Westmore · UDRP DecisionPortliandlaathargood.click
The Panel ordered transfer of <portliandlaathargood.click>. It found the intentionally misspelled domain confusingly similar to the Complainant’s registered PORTLAND LEATHER and PORTLAND LEATHER GOODS marks, found no rights or legitimate interests, and concluded that the Respondent registered and used the domain in bad faith to mimic the Complainant’s official website, impersonate the Complainant, and attract Internet users for commercial gain through confusion.
The timeline behind portliandlaathargood.click
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The case combines strong evidence of typosquatting with direct website-copying evidence. The copied branding, product material, images, and verbatim text did more than show confusing similarity: they demonstrated actual awareness of the Complainant and an intentional plan to create a misleading commercial lookalike. The decision also illustrates how a service provider’s response to takedown notices may corroborate bad faith, while respondent default remains supplementary rather than a substitute for proof.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Portland Leather Goods, Inc. v. pi te Case No. D2025-4858 1. The Parties The Complainant is Portland Leather Goods, Inc., United States of America (“United States”), represented by Sheppard, Mullin, Richter & Hampton, LLP, United States. The Respondent is pi te, United States. 2. The Domain Name and Registrar The disputed domain name <portliandlaathargood.click> is registered with Dynadot Inc (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 21, 2025. On November 24, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On November 25, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which dif f ered f rom the named Respondent (Unkno wn) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on November 25, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on the same date. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on November 27, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was December 17, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on December 18, 2025 page 2 The Center appointed Phillip V. Marano as the sole panelist in this matter on January 5, 2026. The Panel f inds 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 purveyor of leather goods that was founded in 2017 and currently has three brick and mortar store locations in Oregon and Texas. The Complainant also sells its goods on its official “www.portlandleathergoods.com” website. The Complainant owns valid and subsisting registrations f or the PORTLAND LEATHER and PORTLAND LEATHER GOODS trademarks (collectively ref erred to herein as “Complainant’s Trademarks”) in the United States, including Reg. Nos. 6,855,612 and 6,693,622, registered on September 27, 2022, and April 5, 2022, with the earliest priority dating back to August 30, 2016, and March 23, 2016, respectively. In each registration, exclusive rights to the terms “leather” and “leather goods” are disclaimed. The Respondent registered the disputed domain name on November 3, 2025. At the time of this Complaint, the disputed domain name resolved to a website titled “Portland Leather Goods | Handmade Leather Products from Portland, OR” that impersonated Complainant through the unauthorized use of the Complainant’s Trademarks, pine tree design trademark, product listing and other pictorial and literary content directly from Complainant’s website (inclusive of a verbatim copy of the Complainant’s “About Us” webpage). 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain name. Notably, the Complainant asserts ownership of Co mplainant’s Trademarks and has adduced evidence of trademark registrations, dated back to April 5, 2022, with earliest priority dating back to March 23, 2016. The disputed domain name is nearly identical to the Complainant’s Trademarks, according to the Complainant, because it is composed entirely of an intentional misspelling of the Complainant’s PORTLAND LEATHER GOODS trademark. The Complainant further asserts that the Respondent lacks any rights or legitimate interests in the disputed domain name based on: the lack of any relationship with the Complainant; the lack of any license, permission, or authorization from the Complainant; the lack of any evidence that the Respondent is known by the disputed domain name; the lack of any evidence the Respondent holds any trademark rights in the disputed domain names; the Respondent’s use of the disputed domain name in connection with illegal activity, namely impersonation of the Complainant and fraudulent off ers to sell authentic goods originated f rom the Complainant. The Complainant argues that the Respondent has registered and used the disputed domain name in bad f aith f or numerous reasons, including: the well-known nature of the Complainant’s Trademarks; the Respondent’s intentional targeting of the Complainant to mimic the Complainant’s of f icial website at “www.portlandleathergoods.com”; the Respondent’s use of the disputed domain name in connection with illegal activity, namely misappropriation of the Complainant’s copywritten website content to impersonate the Complainant and f raudulently of f er to sell authentic goods originated f rom the Complainant; and the Complainant’s successful website takedown notices sent to the Registrar and Respondent’s webhost to disable the disputed domain name. page 3 B. Respondent The Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings To succeed in its Complaint, the Complainant must establish in accordance with paragraph 4(a) of the Policy: i. the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights; ii. the Respondent has no rights or legitimate interests in respect of the disputed domain name; and iii. the disputed domain name has been registered and is being used in bad f aith. Although the Respondent did not reply to the Complainant’s contentions, the burden remains with the Complainant to establish by a balance of probabilities, or a preponderance of the evidence, all three elements of paragraph 4(a) of the Policy. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.3 (“A respondent’s def ault would not by itself mean that the complainant is deemed to have prevailed; a respondent’s def ault is not necessarily an admission that the complainant’s claims are true ... [UDRP] panels have been prepared to draw certain inf erences in light of the particular facts and circumstances of the case e.g., where a particular conclusion is prima f acie obvious, where an explanation by the respondent is called for but is not forthcoming, or where no other plausible conclusion is apparent.”); The Vanguard Group, Inc. v. Lorna Kang, WIPO Case No . D2002-1064 (“The Respondent’s def ault does not automatically result in a decision in f avor of the complainant. The Complainant must still prove each of the three elements required by Policy paragraph 4(a)”). A. Identical or Confusingly Similar It is well accepted that the first element f unctions 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. Ownership of a nationally or regionally registered trademark serves as prima f acie evidence that the Complainant has trademark rights for the purposes of standing to file this Complaint. WIPO Overview 3.0, section 1.2.1. The Complainant submitted evidence that the Complainant’s Trademarks have been registered in United States as of April 5, 2022, with earliest priority dating back to March 23, 2016. Thus, the Panel f inds that the Complainant’s rights in the Complainant’s Trademarks have been established pursuant to the f irst element of the Policy. The only remaining question under the first element of the Policy is whether the disputed domain name is identical or confusingly similar to the Complainant’s Trademarks. In this case, the disputed domain name is conf usingly similar to the Complainant’s Trademarks because, disregarding the “.click” generic To p-Level Domain (“gTLD”), the entirety of the marks are recognizable within the disputed domain name. WIPO Overview 3.0, section 1.7. (“This test typically involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the domain name ... [I]n cases where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the domain name, the domain name will normally be considered conf usingly similar [...]”). Specif ically, the Respondent appears to have intentionally misspelled the terms “portliand” for “portland” and “laathar” f or “leather” in the Complainant’s Trademarks. gTLDs, such as “.click” in the disputed domain name, are generally viewed as a standard registration requirement and are disregarded under the f irst element. WIPO Overview 3.0, sections 1.9 and 1.11. The Panel f inds the f irst element of the Policy has been established. page 4 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 dif f icult task of “proving a negative”, requiring inf ormation that is of ten 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Where, as in this case, the Respondent f ails to come f orward with any relevant evidence, the Complainant is deemed to have satisfied the second element of the Policy. WIPO Overview, section 2.1. There is no evidence that the Respondent, identified by registration data for the disputed domain name as “pi te”, is commonly known by the disputed domain name or the Complainant’s Trademarks. UDRP panels have categorically held that use of a domain name f or illegal activity—including the impersonation of the complainant and other types of fraud—can never confer rights or legitimate interests on a respondent. Circumstantial evidence can support a credible claim made by the Complainant asserting the Respondent is engaged in such illegal activity, including that the Respondent has masked its identity to avoid being contactable, or that the Respondent’s website has been suspended by its hosting provider. WIPO Overview 3.0, section 2.13. See e.g. Graybar Services Inc. v. Graybar Elec, Grayberinc Lawrenge, WIPO Case No . D2009-1017 (“Respondent has used the domain name to pretend that it is the Complainant and in particular to create false emails pretending that they are genuine emails coming f rom the Complainant and one of its senior executives”). See also The Commissioners for HM Revenue and Customs v. Name Redacted, WIPO Cas e No . D2017-0501 (“In addition, the disputed domain names ... have had their web hosting suspended as a result of fraudulent activities. This is evidence of bad f aith registration and use of the disputed domain names.”) The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy proscribes the following non-exhaustive circumstances as evidence of bad f aith registration and use of the disputed domain name: i. Circumstances indicating that the Respondent has registered or the Respondent has acquired the disputed domain name primarily f or the purpose of selling, renting, or otherwise transf erring the disputed domain name registration to the Complainant who is the owner of the trademark to a competitor of that Complainant, for valuable consideration in excess of the Respondent’s documented out of pocket costs directly related to the disputed domain name; or ii. the Respondent has registered the disputed domain name in order to prevent the owner of the trademark from reflecting the mark in a corresponding