Westmore · UDRP decision
WIPO · Case No. D2026-0277

Speroni.com

Complaint deniedWIPO-indexed · informational, not legal advice

The Panel denied transfer of <speroni.com>. Although the domain name was confusingly similar to the textual component of the Complainant’s stylized SPERONI trademark, the Respondent had rights and legitimate interests arising from his surname and decades-long personal use of the domain for family email and an amateur-radio website. The Panel also found good-faith registration and use. It declared that the Complaint was brought in bad faith and constituted Reverse Domain Name Hijacking because the Complainant continued after the registrant was identified as Joseph Speroni and failed to investigate readily available historical records showing longstanding surname-related use.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-03-01
Panelist(s)
Christie, Andrew F.
Complainant
Speroni General Trading LLC OPC
Respondent
Joseph Speroni, 2781 Kapiolani Blvd
Counsel
Al Tamimi & Company
Disputed domain(s)
speroni.com
Domain history UDRP Intelligence

The timeline behind speroni.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 speroni.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 denied. speroni.com remained with the respondent.
Reverse Domain Name Hijacking
Reverse Domain Name Hijacking: found.
Westmore Insight

This decision illustrates the importance of investigating a domain’s historical use and the disclosed registrant’s identity before alleging that an inactive exact-match domain is being passively held in bad faith. Current inactivity did not displace decades of documented surname-related personal use. The case is also significant because the Panel found RDNH after the Complainant continued despite registrar disclosure and readily available archival evidence that directly contradicted its allegations.

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.

