Westmore · UDRP DecisionGhaf-woods-dubailand.com
The Panel ordered transfer of <ghaf-woods-dubailand.com>. It found the domain confusingly similar to the Complainant’s GHAF WOODS trademark because it incorporated the mark in its entirety and added the geographical term “dubailand.” The Respondent did not rebut the Complainant’s prima facie case concerning rights or legitimate interests and stated that he was ready to transfer the domain. Bad faith was found from the targeting composition of the domain, passive holding, the accepted well-known character of the mark in its field, lack of a plausible explanation or good-faith use, use of a privacy service in the surrounding circumstances, and the Respondent’s lack of participation.
The timeline behind ghaf-woods-dubailand.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 ghaf-woods-dubailand.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an entire real estate project mark with wording tied to the project’s location can support findings across all three UDRP elements. The same added term that did not avoid confusing similarity was significant under the later elements because it increased the appearance of affiliation and supported an inference of deliberate targeting. The case also shows that informal willingness to transfer does not necessarily prevent a panel from issuing findings on the merits.
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 Majid Al Futtaim Properties LLC v. Raheel Rizwan Case No. D2026-0276 1. The Parties The Complainant is Majid Al Futtaim Properties LLC, United Arab Emirates, represented by Al Tamimi & Company, United Arab Emirates. The Respondent is Raheel Rizwan, Pakistan. 2. The Domain Name and Registrar The disputed domain name <ghaf-woods-dubailand.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 23, 2026. On January 23, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 23, 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 (Privacy Service Provided by GoDaddy.com, LLC / Unknown Registrant) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 26, 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 on April 3, 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”). From February 5, 2026, until March 31, 2026, the proceedings were suspended. On March 30, 2026, the Complainant requested the Center to re-institute the procedure as the parties were not able to find a settlement. page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on April 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 27, 2026. The Respondent sent email communications to the Center on January 29, 2026, March 30, 2026, and April 7, 2026. The Center appointed Emre Kerim Yardimci as the sole panelist in this matter on May 8, 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 Majid Al Futtaim Properties LLC, is company duly incorporated under the laws of the United Arab Emirates and forms part of the Majid Al Futtaim group of companies, a leading developer and operator of integrated lifestyle destinations in the Middle East, Africa, and Asia. The Complainant is active in the development, ownership, and management of large-scale mixed-use real estate projects, including residential, commercial, retail, and leisure developments. Over several decades, the Complainant has established substantial goodwill and reputation in connection with its real estate projects, which are marketed and sold under distinctive project names and brands owned and controlled by the Complainant. The Complainant is the owner of following trademarks incorporating GHAF WOODS: - The UAE registrations Nos. 378279 and 378280 GHAF WOODS (fig.), filed on June 21, 2022, and registered on February 2, 2023, covering services in classes 35 and 36. - The Egyptian registrations Nos. 479489 and 479490 GHAF WOODS (fig.), filed on June 26, 2022, and registered on March 24, 2024, covering services in classes 35 and 36. - The Saudi registrations Nos. 1443038712 and 1443038716 GHAF WOODS (fig.), filed on June 29, 2022, and registered on October 5, 2022, covering services in classes 35 and 36. The disputed domain name was registered on March 20, 2024 and resolve to an inactive page. 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 is confusingly similar, and at the same time, incorporating the Complainant’s well-known trademark GHAF WOODS and that the addition of the descriptive term “dubailand” does not lessen the association between the disputed domain name and the Complainant’s trademark. The Complainant considers that the Respondent has no rights or legitimate interests in respect of the disputed domain name, mainly because the Complainant has neither licensed nor otherwise authorized the Respondent to use its marks or to apply for or use any domain name incorporating the trademark GHAF WOODS. The Complainant further asserts that although the Respondent is not using the disputed domain name, any future use cannot be considered for a bona fide offering of goods and services. page 3 Finally, in addressing the question of registration and use of the disputed domain name in bad faith, the Complainant observes that the Respondent is well aware of the Complainant’s trademark considering the use of the geographical term “dubailand” where the Complainant master-planned real estate development project Lastly, the Complainant stated that the Respondent admitted that he does not require the disputed domain name and that he is prepared to transfer it voluntarily, which is and unambiguous confirmation that the registration was not made with any legitimate purpose, and that no such purpose has since developed. