly similar to the Complainant’s <jll.eu> domain name. 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. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights to or legitimate interests in the disputed domain name. The Complainant has asserted that there is no evidence of the Respondent’s use of the disputed domain name in connection with a bona fide offering of goods or services, and that the Respondent has not been licensed or otherwise permitted by the Complainant to use its JLL trademarks, or to register the disputed domain name (see Amdocs Development Ltd. and Amdocs Software Systems Ltd. v. cenk erdogan, WIPO Case No. D2023-3044 ; Amdocs Development Ltd. and Amdocs Software Systems Ltd. v. Nick Lamba, WIPO Case No. D2023-2573 and Autodesk, Inc. v. Brian Byrne, meshIP, LLC, WIPO Case No. D2017-0191). The case file contains no evidence that demonstrates that the Respondent has used or has made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services (see Valentino S.p.A. v. Qiu Yufeng, Li Lianye, WIPO Case No. D2016-1747 ; and Associated Newspapers Limited v. Manjeet Singh, WIPO Case No. D2019-2914). 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. Furthermore, the Panel considers that the composition of the disputed domain name carries a risk of implied affiliation with the Complainant, its trademarks, and its business. WIPO Overview 3.0 , section 2.5.1. The Panel finds the second element of the Policy has been established. page 7 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 Complainant has ascertained its rights over its JLL trademarks. The Panel notes that the dates of registration of the Complainant’s JLL trademarks significantly precede the date of registration of the disputed domain name. Previous panels appointed under the Policy have found that the mere registration of a domain name that is identical or confusingly similar to a well-known trademark by an unaffiliated entity can in itself create a presumption of bad faith (see section 3.1.4 of the WIPO Overview 3.0 ). This is so in the present case because the Complainant’s JLL trademarks are well-known and have been extensively used worldwide (see S Jones Lang LaSalle IP, Inc. v. Goat / Goat, WIPO Case No. D2023-3148 and Jones Lang LaSalle IP, Inc. v. Gonzalez Lauren, WIPO Case No. D2023-2598). According to the evidence comprised in the case file, the Respondent more likely than not provided false contact information when registering the disputed domain name (listing “JLL EU” as his organization). Previous panels appointed under the Policy have held that circumstances such as this one serve as an indication of bad faith. WIPO Overview 3.0 , section 3.6. In the present case, the Panel notes that the Respondent registered the disputed domain name on March 12, 2025, well after the Complainant obtained its first registrations for its JLL trademarks and began using said trademarks. The Respondent’s bad faith registration is evidenced by the fact that (1) the disputed domain name is confusingly similar to the Complainant’s well-known JLL trademarks, as it incorporates said trademarks entirely; (2) the disputed domain name is also confusingly similar to the Complainant’s <jll.eu> domain name; (3) the Respondent is passively holding the disputed domain name; and (4) the Complainant has submitted evidence of the Respondent’s activation of the disputed domain name’s MX records which could likely be used by the Respondent to send emails from an email address associated with the disputed domain name in order to impersonate or pass off as the Complainant. The Complaint shows that the Respondent has targeted the Complainant and its potential clients, which constitutes opportunistic bad faith (see section 3.2.1 of the WIPO Overview 3.0 ; see also L’Oréal v. Contact Privacy Inc. Customer 0149511181 / Jerry Peter, WIPO Case No. D2018-1937; and Gilead Sciences Ireland UC / Gilead Sciences, Inc. v. Domain Maybe For Sale c/o Dynadot, WIPO Case No. D2019-0980). The disputed domain name does not resolve to an active website. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. Having reviewed the record, the Panel finds that the current non-use of the disputed domain names does not prevent a finding of bad faith in the circumstances of this proceeding. While panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s well-known JLL trademarks; (ii) the failure of the respondent to submit a response or to provide any explanation of why he registered a domain name that fully incorporates the Complainant’s well- known JLL trademarks, or any evidence of actual or contemplated good-faith use; (iii) the respondent’s concealing his identity or use of false contact details (noted to be in breach of the registration agreement), ; and (iv) the implausibility of any good faith use to which the domain name may be put. WIPO Overview 3.0 , section 3.3. Having reviewed the record, the Panel notes the well-known nature and reputation of the Complainant’s trademark, and the composition of the disputed domain names, and finds that under the circumstances of this case the current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 8 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-eu.com> be transferred to the Complainant. /Kiyoshi Tsuru/ Kiyoshi Tsuru Sole Panelist Date: August 7, 2025

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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