Westmore · UDRP DecisionHolidayinnreservahoy.com
The Panel ordered transfer of <holidayinnreservahoy.com>. It found the domain confusingly similar to the Complainant’s HOLIDAY INN trademark, that the Respondent lacked rights or legitimate interests, and that the Respondent registered and used the domain in bad faith to attract Internet users for commercial gain through confusion with the mark. The domain resolved to a Spanish-language hotel pre-reservation website.
The timeline behind holidayinnreservahoy.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 holidayinnreservahoy.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining a famous hotel mark with booking-related words can strengthen, rather than dispel, an inference of targeting. The domain’s actual use for hotel pre-reservations closely matched both the trademark owner’s business and the meaning of the added Spanish terms, supporting the Panel’s findings under the second and third 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 Six Continents Hotels, Inc. v. Ray cantu, Mesco Medios Case No. D2025-4696 1. The Parties The Complainant is Six Continents Hotels, Inc., United States of America (“United States”), represented by The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States. The Respondent is Ray cantu, Mesco Medios, Mexico. 2. The Domain Name and Registrar The disputed domain name <holidayinnreservahoy.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 13, 2025. On November 13, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 13, 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 (Registration Private / Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 17, 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 amendment to the Complaint on November 18, 2025. The Center verified that the Complaint together with the amendment to the 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 19, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 9, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 12, 2025. page 2 The Center appointed Rodrigo Azevedo 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. 4. Factual Background The Complainant is Six Continents Hotels, Inc., a United States corporation and part of the IHG Hotels & Resorts group, one of the world’s largest hotel groups, which owns, manages, leases, or franchises thousands of hotels in over 100 countries. The Complainant owns a portfolio of well-known hotel brands, including HOLIDAY INN. The Complainant is the owner of numerous trademark registrations for the mark HOLIDAY INN worldwide, including the United States Registration No. 592,539 registered on July 13, 1954, No. 864,359 registered on January 28, 1969, and No. 3,350,226 registered on December 4, 2007, among others. The Complainant also owns domain names incorporating its HOLIDAY INN trademark, including <holidayinn.com>, which was registered on March 21, 1995. The disputed domain name <holidayinnreservahoy.com> was registered on September 8, 2025, and directs Internet users to a webpage entitled “PortaliA”, described – in Spanish language – as a new website for hotel pre-reservations. 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: (i) The disputed domain name is identical or confusingly similar to the Complainant’s trademark. The Complainant asserts that the disputed domain name <holidayinnreservahoy.com> is confusingly similar to its HOLIDAY INN trademark, which it describes as “renowned” and “well-known”. The disputed domain name incorporates the HOLIDAY INN mark in its entirety, which is sufficient to establish confusing similarity. The additional elements “reserva” and “hoy” (Spanish for “reservation” and “today”, respectively) are merely generic and descriptive terms that do not prevent a finding of confusing similarity. On the contrary, these terms increase the likelihood of confusion, as they suggest hotel booking services and thus enhance the false impression that the disputed domain name is connected with the Complainant. The Complainant further notes that the generic Top-Level Domain (“gTLD”) “.com” is disregarded in this analysis. (ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant contends that it has not authorized the Respondent to use its HOLIDAY INN trademark in any way, including in a domain name. There is no evidence the Respondent is commonly known by the disputed domain name, nor that the Respondent is making any legitimate noncommercial or fair use of the disputed domain name. Instead, by using the disputed domain name in connection with a website that appears to be a website for, or otherwise associated with, the Complainant – by offering the ability to make hotel reservations – the Respondent has failed to create a bona fide offering of goods or services under the Policy, and, therefore, the Respondent cannot demonstrate rights or legitimate interests. page 3 (iii) The disputed domain name was registered and is being used in bad faith. The Complainant maintains that Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. The Respondent intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s HOLIDAY INN mark. A further indication of bad faith under the Policy is the fact that the Complainant’s first registration for the HOLIDAY INN trademark pre-dates the Respondent’s registration of the disputed domain name – by 71 years. 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 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. Annex 10 to the Complaint shows numerous trademark registrations for HOLIDAY INN since 1954. Based on the available record, the Panel finds 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 disputed domain name incorporates the Complainant’s trademark HOLIDAY INN, with the addition of the expression “reserva hoy” (which corresponds to “reserve today” in Spanish language). The disputed domain name also presents the gTLD extension “.com”. Although the addition of other terms (here, “reserva” and “hoy”) 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. It is also well established that the addition of a gTLD (such as “.com”) is typically disregarded when determining whether a domain name is confusingly similar to a complainant’s trademark as such is viewed as a standard registration requirement. WIPO Overview 3.0, section 1.11.1. Therefore, the Panel finds the disputed domain name is confusingly similar to the Complainant’s trademark and that 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 page 4 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. The Panel finds no indication that the Respondent is commonly known by the disputed domain name. The Complainant has asserted that the Respondent is not an authorized representative, nor has it obtained any permission for registering the disputed domain name. The Panel finds that the nature of the disputed domain name, comprising the Complainant’s famous trademark and additional words directly related to the Complainant’s hotel activities, indicate an awareness of the Complainant and its trademark and an intent to take unfair advantage of such, which does not support a finding of any rights or legitimate interests. Based on the available record, 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. 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 disputed domain name includes the distinctive trademark HOLIDAY INN in its entirety. According to the WIPO Overview 3.0, section 3.1.4, UDRP panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith. Actually, when the disputed domain name was registered in 2025, the HOLIDAY INN trademark was already famous and directly connected with the Complainant’s products and services worldwide for many decades. The Panel believes that the addition of the terms “reserva” and “hoy” enhances the likelihood of confusion, considering that may suggest that the respective website is an official channel for HOLIDAY INN hotel reservations. The Panel concludes that it is unlikely that the Respondent was not aware of the Complainant’s trademark and that the registration of the disputed domain name was a mere coincidence. Especially considering that the Complainant brought evidence that the disputed domain name is linked to a website designed for hotel reservation, making clear that the intent of the Respondent with the disputed domain name was to specifically target the Complainant’s trademark and customers. The Panel holds that the Respondent is intentionally attempting to attract, for commercial gain, Internet users to its own website by creating a likelihood of confusion with the Complainant’s trademark as to the source, affiliation, or endorsement of the disputed domain name. Therefore, having reviewed the record, the Panel finds the registration and use of the disputed domain name constitutes bad faith under the Policy. page 5 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 <holidayinnreservahoy.com> be transferred to the Complainant. /Rodrigo Azevedo/ Rodrigo Azevedo Sole Panelist Date: January 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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