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. The Respondent has informed the Center and the Complainant that he is ready to unilaterally transfer the disputed domain name. 6. Discussion and Findings According to paragraph 4(a) of the Policy, the Complainant must prove that; (i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent has no rights or legitimate interest in respect of the disputed domain name; and (iii) The disputed domain name has been registered in bad faith and is being used in bad faith. 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 of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that the disputed domain name <ghaf-woods-dubailand.com> wholly incorporates the Complainant’s distinctive trademark GHAF WOODS and the term “dubailand” which is purely descriptive and only refers to a designation of the geographical location. See WIPO Overview 3.0, section 1.8. The Panel finds that the disputed domain name is confusingly similar for the purpose of the Policy to the Complainant’s trademark GHAF WOODS. Although the addition of other terms here, “dubailand” 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 the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. As regards the generic Top-Level Domain, it is typically disregarded under the confusing similarity test. 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. page 4 Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving that 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 3.1, 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. Moreover, considering the sector within which the Complainants operate, the geographical reference “dubailand” may even enhance the false impression that any services offered under the disputed domain name are officially linked to the Complainant. Thereby, the Panel finds that the composition of the disputed domain name incorporating the Complainant’s trademark in its entirety, creates a risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. Lastly, the fact that the Respondent has informed the Center and the Complainant that he is ready to unilaterally transfer the disputed domain name corroborates the fact that he has no rights or legitimate interests in the disputed domain name. The Panel finds the second element of the Policy has been established C. Registered and Used in Bad Faith The Panel accepts the Complainant’s assertions that the trademark GHAF WOODS. is a well-known trademark in its field services. The incorporation of a well-known trademark into a domain name by a registrant having no plausible explanation for doing so may be, in and of itself, an indication of bad faith. WIPO Overview 3.1, section 3.1.1 The Respondent’s registration of the disputed domain name with addition of the descriptive term “dubailand” - which refers to Complainant’s project location – supports a finding of bad faith registration as it clearly targets the Complainant’s company and its products and services. The Panel considers that the Respondent is likely attempting to build an appearance that the disputed domain name is connected or associated to the Complainant. The Respondent, by retaining control of the disputed domain name creates a real or implied threat to the Complainant. The disputed domain name resolves to an inactive page. The Panel is not aware of any use, seeing as the Respondent is holding the disputed domain name passively. It has long been generally held in UDRP decisions that the passive holding of a domain name that incorporates a well-known trademark, without any actual or contemplated good faith use, does not prevent a finding that the domain name is in use within the requirements of paragraph 4(a)(iii) of the Policy (See Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003, and WIPO Overview 3.1, section 3.3) Lastly, the Panel observed that the Respondent used a privacy shield. While the Respondent’s use of a privacy service will not in itself constitute bad faith under the Policy, the Panel may still take it into account and draw adverse inferences under certain circumstances. The use of the privacy shield in this case together with other elements gives rise to the suspicion that the privacy shield was used to mask the identity of the underlying registrant, and, thus, supports a finding of bad faith. WIPO Overview 3.1, section 3.2.1. page 5 Given the Respondent’s lack of participation in this proceeding, the history and well-known character of the Complainant’s mark, the composition of the disputed domain name, the lack of use of the disputed domain name, and the Respondent’s use of privacy service, the totality of circumstances supports an inference of bad faith. Therefore, in the view of cumulative circumstances, the Panel finds that the requirement of registration and use in bad faith is satisfied, according to the Policy, paragraph 4(a)(iii). 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 <ghaf-woods-dubailand.com> be transferred to the Complainant. /Emre Kerim Yardimci/ Emre Kerim Yardimci Sole Panelist Date: May 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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