Westmore · UDRP decision
WIPO · Case No. D2026-0414

Chief-mounts.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <chief-mounts.com>. It found the domain confusingly similar to the Complainant’s registered CHIEF mark because it reproduced the mark with the descriptive word “mounts.” The Respondent lacked rights or legitimate interests because the Complainant had not authorized the use, the website targeted the Complainant, and the Respondent provided no relevant rebuttal. Bad faith was established from the deliberate targeting of the CHIEF mark, use of content similar to the Complainant’s website, references to related mounting products, commercial affiliate links, and evidence of potential phishing. Removal of the content and subsequent passive holding did not prevent a finding of bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-23
Panelist(s)
Weston, Nicholas
Complainant
Legrand AV, Inc.
Respondent
Ivanov Roman
Disputed domain(s)
chief-mounts.com
Domain history UDRP Intelligence

The timeline behind chief-mounts.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 chief-mounts.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 granted. Panel ordered transfer of chief-mounts.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a domain combining a trademark with a term describing the trademark owner’s products can support findings across all three UDRP elements when accompanied by a website resembling the owner’s site. It also shows that removing challenged content after notice does not erase prior use or prevent a bad-faith finding under passive-holding principles.

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
Transfer
Decision date
2026-03-23
Panel
Weston, Nicholas
Full decision
13 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Legrand AV, Inc. v. Ivanov Roman Case No. D2026-0414 1. The Parties The Complainant is Legrand AV, Inc., United States of America (“United States”), represented by DeWitt LLP, United States. The Respondent is Ivanov Roman, Ukraine. 2. The Domain Name and Registrar The disputed domain name <chief-mounts.com> (the “Disputed Domain Name”) is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 2, 2026. On February 2, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On February 3, 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, Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 4, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Respondent sent an email communication to the Center on February 5, 2026. The Complainant filed an amendment to the Complaint on February 7, 2026. The Center verified that the Complaint together with the amendment to the 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 11, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 3, 2026. The Center commenced the panel appointment process on March 6, 2026. page 2 The Center appointed Nicholas Weston as the sole panelist in this matter on March 13, 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. Procedural Issue Paragraph 10(b) of the Rules requires the Panel to ensure that the parties are treated with equality and that each party is given a fair opportunity to present its case. Paragraph 10(c) requires that the administrative proceeding takes place with due expedition. The Respondent’s mailing address is in Ukraine, which is subject to an international conflict at the date of this Decision. These circumstances may impact case notification and it is appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceeding should continue. The Panel is of the view that the proceeding should continue, having considered all the circumstances of the case. The Panel notes that the Center has used the Respondent’s email address as registered with the Registrar for the purposes of notifying the Complaint. There is no evidence that the case notification email to this email address was not successfully delivered – on the contrary, the Center received a communication from this email address. 5. Factual Background The Complainant is a Euronext listed industrial group that sells its products in more than 180 countries generating EUR 8.6 billion of revenue in 2024. The Complainant cites its registrations for the trademark CHIEF and variations of it in several countries. These include United States Registered trademark No. 2,834,438 for the word CHIEF in class 9 registered on April 20, 2004, for “mechanical mounting systems, namely, mounting racks, stands, tables and carts for liquid crystal displays, [plasma displays, cathode ray tube displays, projectors, video cameras, video cassette players, video cassette recorders,] and dvd players” and United States Registered trademark No. 7,367,206 for the word CHIEF registered on April 23, 2024, in class 9 for “wall and ceiling mounts, mounting racks, stands, tables, and wheeled carts, all specially adapted for av and computer equipment, namely, flat panel display screens, direct view led displays, media players, audio devices, and computer networking equipment.” The Complainant displays information about its CHIEF branded products on the Internet at <legrandav.com/products/chief>. The Disputed Domain Name was registered on June 28, 2024. It was used to host an unauthorized version of the Complainant’s official website referencing the Complainant’s trademark and products, and currently does not resolve to an active website. 6. 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 cites its trademark registrations in a number of jurisdictions for the mark CHIEF, as prima facie evidence of ownership. page 3 The Complainant submits that its rights in the mark CHIEF predate the Respondent’s registration of the Disputed Domain Name. It submits that the Disputed Domain Name is confusingly similar to its trademark, because the Disputed Domain Name is comprised of the CHIEF trademark and that the addition of the hyphen and the word “mounts” and the generic Top-Level Domain (gTLD) “.com” is not sufficient to avoid the confusing similarity. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because “Complainant has never authorized Respondent to use its CHIEF mark” and “Respondent is not commonly known by any consumer under the domain name ‘chief-mounts.com’ or under the name ‘Chief Mounts’”, and infers that none of the circumstances set out in paragraph 4(c) of the Policy apply. Finally, the Complainant alleges that the registration and use of the Disputed Domain Name was, and currently is, in bad faith, contrary to the Policy and the Rules having regard to evidence that points to knowledge of the Complainant and its trademarks. On the issue of registration in bad faith the Complainant submits that its trademark “had been used in commerce continuously since December, 1977. Hence, Complainant’s trademark’s rights significantly pre-date Respondent’s registration of the [Disputed Domain Name]”, presumably inferring that the mark is distinctive or widely recognized for mechanical mounting systems. On the issue of bad faith use, the Complainant submits that one of the Respondent website pages contains a webform intended to harvest private information, and that the “Respondent is diverting traffic to an Amazon search page which displays mounts from Complainant’s competitors as well as Complainant’s CHIEF brand mounts”, and that this amounts to use in bad faith. B. Respondent The Respondent did not substantively reply to the Complainant’s contentions but sent a communication stating “[h]ello, removed domain content to solve the problem”. 7. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant has the burden of proving the following: (i) that the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) that the 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 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. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Panel finds that the Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. The requirements of the first element for purposes of the Policy may be satisfied by a trademark registered in any country. WIPO Overview 3.1, section 1.2.1. The Complainant has produced sufficient evidence to demonstrate that it has registered trademark rights in the mark CHIEF. Turning to whether the Disputed Domain Name is identical or confusingly similar to the CHIEF trademark, the Panel observes that the Disputed Domain Name is comprised of: (a) an exact reproduction of the Complainant’s trademark CHIEF; (b) followed by a hyphen and the word “mounts”; (c) followed by the gTLD “.com”. page 4 It is well established that the gTLD used as part of a domain name is generally disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11. The relevant comparison to be made is with the second-level portion of the Disputed Domain Name, specifically: “chief-mounts”. The Panel finds the mark is recognizable within the Disputed Domain Name. Accordingly, the Panel finds that the Disputed Domain Name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 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 Disputed 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. The Panel notes that the Complainant has not licensed or otherwise authorized the Respondent to use its trademark and that there is no relationship between the Complainant and the Respondent, let alone any accurate or prominent disclosure of that relationship, or absence of such, on its website. The use of the Complainant’s trademark and similarity of the Parties’ respective products displayed on the Respondent’s website suggests that the Respondent has targeted the Complainant. The Panel finds that the Respondent’s activities do not represent a bona fide offering of goods or services, or a legitimate noncommercial or fair use, given the substantial reputation and goodwill of the Complainant’s mark or capacity to otherwise mislead Internet users. Panels have held that the use of a domain name for illegitimate activity such as phishing, impersonation, passing off, or other types of fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has 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. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may 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. page 5 In the present case, the Panel finds that the evidence in the case shows the Respondent registered and has used the Disputed Domain Name in bad faith. On the issue of registration, taking into account the composition and subsequent use of the Disputed Domain Name, the Panel is satisfied that the Respondent deliberately targeted the Complainant’s trademark CHIEF when it registered the Disputed Domain Name. This Panel finds that there is no reason for the Respondent to have registered the Disputed Domain Name other than to trade off the reputation and goodwill of the Complainant’s trademark. WIPO Overview 3.1, section 3.1.4. Further, a gap of several years between registration of a complainant’s trademark and respondent’s registration of a disputed domain name (containing the trademark) may indicate bad faith registration. In this case, the Respondent registered the Disputed Domain Name 20 years after the Complainant established registered trademark rights in the CHIEF mark. The Respondent has not come forward to rebut the Complainant’s allegations or to offer an alternative explanation. On the issue of use, the Complainant’s evidence is that the Disputed Domain Name was used to host a website that displays content similar to that of the Complainant’s legitimate website, displaying the Complainant’s actual trademark and making reference to wall mounting products similar to those displayed by the Complainant on its own webpage, as well as commercial affiliate links to third party websites. There is also evidence of potential phishing in the form of a webpage that displayed a “Contact us” form with fields including “Name”, “Email”, and “Phone” form. Panels have held that the use of a domain name for unlawful activity, here, alleged impersonation or passing off, and potential phishing, constitutes bad faith. WIPO Overview 3.1, section 3.4. The Complainant supplied evidence of the misleading website. In the circumstances, having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under paragraph 4(b)(iv) of the Policy. The Respondent claimed to have removed its website content and the Disputed Domain Name does not currently resolve to an active website. Panels have found that the non-use of a domain name would not 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. Factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s taking active steps to conceal its identity, or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent’s registration agreement). Taking the above factors into consideration, panels assess the overall plausibility of any (claimed) good faith use to which the domain name may be put in light of the composition of the domain name in relation to the relevant mark, such that, the more arbitrary or distinctive a mark the less plausible a claimed non-infringing good faith use is likely to be, and vice versa. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the Complainant’s distinctive CHIEF trademark, the composition of the Disputed Domain Name, and the Respondent’s failure to provide any evidence of actual or contemplated good-faith use and finds that in the circumstances of this case the current passive holding of the Disputed Domain Name does not prevent a finding of bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 6 8. 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 <chief-mounts.com> be transferred to the Complaint. /Nicholas Weston/ Nicholas Weston Sole Panelist Date: March 23, 2026

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

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