domain name, provided that the Respondent has engaged in a pattern of such conduct; or page 5 iii. the Respondent has registered the disputed domain name primarily for the purpose of disrupting the business of a competitor; or iv. by using the disputed domain name, the Respondent has intentionally attempted to attract, f or commercial gain, Internet users to the Respondent’s website or other online location, by creating a likelihood of conf usion with the Complainant’s mark as to the source, sponsorship, af f iliation, or endorsement of the Respondent’s website or location or of a product or service on the Respondent’s website or location. UDRP panels have categorically held that registration and use of a domain name f or illegal activity— including impersonation, passing off, and other types of f raud—is manif estly considered evidence of bad f aith. WIPO Overview 3.0, section 3.1.4. See also GEA Group Aktiengesellschaft v. J. D., WIPO Case No . D2014-0357 (concluding that the respondent’s use of the disputed domain name to impersonate the complainant for commercial gain was evidence of respondent’s bad faith registration and use of the disputed domain name). Circumstantial evidence can support a complainant’s otherwise credible claim of illegal respondent activity, including evidence that: (i) the respondent has misappropriated copyrighted images o r text f rom the complainant; (ii) the respondent has masked its identity to avoid being contactable, or ignored cease-and-desist correspondence from the complainant; (iii) the disputed domain name is a typosquatted variant of the complainant’s trademark; and (iv) the respondent’s registrar or webhost has acceded to the complainant’s takedown request and therefore independently corroborated bad f aith use of the disputed domain name. WIPO Overview 3.0, section 2.13.2. Here, the Complainant has proffered persuasive and uncontroverted evidence that the Respondent has used the disputed domain name f or illegitimate or illegal activity. Specif ically, even a cursory side-by-side comparison of the of f icial website of the Complainant and the Respondent’s website reveals that the Respondent has intentionally misappropriated the Complainant’s pictorial and literary content in an attempt to mimic the Complainant’s official website and impersonate the Complainant. Moreover, it is equally clear that the Respondent intentionally registered the disputed domain name to mimic the Complainant’s Trademarks and official “www.portlandleathergoods.com” website. Indeed, the act of “typosquatting” or registering a domain name that is a common misspelling of a mark in which a party has rights has often been recognized as evidence of bad faith. WIPO Overview, section 3.2.1 (“Particular circumstances UDRP panels take into account in assessing whether the respondent’s registration of a domain name is in bad f aith include: (i) the nature of the domain name (e.g., a typo of a widely known mark ...”). It is evident that the Respondent registered and used the typosquatted disputed domain name to intentionally attract, f or commercial gain, Internet users to the website linked to disputed domain name in a manner that conf uses and misleads Internet users. Thus, the Panel infers the Respondent's bad f aith based on the f act that the Respondent is trying to mimic the Complainant’s of f icial domain name. The Panel f urther concludes that failure by the Respondent to answer the Complainant’s cease-and-desist letter “suggests that Respondent was aware that it has no rights or legitimate interests in the disputed domain name, and that the disputed domain name has been registered and is being used in bad f aith.” See America Online, Inc. v. Antonio R. Diaz, WIPO Case No. D2000-1460 (internal citations omitted). See also Spyros Michopoulos S.A. v. John Tolias, ToJo Enterprises, WIPO Case No. D2008-1003. Furthermore, the f ailure of the Respondent to answer this Complaint or take any part in the present proceedings, in the view of the Panel, is another indication of bad faith on the part of the Respondent. See Bayerische Motoren Werke AG v. (This Domain is For Sale) Joshuathan Investments, Inc., WIPO Case No . D2002-0787. Numerous panels have viewed website suspension by the reg istrar or webhost, absent any explanation or attempted justification by the respondent, as added corroboration of bad f aith. See LEGO Juris A/S v. Ammar Briouel / Brahim Mahjoubi, WIPO Case No. D2019-0750 (involving website suspension f ollowing a takedown request by Complainant); Hershey Entertainment & Resorts Company v. Matthew Faust et al., WIPO Case No . D2023-3384 (“Respondent’s ... failure to respond to the takedown of its Shopify page at the disputed domain name ... make it more likely than not that Respondent opportunistically registered and used the disputed domain name” in bad f aith). Here, the Respondent’s website content was disabled by the Registrar and/or the Respondent’s webhost in reaction to the takedown notices sent by the Complainant. page 6 Domain name suspension or content removal in this manner provides independent third-party corroboration of bad faith registration and use by the Respondent in connection with, at best, the mere impersonation of the Complainant, and at worst, a fake web shop designed to defraud visitors or phish f or their personal and f inancial inf ormation. The Panel f inds the third element of the Policy has been established. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <portliandlaathargood.click> be transf erred to the Complainant. /Phillip V. Marano/ Phillip V. Marano Sole Panelist Date: January 24, 2025
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