Westmore · UDRP DecisionReedsmithgroup.com
The Panel ordered transfer of <reedsmithgroup.com> after finding all three UDRP elements satisfied. The Domain Name incorporated the REED SMITH mark with the additional term “group”; Respondent lacked authorization or other rights or legitimate interests; and the Domain Name was registered and used with knowledge of Complainant for impersonation and phishing emails. The inactive website did not alter the bad-faith finding.
The timeline behind reedsmithgroup.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 reedsmithgroup.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates that an inactive website does not prevent transfer when the domain is actively used as email infrastructure for phishing and impersonation. The combination of a complete law-firm mark, the organizational term “group,” and use of the firm’s genuine website in email signatures gave the Panel direct evidence of targeting across all three UDRP 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 Reed Smith LLP v. Kaitlyn Spearman Case No. D2025-4626 1. The Parties Complainant is Reed Smith LLP, United States of America (“U.S.” or “United States”), Internally represented. Respondent is Kaitlyn Spearman, U.S. 2. The Domain Name and Registrar The disputed domain name <reedsmithgroup.com> (the “Domain Name”) is registered with Network Solutions, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 7, 2025. On November 7, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On November 8, 2025, the Registrar transmitted by email to the Center its verification response confirming that Respondent is listed as the registrant and providing the contact details. Complainant filed an amended Complaint on November 17, 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 November 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 8, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on December 12, 2025. The Center appointed Kimberley Chen Nobles as the sole panelist in this matter on December 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. page 2 4. Factual Background Complainant is a law firm with over 1,700 attorneys worldwide and 31 full service legal offices across the United States, Europe, Middle East, and Asia. In 2023, Complainant had a gross profit of USD 1.4 billion. Complainant owns numerous registered trademarks in a number of jurisdictions worldwide with the REED SMITH mark, including: - U.S. registered trademark number 1,293,150 for the REED SMITH word mark, registered on September 4, 1984; - United Kingdom registered trademark number UK00902212405 for the REED SMITH word mark, registered on April 29, 2005; and - Hong Kong, China registered trademark number 301011563 for the REED SMITH word and design mark, registered on September 8, 2008. Complainant also owns numerous domain names with the REED SMITH mark, including <reedsmith.com>. The Domain Name was registered on October 16, 2025 and at the time of filing of the Complaint, resolved to an inactive website. However, Complainant noticed around October 27, 2025 that phishing messages were circulated from an email address affiliated with the Domain Name. Complainant informed the Registrar. On November 2, 2025, Complainant received a phishing notice from the Registrar via its web host, indicating that the registrant had been told to cease phishing. In addition, around November 4, 2025, consumers have reported receiving phishing messages from email addresses associated with the Domain Name, such as “[redacted]@reedsmithgroup.com”. Complainant also alleges that Respondent has transmitted such messages through various “Contact Us” portals and that Respondent is using the Domain Name to impersonate Complainant, promote fraudulent legal services and consultations, and carry out a phishing scheme to try and deceive consumers into disclosing sensitive information or transmitting money under false pretenses. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. Complainant contends that (i) the Domain Name is identical or confusingly similar to Complainant’s trademarks; (ii) Respondent has no rights or legitimate interests in the Domain Name; and (iii) Respondent registered and is using the Domain Name in bad faith. In particular, Complainant contends that it has trademark registrations for REED SMITH and that Respondent registered and is using the Domain Name with the intention to confuse Internet users looking for bona fide and well-known REED SMITH products and services. Complainant notes that it has no affiliation with Respondent, nor authorized Respondent to register or use the Domain Name, which includes Complainant’s trademarks, and that Respondent has no rights or legitimate interests in the registration and use of the Domain Name. Rather, Complainant contends that Respondent has acted in bad faith in acquiring and setting up the Domain Name, when Respondent clearly knew of Complainant’s rights. B. Respondent Respondent did not reply to Complainant’s contentions. page 3 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed Complainant must satisfy the Panel that: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the Domain Name; and (iii) the Domain Name was registered and is being used in bad faith. Section 4.3 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) states that failure to respond to the complainant’s contentions would not by itself mean that the complainant is deemed to have prevailed; a respondent’s default is not necessarily an admission that the complainant’s claims are true. Thus, although in this case Respondent has failed to respond to the Complaint, the burden remains with Complainant to establish the three elements of paragraph 4(a) of the Policy by a preponderance of the evidence. See, e.g., The Knot, Inc. v. In Knot We Trust LTD, WIPO Case No. D2006-0340. A. Identical or Confusingly Similar Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy. See WIPO Overview 3.0, section 1.2.1. Complainant has provided evidence of its rights in the REED SMITH trademarks, as noted above. With Complainant’s rights in the REED SMITH trademarks established, the remaining question under the first element of the Policy is whether the Domain Name, typically disregarding the Top-Level Domain (“TLD”) in which it is registered (in this case, “.com”), is identical or confusingly similar to Complainant’s trademark. See, e.g., B & H Foto & Electronics Corp. v. Domains by Proxy, Inc. / Joseph Gross, WIPO Case No. D2010- 0842. Here, the Domain Name is confusingly similar to Complainant’s REED SMITH trademarks. These trademarks are recognizable in the Domain Name. In particular, the Domain Name includes Complainant’s REED SMITH trademarks in their entirety, with the deletion of the space between “REED” and “SMITH” and addition of the term “group” following Complainant’s trademark REED SMITH, in the Domain Name <reedsmithgroup.com>. The deletion of the space and addition of the term “group” in the