Westmore · UDRP DecisionGforgolfs.com
The Panel ordered transfer of <gforgolfs.com>. It found the domain confusingly similar to Complainant’s G FORE and G/FORE marks, found no rights or legitimate interests based on the unrebutted evidence of a competing commercial website, and concluded that Respondent registered and used the domain to trade on Complainant’s goodwill for commercial gain.
The timeline behind gforgolfs.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 gforgolfs.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how adding a term closely connected to a complainant’s commercial field may reinforce rather than dispel the significance of a recognizable trademark within a domain. The commercial use of the domain for third-party products, combined with the absence of any respondent explanation, was central to the findings on legitimate interests and bad faith.
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 Peter Millar LLC v. Shaquena Crawford Case No. D2025-3598 1. The Parties Complainant is Peter Millar LLC, United States of America (“United States”), represented by Corsearch, United States. Respondent is Shaquena Crawford, United States. 2. The Domain Name and Registrar The disputed domain name <gforgolfs.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 September 10, 2025. On September 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 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 (Domain Administrator, PrivacyGuardian.org LLC) and contact information in the Complaint. The Center sent an email communication to Complainant on September 11, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on September 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 Respondent of the Complaint, and the proceedings commenced on September 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 8, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on October 9, 2025. page 2 The Center appointed Lorelei Ritchie as the sole panelist in this matter on October 17, 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 Complainant is a limited liability company based in the United States. For over a decade prior to the registration of the disputed domain name, Complainant, together with its predecessors and affiliates (collectively, “Complainant”) has offered golf gloves and other athletic apparel and products under its G FORE and G/FORE marks. In this regard, Complainant owns registrations for these marks in jurisdictions throughout the world. These include, among others, United States Registration Nos. 4,035,425 (registered October 4, 2011) and 4,808,894 (registered September 8, 2015); and International Registration No. 1526743 (registered March 9, 2020). The disputed domain name was registered on July 23, 2025. Respondent has directed the URL associated with the disputed domain name to a website that offers third-party products competing with those offered by Complainant under the sign “gforgolfs”. Complainant has not authorized any activities by Respondent, nor any use of its trademarks thereby. 5. Parties’ Contentions A. Complainant Complainant contends that (i) the disputed domain name is identical or confusingly similar to Complainant’s trademarks, (ii) Respondent has no rights or legitimate interests in the disputed domain name; and (iii) Respondent registered and is using the disputed domain name in bad faith. Specifically, Complainant contends that it owns rights to the G FORE and G/FORE marks for golf gloves and other athletic apparel and products, for which Complainant has gained “world-wide fame.” Complainant further contends that it owns the registration for the domain name <gfore.com> (registered March 31, 2009), which Complainant uses to connect with consumers online regarding its G FORE and G/FORE products. Complainant contends that Respondent has incorporated the “dominant portion” of Complainant’s “well- known” mark, with the addition only of the term “golfs”, which would likely be understood by consumers as referring to the nature of Complainant’s athletic products, including apparel and accessories for golf. Complainant contends that Respondent lacks rights or legitimate interest in the disputed domain name, and rather has registered and is using it in bad faith. In this regard, Complainant alleges that Respondent has directed the URL associated with the disputed domain name to a website that offers third-party products competing with those offered by Complainant under its registered G FORE and G/FORE marks, presumably for Respondent’s own commercial gain. B. Respondent Respondent did not reply to 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 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. Complainant has shown rights in respect of trademarks G FORE and G/FORE, for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. Although the addition of other terms (here, “golfs”) may bear on assessment of the second and third elements, the Panel finds the addition of such term to the dominant portion of Complainant’s mark does not prevent a finding of confusing similarity between the disputed domain name and Complainant’s mark for purposes of the Policy, as the Complainant’s mark remains recognizable. WIPO Overview 3.0, sections 1.8 and 1.9. The Panel therefore finds that the disputed domain name is confusingly similar to a trademark in which Complainant has rights in accordance with paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which 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. Complainant notes that the website associated with the disputed domain name offers third-party products that compete with those offered by Complainant under the sign “gforgolfs” which is confusingly similar to the Complainant’s G FORE and G/FORE marks. The Panel finds that Complainant has provided sufficient evidence of Respondent’s lack of rights or legitimate interests in accordance with paragraph 4(a)(ii) of the Policy, which Respondent has not rebutted, and accordingly the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith There are several ways that a complainant can demonstrate that a domain name was registered and used in bad faith. As noted in Section 4 of this Panel’s decision, Respondent has directed the URL associated with the disputed domain name to a website that offers third-party products competing with those offered by Complainant under its registered G FORE and G/FORE marks. There is no plausible explanation, and Respondent did not provide any, of why it chose “gforgolfs” other than for creating a likelihood of confusion with the Complainant’s mark, as “golfs” is directly related to the Complainant’s activity. All the more, the clothes sold on the disputed domain name’s website seem unrelated to golf practice. Hence, Respondent was more likely than not aware of Complainant’s rights when registering the disputed domain name and is trading on the goodwill of Complainant’s trademarks to attract Internet users for Respondent’s own commercial gain. page 4 Therefore, the Panel finds sufficient evidence that Respondent registered and used the disputed domain name in bad faith for purposes of paragraph (4)(a)(iii) 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 <gforgolfs.com> be transferred to Complainant. /Lorelei Ritchie/ Lorelei Ritchie Sole Panelist Date: October 29, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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