Westmore · UDRP DecisionRallphlauren.com
The Panel ordered transfer of <rallphlauren.com>. It found the domain confusingly similar to the RALPH LAUREN mark because it reproduced the mark with an additional letter “l”; found that the Complainants had established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests; and found bad-faith registration and use based on the mark’s distinctiveness and reputation, the domain’s composition, passive holding, and the record concerning claimed phishing and passing off.
The timeline behind rallphlauren.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 rallphlauren.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case combines a straightforward one-letter typosquatting pattern with passive web use and alleged email-based impersonation. It illustrates that a blank website does not insulate a respondent from a bad-faith finding where the domain closely tracks a distinctive mark, supports email through MX configuration, and the record contains allegations of targeted payment diversion that go unrebutted.
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 PRL USA Holdings, Inc., The Polo/Lauren Company L.P. v. Jaime Vinals-Parra Case No. D2026-0295 1. The Parties Complainants are PRL USA Holdings, Inc., and The Polo/Lauren Company L.P., United States of America (“United States”), represented by CSC Digital Brand Services Group AB, Sweden. Respondent is Jaime Vinals-Parra, United States. 2. The Domain Name and Registrar The Disputed Domain Name <rallphlauren.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 26, 2026. On January 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On January 26, 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 Complainant on January 28, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on January 29, 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 Respondent of the Complaint, and the proceedings commenced on January 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 19, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on February 20, 2026. page 2 The Center appointed Richard W. Page as the sole panelist in this matter on February 25, 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 American fashion designer Ralph Lauren launched his own fashion company, under the brand and the RALPH LAUREN Mark, in 1967. Initially a neckwear line, RALPH LAUREN soon expanded to cover full lines for men and women and opened his own flagship stores. Continuously developing and strengthening his reputation and distinctive image for nearly 60 years, RALPH LAUREN has become a global leader in the design, marketing, and distribution of premium lifestyle products across apparel, accessories, home, fragrance, and hospitality. Ralph Lauren Corporation is the parent company that wholly owns the subsidiaries PRL USA Holdings, Inc. and The Polo/Lauren Company L.P (“Complainants”). Ralph Lauren Corporation’s global reach is extensive, selling its products to customers worldwide via 1,351 stores and employing 15,000 people globally. It is listed on the New York Stock Exchange under the symbol “RL”. In fiscal year 2025, the Ralph Lauren Corporation achieved net revenues of over USD 7.079 million. Mr. Ralph Lauren has been recognized for his contributions to fashion on numerous occasions, including receiving two Mensware Designer of the Year awards from the Council of Fashion Designers of America, as well as their Lifetime Achievement Award. In 2018, he was honored as a Design Legend by GQ UK, a Fashion Innovator by the Wall Street Journal, and a British Knighthood for his impact in “fashion, business, and philanthropy”. Further, Mr. Ralph Lauren received the Légion D’Honneur (Legion of Honor) in 2019 and the Presidential Medal of Freedom in 2025. Complainants are the owners of numerous trademark registrations across various jurisdictions for the RALPH LAUREN Mark, including without limitation the following: United States Registration No. 1,222,278 for RALPH LAUREN registered January 4, 1983, in international class 03; United Kingdom Registration No. UK00002027087 for RALPH LAUREN registered June 21, 1996, in international class 03; and European Registration No. 002730323 for RALPH LAUREN registered August 18, 2003, in international class 35. Complainants, also, maintain a strong Internet presence, promoting its range of products predominantly through its primary domain name, <ralphlauren.com>, registered since September 25, 1996. According to SimilarWeb.com, it received 7.4 million individual visits in May 2025, making it the 6,308 th most popular website globally and 1,311 st in the United States. The Disputed Domain Name was registered on January 8, 2026, resolves to an inactive website which has a blank page and no content. The Disputed Domain Name is enrolled in a mail exchange (MX) allowing for the sending and receiving of email messages. page 3 5. Parties’ Contentions A. Complainant Complainants contend that RALPH LAUREN is not a dictionary term and does not have a generic meaning. It is the name of its founder, Ralph Lauren. Moreover, the RALPH LAUREN Mark has become a famous and distinctive mark throughout the world as a symbol of the high-quality standards and exclusivity that Complainants maintain for their products and related services. Complainants further contend that the RALPH LAUREN Mark is a direct reference to the company’s origins and history. Complainants further contend that they have spent a considerable amount of time and money protecting their intellectual property rights. Complainants further contend that the entire RALPH LAUREN Mark with the addition of the letter “L” makes the Disputed Domain Name confusingly similar to the RALPH LAUREN Mark. Complainants further contend that the Disputed Domain Name is a purposeful misspelling of the RALPH LAUREN Mark and should be considered a prototypical example of typosquatting, which intentionally takes advantage of Internet users that inadvertently type an incorrect address – often a misspelling of the RALPH LAUREN Mark – when seeking to access Complainants’ website. Complainants submit that Respondent is not sponsored by or affiliated with Complainants in any way, nor have Complainants given Respondent permission to use the RALPH LUAREN Mark in any manner. Furthermore, Complainants have not licensed, authorized, or permitted Respondent to register any domain name incorporating the RALPH LAUREN Mark. Complainants submit that Respondent is not commonly known by the Disputed Domain Name. Complainants further submit that Respondent’s phishing scheme is a type of passing off which precludes Respondent from having any rights or legitimate interests in the Disputed Domain Name. Complainants further submit that Respondent is using the Disputed Domain Name to redirect Internet users to Respondent’s website that resolves to a blank page and lacks content which is apparently being passively held by Respondent. Complainants further submit that there appears to be active email using the Disputed Domain Name’s enrollment in the MX exchange as part of a phishing scam. Complainants further submit that Respondent has failed to make use of the Disputed Domain Name’s website and has not demonstrated any attempt to make legitimate use of the Disputed Domain Name. Complainants allege that, by the time Respondent registered the Disputed Domain Name on January 8, 2026, the RALPH LAUREN Mark had been registered for years and Complainants’ worldwide reputation established for decades. Complainants further allege that Respondent is trying to impersonate one of Complainants’ employees as part of a phishing scam, which is unequivocal evidence of knowledge of Complainants’ rights in the RALPH LAUREN Mark. Complainant further submits that Respondent created the Disputed Domain Name to facilitate email phishing attacks, targeting clients of Complainants. Specifically, the Disputed Domain Name has been used to send out email communications from <[...]