Westmore · UDRP decision
WIPO · Case No. D2025-4667

Thetravellerwhiskey.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <thetravellerwhiskey.com>. It found the domain confusingly similar to the Complainant’s registered TRAVELLER mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The domain had previously resolved to an imposter website displaying the Complainant’s branded bottles and references to its Buffalo Trace Distillery, and later resolved to an inactive page. The Panel found that the later passive holding did not prevent a finding of bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-08
Panelist(s)
Wong Wai Man, Deanna
Complainant
Sazerac Brands, LLC
Respondent
Liu Ying Huan (刘迎欢)
Disputed domain(s)
thetravellerwhiskey.com
Citation weightCited by 1 later decision · relies on 2 authorities
Domain history UDRP Intelligence

The timeline behind thetravellerwhiskey.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 thetravellerwhiskey.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of thetravellerwhiskey.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates that a complainant may prevail on the strength of a registered word mark even when its evidence of broader common-law rights in a mark-plus-product phrase is inadequate. It also shows how website content specifically reproducing branded products and referring to the complainant’s facility can be decisive across both the legitimate-interests and bad-faith elements. A respondent cannot avoid scrutiny of earlier impersonation merely by making the domain inactive before the decision.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-08
Panel
Wong Wai Man, Deanna
Full decision
15 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sazerac Brands, LLC v. Liu Ying Huan (刘迎欢) Case No. D2025-4667 1. The Parties The Complainant is Sazerac Brands, LLC, United States of America (“United States”), represented by Dorsey & Whitney, LLP, United States. The Respondent is Liu Ying Huan (刘迎欢), China. 2. The Domain Name and Registrar The disputed domain name <thetravellerwhiskey.com> is registered with eName Technology Co., Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on November 10, 2025. On November 11, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 12, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 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 in English on December 1, 2025. On November 28, 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 December 1, 2025, the Complainant requested English to 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 proceedings commenced on December 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 22, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 23, 2025. The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on December 26, 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. The Complainant requested on December 5, 2025, after the commencement of these proceedings, to include an additional domain name to the proceeding. As such request was made following the Complaint notification and allowing the request would hence delay the proceeding, the Panel declines the Complainant’s request. The Complainant may file a new complaint to address any additional domain names should it wish to do so. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.12. 4. Factual Background Founded in the 1890s, the Complainant is a family-owned business and one of the largest spirits and beverage companies in the United States. For over a century, together with and through its affiliates, licensees, and predecessors-in-interest, the Complainant has marketed and sold a wide variety of different types of alcoholic and distilled spirits beverages, including, but not limited to, vodkas, bourbons, whiskeys, tequilas, and liqueurs under various highly acclaimed and recognizable brands. Among these spirits brands is the TRAVELLER whiskey brand, used by the Complainant for small-batch whiskey products. Since its first creation, these products are exclusively distilled at the Complainant’s Buffalo Trace Distillery located in Frankfort, Kentucky, United States. The Complainant markets, advertises, and sells its TRAVELLER whiskey products via a dedicated product page through its Buffalo Trace Distillery website, where it also lists the awards its TRAVELLER products have earned, including the 2025 Silver at the International Wine & Spirits Competition, 2024 Silver at the International Spirits Challenge, 2024 Silver at the Global Whiskey Challenge, and 2024 Silver at the International Wine & Spirits Competition. The TRAVELLER mark is also prominently used and featured on social media platforms. The Complainant provides evidence that it owns an international portfolio of trademark registrations for the TRAVELLER mark, including, but not limited to the following registrations: European Union Trademark Registration No. 019018603 for the TRAVELLER word mark, registered on September 14, 2024 in Nice Class 33 and United Kingdom Trademark Registration No. UK00004043402 for the TRAVELLER word mark, registered on April 24, 2024 in Nice Class 33. The Panel notes that the Complainant also claims common law trademark rights in the TRAVELLER WHISKEY brand, but finds that the Complainant did not provide sufficient evidence of use (submitting only a few search engine results) that would allow the Panel to recognize such unregistered rights. In the absence of more persuasive evidence demonstrating the requisite secondary meaning (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.3), the Panel bases this Decision only on the Complainant’s TRAVELLER trademark registrations. The disputed domain name was registered on February 11, 2025 and is therefore of a later date than the abovementioned Complainant’s trademark registrations. The Complainant provides evidence that the disputed domain name directed to an imposter website, prominently titled “The Traveller Whiskey”, displaying images of the Complainant’s bottles branded with the TRAVELLER whiskey mark and containing references to the Complainant’s Buffalo Trace Distillery. However, the Panel notes that on the date of this Decision, the disputed domain name directs to an inactive website. page 3 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. Notably, the Complainant contends that it has established substantial common law and registered trademark rights in the TRAVELLER WHISKEY mark through extensive use, promotion, media recognition, and international trademark filings. The disputed domain name incorporates the TRAVELLER WHISKEY mark in its entirety, with the mere addition of the definite article “the” and the generic Top-Level Domain (“gTLD”) “.com”, neither of which dispels confusing similarity. According to the Complainant, the disputed domain name is therefore confusingly similar to a trademark in which it has rights and is likely to mislead Internet users into believing it is associated with, endorsed