Westmore · UDRP DecisionStylerickowens.com
The Panel ordered transfer of <stylerickowens.com>. It found the domain confusingly similar to the Complainant’s RICK OWENS marks because it incorporated the mark with the additional term “style.” The Respondent lacked rights or legitimate interests because the Complainant had not authorized the use, the associated website purportedly offered products under the mark without a prominent and accurate disclaimer, and the Respondent provided no rebuttal. The Panel found bad-faith registration and use because the domain and website demonstrated awareness of the Complainant and were intended to attract Internet users for commercial gain through confusion about source, sponsorship, affiliation, or endorsement.
The timeline behind stylerickowens.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 stylerickowens.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a complete fashion mark with a descriptive term tied to the brand’s business can support findings across all three UDRP elements when it is used for a commercial website displaying the mark and offering related products without an accurate affiliation disclaimer. The Panel treated the uncertainty over whether the goods were genuine as non-determinative because the misleading impression of authorization or affiliation itself supported bad faith.
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 Skorpio Limited v. Li Yingjiu Case No. D2026-0136 1. The Parties The Complainant is Skorpio Limited, Switzerland, represented by Keltie LLP, United Kingdom. The Respondent is Li Yingjiu, China. 2. The Domain Name and Registrar The disputed domain name <stylerickowens.com> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on January 13, 2026. On January 14, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 15, 2026, 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 (Redacted for privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 15, 2026, 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 amended Complaint in English on January 15, 2026. On January 15, 2026, the Center informed the parties in Chinese and English, that the language of the registration agreement for the disputed domain name is Chinese. On January 15, 2026, the Complainant requested English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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 in Chinese and English of the Complaint, and the proceedings commenced on January 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 5, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 6, 2026. page 2 The Center appointed Joseph Simone as the sole panelist in this matter on February 10, 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, Skorpio Limited, is a Swiss company that manages the intellectual property rights of American fashion designer Rick Owens. Rick Owens’ clothing designs have been worn by many celebrities, including Courtney Love, Madonna, and Kobe Bryant. Owens has opened up stores in Paris, France, New York, United States of America, London, United Kingdom, Seoul, Republic of Korea, Tokyo, Japan, and Hong Kong, China. The Complainant has a portfolio of trade mark registrations for the RICK OWENS marks, including the following: - European Union Trade Mark Registration No. 018510789 for RICK OWENS in Classes 3, 9, 14, 18, 25, and 42, registered on March 2, 2022; - International Trade Mark Registration No. 1667333 for RICK OWENS in Classes 3, 9, 14, 18, 25, and 42, registered on December 10, 2021, designating inter alia Japan, Republic of Korea, United States of America, China, and Egypt; and - International Trade Mark Registration No. 1026597 for RICK OWENS (Stylized) in Classes 3, 9, 14, 18, and 25, registered on December 30, 2009, designating inter alia Australia, Russian Federation, Singapore, Switzerland, Türkiye, and United States of America. The disputed domain name <stylerickowens.com> was registered on July 11, 2023. The Complainant has submitted evidence showing that the disputed domain name has been used to operate a website featuring the RICK OWENS mark, and purportedly offering a range of goods, including clothing and footwear under the RICK OWENS mark. At the time of this decision, the disputed domain name continued to resolve to the same website. 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 the disputed domain name registered by the Respondent is identical or confusingly similar to the Complainant’s RICK OWENS marks. The Complainant asserts that it has not authorized the Respondent to use the RICK OWENS mark, and there is no evidence to suggest that the Respondent has used, or has undertaken any demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services, but rather, as the Complainant further contends, has used it in a deliberate attempt to deceive third parties as to the Respondent’s identity by operating a fraudulent website offering a range of products under the Complainant’s name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 6.1 Preliminary Issue: Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for the following reasons: - The Complainant and its representatives have no proficiency in the Chinese language and are fluent only in English. - Requiring the Complainant to translate the Complaint, all supporting evidence, annexes, and any subsequent submissions into Chinese would impose an unfair and substantial burden. This would involve significant translation costs (given that professional legal translations are necessary for accuracy in such proceedings) and cause considerable delay, contrary to the aim of conducting proceedings with due expedition under paragraph 10(c) of the Rules. - English is one of the primary working languages of the WIPO Arbitration and Mediation Center and is the most widely used language in international commercial and intellectual property matters, including UDRP proceedings. - The Complainant would be unfairly disadvantaged if forced to proceed in Chinese, while the Respondent would not suffer prejudice in English. The Center has already notified the Respondent in both English and Chinese, providing a fair opportunity to participate or object (and any Response may be submitted in Chinese if preferred, subject to Panel discretion). In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions (“WIPO Overview 3.1”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 6.2 Substantive Issues 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 Panel acknowledges that the Complainant has established rights in the RICK OWENS trade marks. WIPO Overview 3.1, section 1.2.1. Disregarding the generic Top-Level Domain (“gTLD”) “.com”, the disputed domain name incorporates the term “rick owens”, which is identical to the Complainant’s RICK OWENS trade marks. The inclusion of the additional term “style” does not prevent a finding of confusing similarity. WIPO Overview 3.1, sections 1.7, 1.8, and 1.11.1. page 4 The Panel therefore finds that the Complainant has satisfied the requirements of paragraph 4(a)(i) of the Policy in establishing its rights in the RICK OWENS trade marks and in showing that the disputed domain name is confusingly similar to its marks. 