Westmore · UDRP DecisionBooktravelandleisure.online
The Panel ordered transfer of <booktravelandleisure.online>. It found the domain confusingly similar to Complainant’s TRAVEL+LEISURE mark because it incorporated the mark in domain-name form with the additional term “book.” Respondent lacked rights or legitimate interests because the associated website used Complainant’s marks without authorization or an apparent disclaimer, and Respondent supplied no rebuttal. Bad faith was established because the website purported to offer products or services under the mark, supporting the findings that Respondent was aware of Complainant’s rights and sought commercial gain from their goodwill.
The timeline behind booktravelandleisure.online
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 booktravelandleisure.online — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that adding a service-related term to a recognizable trademark does not avoid confusing similarity and may reinforce the domain’s connection to the trademark owner’s business. It also shows the importance of website presentation under the rights-or-legitimate-interests and bad-faith elements: unauthorized mark use, travel-related offerings, and the absence of an apparent affiliation disclaimer supported both findings.
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 Travel + Leisure Holdco, LLC v. Brysen Cortez Case No. D2025-4761 1. The Parties Complainant is Travel + Leisure Holdco, LLC, United States of America (“United States”), represented by Lewis Rice, LLC, United States Respondent is Brysen Cortez, United States. 2. The Domain Name and Registrar The disputed domain name <booktravelandleisure.online> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 17, 2025. On November 18, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 19, 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 (Withheld for Privacy / Privacy Service Provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on November 20, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on November 24, 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 28, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 18, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on December 19, 2025. page 2 The Center appointed Lorelei Ritchie as the sole panelist in this matter on December 23, 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 Complainant is a limited liability company based in the United States. For decades prior to the registration of the disputed domain name, Complainant has offered publications and travel-related services under its mark TRAVEL+LEISURE. In this regard, Complainant owns several registrations for these marks. These include United States Registration Nos. 6,616,880 (registered January 11, 2022) and 6,623,902 (registered January 18, 2022). The disputed domain name was registered on September 11, 2025. Respondent has set up a website at the URL associated with the disputed domain name that purports to offer vacation travel services under the TRAVEL+LEISURE mark, and including references to Complainant’s registered TRAVEL+LEISURE marks. Complainant has not authorized any activities by Respondent, nor any use of its trademarks thereby. 5. Parties’ Contentions A. Complainant Complainant contends that (i) the disputed domain name is identical or confusingly similar to Complainant’s trademarks, (ii) Respondent has no rights or legitimate interests in the disputed domain name; and (iii) Respondent registered and is using the disputed domain name in bad faith. Specifically, Complainant contends that it owns rights to the TRAVEL+LEISURE mark, which Complainant has used for “more than 50 years of publication and millions of readers,” and which Complainant offers under its own domain name at <travelandleisure.com>. Complainant contends that Respondent has incorporated its long-standing mark TRAVEL+LEISURE—with the plus sign presented in a domain name as the word “and”, with the addition only of the term “book,” which will likely be understood by consumers as referring to Complainant’s travel booking services. Complainant contends that Respondent lacks rights or legitimate interest in the disputed domain name, and rather has registered and is using it in bad faith, having simply acquired the disputed domain name for Respondent’s own commercial gain. In this regard, Complainant alleges that Respondent has set up a website at the URL associated with the disputed domain name that purports to offer products under the TRAVEL+LEISURE mark, including references to Complainant’s registered TRAVEL+LEISURE marks, in a deliberate effort to “actively impersonate and pose as Complainant” in order to confuse consumers seeking Complainant’s products and services. B. Respondent Respondent did not reply to 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 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. Complainant has shown rights in respect of trademark TRAVEL+LEISURE, for the purposes of the Policy. WIPO Overview 3.0, page 3 section 1.2.1. Although the addition of other terms (here, “book”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and Complainant’s mark for purposes of the Policy. WIPO Overview 3.0, sections 1.8 and 1.9. The Panel therefore finds that the disputed domain name is confusingly similar to a trademark in which Complainant has rights in accordance with paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which 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. Complainant notes that the website associated with the disputed domain name purports to offer products or services that include Complainant’s TRAVEL+LEISURE marks. Prior UDRP panels have indicated that a reseller may be considered to have rights or legitimate interests in a mark, provided certain requirements are met. These generally include that: (i) the site is actually offering the goods at issue; (ii) the site is used only to sell the trademarked goods; (iii) the site accurately and prominently discloses the registrant’s relationship to the mark holder; and (iv) respondent does not try to “corner the market” in domain names that reflect the mark. See WIPO Overview 3.0, section 2.8; see also Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. The Panel finds that these qualifications are not fulfilled by the website associated with the disputed domain name. Rather, to the extent that any legitimate goods or services may be offered via the disputed domain name, the associated website does not appear to include a disclaimer of affiliation or endorsement by Complainant, and rather includes unauthorized use of Complainant’s marks. Respondent has not put forward any claims or evidence that would suggest rights or legitimate interests for the purposes of the Policy. The Panel finds that Complainant has provided sufficient evidence of Respondent’s lack of “rights or legitimate interests” in accordance with paragraph 4(a)(ii) of the Policy, which Respondent has not rebutted, and accordingly the Panel finds the second element of the Policy has been established. D. Registered and Used in Bad Faith There are several ways that a complainant can demonstrate that a domain name was registered and used in bad faith. As noted in Section 4 of this Panel’s decision, Respondent has set up a website at the URL associated with the disputed domain name that purports to offer products or services under the TRAVEL+LEISURE mark, and including references to Complainant’s TRAVEL+LEISURE marks. Hence, Respondent was presumably aware of Complainant’s rights when registering the disputed domain name and is trading on the goodwill of Complainant’s trademarks to attract Internet users for Respondent’s own commercial gain. page 4 Therefore, the Panel finds sufficient evidence that Respondent registered and used the disputed domain name in bad faith for purposes of paragraph (4)(a)(iii) 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 <booktravelandleisure.online> be transferred to Complainant. /Lorelei Ritchie/ Lorelei Ritchie Sole Panelist Date: January 6, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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