Westmore · UDRP DecisionWomenmanagment.com
The Panel ordered transfer of <womenmanagment.com>. It found the Domain Name confusingly similar to the Complainant’s WOMEN MANAGEMENT mark because it omitted one letter from “management,” an example of typosquatting. The Respondent lacked rights or legitimate interests because the Domain Name had been used for PPC links and appeared to have been used to solicit personal information through impersonation. The slight misspelling and deceptive communications also established that the Domain Name was registered and used in bad faith.
The timeline behind womenmanagment.com
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The decision illustrates how a one-letter omission combined with domain-based impersonation can support all three UDRP elements. The Panel treated the typographical variation as readily recognizable, found no legitimate interest in PPC and deceptive use, and relied on the apparent solicitation of personal information to establish deliberate targeting 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 Elite Licensing Company S.A.G.L v. Diogo Jota, Diogo Jota Foundation Case No. D2025-4459 1. The Parties The Complainant is Elite Licensing Company S.A.G.L, Switzerland, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Diogo Jota, Diogo Jota Foundation, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <womenmanagment.com> (the “Domain Name”) is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 29, 2025. On October 29, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On October 30, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 31, 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 5, 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 7, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 27, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 3, 2025. page 2 The Center appointed Ian Lowe as the sole panelist in this matter on December 11, 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 is a member of the Elite World Group founded in 1972, a pioneer of fashion talent management. The group has a number of networks, each representing distinct rosters of talent with diverse points of entry into the modern fashion, beauty and luxury lifestyle industries, including Elite Model Management and Women Management. The WOMEN MANAGEMENT brand was launched in 1988 with the opening of its first agency office in New York. The network has since expanded to Paris, Milan and Los Angeles, and today represents many of the fashion world’s most celebrated talent, including Naomi Campbell, Mariclara Boscono and Winnie Harlow. The Complainant operates a website at “www.womenmanagement.com” promoting its leading models. The Complainant is the proprietor of a number of registered trademarks for WOMEN MANAGEMENT (the ”Mark”) including United States trademark number 3039241 registered on January 10, 2006; European Union trademark number 010929008 registered on October 10, 2012 and the comparable United Kingdom trademark No. 91029008 created following the United Kingdom’s exit from the European Union, and also treated as registered on October 10, 2012; and International trademark number 1174610, registered on May 2, 2013. The Domain Name was registered on August 14, 2025. It does not currently resolve to an active website. At the time of preparation of the Complaint, the Domain Name resolved to a parking page comprising dynamic links to webpages of pay-per-click (“PPC”) links to a number of third-party websites. In addition, the Complainant has been informed by third parties that they have received text messages from a person claiming to be one of the Complainant’s employees, inducing them to email personal information to an email address at the Domain Name. 5. Parties’ Contentions A. Complainant The Complainant contends that the Domain Name is confusingly similar to the Mark, that the Respondent has no rights or legitimate interests in respect of the Domain Name, and that the Respondent registered and is using the Domain Name in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings For this Complaint to succeed in relation to the Domain Name the Complainant must prove that: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the Domain Name; and (iii) the Domain Name has been registered and is being used in bad faith. page 3 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 a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. Ignoring the generic Top-Level Domain “.com”, the Domain Name comprises the entirety of the Complainant’s WOMEN MANAGEMENT mark save for the omission of the second letter “e”. In the Panel’s view the omission of this letter (indicative of “typosquatting”) does not prevent a finding of confusing similarity between the Domain Name and the Mark. Accordingly, the Panel finds that the Domain Name is confusingly similar to a trademark in which the Complainant has rights, and 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. Accordingly, 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. The Domain Name has been used, first, to resolve to a webpage of PPC links comprising in turn click through links to third party websites. In addition, it appears to have been used to confuse targeted individuals into sending personal information to an email address at the Domain Name in the mistaken assumption that they were being asked to communicate with the Complainant. In the Panel’s view, the Domain Name is an example of typosquatting, whereby a domain name is registered with a minor variation of a well-known brand name with a view to taking advantage of typographical errors or mistaken perception by Internet users. Such a registration cannot possibly, on the face of it, give rise to rights or legitimate interests on the part of the registrant of a domain name. Furthermore, UDRP panels have consistently held that the use of a domain name for illegal activity (such as impersonation, phishing, or passing off) can never confer rights or legitimate interests on a respondent. See WIPO Overview 3.0 section 2.13.1. Having reviewed the available evidence, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the 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 Domain Name such as those enumerated in the Policy or otherwise. The Panel finds the second element of the Policy has been established. page 4 C. Registered and Used in Bad Faith In light of the nature of the Domain Name, comprising a slight misspelling of the Complainant’s mark, and the sending of text messages purporting to be from an employee of the Complainant, the Panel is satisfied that the Respondent had the Complainant and its rights in the Mark in mind when it registered the Domain Name, and that it did so with the intention of using the Domain Name to deceive Internet users into believing that it was registered by or associated with the Complainant for legitimate purposes related to the Complainant’s activities. 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. The Panel cannot conceive of a legitimate use to which the Respondent could put the Domain Name. A legitimate registrant would not use a domain name comprising a misspelling of the word “management”. Since the Respondent has used the Domain Name to attempt to deceive unsuspecting third parties into sending personal information to an email address at the Domain Name, the Panel is in no doubt that the Respondent registered and uses the Domain Name for commercial gain with a view to taking unfair advantage of the Complainant’s rights in the Mark. Accordingly, the Panel finds that the Domain Name has been registered and is being used in bad faith. 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 Domain Name <womenmanagment.com> be transferred to the Complainant. /Ian Lowe/ Ian Lowe Sole Panelist Date: December 25, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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