Westmore · UDRP decision
WIPO · Case No. D2025-3343

Billshappenapply.com, Billshappenloansapply.com, Billshappy.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of all three disputed domain names. It found them confusingly similar to the Complainant’s registered BILLSHAPPEN mark, including treating <billshappy.com> as a slight intentional misspelling. Although the Complaint’s assertions on rights or legitimate interests and the overall record lacked specificity and evidentiary substance, the Panel conducted limited factual research by visiting the associated websites. It found that two domains offered competing short-term loan services through websites with layouts and colors similar to the Complainant’s website, while the third domain was inactive. Those facts, the matching 2019 copyright notices, the solicitation of users’ contact details, the Respondent’s default, and apparent targeting supported findings of no rights or legitimate interests and bad-faith registration and use. Passive holding did not prevent a bad-faith finding for the inactive domain.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-31
Panelist(s)
König Horowicz, Theda
Complainant
Winston Wolfe Media Group, LLC
Respondent
jakchai shinghapat
Counsel
IntegriShield
Disputed domain(s)
billshappenapply.com, billshappenloansapply.com, billshappy.com
Citation weightCited by 1 later decision
Domain history UDRP Intelligence

The timeline behind billshappenapply.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 billshappenapply.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
Outcome by domain

How each disputed name was decided in this proceeding.

