Westmore · UDRP decision
WIPO · Case No. D2025-2865

Rarebreedtriggerllc.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <rarebreedtriggerllc.com>. It found the domain confusingly similar to the Complainant’s registered RARE BREED FIREARMS mark because the dominant words “Rare Breed” remained recognizable. The Respondent did not rebut the Complainant’s prima facie case concerning rights or legitimate interests. Bad faith was established by the domain’s use for a commercial website selling forced reset trigger products while closely mimicking the Complainant’s branding, trade dress, and presentation and falsely claiming to produce RARE BREED products.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-09-03
Panelist(s)
Hamilton, William F.
Complainant
M.S.E.O. Holdings LLC
Respondent
NameSilo, LLC, Domain Administrator
Disputed domain(s)
rarebreedtriggerllc.com
Citation weightCited by 1 later decision · relies on 2 authorities
Domain history UDRP Intelligence

The timeline behind rarebreedtriggerllc.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 rarebreedtriggerllc.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 rarebreedtriggerllc.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates that a complainant may satisfy the standing element through a registered mark whose dominant wording remains recognizable in the domain, even when the domain more closely resembles a separately asserted unregistered mark. It also shows the importance of website content under the second and third elements: direct commercial competition combined with imitation of branding, trade dress, and product-source claims supported findings of no legitimate interest and deliberate bad-faith impersonation.

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
2025-09-03
Panel
Hamilton, William F.
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION M.S.E.O. Holdings LLC v. NameSilo, LLC, Domain Administrator Case No. D2025-2865 1. The Parties The Complainant is M.S.E.O. Holdings LLC, United States of America (“United States”), represented by Wood, Herron & Evans, LLP, United States. The Respondent is NameSilo, LLC, Domain Administrator, United States. 2. The Domain Name and Registrar The disputed domain name <rarebreedtriggerllc.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 18, 2025. On July 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 21, 2025, the Registrar transmitted by email to the Center its verification response confirming that the disputed domain name is registered with it and indicating that its own contact details appear in the registration record, with only the registrant’s email address verified. On July 23, 2025, the Center sent an email communication to the Complainant providing the registrant contact information disclosed by the Registrar and inviting the Complainant to submit an amendment to the Complaint. On July 23, 2025, the Complainant confirmed that it wished to add the registrant contact information but did not make any substantive amendments. The Center verified that the Complaint together with the amendment to 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 July 25, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 14, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 15, 2025. page 2 The Center appointed William F. Hamilton as the sole panelist in this matter on August 21, 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 M.S.E.O. Holdings LLC, a limited liability company organized under the laws of Wyoming. The Complainant conducts its business through two exclusive licensees: Rare Breed Firearms, LLC and Rare Breed Triggers, Inc, based in Texas. These entities market and sell firearms and related technology, including a forced reset trigger (a device that mechanically resets the trigger’s position after each shot) under the Complainant’s registered trademark RARE BREED FIREARMS and its unregistered mark RARE BREED TRIGGERS (the “Marks”). The Complainant has used the trademark RARE BREED FIREARMS since 2017. The Complainant owns United States Registration No. 5,656,596 for the RARE BREED FIREARMS trademark, which was registered on January 15, 2019. The Complainant owns the domain names <rarebreedtriggers.com> and <rarebreedfirearms.com> and the associated websites. Currently pending before the United States Patent and Trademark Office is the Complainant’s application bearing Serial Number 99210030, dated May 30, 2025, for the registration of the trademark RARE BREED TRIGGERS. The application asserts a first use date of December 31, 2020. The disputed domain name was registered on June 16, 2024. It resolves to a website that sells forced reset triggers for installation on firearms. The Respondent’s website prominently displays the terms “Rare Breed Triggers” in a stylized way that mimics the style of the Complainant’s mark RARE BREED TRIGGERS displayed on the Complainant’s website. Additionally, the expression “Rare Breed Triggers” is prominently featured throughout the Respondent’s 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 name. The Complaint asserts unregistered trademark rights in the trademark RARE BREED TRIGGERS based upon certain media coverage principally reporting on legal disputes with United States government entities. The Complainant also asserts that the RARE BREED TRIGGERS trademark has developed a secondary meaning which is demonstrated by numerous websites that incorporate the RARE BREEDS TRIGGERS trademark in their domain names and resolve to websites selling counterfeit goods. The Complainant further asserts that the disputed domain name is confusingly similar to the RARE BREED TRIGGERS trademark because the trademark is wholly incorporated into the disputed domain name with the deletion of the letter “s”. The Complainant argues that the disputed domain name is also confusingly similar to Complainant’s RARE BREED FIREARMS trademark because the dominant portion of the mark “RARE BREED” is recognizable within the disputed domain name. The Complainant claims that the Respondent has no rights or legitimate interests regarding the disputed domain name, as the Complainant did not authorize the Respondent to use its Marks, and components thereof, in the disputed domain name. The Complainant also states that the Respondent is neither commonly recognized by the disputed domain name, nor is it engaged in legitimate noncommercial or fair use of the disputed domain name. Additionally, the Complainant contends that the disputed domain name has been fraudulently used to attract unsuspecting Internet users to the Respondent's website for commercial gain. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 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 the RARE BREED FIREARMS trademark (the “Mark”) for the purposes of the Policy by virtue of the registration of the Mark. WIPO Overview 3.0, section 1.2.1. The Panel finds the Mark is recognizable within the disputed domain name. The dominant feature of the Mark, namely “Rare Breed”, is incorporated in the disputed domain name, followed by the terms “trigger” and “llc . The term “llc ” is a common business organization abbreviation meaning “limited liability corporation”. Accordingly, the Panel finds that the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of “trigger” and “llc ” may bear on the assessment of the second and third elements, t he Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The Panel notes the Complainant’s assertion of unregistered trademark rights in RARE BREED TRIGGERS. However, in light of the above findings, the Panel considers it unnecessary to determine whether the Complainant has established such rights. 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 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. page 4 Panels have held that the use of a domain name to confuse Internet users into believing that the disputed domain name resolves to the Complainant’s website can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. 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. In the present case, the Panel notes that the Respondent has registered a confusingly similar domain name that resolves to a website that prominently features the “Rare Breed Triggers” words to accomplish commercial sales of its forced reset trigger installation kits. The Respondent’s website not only resolves to a commercial site selling forced reset triggers, but also prominently displays the Complainant’s RARE BREED stylization and trade dress. The evidence provided in the Complaint shows that the Respondent adopted a logo that closely mimics the Complainant’s presentation of its Mark, and falsely claims to be the producer of RARE BREED products. The Panel finds that such conduct amounts to deliberate impersonation of the Complainant. Panels have consistently found that this type of passing off constitutes strong evidence of bad faith under the Policy. See, e.g., Evergreen Federal Bank v. victory victor, Admintechnologies, WIPO Case No. D2022-4662; All -Clad Metalcrafters LLC v. Eugene Preston, WIPO Case No. D2021-0799. The deliberate attempt to pass off as the Complainant underscores the Respondent’s intent to mislead Internet users for commercial gain. 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 <rarebreedtriggerllc.com> be transferred to the Complainant. /William F. Hamilton/ William F. Hamilton Sole Panelist Date: September 3, 2025

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

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