Case details
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-03-01
Panel
Christie, Andrew F.
Full decision
17 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Speroni General Trading LLC OPC v. Joseph Speroni Case No. D2026-0277 1. The Parties The Complainant is Speroni General Trading LLC OPC, United Arab Emirates, represented by Al Tamimi & Company, United Arab Emirates. The Respondent is Joseph Speroni, Honolulu, Hawaii, United States of America, represented by John Berryhill, Ph.d., Esq., United States of America. 2. The Domain Name and Registrar The disputed domain name <speroni.com> is registered with Wild West Domains, 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 (Registration Private, Domains by Proxy, LLC) 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 January 30, 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 February 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 26, 2026. On February 2, 2026, the Respondent requested the four day extension under Paragraph 5(b) of the Rules, which was granted. The Response was filed with the Center on February 4, 2026. page 2 The Center appointed Andrew F. Christie as the sole panelist in this matter on February 16, 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 company incorporated in the United Arab Emirates and holds a valid trade license issued in Abu Dhabi. It is active in the field of footwear, leather goods, retail services, and related commercial activities. The Complainant’s products are available through a dedicated boutique located in Al Khalidiyah, Central West in Abu Dhabi. The Complainant is the owner of a number of registrations for a trademark consisting of a heraldic shield-like device and the text string “Speroni” in a stylized font, including European Union Trade Mark Registration No. 013729711 (registered on May 28, 2015) and Qatar Trademark Registration numbers 180433 (registered on January 23, 2025) and 180434 (registered on October 2, 2025). It is also the owner of United Arab Emirates Trade Mark Registration No. 449926 (registered on June 25, 2025) for a trademark consisting of the text string “Speroni” in a stylized font. The Complainant operates the domain name <speronishoe.com>, which serves as its primary Internet address. At the time of filing of the Complaint, the Complainant said that its website using this domain name was temporarily unavailable due to maintenance. The Complainant maintains an official presence on a number of Instagram accounts, which have account names that include the string “speroni”. The Registrar’s verification response states that the disputed domain name was created on February 3, 1997. The Respondent says he obtained the disputed domain name “prior to 1997”. The Respondent provided a screenshot of an Internet Archive Wayback Machine record for the disputed domain name on December 21, 1997, showing it resolved to a page providing contact details for the Respondent and his wife, including email addresses using the disputed domain name. That webpage provided a link to the “AH0A Amateur Radio Site”, a website authored by the Respondent. The Respondent also provided a screenshot of a DomainTools record showing that the registrant of the disputed domain name on January 29, 2001 was “Speroni Family”, and on October 27, 2007 was the Respondent. At the date of the filing of the Complainant, the disputed domain name did not resolve to an active location. That is also the situation at the date of this Decision. 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 contends that the disputed domain name is confusingly similar to a trademark in which it has rights on the following grounds. The Complainant is the owner of multiple trademark registrations for SPERONI. The disputed domain name consists entirely and exclusively of the Complainant’s trademark, without any distinguishing element. The disputed domain name is identical to the Complainant’s registered trademark, differing only by the generic Top-Level Domain (“gTLD”) “.com”, which is irrelevant for the purpose of the confusing similarity test. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name on the following grounds. The Respondent is not affiliated with the Complainant in any way. The Respondent has not been authorized, licensed, or permitted to use the SPERONI trademark. The disputed page 3 domain name does not resolve to an active website and is not used for any bona fide offering of goods or services. There is no legitimate noncommercial or fair use of the disputed domain name. The passive holding of a domain name identical to a third party ’s trademark does not confer rights or legitimate interests, particularly where the Respondent has taken steps to conceal its identity. Although the Respondent appears to bear the surname “Speroni”, there is no evidence that the Respondent has been commonly known, in a commercial or public sense, by the name SPERONI in connection with goods, services, or any legitimate business activity. The mere fact that a respondent’s surname corresponds to a domain name does not, of itself, confer rights or legitimate interests within the meaning of paragraph 4(c)(ii) of the Policy, particularly where the domain name is identical to a registered trademark and is not used for any bona fide or legitimate purpose. The Complainant contends that the Respondent has registered and is using the disputed domain name in bad faith on the following grounds, among others. The Respondent’s apparent surname does not provide a plausible good-faith explanation for the registration and retention of an exact-match domain name identical to the Complainant’s registered SPERONI trademark, particularly in the absence of any demonstrable legitimate use or preparatory steps toward such use. At the time of filing the Complaint, the disputed domain name does not resolve to an active website. All of the factors considered by Panels to constitute a bad faith passive holding of a domain name are present in this case. Any potential future use of the disputed domain name by an unaffiliated third party would inevitably mislead Internet users into believing that the domain name is associated with, endorsed by, or connected to the Complainant. The Respondent has elected to mask its identity through a proxy registration service and has not come forward with any legitimate explanation for its registration or intended use of the disputed domain name. By holding the disputed domain name, the Respondent prevents the Complainant from reflecting its trademark in the most commercially significant gTLD. Given the identity between the disputed domain name and the Complainant’s trademark, there is no conceivable good faith use that the Respondent could make of the disputed domain name without infringing the Complainant’s rights or misleading consumers. B. Respondent The Respondent contends that the Complainant has not satisfied any of the elements required under the Policy for a transfer of the disputed domain name. The Respondent contends that the Complainant does not have a trademark or service mark to which the Policy applies, on the following grounds. The Complainant shows that it filed some trademark in December 2025, and that it has some prior filings from 2014. The Complainant does not have a functioning website at this time, and instead refers to its Instagram account as evidence of conducting business. The Complainant does not mention its X account, @Speronishoes, which has been inactive since 2016, or its domain name <speroni.ae> which, like its <speroni-ae.com> domain name, is defunct. The Complainant claims a number of junior trademark filings for SPERONI, supposedly for shoe business. Not only does the Complainant fail to provide any evidence of the size or substantiality of its business, but it is also plainly obvious that the Complainant did not even exist when the Respondent registered the disputed domain name. The Respondent contends that he has rights or legitimate interests in the disputed domain name, on the following grounds, among others. The fact that the Respondent in this proceeding is Mr. Joseph Speroni should be the entirety of a sufficient response to the Complaint. The Respondent registered the disputed domain name on behalf of his family as early as 2001, and later updated the registration to his name and to a new address in 2007. Prior to 2023, the Respondent utilized the disputed domain name to re-direct to a website about amateur radio authored by the Respondent. The Respondent has been commonly known as “Speroni” since the day he was born. For many years the Respondent registered and used the disputed domain name to provide email addresses for himself and his wife. The right to register one’s own surname as a domain name for personal