by, or affiliated with the Complainant. The Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant argues that the Respondent is not affiliated with, licensed by, or otherwise authorized by the Complainant to use the TRAVELLER WHISKEY mark, and that there is no evidence that the Respondent has been commonly known by the disputed domain name. The Complainant further argues that the Respondent’s use of the disputed domain name is not a bona fide offering of goods or services, nor a legitimate noncommercial or fair use, but rather a misleading use intended to trade on the Complainant’s trademark goodwill. The Complainant also contends that the disputed domain name was registered and is being used in bad faith. The Complainant submits that the Respondent was clearly aware of the Complainant and its TRAVELLER WHISKEY mark at the time of registration, given the mark’s prominence and reputation, and that the Respondent’s website deliberately impersonates or falsely suggests an affiliation with the Complainant, including references to the Complainant’s Buffalo Trace Distillery. According to the Complainant, such conduct constitutes an intentional attempt to attract Internet users for commercial gain by creating a likelihood of confusion as to source, sponsorship, or affiliation, within the meaning of paragraph 4(b)(iv) of the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Preliminary Issue: 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 disputed domain name is in English; the fact that the contents of the website to which the disputed domain name resolves are exclusively in English; and the fact that the Complainant’s trademarks are all in English, and registered in English with the respective intellectual property offices. The Respondent did not make any submissions with respect to the language of the proceeding. page 4 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, 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. 6.2 Findings on the Merits 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 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. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms here, “the” and “whiskey”, 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 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. 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. Moreover, the Panel finds that the Respondent is not commonly known by the disputed domain name, has not been licensed or otherwise authorized by the Complainant to use the TRAVELLER mark, and has failed to adduce any evidence of use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Instead, upon review of the facts and the evidence submitted in this proceeding, the Panel notes that the disputed domain name directed to an active imposter page 5 website, prominently titled “The Traveller Whiskey” and displaying images of the Complainant’s bottles branded with the TRAVELLER mark and containing references to the Complainant’s Buffalo Trace Distillery. The Panel notes that this suggests that the Respondent is using the disputed domain name to mislead Internet users by creating a misleading affiliation or appearance of a business connection with the Complainant. Additionally, panels have held that the use of a domain name for illegitimate activity here, claimed impersonation/passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. However, the Panel notes that on the date of this Decision, the disputed domain name directs to an inactive or blank webpage. In this regard, the Panel finds that holding a domain name passively, without making any use of it, also does not confer any rights or legitimate interests in the disputed domain name on the Respondent in the circumstances of this case (see in this regard earlier UDRP decisions such as Bollore SE v. 赵竹飞 (Zhao Zhu Fei), WIPO Case No. D2020-0691; and Vente-Privee.Com and Vente-Privee.com IP S.à.r.l. v. 崔郡 (jun cui), WIPO Case No. D2021-1685). 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 the present case, the Panel notes that the Respondent has registered a domain name which is confusingly similar to the Complainant’s prior trademark for TRAVELLER, incorporating it in its entirety, merely adding the descriptive words “the” and “whiskey”. The Panel also notes that the Complainant’s trademarks in this case predate the registration date of the disputed domain name. Even a cursory Internet search or trademark search at the time of registration of the disputed domain name would have made it clear to the Respondent that the Complainant owned prior rights in its trademarks for TRAVELLER, and the Panel therefore finds that the Respondent could not have been reasonably unaware of them. This finding is further confirmed by the fact that the Respondent seemed to attempt misrepresenting itself as the Complainant or at least attempted to create an impression of connection or affiliation with the Complainant on the website which was previously linked to the disputed domain name, including by prominently displaying “The Traveller Whiskey” as the title of the website at the disputed domain name and by displaying product images of the Complainant’s bottles branded with the TRAVELLER whiskey mark and by providing references to the Complainant’s Buffalo Trace Distillery. In the Panel’s view, the above elements clearly indicate bad faith on the part of the Respondent, and the Panel therefore finds that it has been demonstrated that the Respondent registered the disputed domain name in bad faith. 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. As to use of the disputed domain name in bad faith, the Complainant provides evidence that the disputed domain name directed to an active imposter website which was used by the Respondent to impersonate or at least create a false impression of a commercial connection with the Complainant, for undue commercial gain. The Panel concludes from these facts that the Respondent is intentionally attracting Internet users for commercial gain to such website, by creating consumer confusion between the website associated with the disputed domain name and the Complainant’s trademarks. This constitutes direct evidence of the Respondent’s bad faith under paragraph 4(b)(iv) of the Policy. Additionally, panels have held that the use of a domain name for illegitimate activity here, claimed impersonation/passing off constitutes bad faith. WIPO Overview 3.0, section 3.4. page 6 However, on the date of this Decision, the disputed domain name directs to an inactive website. In this regard, panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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 distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 name <thetravellerwhiskey.com> be transferred to the Complainant. /Deanna Wong Wai Man/ Deanna Wong Wai Man Sole Panelist Date: January 8, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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