Domain Name as noted does not prevent a finding of confusing similarity between the Domain Name and Complainant’s REED SMITH trademarks. Thus, the Panel finds that Complainant has satisfied the first element of the Policy. B. Rights or Legitimate Interests Under paragraph 4(a)(ii) of the Policy, a complainant must make a prima facie showing that a respondent possesses no rights or legitimate interests in a disputed domain name. See, e.g., Malayan Banking Berhad v. Beauty, Success & Truth International, WIPO Case No. D2008-1393. Once a complainant makes such a prima facie showing, the burden of production shifts to the respondent, though the burden of proof always remains on the complainant. If the respondent fails to come forward with relevant evidence showing rights or legitimate interests, the complainant will have sustained its burden under the second element of the UDRP. From the record in this case, it is evident that Respondent was, and is, aware of Complainant and its trademarks, and does not have any rights or legitimate interests in the Domain Name. Complainant has confirmed that Respondent is not affiliated with Complainant, or otherwise authorized or licensed to use Complainant’s trademarks or to seek registration of any domain name incorporating the trademarks. page 4 Respondent is also not known to be associated with the REED SMITH trademarks and there is no evidence showing that Respondent has been commonly known by the Domain Name. Further, the nature of the Domain Name comprising Complainant’s trademarks in their entirety, with the inclusion of the term “group”, indicates an awareness of Complainant. In the present circumstances, although the Domain Name does not resolve to an active website, emails were sent from the Domain Name impersonating Complainant’s employee, on the pretext of promoting fraudulent legal services and consultations and carry out a phishing scheme to try and deceive consumers under false pretenses. The record shows that the email addresses in the originating email (sent by Respondent) all use the <reedsmithgroup.com> Domain Name, but the website address appearing in the signature block of the email is <reedsmith.com>, which is the legitimate address of Complainant’s website. Such use of the Domain Name is misleading and such potential attempts to reach Complainant’s consumers or third parties, may result in giving the false impression to Internet users that the Domain Name is owned by Complainant. The resulting confusion would cause damage to Complainant’s reputation, goodwill and interfere with Complainant’s business activities. The use of a domain name for email phishing and impersonation/passing off can never confer rights or legitimate interests on Respondent. See section 2.13, WIPO Overview 3.0. Accordingly, Complainant has provided evidence supporting its prima facie claim that Respondent lacks any rights or legitimate interests in the Domain Name. Respondent has failed to produce countervailing evidence of any rights or legitimate interests in the Domain Name. Thus, the Panel concludes that Respondent does not have any rights or legitimate interests in the Domain Name and Complainant has met its burden under paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Panel finds that Respondent’s actions indicate that Respondent registered and is using the Domain Name in bad faith. Paragraph 4(b) of the Policy provides a non-exhaustive list of circumstances indicating bad faith registration and use on the part of a domain name registrant, namely: “(i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or (ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product or service on your website or location.” The Panel finds that Complainant provided ample evidence to show that registration and use of the REED SMITH trademarks long predate the registration of the Domain Name. Complainant is also well established and known. Indeed, the record shows that Complainant’s REED SMITH trademarks and related products and services are widely known and recognized. Moreover, Respondent’s impersonating emails confirm its knowledge of Complainant and its trademarks. Therefore, the Panel finds Respondent was aware of the REED SMITH trademarks when it registered the Domain Name. page 5 The Panel therefore finds that Respondent’s awareness of Complainant’s trademark rights at the time of registration suggests bad faith. See Red Bull GmbH v. Credit du Léman SA, Jean-Denis Deletraz, WIPO Case No. D2011-2209; Nintendo of America Inc v. Marco Beijen, Beijen Consulting, Pokemon Fan Clubs Org., and Pokemon Fans Unite, WIPO Case No. D2001-1070; and BellSouth Intellectual Property Corporation v. Serena, Axel, WIPO Case No. D2006-0007. Here, although the Domain Name does not resolve to an active website, emails were sent from the Domain Name impersonating Complainant’s employee, on the pretext of promoting fraudulent legal services and consultations and carry out a phishing scheme to try and deceive consumers under false pretenses. The record shows that the email addresses in the originating email (sent by Respondent) all use the <reedsmithgroup.com> Domain Name, but the website address appearing in the signature block of the email is <reedsmith.com>, which is the legitimate address of Complainant’s website. Such use of the Domain Name is misleading and such potential attempts to reach Complainant’s consumers or third parties, may result in giving the false impression to Internet users that the Domain Name is owned by Complainant. The resulting confusion from such impersonation and/or phishing communications would cause damage to Complainant’s reputation and goodwill and interfere with Complainant’s business activities. UDRP panels have consistently held that Respondent’s use of the Domain Name to trade off goodwill in Complainant’s well-known trademark and impersonate Complainant constitutes bad faith. See Philip Morris Products S.A. v. homn mohmoodi, WIPO Case No. D2022-4158. The use of a domain name for email phishing and impersonation/passing off shows Respondent’s acts of bad faith and is not rebutted by Respondent. At the time of the Decision, the Domain Name resolves to an inactive webpage, which does not change the Panel’s finding of Respondent’s bad faith. Finally, considering the distinctiveness and reputation of the REED SMITH trademarks, the failure of Respondent to submit a Response or to provide any evidence of actual or contemplated good faith use, and particularly noting the Domain Name clearly targeted Complainant, the Panel finds that Respondent has registered and is using the Domain Name in bad faith and Complainant succeeds under the third element of paragraph 4(a) 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 <reedsmithgroup.com> be transferred to Complainant. /Kimberley Chen Nobles/ Kimberley Chen Nobles Sole Panelist Date: December 29, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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