use is one of the most basic species of legitimate interests under the Policy. page 4 The Respondent contends that he did not register or use the disputed domain name in bad faith, on the following grounds. The disputed domain name cannot have been registered in bad faith for the reason that the Respondent has had the disputed domain name for longer than the Complainant has existed. The Complainant likely knew the Respondent owned the disputed domain name when the Complainant made the deliberate decision to copy the Respondent’s surname as its business name. It is not credible that, at no time during its existence up until a few weeks ago, the Complainant was not aware the disputed domain name directed to a page run by a Joe Speroni in Hawaii. The Complaint should be denied and the Panel should exercise its sole discretion under UDRP Rule 15(e). The Respondent has a grave medical condition which has left him and his family with a number of things to deal with, the last of which is updating the Respondent’s email contact address with the Registrar. Since he had decommissioned his “speroni.com” email address, this inadvertently left the disputed domain name with a stale email address, which is why a non-functional email address was associated with the domain information provided by the Registrar. The Registrar has stated it cannot correct the Respondent’ data during pendency of this Proceeding. The Respondent requests the Panel to specifically instruct the Registrar to work to ensure the Respondent’s contact information is updated. 6. Discussion and Findings 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. Panel assessment of identity or confusing similarity involves comparing the (alpha-numeric) domain name and the textual components of the relevant mark. To the extent that design (or figurative/stylized) elements would be incapable of representation in domain names, these elements are largely disregarded for purposes of assessing identity or confusing similarity under the first element. WIPO Overview 3.1, section 1.10. The Complainant is the owner of a registration for a trademark consisting of the text string “Speroni” in a stylized font. The disputed domain name consists of “speroni” and the gTLD “.com”. Once the gTLD “.com” is ignored, which is appropriate in this case, the disputed domain name is identical to the text string component of the Complainant’s stylized trademark. Accordingly, the disputed domain name is confusingly similar to the Complainant’s stylized trademark. 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 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. page 5 The Respondent’s surname is identical to the disputed domain name, once the gTLD is ignored. The Respondent has been the registrant of the disputed domain name for a number of decades, and until relatively recently the Respondent used the disputed domain name for email addresses for him and his wife, and to redirect to another website about amateur radio that was authored by him. There is no evidence that the Respondent has at any time used the disputed domain name for any other purpose, including any purpose that might cause confusion with the Complainant or its business. It is clear that the Respondent has, and always had, rights and legitimate interests in the disputed domain name. The Panel finds the second element of the Policy has not 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. None of those circumstances apply in this case, and there are no other circumstances in this case which establish that the Respondent registered and has used the disputed domain name in bad faith. Indeed, the circumstances outlined in section 6.B above make it clear that the Respondent registered and has used the disputed domain name in good faith. The Panel finds the third element of the Policy has not been established. D. Reverse Domain Name Hijacking Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking (“RDNH”) or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. RDNH is furthermore defined under the UDRP Rules as “using the UDRP in bad faith to attempt to deprive a registered domain-name holder of a domain name”. The mere lack of success of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.01 section 4.16. Section 4.16 of the WIPO Overview 3.1, lists, non-exhaustively, circumstances which previous panels have considered to be indicative of a complaint having been brought in bad faith. One such circumstance is facts which demonstrate that the complainant clearly ought to have known it could not succeed under any fair interpretation of facts reasonably available prior to the filing of the complaint, including relevant facts readily available public sources. Another such circumstance is unreasonably ignoring established Policy precedent notably as captured in this WIPO Overview. The Panel considers that both of those circumstances are present in this case. Prior to filing the Complainant, the Complainant could have taken the obvious and simple step of using the Internet Archive Wayback Machine to ascertain when, how and by whom the disputed domain name had been used. If it had done so, it would have identified that as early as 1997 (which is nearly two decades before the Complainant registered its trademark) the disputed domain name was used for an email address for “Joe Speroni”, and that from 1997 until 2024 the disputed domain name was used to link or redirect to an information website that was authored by “Joe Speroni”. This information would have put the Complainant on notice that, while the identity of the actual registrant of the disputed domain name was hidden due to use of a proxy registration service, it very likely was a person known as Joe Speroni, and hence was someone very likely to have rights and legitimate interests in the disputed domain name due to it being that person’s surname. page 6 In any event, a t the time it filed the amended Complaint, the Complainant was aware from the Registrar’s verification response that the registrant of the disputed domain name was Joseph Speroni. If the Complainant had consulted Wayback Machine records, it would have been clear to the Complainant when it received the Registrar’s verification response that the registrant was the same person as the “Joe Speroni” that had been using the disputed domain name for many decades for bona fide purposes connected to their identity. Precedent under the Policy makes it clear that this sort of use of the disputed domain name establishes that the Respondent had rights and legitimate interests in the disputed domain name, and could not be said to have registered and used the disputed domain name in bad faith. Nevertheless, after receiving the Registrar’s verification response the Complainant continued the proceeding by filing an amended Complaint, in which assertions were made that the Respondent was passively holding the disputed domain name, had not used the disputed domain name for any bona fide or legitimate purpose, had registered and retained the disputed domain name with intent to target the Complainant’s trademark, and did not have any potential future use of the disputed domain name that would not inevitably mislead Internet users into believing that the disputed domain name was associated with, endorsed by, or connected to the Complainant – all of which were incorrect. The failure of the Complainant to properly consider the revealed registrant information or undertake the obvious and simple step of using the Internet Archive Wayback Machine to inform itself of when, how, and by whom the disputed domain name had been used imposed an unnecessary and significant burden on the Respondent, who had to respond to a Complaint that had no foundation. This failure was inexcusable. The Panel finds that the Complaint was an attempt at Reverse Domain Name Hijacking, was brought in bad faith, and constitutes an abuse of the administrative proceeding. E. Registrar’s Correction of Registrant’s contact email address The Respondent requested the Panel to specifically instruct the Registrar to work to ensure the Respondent’s contact information is updated. The Panel notes such request is properly a registration-related matter for the Registrar and beyond the scope of available remedies under the UDRP. In any event, the Panel notes that upon conclusion of this proceeding the locks associated with paragraph 4(b) of the Rules will be lifted. The Respondent may then coordinate directly with the Registrar to update its contact information. 7. Decision For the foregoing reasons, the Complaint is denied. /Andrew F. Christie/ Andrew F. Christie Sole Panelist Date: March 1, 2026

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

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