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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. In this case, the Complainant asserts that it has not authorized the Respondent to use its trade marks and there is no evidence to suggest that the Respondent has used, or undertaken any demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Having reviewed the available records, 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 did not file a response and has therefore failed to assert factors or put forth evidence to establish that it enjoys rights or other legitimate interests in the disputed domain name. According to the Complainant, the Respondent is not affiliated or connected with the Complainant in any manner, and the Complainant has not granted the Respondent any license or authorization to use or register a domain name incorporating the Complainant’s RICK OWENS trade marks. The Respondent did not respond to the Complaint and did not provide any information or factors that could potentially establish prior rights or legitimate interests in the disputed domain name. Furthermore, there is no evidence indicating that the Respondent has engaged in any legitimate noncommercial or bona fide use of the disputed domain name. The Complainant has presented evidence linking the disputed domain name to a website purportedly offering a range of products in the same industry as the Complainant under the Complainant’s RICK OWENS mark without any prominent and accurate disclaimer as to the (lack of) relationship between the Parties, which supports a finding that the Respondent has no rights or legitimate interests in the disputed domain name. C. Registered and Used in Bad Faith The third and final element that a complainant must prove is that the respondent has registered and is using the disputed domain name in bad faith. Paragraph 4(b) of the Policy states that any of the following circumstances, in particular but without limitation, shall be considered as evidence of the registration and use of a domain name in bad faith: (i) circumstances indicating that the respondent registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant (the owner of the trade mark or service mark) or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or (ii) circumstances indicating that the respondent registered the domain name in order to prevent the owner of the trade mark or service mark 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) circumstances indicating that the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) circumstances indicating that the respondent is using the domain name to intentionally attempt to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on its website or location. The examples of bad faith registration and use set forth in paragraph 4(b) of the Policy are not meant to be exhaustive of all circumstances in which bad faith may be found. Other circumstances may also be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. For reasons discussed under this and the preceding heading, the Panel believes that the Respondent’s conduct in this case constitutes bad faith registration and use of the disputed domain name. In the present case, the Panel observes that the disputed domain name <stylerickowens.com>, is composed of the Complainant’s RICK OWENS trade marks together with the term “style”, which describes the Complainant’s business activities. This combination provides a more accurate and thorough representation of the Complainant’s operations. The Panel finds that the registration of the disputed domain name, which reproduces the Complainant’s RICK OWENS trade mark together with additional elements directly related to the Complainant’s business, indicates the Respondent’s clear awareness of the Complainant and its trade mark rights. Regarding the question of whether the Respondent acted in bad faith at the time of registration, the Panel finds that the Respondent was aware of the Complainant’s rights in the RICK OWENS trade mark, as the disputed domain name is used to operate a website purportedly offering a range of products in the same industry as the Complainant under the Complainant’s RICK OWENS mark. Even in the event that the Respondent offered genuine RICK OWENS merchandise (e.g., as a non- authorised reseller), the misleading of Internet users and consumers into thinking that the Respondent is, in some way or another, connected to, sponsored by or affiliated with the Complainant and its business, or that the Respondent’s activities are approved or endorsed by the Complainant, indicates bad faith (Swarovski Aktiengesellschaft v. bingbing chen, WIPO Case No. D2011-1524). In the present case, the Respondent actually intended to create the impression that the website to which the disputed domain name resolves is operated or authorized by the Complainant. It is thus reasonable to assume that the Respondent registered the disputed domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trade marks (cf. Tottenham Hotspur Limited v. [Name redacted] and Maurice Buckhanna, WIPO Case No. D2025-2937). Paragraph 4(b)(iv) of the Policy. Accordingly, the Panel finds that the Respondent has registered and used the disputed domain name pursuant to 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 <stylerickowens.com> be transferred to the Complainant. /Joseph Simone/ Joseph Simone Sole Panelist Date: February 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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