Westmore · UDRP DecisionMygorhino.com
The Panel ordered transfer of <mygorhino.com>. It found the domain confusingly similar to the Complainant’s registered GO RHINO mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to attract Internet users for potential commercial gain by creating confusion with the Complainant and its products.
The timeline behind mygorhino.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 mygorhino.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a straightforward targeting pattern in which a domain incorporates an entire trademark, adds a short term, and is then used in the trademark owner’s product sector while displaying the mark and the owner’s products. It also shows that temporary website inaccessibility does not prevent reliance on archived content and that a panel may continue a proceeding despite conflict-related postal notification concerns where electronic delivery succeeded and the respondent received a fair opportunity to participate.
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 NAADE, INC. v. Details Not Provided by Registrant Case No. D2025-5293 1. The Parties The Complainant is NAADE, INC., United States of America (“US”), represented by MacMillan, Sobanski & Todd, LLC, US. The Respondent is Details Not Provided by Registrant, Ukraine. 2. The Domain Name and Registrar The disputed domain name <mygorhino.com> is registered with Sav.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 17, 2025. On December 18, 2025, the Complainant filed an amended Complaint. On the same day the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name, and the Registrar transmitted by email to the Center its verification response, which differed from the named Respondent and contact information in the Complaint. 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 the Respondent of the Complaint, and the proceedings commenced on December 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 20, 2026. The Respondent was subsequently provided, due to an administrative oversight, with additional time until January 28, 2026, to indicate whether it wishes to participate to these proceedings. No communications were received from the Respondent. page 2 The Center appointed Rebecca Slater as the sole panelist in this matter on February 4, 2026. 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. Procedural Issue Paragraph 10(b) of the Rules requires the Panel to ensure that the parties are treated with equality and that each party is given a fair opportunity to present its case. Paragraph 10(c) of the Rules requires that the administrative proceeding takes place with due expedition. The Respondent’s mailing address is in Ukraine, which is subject to an international conflict at the date of this Decision. These circumstances may impact case notification and it is appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceedings should continue. The Panel is of the view that the proceedings should continue, having considered all the circumstances of the case. The Panel notes that the postal delivery of the Center’s written communication to the Respondent’s address in Ukraine seems to have failed; however, the Complaint was delivered to the Respondent’s email address provided by the Registrar without any delivery failure response. The Respondent has not opposed the continuation of the proceedings. The Panel also notes that the website previously hosted at the disputed domain name was in the English language and sought to target English-speaking Internet users, which may support an inference that the Respondent is actually not located in Ukraine. Additionally, as set out below, the Panel has formed the view that the Respondent registered and has used the disputed domain name in bad faith. 5. Factual Background The Complainant is a US company that manufactures automotive accessories, including side steps, bull bars, running boards and sports bars. The Complainant holds US Trade Mark Registration 4,554,591 for GO RHINO word mark (registered June 24, 2014) (the “Trade Mark”). The Respondent has a listed address in Ukraine. The Respondent did not submit a response, and, consequently, little information is known about the Respondent. The disputed domain name was registered on October 16, 2024. The website at the disputed domain name is currently inaccessible due to an invalid SSL certificate. The disputed domain name previously resolved to a website selling accessories for trucks and SUVs. The website featured the Trade Mark, including in the description of the products offered. page 3 6. 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: - The disputed domain name is materially identical to the Trade Mark. The addition of the term “my” is insufficient to differentiate the disputed domain name from the Trade Mark. - The Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services. Prior to expiration or invalidation of the SSL certificate, the website at the disputed domain name used the Trade Mark in an unauthorized and illegitimate manner to promote third party products competitive with the Complainant’s products. The Respondent is not a licensee of the Complainant, and is not otherwise authorized to use the Trade Mark. The Respondent is not an authorized distributor, reseller, or service provider of the Complainant. - The Respondent registered the disputed domain name in bad faith after the Complainant had been using the Trade Mark for decades. The website at the disputed domain name previously featured images, photos and logos from the Complainant’s website, indicating that the Respondent registered the disputed domain name in bad faith and with knowledge of the Complainant and the Trade Mark. B. Respondent The Respondent did not reply to the Complainant’s contentions. 7. Discussion and Findings To succeed, the Complainant must demonstrate that all the elements enumerated in paragraph 4(a) of the Policy have been satisfied, namely: - the disputed domain name is identical or confusingly similar to a trade mark or service mark in which the Complainant has rights; - the Respondent has no rights or legitimate interests in respect of the disputed domain name; and - the disputed domain name has been registered and is being used in bad faith. The onus of proving these elements is on the Complainant. 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 trade mark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the Trade Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms (here, “my”) may bear on assessment of the second and third elements, the Panel finds the addition of this term does not prevent a finding of confusing similarity between the disputed domain name and the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. page 4 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. The Complainant has not authorized the Respondent to use the Trade Mark and there is no evidence that the Respondent is commonly known by the disputed domain name. The evidence provided by the Complainant (i.e., archived content from website to which the disputed domain name resolves) indicates that the disputed domain name has rather been used to either: (a) impersonate the Complainant and its business; or (b) to create the incorrect impression that the Respondent is affiliated with the Complainant; or (c) to resell the Complainant’s products without any indication of the lack of relationship with the Complainant. 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. 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. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. Under paragraph 4(b)(iv) of the Policy, there is evidence of registration and use of the disputed domain name in bad faith where a respondent has used the disputed domain name to intentionally attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s trade marks as to the source, sponsorship, affiliation or endorsement of the website. page 5 The Panel finds it unlikely that the disputed domain name was registered without knowledge of the Complainant and the Trade Mark, given: (a) the reputation of the Complainant and the Trade Mark; and (b) the composition of the disputed domain name, which includes the Trade Mark. The Respondent’s goal in registering and using the disputed domain name appears to be to attract Internet users for potential gain, taking unfair advantage of the Trade Mark. This finding is reinforced by the Respondent’s use of the website at the disputed domain name to host website that features the Complainant’s Trade Mark and the Complainant’s products. The Panel finds that the Complainant has established the third element of the Policy. 8. 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 <mygorhino.com> be transferred to the Complainant. /Rebecca Slater/ Rebecca Slater Sole Panelist Date: February 17, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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