@rallphlauren.com>, purporting to originate from an executive of Complainants’ business. The emails, which contained Complainants’ official information in the signature, were sent to clients of Complainants with the intent of redirecting legitimate payments to Respondent for its own financial gain. page 4 Complainants further allege that given these circumstances it is “not possible to conceive of a plausible situation in which the Respondent would have been unaware of Complaints’ trademark rights at the time the Disputed Domain Name was registered – which demonstrates Respondent’s bad faith in the registration and use of the Disputed Domain Name”. Complainants contend that they have satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. B. Respondent Respondent did not reply to the Complainants’ contentions. 6. Discussion and Findings Complainants are both wholly-owned subsidiaries of Ralph Lauren Corporation. Under the Policy, if multiple Complainants have a common cause of action against a single respondent, they can file a single complaint. Here, Complainants form part of the same organization and have a common grievance against Respondent, which entitles Complainants to consolidation. The Panel finds that consolidation is equitable and procedurally efficient, since both entities are part of the same group of companies. Paragraph 15(a) of the Rules instructs the Panel as to the principles the Panel is to use in determining the dispute: “A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any rules and principles of law that it deems applicable.” Even though Respondent has failed to file a Response or to contest Complainants’ assertions, the Panel will review the evidence proffered by Complainants to verify that the three essential elements of the claims are met. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.3. Paragraph 4(a) of the Policy directs that Complainants must prove each of the following three elements: i) that the Disputed Domain Name registered by Respondent is identical or confusingly similar to the RALPH LAUREN Mark which Complainants have rights; and ii) that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and iii) that the Disputed Domain Name has been registered and is being used in bad faith. A. Identical or Confusingly Similar WIPO Overview 3.1, section 1.2.1 states that registration of the RALPH LAUREN Mark is prima facie evidence of Complainant having enforceable rights in the RALPH LAUREN Mark. Complainant has shown rights in respect of the RALPH LAUREN Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. 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 RALPH LAUREN Mark and the Disputed Domain Name. WIPO Overview 3.1, section 1.7. page 5 The entirety of the RALPH LAUREN Mark is reproduced within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the RALPH LAUREN Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms, here an additional letter “L”, may bear on assessment of the second and third elements, the Panel finds the addition of such additional letter does not prevent a finding of confusing similarity between the Disputed Domain Name and the RALPH LAUREN Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 Respondent may demonstrate rights or legitimate interests in the Disputed Domain Name. Paragraph 4(c) of the Policy allows three nonexclusive methods for the Panel to conclude that Respondent has rights or a legitimate interest in the Disputed Domain Name: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Disputed Domain Name or a name corresponding to the Disputed Domain Name in connection with a bona fide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Disputed Domain Name, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the RALPH LAUREN Mark. Although the overall burden of proof in UDRP proceedings is on Complainant, panels have recognized that proving that Respondent lacks rights or legitimate interests in the Disputed Domain Name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of Respondent. As such, where Complainant makes out a prima facie case that Respondent lacks rights or legitimate interests, the burden of production on this element shifts to Respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the Disputed Domain Name (although the burden of proof always remains on Complainant). If Respondent fails to come forward with such relevant evidence, Complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent has not rebutted 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. Panels have held that the use of a domain name for illegitimate activity, here claimed as phishing and passing off, can never confer rights or legitimate interests on Respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. page 6 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 the Disputed Domain Name in bad faith. Paragraph 4(b) of the Policy sets forth four nonexclusive criteria for Complainant to show bad faith registration and use of the Disputed Domain Name: (i) circumstances indicating that you [Respondent] have registered or you have acquired the Disputed Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Disputed Domain Name registration to Complainant who is the owner of the RALPH LAUREN Mark or to a competitor of Complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the Disputed Domain Name; or (ii) you [Respondent] have registered the Disputed Domain Name in order to prevent the owner of the RALPH LAUREN Mark from reflecting the RALPH LAUREN Mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you [Respondent] have registered the Disputed Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the Disputed Domain Name, you [Respondent] have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with the RALPH LAUREN Mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product on your website or location. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that the Disputed Domain Name was registered and used in bad faith, but other circumstances may be relevant in assessing whether Respondent’s registration and use of the Disputed Domain Name is in bad faith. WIPO Overview 3.1, section 3.2.1. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the RALPH LAUREN Mark, and the composition of the Disputed Domain Name, and finds that in the circumstances of this case the passive holding of the Disputed Domain Name does not prevent a finding of bad faith under the Policy. The Panel finds that given these circumstances it is “not possible to conceive of a plausible situation in which the Respondent would have been unaware of” Complaints’ trademark rights at the time the Disputed Domain Name was registered – which demonstrates Respondent’s bad faith in the registration and use of the Disputed Domain Name. Panels have held that the use of a domain name for illegitimate activity, here claimed as phishing and passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. The Panel finds that Complainant has established the third element of the Policy. page 7 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 <rallphlauren.com> be transferred to Complainant. /Richard W. Page/ Richard W. Page Sole Panelist Date: March 9, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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