Westmore · UDRP DecisionCarnivorasnaxs.click + 4 more domains
The Panel ordered the transfer of all five disputed domain names. It found that the Complainant had established unregistered trademark rights in CARNIVORE SNAX and that the domains contained recognizable, obvious misspellings of that mark. The Respondent lacked rights or legitimate interests because the Complainant made a prima facie case that went unrebutted, while one domain had replicated the Complainant’s website wholesale. The same registration pattern supported the inference of an impersonation intention for all five domains. The Panel found bad-faith registration and use under paragraph 4(b)(iv), including through impersonation and, for inactive domains, passive holding in the circumstances of the case.
The timeline behind carnivorasnaxs.click
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 carnivorasnaxs.click — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a complainant can establish UDRP standing through unregistered rights where the record shows meaningful commercial use and recognition, even though its trademark application remains pending. It also demonstrates portfolio-level analysis: proven website cloning by one domain, combined with common registrant details, close registration timing, and highly similar typosquatting formats, supported an inference of a shared impersonation intention across all five domains. Inactivity did not insulate the remaining domains because the Panel assessed passive holding in the context of the mark’s reputation and the proven abuse within the same domain portfolio.
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 Carnivore Snax LLC v. li xue Case No. D2025-4375 1. The Parties The Complainant is Carnivore Snax LLC, United States of America (“United States”), represented by ESCA Legal, United States. The Respondent is li xue, China. 2. The Domain Names and Registrar The disputed domain names <carnivorasnaxs.click>, <carnivorasnaxs.store>, <carnivorasnaxs.top>, <carnivoresnaxs.club> and <carnivoresnaxs.top> are registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 24, 2025. On October 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On October 27, 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 (“Super Privacy Service LTD c/o Dynadot”) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 28, 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 November 1, 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 November 4, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 24, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 26, 2025. page 2 The Center appointed Jeremy Speres as the sole panelist in this matter on December 3, 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 has, since 2022, produced and sold meat crisps in the United States under its CARNIVORE SNAX mark. The Complainant sells its products exclusively through its online store hosted at its domain name <carnivoresnax.com>, which was registered in 2019. The Complainant has generated USD 20 million in turnover since its inception and has sold to over 110,000 customers to date. The Complainant has a pending trade mark application for CARNIVORE SNAX (No. 98782616) filed on October 2, 2024, with the United States Patent and Trademark Office (USPTO) for classes 29 and 35. The disputed domain names were registered on the dates set out below: - <carnivorasnaxs.click>: September 22, 2025 - <carnivorasnaxs.store>: August 26, 2025 - <carnivorasnaxs.top>: August 20, 2025 - <carnivoresnaxs.club>: July 22, 2025 - <carnivoresnaxs.top>: July 12, 2025 None of the disputed domain names presently resolve to any website. The Complainant’s evidence establishes that <carnivorasnaxs.store> previously resolved to a website that replicated the Complainant’s entire website hosted at its domain name <carnivoresnax.com>. 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 that the disputed domain names were registered and have been used in bad faith in order to impersonate the Complainant for the Respondent’s commercial gain. B. Respondent The Respondent did not reply to the Complainant’s contentions. 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 trade mark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. page 3 The Panel finds the Complainant has established unregistered trade mark or service mark rights for CARNIVORE SNAX for the purposes of the Policy. WIPO Overview 3.0, section 1.3. The Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. To the extent that the Complainant’s mark is misspelled within the disputed domain names, the misspellings are common or obvious, which does not prevent a finding of confusing similarity. WIPO Overview 3.0, section 1.9. 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. 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 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. Panels have held that the use of a domain name for illegitimate activity, here claimed impersonation, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Complainant’s evidence establishes that at least one of the disputed domain names has been used to replicate, wholesale, the Complainant’s own website. This shows that the Respondent’s intentions were to impersonate the Complainant. Given that all of the disputed domain names were registered by the same registrant within a few months of one another and are similarly composed and confusingly similar to the Complainant’s mark, it is probable that the Respondent had the same intention for all of the disputed domain names, specifically, to impersonate the Complainant. 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. For the following reasons, the Panel finds that it is more likely than not that the Respondent registered and has used the disputed domain names to take advantage of the confusion with the Complainant’s mark for the Respondent’s commercial gain, falling squarely within paragraph 4(b)(iv) of the Policy. page 4 Panels have held that the use of a domain name for illegitimate activity, here claimed impersonation, constitutes bad faith. WIPO Overview 3.0, section 3.4. As set out in relation to the second element above, it is likely that the Respondent’s intentions were to impersonate the Complainant and to take advantage of the reputation of its mark. The Complainant’s evidence, including endorsements by celebrities and an extensive social media following, establishes that its mark enjoys a reputation. This is corroborated by the fact that Internet searches for the mark return results overwhelmingly relating to the Complainant. To the extent that there is no evidence in the record that some of the disputed domain names ever resolved to an active website, 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 reputation of the Complainant’s trade mark, the composition of the disputed domain names constituting obvious misspellings of the Complainant’s mark, and the fact that one of the disputed domain names has been used for obvious impersonation. The Panel finds that in the circumstances of this case the passive holding of the disputed domain names does not prevent a finding of bad faith under the Policy. 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 names <carnivorasnaxs.click>, <carnivorasnaxs.store>, <carnivorasnaxs.top>, <carnivoresnaxs.club>, and <carnivoresnaxs.top> be transferred to the Complainant. /Jeremy Speres/ Jeremy Speres Sole Panelist Date: December 8, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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