Westmore · UDRP decision
WIPO · Case No. D2026-0037

Putitonashirtdallas.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <putitonashirtdallas.com>. It found the domain confusingly similar to the Complainant’s registered PUT IT ON A SHIRT, ETC. mark, held that the Respondent’s former involvement with the Complainant did not confer personal rights in the company’s trademark, and determined that the Respondent knowingly used the domain for a competing apparel-printing business in a manner likely to create confusion for commercial gain under paragraph 4(b)(iv) of the Policy.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-27
Panelist(s)
Bernstein, David H.
Complainant
Put It On A Shirt, etc. LLC.
Respondent
Alshon Rose, InkThread
Disputed domain(s)
putitonashirtdallas.com
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind putitonashirtdallas.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 putitonashirtdallas.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 putitonashirtdallas.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a UDRP panel may separate a narrow domain-name inquiry from a broader dispute between former business associates. The decisive distinction was between the rights of the LLC and the personal interests of an owner, partner, investor, or former member. The decision also shows that a trademark registration issued after domain registration did not prevent a bad-faith finding where the respondent’s prior relationship established knowledge of the complainant’s earlier use and goodwill.

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
2026-02-27
Panel
Bernstein, David H.
Full decision
14 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Put It On A Shirt, etc. LLC. v. Alshon Rose, InkThread Case No. D2026-0037 1. The Parties The Complainant is Put It On A Shirt, etc. LLC., United States of America, self-represented. The Respondent is Alshon Rose, InkThread, United States of America, self-represented. 2. The Domain Name and Registrar The disputed domain name <putitonashirtdallas.com> is registered with Squarespace Domains LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 7, 2026. On January 7, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 7, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to the Complainant on January 14, 2026, requesting the Complainant to submit an amendment to the Complaint for fulfilling formality requirements. The Complainant filed an amended Complaint on January 18, 2026. 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 January 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 9, 2026. The Respondent sent an email communication to the Center on January 21, 2026 raising the possibility of settlement. On the same day, the Center sent an email to the Parties asking whether the parties wanted to suspend the proceeding to allow time for settlement negotiations. The Complainant replied that it does not wish to request for suspension and prefers to move forward with the proceeding. The Response was filed with the Center on February 9, 2026. page 2 The Center appointed David H. Bernstein as the sole panelist in this matter on February 13, 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. Factual Background The Complainant is a Texas limited liability company engaged in the business of custom apparel printing and related services. The Complainant is the owner of United States Trademark Registration No. 8,075,963 for PUT IT ON A SHIRT, ETC., filed on April 17, 2025 and registered on December 23, 2025, in Class 40 for screen printing. The registration reflects a claimed date of first use in commerce of January 1, 2019. The Respondent is an individual located in the United States who used to be associated with the Complainant. In 2025, the relationship between the Parties deteriorated. The Respondent asserts that he began operating a separate apparel printing business under the name “Put It On A Shirt Dallas” in or around April 2025. On June 10, 2025, the Respondent sent a written communication asserting ownership and compensation-related grievances. On October 31, 2025, the Complainant, through counsel, sent a cease and desist letter asserting trademark rights and demanding that the Respondent cease use of the name. On December 22, 2025, the Complainant provided written notice removing the Respondent as a member of the LLC. There is no evidence in the record of any court proceeding resolving the Parties’ respective ownership claims. The Respondent has since operated his apparel printing business under the name Ink Threads Dallas. The Respondent registered the disputed domain name <putitonashirtdallas.com> on August 14, 2025. It previously resolved to a website promoting apparel printing services in Dallas, Texas under the name “Put It On A Shirt Dallas.” Subsequently, the website content reflected the Respondent’s rebranded business under the name “Ink Threads Dallas.” At the time of this Decision, the website displays an “under construction” notice. 