Westmore · UDRP DecisionSupplydemanduk.com
The Panel ordered transfer of <supplydemanduk.com>. It found the domain confusingly similar to the Complainant’s SUPPLY & DEMAND mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to impersonate the Complainant and attract users for commercial gain through affiliate links. A disclaimer did not overcome the website’s contradictory branding, commercial claims, copied imagery, and false brand narrative.
The timeline behind supplydemanduk.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 supplydemanduk.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates that a nominal fan-site disclaimer will carry little weight when the rest of a website presents itself as the trademark owner, claims commercial operations, reproduces protected branding and product imagery, and monetizes traffic through affiliate links. It also shows how a geographic term tied to the complainant’s home market can reinforce targeting even though it does not avoid confusing similarity.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION JD SPORTS FASHION PLC v. tong xiaonian Case No. D2025-3901 1. The Parties The Complainant is JD SPORTS FASHION PLC, United Kingdom, internally represented. The Respondent is tong xiaonian, China. 2. The Domain Name and Registrar The disputed domain name <supplydemanduk.com> is registered with Dynadot Inc (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 25, 2025. On September 25, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On September 26, 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 (Super Privacy Service LTD c/o Dynadot) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on September 29, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on October 1, 2025. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on October 8, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was October 28, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on October 31, 2025. The Center appointed Ganna Prokhorova as the sole panelist in this matter on November 6, 2025. The Panel f inds 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. page 2 4. Factual Background The Complainant is one of the leading United Kingdom-based sports f ashion retailers f ounded in 1981. Today, the Complainant operates over 4,500 stores across 49 countries with a strong presence in the United Kingdom, European Union, North America and Asia Pacif ic. Among its portfolio, the Complainant owns the SUPPLY & DEMAND trademarks, used for apparel, footwear, and accessories, including, f or example: - European Union Trademark Registration No. 012056438 f or SUPPLY & DEMAND, registered on January 4, 2014, in Classes 18, 25, and 28; - United Kingdom (“UK”) Trademark Registration No. UK00003000113 f or SUPPLY & DEMAND, registered on July 19, 2013, in Class 25; and - UK Trademark Registration No. UK00003873505 f or SUPPLY & DEMAND, registered on April 21, 2023, in Class 9. The SUPPLY & DEMAND branded products are sold through the Complainant’s retail outlets and online channels, and is well-known to consumers in the streetwear and sports f ashion market. The disputed domain name was registered on June 24, 2025. The Respondent has used the disputed domain name to operate a website purporting to sell clothing. At the time of f iling of the Complaint, the website prominently used the SUPPLY & DEMAND mark and offered links f or purchasing SUPPLY & DEMAND-branded products, and included a notice that it participated in the Amazon af f iliate advertising program, thus monetizing traf f ic via af f iliate links to Amazon platform. The website to which the disputed domain name currently resolves includes a disclaimer stating: “This website is an independent, fan-created platf orm that provides content about various brands. It is neither af f iliated with, endorsed by, nor officially associated with these brands. All trademarks, logos, and brand names mentioned are the property of their respective owners. We are merely a platf orm f or publishing content and do not sell products”. Notwithstanding this disclaimer, the “About Us” section presents the entity as a commercial enterprise operating under the name Supply And Demand®, stating: “Supply And Demand® was f ounded in 2016... We started out small, selling our original designs at local street fairs and markets...Within our f irst year, we opened our flagship store in London and launched our online store. Over the years, Supply And Demand® has grown into one of the most recognizable streetwear brands in the UK.... Today, we operate two retail stores and our ever-expanding online store...”. In the “Introduction” section, the website states that it is owned and operated by Supply And Demand® Ltd and invites users to purchase its products through the site or its retail outlets. Finally, the “How to Contact Us” section provides a postal address in London, UK. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain name. Notably, the Complainant contends that: (1) the disputed domain name is confusingly similar to the Complainant’s trademark. The Complainant holds registered rights and global goodwill in the SUPPLY & DEMAND mark, widely recognized in the UK and internationally. The disputed domain name incorporates the entirety of the Complainant’s mark, with the addition of “uk”, a geographic term that heightens conf usion given the Complainant’s UK origins. page 3 (2) the Respondent does not have any rights or legitimate interests in the disputed domain name. The Respondent is using the disputed domain name to operate a website that replicates the Complainant’s product images and branding without authorization, amounting to copyright infringement. The site promotes identical goods and f eatures af f iliate links, including to Amazon, f rom which the Respondent derives commercial gain. It also includes misleading content such as fabricated reviews, falsely implying af f iliation with the Complainant. The Complainant has no connection with the Respondent and has not authorized the registration or use of the disputed domain name. The Respondent is not commonly known by the domain name. Given the Complainant’s long-standing and well-known SUPPLY & DEMAND brand, the Respondent must have been aware of the Complainant’s rights and reputation when registering and using the domain name. (3) the Respondent registered and is using the disputed domain name in bad faith. The disputed domain name incorporates the Complainant’s SUPPLY & DEMAND mark, which predates the disputed domain name registration. The Respondent must have been aware of the Complainant’s rights. The disputed domain name has been registered by the Respondent in a way to conf use consumers into thinking that it is controlled by the Complainant. The disputed domain name is directed at disrupting the Complainant’s business; and/or intentionally attempting to attract f or commercial gain, Internet users to Respondent’s web site. The disputed domain name misleads users into believing it is affiliated with the Complainant, likely f or commercial gain. Such conduct demonstrates bad f aith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings To succeed in a UDRP complaint, the Complainant has to demonstrate that all the elements listed in paragraph 4(a) of the Policy have been satisf ied, namely: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad f aith. The Respondent had 20 days to submit a response in accordance with paragraph 5(a) of the Rules and f ailed to do so. Paragraph 5(f ) of the Rules establishes that if a respondent does not respond to the Complaint, the Panel’s decision shall be based upon the Complaint. However, even if the Respondent has not replied to the Complainant’s contentions, the Complainant still bears the burden of proving that all these requirements are fulfilled. Concerning the uncontested information provided by the Complainant, the Panel may, where relevant, accept the provided reasonable f actual allegations in the Complaint as true. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.3. It is f urther noted that the Panel has taken note of the WIPO Overview 3.0 and, where appropriate, will decide consistently with the consensus views captured therein. A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s mark and the disputed domain name. WIPO Overview 3.0, section 1.7. page 4 Based on the evidence submitted by the Complainant, the Panel finds that the Complainant has shown rights in respect of its SUPPLY & DEMAND mark f or the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Panel f inds that the Complainant’s mark is recognizable within the disputed domain name. The disputed domain name incorporates the Complainant’s SUPPLY & DEMAND mark in its entirety, with the only dif ferences being the deletion of spaces between the words, omission of the sign “&” and the addition of the term “uk”. In accordance with WIPO Overview 3.0, section 1.8, the inclusion of a geographical term does not prevent a f inding of confusing similarity under the first element, as the Complainant’s mark remains clearly recognizable within the disputed domain name. The Panel f urther notes that the generic Top-Level Domain (“gTLD”) “.com” is required only f or technical reasons and is generally ignored for the purposes of comparison of the Complainant’s mark to the disputed domain name. WIPO Overview 3.0, section 1.11.1. Accordingly, the Panel concludes that the disputed domain name is confusingly similar to the Complainant’s mark and that the f irst element of paragraph 4(a) of the Policy is satisf ied. 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 of ten 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. See WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. In this case, the Complainant has established trademark rights in the SUPPLY & DEMAND mark and has credibly asserted that it has not authorized, licensed, or otherwise permitted the Respondent to use these marks in any manner. The Complainant conf irms that it has no business or other relationship with the Respondent and has not consented to the registration or use of the disputed domain name. Based on the available record, there is no evidence that the Respondent has been commonly known by the disputed domain name. The website to which the disputed domain name resolves does not constitute a bona fide offering. Although the website currently contains a disclaimer - which was seemingly added after the Complaint had been f iled – purporting to characterize the site as an “independent, f an-created platf orm”, this is contradicted by multiple sections of the website describing ongoing commercial operations, retail stores, and sales. Furthermore, the Respondent is reproducing the Complainant’s trademark and product photographs, including its models and products, without authorization, and without any disclosure of lack of relationship with the Complainant, rather, on the contrary, fabricating a narrative of the brand’s history. Moreover, the Respondent’s monetization of traffic through affiliate links to third-party e-commerce site demonstrates that the domain name is being used for the Respondent’s financial gain, not f or any genuine noncommercial or f air use. The unauthorized use of the Complainant’s trademark to attract users to generate af f iliate revenue is not a bona fide offering of goods or services under paragraph 4(c)(i) of the Policy, nor is it legitimate noncommercial use. page 5 The Respondent’s conduct also raises concerns of malicious intent, including phishing. The website invites users to submit their email addresses in a “Leave a Reply” section, thereby collecting personal data f rom unsuspecting users. The Respondent has not submitted a Response and has failed to rebut the Complainant’s prima f acie case. In light of the foregoing, the Panel finds that the Respondent has no rights or legitimate interests in respect of the disputed domain name and that the Complainant has satisf ied the requirement of paragraph 4(a)(ii) of the Policy. 