Westmore · UDRP DecisionHairitageshampoo.com
The Panel ordered transfer of <hairitageshampoo.com>. It found the domain confusingly similar to the Complainant’s HAIRITAGE mark because adding the descriptive word “shampoo” did not avoid similarity. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests. Bad faith was established from the implausibility of selecting the domain without the mark in mind and the website’s deliberate impersonation of the Complainant while offering competing products and services.
The timeline behind hairitageshampoo.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 hairitageshampoo.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a strong impersonation pattern in which a domain combines a trademark with a term describing the trademark owner’s goods and then uses the corresponding website to reproduce the owner’s branding and associated imagery. It also shows that a panel may issue findings on all three UDRP elements notwithstanding a respondent’s consent to transfer without an admission of liability.
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 Hairitage IP LLC v. Andrew Tetan Case No. D2025-3231 1. The Parties The Complainant is Hairitage IP LLC, United States of America, represented by Dorf Nelson & Zauderer LLP, United States of America (or USA). The Respondent is Andrew Tetan, Ukraine. 2. The Domain Name and Registrar The disputed domain name <hairitageshampoo.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 12, 2025. On August 13, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 13, 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 (Heritage Hair Cosmetics and NameCheap) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 14, 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 August 14, 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”). On August 22, 2025, following the Respondent’s communication, the Center sent a Possible Settlement email to the Parties to which the Complainant responded requesting Suspension of the proceeding to explore settlement options before commencement of the proceedings. The Center suspended the proceedings from August 29, 2025, until September 28, 2025. On September 26, 2025, the Complainant sent an email to the Center informing that the Parties will not settle the case and requesting that the proceeding be continued. The Center reinstituted the proceeding on September 29, 2025. page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on September 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 20, 2025. The Respondent sent various email communications to the Center in August and September 2025. On October 27, 2025, the Center informed the Parties about the Commencement of Panel Appointment Process. The Center appointed George R. F. Souter as the sole panelist in this matter on October 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 by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is a beauty-care company that offers products and services for haircare which, in 2020, introduced the trademark HAIRITAGE by Mindy McKnight, a famous hair stylist and influencer. The Harvard business school, in a public report, calculated the turnover of products and services under the HAIRITAGE trademark as US dollars 23 million in 2023. The Complainant is the proprietor of a number of registrations of its HAIRITAGE trademark in the USA and abroad, including US Registration No. 6,035,620, registered on April 14, 2020, and International Registration No. 1678427, registered on July 14, 2022. The disputed domain name was registered on July 15, 2025, and resolves to a website prominently displaying “HAIRITAGE by Mindy McKnight”, together with photographs of Mindy McKnight in proximity to HAIRITAGE products. 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 Respondent is not generally known by the disputed domain name, and that the Complainant has never granted permission to the Respondent to use its HAIRITAGE trademark in connection with the registration of a domain name, or otherwise. B. Respondent The Respondent consented to the transfer of the disputed domain name to the Complainant and waived its rights to file a formal Response. The Respondent agreed to proceed with a peaceful resolution of the case without any admission of liability and without any monetary compensation. 6. Discussion and Findings A. Preliminary Matters The Panel notes that the Respondent’s postal address is stated to be in Ukraine and that many communications were received from the Respondent in the proceeding. Noting that Ukraine is subject to an international conflict at the date of this Decision, the Panel is to consider, in accordance with paragraph 10 of the Rules, whether the proceeding should continue. page 3 Having considered the circumstances of the case and that the Respondent participated in this proceeding, the Panel is of the view that it should. B. Identical or Confusingly Similar The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The mere addition of the descriptive word “shampoo” does not detract from this finding. The Panel finds the first element of the Policy has been established. C. Rights or Legitimate Interests 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 Panel finds the second element of the Policy has been established. D. Registered and Used in Bad Faith The Panel considers it implausible that the disputed domain name was adopted without the Complainant’s trademark in mind, and the subsequent use of the disputed domain name by the Respondent appears to confirm this. The Panel finds that the disputed domain name was registered in bad faith It is well-established in prior decisions under the Policy that the use of a domain name to offer products and services in direct competition with genuine products and services of a trademark owner constitutes use of that domain name in bad faith. In the circumstances of the present case, the situation is aggravated by what the Panel considers to be a deliberate attempt by the Respondent to impersonate the Complainant, which clearly justifies a finding of use in bad faith, and the Panel so finds. The Panel finds that 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 that the disputed domain name <hairitageshampoo.com> be transferred to the Complainant. /George R. F. Souter/ George R. F. Souter Sole Panelist Date: November 14, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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