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. The Complainant asserts that the disputed domain name is confusingly similar to its PUT IT ON A SHIRT, ETC. trademark because it incorporates most of the mark, removing only the “etc.” portion and adding only the geographic term “Dallas,” which does not avoid confusion. The Complainant further contends that the Respondent lacks rights or legitimate interests in the disputed domain name. The Complainant asserts that it has not licensed, authorized, or otherwise permitted the Respondent to use the PUT IT ON A SHIRT mark in a domain name. The Complainant maintains that the Respondent is not commonly known by the disputed domain name and has not acquired any trademark rights corresponding to it. The Complainant further asserts that the disputed domain name has been used to promote a competing apparel business and to create a false impression of affiliation with the Complainant’s established business. The Complainant contends that the Respondent used the name “Put It On A Shirt Dallas” in connection with the disputed domain name and in related promotional materials, including social media postings, thereby trading on the goodwill associated with the Complainant’s mark. According to the Complainant, such commercial use is not a bona fide offering of goods or services and does not constitute legitimate noncommercial or fair use under paragraph 4(c) of the Policy. page 3 B. Respondent The Respondent contends that the Complainant has not satisfied all three of the elements required under the Policy for a transfer of the disputed domain name. The Respondent contends that the dispute arises from a broader business disagreement between the Parties and should not be resolved under the Policy. According to the Respondent, the Parties operated jointly under the name “Put It On A Shirt” for several years, and the Respondent’s use of the name in connection with “Put It On A Shirt Dallas” beginning in or around April 2025 was part of a bona fide apparel business. The Respondent asserts that he has rights or legitimate interests in the disputed domain name arising from years of authorized, joint, and continuous use of the business name. He contends that he is commonly known by the name in connection with his apparel printing activities and that the disputed domain name was registered to support legitimate commercial operations. The Respondent denies that the disputed domain name was registered or used in bad faith. He maintains that his use of the disputed domain name was connected to an ongoing business relationship and that any dispute between the Parties concerns ownership, compensation, and dissolution issues that extend beyond the scope of the Policy. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant must establish that (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which it has rights; (ii) the Respondent lacks rights or legitimate interests in the disputed domain name; and (iii) the disputed domain name was registered and is being used in bad faith. The Respondent contends that the dispute arises from a broader business disagreement and therefore falls outside the scope of the Policy. The Panel disagrees. Although the Parties were previously associated in a business relationship and may have disputes arising from the dissolution of their relationship, the present proceeding concerns only whether the Respondent registered and used the disputed domain name in a manner that satisfies the elements of paragraph 4(a) of the Policy. The existence of a business dispute does not preclude application of the UDRP where the record supports a finding of abusive domain name registration and use. Having considered the factual record, the Parties’ contentions, the Policy, the Rules, and applicable UDRP jurisprudence as reflected in the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), the Panel finds that the Complainant has satisfied each of the elements required under paragraph 4(a) of the Policy. The Panel finds that the disputed domain name is confusingly similar to the Complainant’s PUT IT ON A SHIRT, ETC. mark, as it incorporates most of the mark, removing only the “etc.” portion, with the addition of a geographic term that does not avoid confusion. The Panel further finds that the Respondent has not demonstrated rights or legitimate interests in the disputed domain name. Although the Parties were previously associated in a business relationship, that prior association did not confer upon the Respondent the right to register and use a domain name incorporating most of the Complainant’s mark for a separate competing enterprise. Finally, the Panel finds that the disputed domain name was registered and used in bad faith. The Respondent registered the disputed domain name with knowledge of the Complainant’s mark and used it to promote competing apparel services in a manner likely to create confusion as to source or affiliation, within the meaning of paragraph 4(b)(iv) of the Policy. page 4 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 3.1, section 1.7. The Complainant’s trademark registration establishes that the Complainant owns trademark rights in the mark PUT IT ON A SHIRT, ETC. As the WIPO Overview 3.1 notes in section 1.2.1, “[w]here the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case.” The disputed domain name reproduces most of the PUT IT ON A SHIRT mark, with the deletion of the word “etc.” The addition of the geographical term “Dallas” does not immunize the disputed domain name from a finding of confusing similarity. See WIPO Overview 3.1, section 1.8 (“Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.”). Accordingly, the Panel finds that the Complainant has satisfied the first element of the Policy. B. Rights or Legitimate Interests To establish that a respondent has rights or legitimate interests in a disputed domain name, paragraph 4(c) of the Policy provides that the respondent may demonstrate, inter alia, that, “before any notice of the dispute,” the respondent used “the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services.” Although the overall burden of proof rests with the Complainant, once the Complainant makes a prima facie showing that the Respondent lacks rights or legitimate interests, the burden shifts to the Respondent to come forward with relevant evidence demonstrating such rights or legitimate interests. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent tries to rebut that showing by contending that he has rights or legitimate interests in the disputed domain name based on his prior association with the Complainant’s business and his use of the disputed domain name in connection with an apparel printing operation in Dallas beginning in or around April 2025. The fact that the Respondent was a former partner in the Complainant’s business does not give the Respondent personal rights in the Complainant’s trademark. That argument reflects a misunderstanding of the corporate form. Although the Respondent may well have been an investor and partner in the Complainant’s business, the Complainant operates as a separate entity, and it is the Complainant (and not its owners or partners) that owns the trademark rights. Thus, the fact that the Respondent was an owner of the Complainant and has a dispute over his separation from the business does not give the Respondent any independent rights or legitimate interests in the Complainant’s trademark. Ernesto Huerta v. Erick Calder, WIPO Case No. D2023-2349 (rights belonging to a company are distinct from the personal interests of its stakeholders, such that ownership does not confer personal rights in the company’s proprietary rights; business dispute between the parties does not give the respondent rights or legitimate interests in the company’s domain name by virtue of his ownership stake in the company). The Respondent is correct in his assertion that, following his separation from the Complainant, he used the disputed domain name to promote a new, independent apparel printing services. The existence of that business, though, does not establish a bona fide offering of goods or services within the meaning of paragraph 4(c)(i). That is because his use of the trademark PUT IT ON A SHIRT DALLAS for a competing screen printing business likely infringed the Complainant’s federally registered trademark PUT IT ON A page 5 SHIRT ETC. for the same services. A use cannot be deemed bona fide where the use at issue trades on another’s trademark rights. See WIPO Overview 3.1, section 2.13.1; Nara Aziza Smith v. Vanessa Clarke, WIPO Case No. D2025-1839 (“an infringing use cannot be bona fide”); On AG, On Clouds GmbH v. Nguyen Luu et al., WIPO Case No. D2021-1714 (“a use cannot be deemed bona fide if the disputed domain names constitute trademark infringement”). Accordingly, the Panel finds that the Complainant has established that the Respondent lacks rights or legitimate interests in the disputed domain name under paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Paragraph 4(b)(iv) of the Policy provides that, where a respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark as to source, sponsorship, affiliation, or endorsement, “shall be evidence of the registration and use of a domain name in bad faith.” That evidence has been established in this case. The Parties had been associated in a business relationship involving that name for several years. However, by June 10, 2025, that relationship had unraveled. On that date, the Respondent sent a written communication to the Complainant asserting grievances relating to ownership and compensation. Thus, it is clear that, at the time that the Respondent registered the disputed domain name on August 14, 2025, the Respondent was well aware of the Complainant’s use of the “Put It On A Shirt” name. Indeed, as the Respondent concedes, the Respondent registered the disputed domain name, the Respondent was well aware of the Complainant’s trademark. Despite knowledge of the Complainant’s trademark rights, the Respondent then used the disputed domain name to promote a competing apparel printing services in Dallas under the confusingly similar name “Put It On A Shirt Dallas.” The Respondent tries to justify those actions by contending that his use was part of an independent apparel business and that his prior association with the Complainant entitled him to continue operating under “Put It On A Shirt” in connection with his apparel printing activities. As noted above, that argument reflects a failure to understand that the Complainant business is a separate entity, and it is the Complainant business, not any of its owners, that owns the trademark. Whatever the merits of the Respondent’s complaints – and the Panel expressly declines to consider the validity of those complaints – the Respondent did not have the right to expropriate the Complainant’s trademark for his own, independent use in connection with a competing business. This Panel’s task is a narrow one – to consider only whether the registration and use of this disputed domain name constitutes a violation of the Policy. Because the Respondent’s conduct falls squarely within paragraph 4(b)(iv) of the Policy, the Panel finds that the Respondent is liable for cybersquatting. See WIPO Overview 3.1, section 3.1 (“Bad faith under the UDRP is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark.”). The fact that the federal registration issued after the disputed domain name registration does not alter the analysis, as the Respondent’s knowledge of the Complainant’s use and goodwill is not disputed and is evident from the Parties’ prior association. See WIPO Overview 3.1, section 3.2.1 and 1.15. The Panel leaves it to another forum to adjudicate whether the Respondent’s other complaints about his treatment by the Complainant are valid. Accordingly, the Panel finds that the Respondent registered and used the disputed domain name in bad faith within the meaning of paragraph 4(a)(iii) of the Policy. page 6 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 <putitonashirtdallas.com> be transferred to the Complainant. /David H. Bernstein/ David H. Bernstein Sole Panelist Date: February 27, 2026

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

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