Westmore · UDRP DecisionCarvanaloan.com
The Panel ordered transfer of <carvanaloan.com>. It found the domain confusingly similar to Complainant’s CARVANA mark, rejected Respondent’s unsupported explanation of an intended unrelated lending venture, and concluded that the mark-plus-“loan” composition more likely than not targeted Complainant. The domain’s non-use did not prevent a bad-faith finding under the passive-holding doctrine.
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The decision illustrates how the combination of a distinctive coined mark with a term closely corresponding to the complainant’s services can support findings of both targeting and bad faith even without conventional evidence of active commercial misuse. It also shows the evidentiary weakness of an asserted business plan when no contemporaneous corroboration is supplied.
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 Carvana, LLC v. Jamil Ashkar Case No. D2026-0399 1. The Parties Complainant is Carvana, LLC, United States of America (“United States”), represented internally. Respondent is Jamil Ashkar, United States. 2. The Domain Name and Registrar The disputed domain name <carvanaloan.com> (the “Domain Name”) 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 31, 2026. On February 2, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On February 2, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the 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 to Complainant on February 3, 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 February 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on February 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 25, 2026. Respondent sent an email to the Center on February 10, 2026. The Center appointed Robert A. Badgley as the sole panelist in this matter on March 5, 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. page 2 4. Factual Background According to the Complaint: “Complainant is a leading e-commerce platform for buying and selling used cars. Complainant is a Fortune 500 company that promotes and renders its online vehicle dealership services and online vehicle financing services throughout the United States under its well-known CARVANA® Marks and through its primary website, <carvana.com>, which hosts its e-commerce platform.” Complainant holds various trademark registrations of CARVANA, in word form or stylized. For instance, Complainant holds United States Reg. No. 4,328,785 for the word mark CARVANA, registered on April 30, 2013 in connection with “[o]nline dealership services featuring automobiles,” with a January 27, 2013 date of first use in commerce. In addition, Complainant holds United States Reg. No. 5,022,315 for the word mark CARVANA, registered on August 16, 2016 in connection with “[s]hipping, pickup, and delivery services for automobiles,” with a February 2013 date of first use in commerce. The Domain Name was registered on June 2, 2018. The Domain name resolves to a “Launching Soon!” page, which invites visitors to “contact us” and supply their names and email addresses to sign up for updates and promotions. There is no evidence in the record that the Domain Name has been put to any other use. As noted below, Respondent states that it registered the Domain Name in connection with a business venture – unrelated to automobiles – that never got off the ground. Respondent provided no contemporaneous evidence to support this contention. The email used by Respondent in this proceeding contains the term “carman.” 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. Complainant cites several prior UDRP decisions in which panels have recognized the CARVANA mark as inherently distinctive and well-known. The cited cases include: Carvana, LLC v. Domain Administrator, Fundacion Privacy Services LTD, WIPO Case No. D2020-1533 (finding that the CARVANA mark “is well- known in its industry with a history of use going back to 2013.”); Carvana, LLC v. Domain Admin, Privacy Protect, LLC (PrivacyProtect.org) / Ferel Demis, WIPO Case No. D2020-2032 (finding that Complainant’s CARVANA mark is “a coined term and as such is very distinctive”); Carvana, LLC v. Registration Private, Domains By Proxy, LLC / Carolina Rodrigues, Fundacion Comercio Electronico, WIPO Case No. D2020-2191 (finding that Complainant’s CARVANA mark is “used extensively and enjoy[s] considerable goodwill in the United States”); Carvana, LLC v. Domain Administrator, Fundacion Privacy Services Ltd, WIPO Case No. D2020-2348 (finding the CARVANA mark as “well-known in the United States” and of “well- known character”); Carvana, LLC v. Privacydotlink Customer 2659160 / Gary Sandor, WIPO Case No. DCO2020-0056 (noting that the CARVANA mark “has achieved a remarkable amount of fame”). Complainant asserts that, given the renown of its trademark and the fact that the Domain Name incorporates that mark and adds the word “loan,” which is one of the services Complainant provides to its customers, Respondent clearly was aware of the CARVANA mark when registering the Domain Name. B. Respondent Respondent’s entire substantive reply to Complainant’s allegations is as follows: page 3 “Respondent registered the domain name carvanaloan.com more than six years ago. At the time of registration, Respondent intended to develop a general-purpose lending business unrelated to vehicle sales, automotive retail, or Complainant’s business. Respondent did not intend to target, reference, or trade on Complainant’s trademark. Due to other professional and business commitments, the project was never launched. The disputed domain name has remained inactive and has never displayed advertising, redirected users, referenced Complainant, or generated revenue. Respondent has never offered the domain name.” 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Name: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) Respondent has no rights or legitimate interests in respect of the Domain Name; and (iii) the Domain Name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The Panel concludes that Complainant has rights in the trademark CARVANA through registration and use demonstrated in the record. The Panel also concludes that the Domain Name is confusingly similar to Complainant’s mark. The Domain Name incorporates Complainant’s mark in its entirety and adds the word “loan.” In the Panel’s view, the CARVANA mark is clearly recognizable within the Domain Name, notwithstanding the additional word. Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests Pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Name, among other circumstances, by showing any of the following elements: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Domain Name or a name corresponding to the 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 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 Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. The Panel concludes that Respondent lacks rights or legitimate interests in respect of the Domain Name. It is undisputed that Respondent has no relationship with Complainant and has not been given any permission to use Complainant’s mark in a Domain Name or otherwise. Respondent has come forward with a brief and unconvincing account of why he registered the Domain Name, which is comprised of a distinctive mark (“carvana” is not a dictionary term in English) that had been widely used for several years, plus the word “loan,” which was part of Complainant’s business activities. Respondent claims that his anticipated business venture would have had nothing to do with automobiles. The Panel finds this claim implausible. It Respondent had such innocuous motives vis-à-vis the Domain Name, it would have been very easy to provide some contemporaneous corroborating evidence. Finally, and this is a small point (but sometimes small points add up when the record is light on hard evidence), Respondent’s email address includes the term “carman.” page 4 In sum, the Panel finds Respondent’s account of its bona fides to be implausible and totally unsupported by record evidence. The Panel concludes that Complainant has established Policy paragraph 4(a)(ii). C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy provides that the following circumstances, “in particular but without limitation,” are evidence of the registration and use of the Domain Name in “bad faith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Domain Name registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of its documented out of pocket costs directly related to the Domain Name; or (ii) that Respondent has registered the Domain Name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) that by using the Domain Name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel concludes, on the record presented here, that Respondent has registered and used the Domain Name in bad faith. The Panel finds it more likely than not that Respondent had Complainant’s mark in mind when registering the Domain name. As discussed above, Complainant’s mark has been found to be well- known and inherently distinctive in several prior UDRP cases. The composition of the Domain Name – the CARVANA mark plus the word “loan” which corresponds to one of Complainant’s services – makes Respondent’s bare and unsupported explanation difficult to credit. Targeting appears far more likely on this record. The Panel simply cannot conceive of a good faith basis on which Respondent could have registered the Domain Name. With this in mind, the Panel notes that the non-use of the Domain Name would not necessarily prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 3.3. Complainant has established 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 Domain Name <carvanaloan.com> be transferred to Complainant. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: March 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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