Westmore · UDRP DecisionImpact-clean.com
The Panel ordered transfer of <impact-clean.com>. It found the domain confusingly similar to the Complainant’s registered IMPACT mark because it incorporated the mark in its entirety and the addition of the hyphenated term “clean” did not prevent confusing similarity. The Respondent lacked rights or legitimate interests because the Website impersonated or passed itself off as associated with the Complainant, and the Respondent did not rebut the Complainant’s prima facie case. The same impersonating use, including prominent display of the IMPACT mark and product logo while purportedly offering the Complainant’s products at discounted prices, established registration and use in bad faith under paragraph 4(b)(iv) of the Policy.
The timeline behind impact-clean.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 impact-clean.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a domain combining a trademark with a term closely connected to the trademark owner’s products can support a broader impersonation analysis. Confusing similarity was straightforward because IMPACT remained recognizable, while the Website’s prominent use of the mark and product logo, purported discounted product sales, and copied-looking third-party reference drove the findings under the second and third elements.
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 The Tranzonic Companies v. Liu Zhenlai Case No. D2025-3718 1. The Parties The Complainant is The Tranzonic Companies, United States of America (“United States”), represented by Renner, Otto, Boisselle, & Sklar, LLP, United States. The Respondent is Liu Zhenlai, China. 2. The Domain Name and Registrar The disputed domain name <impact-clean.com> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on September 12, 2025. On September 15, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 16, 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 (John Doe, Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 17, 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 in English on September 17, 2025. On September 17, 2025, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On September 17, 2025, the Complainant confirmed its request that English be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in Chinese and English of the Complaint, and the proceeding commenced on September 26, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 16, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 17, 2025. The Center appointed Sebastian M.W. Hughes 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 A. Complainant The Complainant is the parent company of the Hospeco Brands Group, the seller of a wide range of cleaning and safety products under the word and logo trade mark IMPACT (the “Trade Mark”). The Complainant is the owner of the following registrations for the Trade Mark in the United States: registration No. 5,142,350, with a registration date of February 14, 2017; and registration No. 5,779,882, with a registration date of June 18, 2019. In addition to its registrations for the Trade Mark, the Complainant also uses the following green stylised logo in connection with the promotion and sale of its products (the “IMPACT Products Logo”): B. Respondent The Respondent is apparently an individual located in China. C. The Disputed Domain Name The disputed domain name was registered on December 29, 2022. D. Use of the Disputed Domain Name The disputed domain name is resolved to an English language website (the “Website”) featuring prominently the Trade Mark and the IMPACT Products Logo; purportedly offering for sale the Complainant’s cleaning and safety products at discounted prices; displaying the copyright notice “Copyright 2025 © www.impact- clean.com”; and containing, on the FAQ page, a quotation referring to a third party brand unrelated to the Complainant. 1 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. 1 “Our goal at Husqva Outlet is to ship your items out to you as soon as possible.” page 3 Notably, the Complainant contends that the Respondent has registered and used the disputed domain name, in bad faith, in order to pass off the Website as a website of, or authorised or approved by, the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that the Website is in the English language. The Respondent did not make any submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 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 Trade Mark and the disputed domain name. WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the Trade Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms (here, the word “clean”, separated by a hyphen) may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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. page 4 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. Panels have held that the use of a domain name for illegal activity (as applicable to this case: impersonation/passing off) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds also that the reference, in the FAQ section of the Website, to an unrelated third party brand, underscores the fact the Website is not a genuine website, and the Respondent’s resultant lack of rights or legitimate interests in the disputed domain name. 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 light of the manner of registration and use of the disputed domain name, the Panel finds that the requisite element of bad faith has been made out pursuant to paragraph 4(b)(iv) of the Policy. Further, panels have also held that the use of a domain name for illegal activity (as applicable to this case: impersonation/passing off) constitutes bad faith. WIPO Overview 3.0, section 3.4. Accordingly, 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 <impact-clean.com> be transferred to the Complainant. /Sebastian M.W. Hughes/ Sebastian M.W. Hughes Sole Panelist Date: November 10, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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