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 f aith. The Complainant has demonstrated that it owns well-established rights in the SUPPLY & DEMAND marks. The disputed domain name incorporates the Complainant’s mark in its entirety, and the record indicates that the Respondent was aware of the Complainant and its trademark rights at the time of registration. The Panel f inds that the Respondent registered the disputed domain name with the intent to impersonate the Complainant and trade of f the reputation and goodwill of the SUPPLY & DEMAND marks. To be more specific, the Complainant’s trademark SUPPLY & DEMAND has been extensively used f o r a decade and enjoys substantial goodwill and reputation globally, including in the United Kingdom. The SUPPLY & DEMAND brand is closely associated with the Complainant’s business in the fashion sector. The disputed domain name was registered in 2025, long after the Complainant established its rights. Given the nature of the Respondent’s website, the Panel finds it implausible that the Respondent was unaware of the Complainant’s trademark at the time of registration . It is also worth noting that the inclusion of “uk” in the disputed domain name suggests the Respondent was specifically targeting the Complainant’s market in the United Kingdom, where the Complainant is based and where the SUPPLY & DEMAND brand originates. Theref ore, the Panel believes that the Respondent was aware of the Complainant’s mark at the time of registration of the disputed domain name. Indeed, the Respondent’s use of the Complainant’s exact branding and imagery on the website is clear evidence that the Respondent targeted the Complainant and its trademark intentionally. The Respondent’s use of the disputed domain name to operate a website impersonating the Complainant, purportedly operating as a commercial entity called “Supply And Demand® Ltd”, combined with invitations to purchase products and the use of affiliate links, demonstrates an intentional attempt to attract Internet users f or commercial gain by creating a likelihood of confusion with the Complainant’s trademark. Such conduct f alls within paragraph 4(b)(iv) of the Policy. The addition of a disclaimer does not mitigate this finding. UDRP panels consistently hold that disclaimers cannot cure bad f aith where the overall circumstances of a case point to the respondent’s trading on a complainant’s trademark reputation. Here, the Respondent prominently uses the Complainant’s SUPPLY & DEMAND mark, reproduces it in the product descriptions, displays images associated with the Complainant’s products, contains multiple references to “Supply And Demand”, such as “Our in-house design team [...],” and claims of being an established UK streetwear brand, including assertions of operating retail stores and an online shop. These elements collectively mislead users into believing that the website is operated or endorsed by the Complainant, despite the contradictory disclaimer. The site also incorporates the Complainant’s own marketing language, such as referring to a product as “JD- exclusive”, which underscores the Respondent’s knowledge of the Complainant and its deliberate attempt to impersonate the Complainant. The use of af f iliate advertising links indicates that the Respondent likely benef its f inancially f rom this conf usion. page 6 Taken together, the Respondent’s use of the disputed domain name, its reproduction of the Complainant’s branding and marketing materials, and its creation of a f alse commercial narrative all demonstrate a clear intent to mislead consumers and exploit the Complainant’s trademark for commercial gain. This pattern of conduct constitutes bad f aith under paragraph 4(b)(iv) of the Policy. The Respondent’s bad faith is further evidenced by its concealment of its identity. While the use of a privacy protection service is not per se unlawf ul or conclusive of bad f aith, in the context of this case it f urther supports the inf erence that the Respondent knew its conduct was improper and wished to avoid being identified. Prior UDRP panels have observed that using a proxy or privacy service to mask one’s identity, especially when combined with other indications of bad faith, can support a f inding of bad f aith use. See Suncor Energy Inc. v. Whois Privacy Protection Service, Inc. / andre bechamp, WIPO Case No . D2012-2123. In the absence of any response from the Respondent, and taking into account all of the above f actors, the Panel concludes that the Respondent registered and is using the disputed domain name in bad f aith within the meaning of paragraph 4(a)(iii) and paragraph 4(b)(iv) of the Policy. Accordingly, the third element of paragraph 4(a) of the Policy has been established . 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <supplydemanduk.com> be transf erred to the Complainant. /Ganna Prokhorova/ Ganna Prokhorova Sole Panelist Date: November 23, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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