billshappenapply.comTransferred
billshappenloansapply.comTransferred
billshappy.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of billshappenapply.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a panel may still find all three UDRP elements satisfied in a default case where the complaint is evidentially thin, provided the available public record and limited panel research reveal a coherent pattern of trademark targeting. It also combines active competing use, possible phishing indicators, typographical variation, and passive holding across a cluster of recently registered domains.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-10-31
Panel
König Horowicz, Theda
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Tony Provenzano, Winston Wolfe Media Group, LLC v. jakchai shinghapat Case No. D2025-3343 1. The Parties The Complainant is Tony Provenzano, Winston Wolfe Media Group, LLC, United States of America (“United States”), represented by IntegriShield, United States. The Respondent is jakchai shinghapat, Thailand. 2. The Domain Names and Registrar The disputed domain names <billshappenapply.com>, <billshappenloansapply.com> and <billshappy.com> are registered with eNom, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 20, 2025. On August 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On August 21, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names 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 August 26, 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 30, 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 September 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 29, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 3, 2025. page 2 The Center appointed Theda König Horowicz as the sole panelist in this matter on October 10, 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 individual Complainant Tony Provenzano is the president of the Complainant company Winston Wolfe Media Group, LLC (hereinafter collectively referred to as “the Complainant”), which operates the domain name <billshappen.com> - a financial service platform with its registered seat in the United States, which provides a network of lenders offering short-term personal loans of up to USD 5,000.00. The Complainant is the owner of the BILLSHAPPEN trademark, which has been registered in the United States, under No. 5866680, on September 24, 2019, inter alia for referral services for lenders to provide consumers with personal loans, as protected in class 35. The Complainant further operates its official website at “www.billshappen.com”, registered in 2018. The Complainant’s website has a copyright notice at the bottom of the page dated 2019. The Respondent is reportedly located in Thailand. The date of registration of the disputed domain names are as follows: <billshappenapply.com>: July 21, 2025; <billshappenloansapply.com>: July 25, 2025; <billshappy.com>: August 8, 2025. The disputed domain name <billshappenapply.com> resolves to an inactive website. The disputed domain names <billshappenloansapply.com> and <billshappy.com> resolve to virtually identical websites offering short-term personal loans of up to USD 5,000. 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 to have registered trademark rights in BILLSHAPPEN and that the disputed domain names are confusingly similar. Furthermore, the Complainant alleges that the Respondent has no rights or legitimate interests in the disputed domain names. Finally, the Complainant alleges that the disputed domain names were registered and are used in bad faith, since the Respondent has no trademark rights in the denominations contained in the disputed domain names; additionally, the Respondent intentionally attempted to attract Internet users for commercial gain to the Respondent’s websites by creating a likelihood of confusion with the Complainant’s mark. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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 respect of the trademark BILLSHAPPEN for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel finds the mark is clearly recognizable within the disputed domain names <billshappenapply.com> and <billshappenloansapply.com>. With regard to <billshappy.com> the situation is slightly different considering the meaning of “happy”. The Panel is nevertheless of the opinion that the Complainant’s BILLSHAPPEN trademark is recognizable within the disputed domain name and actually that the use of “happy” instead of “happen” may be considered as an intentional misspelling since it only differs very slightly from the said trademark (only the two last letters are actually different). The Panel’s findings are also supported by the content of the website connected to the disputed domain name <billshappy.com> which provides competing services as the Complainant and has the same layout as the disputed domain name <billshappenloansapply.com>. WIPO Overview 3.0, section 1.15. Accordingly, the disputed domain names are confusingly similar to the BILLSHAPPEN mark. 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. In this case, the Complainant’s allegations on this point are lacking in specificity and are not evidenced. Furthermore, the Respondent decided to not to reply. Under the circumstances, the Panel cannot purely rely on the available record in order to make its findings. It needs to consider the overall circumstances of the case and make use of the general power which is given to panels inter alia in paragraphs 10 and 12 of the Rules to undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision. This may include visiting the website linked to the disputed domain name in order to obtain more information about the respondent or its use of the domain name (WIPO Overview 3.0, section 4.8). Having reviewed the available information in the record, the Panel notes that the Complainant could establish that it has an online business dedicated to loans for which it uses the trademark BILLSHAPPEN and that the Respondent did register the disputed domain names only recently thus concluding that the Respondent is not commonly known by the said domain names. page 4 Furthermore, the Complainant’s distinctive trademark is used for financial services and the Complainant uses BILLSHAPPEN on its official website while the Respondent did not show to have any trademark rights. When visiting the websites linked to the disputed domain names, the Panel noted that <billshappenapply.com> is not active and that the two other disputed domain names <billshappenloansapply.com> and <billshappy.com> resolve to websites providing cash loans thus offering services in the exact same field as the Complainant. The Panel also notes that the layout and colours of the Respondent’s websites are very similar to the Complainant’s official website. Under the circumstances, the Panel finds that even if the Complainant’s allegations on this point were lacking substance, it can be concluded that a prima facie case was established that the Respondent lacks rights or legitimate interests in the disputed domain names. 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 names such as those enumerated in the Policy or otherwise. 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 reaffirms that the available record lacks substance and that it therefore has to make use of its discretion to visit the Respondent’s websites in order to make its assessments. In this frame, the Panel is of the opinion that the Respondent more likely than not knew about the Complainant’s trademark when registering the disputed domain names . The disputed domain names <billshappenloansapply.com> and <billshappy.com> resolve to websites focusing on the same financial services as the Complainant, having a very similar layout and which also invite Internet users to provide their details such as email addresses which can be considered as phishing operations which are considered as bad faith use under the Policy. WIPO Overview 3.0, section 3.4. The Panel further notes that although the three disputed domain names were all registered in 2025, the two active disputed domain names have copyright notices dated 2019, which is the same copyright date on the Complainant’s website. Taken together, and in the absence of any response from the Respondent, the Panel finds it more likely than not that this further illustrates the Respondent’s targeting of the Complainant and its trademark, and that the Respondent has used the disputed domain names within the meaning of paragraph 4(b)(iv) of the Policy. The disputed domain name <billshappenapply.com> is inactive. In this regard, the Panel notes that paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1. In particular, panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and apparent targeting of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name <billshappenapply.com> does not prevent a finding of bad faith under the Policy. page 5 Finally, the Panel notes that the Respondent did not intervene in these proceedings and that a serious doubt can be raised on the identity and contact details given by him when registering the disputed domain names, which is an additional factor of bad faith. The Panel finds 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 names <billshappenapply.com>, <billshappenloansapply.com> <billshappy.com> be transferred to the Complainant. /Theda König Horowicz/ Theda König Horowicz Sole Panelist Date: October 31, 2025

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

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