Westmore · UDRP decision
WIPO · Case No. D2026-0428

Powellgillbert.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <powellgillbert.com>. It found the domain confusingly similar to the POWELL GILBERT mark because it merely added a second letter “l” to “Gilbert,” constituting an obvious misspelling or typosquatting. The Respondent did not rebut the Complainant’s prima facie showing of no rights or legitimate interests. Considering the mark’s longstanding use and Internet presence, the domain’s composition, the absence of any relationship between the Respondent’s name and the two surnames in the domain, and the passive holding of the domain, the Panel found registration and use in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-20
Panelist(s)
Campello Estebaranz, Reyes
Complainant
Powell Gilbert LLP
Respondent
Peter Pete, Muller
Disputed domain(s)
powellgillbert.com
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind powellgillbert.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 powellgillbert.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 powellgillbert.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a single repeated letter can support a straightforward typosquatting finding and how passive holding may satisfy the bad-faith element when the domain closely targets a longstanding mark, offers no apparent legitimate explanation, and remains unrebutted by the respondent.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-20
Panel
Campello Estebaranz, Reyes
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Powell Gilbert LLP v. Peter Pete, Muller Case No. D2026-0428 1. The Parties The Complainant is Powell Gilbert LLP, United Kingdom, internally represented. The Respondent is Peter Pete, Muller, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <powellgillbert.com> is registered with Name SRS AB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 3, 2026. On February 3, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 4, 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 (Protected Protected, Shield Whois) 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 Complainant filed an amendment to the Complaint on February 5, 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 10, 2026. In accordance with the Rules, paragraph 5, the due date for the Response was March 2, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 4, 2026. page 2 The Center appointed Reyes Campello Estebaranz 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. Factual Background The Complainant is a limited liability partnership providing legal services in the field of intellectual property under the brand POWELL GILBERT. The Complainant has operated in this field for nearly 20 years and is recognized as one of the leading European intellectual property litigation firms by several legal rankings and directories, including the Chambers & Partners directory. The Complainant owns various trademark registrations for its brand, including United Kingdom Trade Mark Registration No. UK00906212559 for POWELL GILBERT (word mark), registered on August 7, 2008, and European Union Trade Mark Registration No. 006212559 for POWELL GILBERT (word mark), registered on August 7, 2008 (collectively referred to hereinafter as the “POWELL GILBERT mark”). The Complainant also owns the domain name <powellgilbert.com>, registered on September 1, 2006, which resolves to its official corporate website. The disputed domain name was registered on June 9, 2025. It is currently inactive and resolves to a blank page. According to the evidence provided by the Complainant, the disputed domain name has remained inactive since its registration. 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. In particular, the Complainant submits that the disputed domain name is almost identical to its trademark, differing only by the addition of the letter “l” in the word “gilbert”, which constitutes a common or obvious misspelling of the POWELL GILBERT mark and amounts to a clear case of typosquatting. The trademark remains clearly recognizable within the disputed domain name, which would likely be pronounced identically to the mark. The Complainant further asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name. There is no evidence that the Respondent has made any preparations to use the disputed domain name in connection with a bona fide offering of goods or services or for a legitimate noncommercial or fair use. Nor is there any indication that the Respondent is commonly known by the disputed domain name. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The reputation of the POWELL GILBERT mark, the high degree of similarity between the mark and the disputed domain name, and the use of an obvious typographical variation indicate intentional targeting in bad faith. Although the Respondent’s precise motives remain unknown, the circumstances of the case suggest a potential intention to create confusion for illegitimate purposes. The fact that the disputed domain name is passively held does not prevent a finding of bad faith. It is implausible that the Respondent was unaware of the Complainant’s trademark when registering the disputed domain name. A Google search for the disputed domain name suggests the Complainant’s name as a “corrected” spelling of the search term and produces numerous results referring either to the Complainant itself or to individuals closely associated with it. In page 3 these circumstances, the Respondent must have been, at least, willfully blind to the Complainant’s rights in breach of its duty to make reasonable, good-faith efforts to avoid a trademark-abusive registration. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Complainant has submitted all relevant assertions under the Policy, and the dispute properly falls within its scope. The Panel has the authority to decide the dispute by examining the three elements set forth in paragraph 4(a) of the Policy, taking into account all relevant evidence, annexed materials, and submissions. The Panel may also conduct limited independent research pursuant to its general powers, as provided, inter alia, in paragraph 10 of the Rules. 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, namely the POWELL GILBERT mark. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name, with the addition of a second letter “l” in the term “Gilbert”. The Panel finds that this constitutes a common or obvious misspelling of the term and of the mark. A domain name that consists of a variation of a trademark — typically involving a common, obvious, or intentional misspelling, a practice referred to as typosquatting — is considered by panels to be confusingly similar to the relevant mark for the purposes of the first element of the Policy. The Panel finds that the mark remains clearly recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy (see WIPO Overview 3.1, sections 1.7 and 1.9). 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. 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. page 4 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 disputed domain name incorporates the names or surnames of the Complainant (“Powell” and “Gilbert” albeit with an extra “l”) that share no similarities with the Respondent’s name revealed by the Registrar verification. The Panel has further searched through the Global Brand Database, finding no trademark rights over the terms included in the disputed domain name owned by the Respondent. 1 The Panel further notes that the disputed domain name is inactive, resolving to a blank page, and nothing in the record suggests that the Respondent has started any demonstrable preparations for its use in connection with any bona fide offering of goods or services or with any fair legitimate use. Therefore, nothing in the record suggests that the Respondent may have any rights or legitimate interests in respect of the disputed domain name, and 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. In the present case, the Panel notes the Complainant’s continuous use of its trademark for over 16 years and its extensive presence on the Internet. The Panel has further corroborated that searches for the terms POWELL GILBERT return results referring to the Complainant’s law firm and its trademark. The Panel further notes the composition of the disputed domain name, which incorporates the Complainant’s trademark with an obvious or common misspelling of the mark, namely the addition of an extra letter “l” in the term “Gilbert”. This minor alteration does not affect the pronunciation of the mark and may easily go unnoticed by Internet users. Panels have consistently found that typosquatting constitutes evidence of bad faith. See, inter alia, Hyperion Materials & Technologies AB v. Osama Osama, WIPO Case No. D2020-0251; and Redbox Automated Retail, LLC d/b/a Redbox v. Milen Radumilo, WIPO Case No. D2019-1600. The Panel further finds that the use of two surnames unrelated to the Respondent, arranged in the same order as the Complainant’s trademark, strongly suggests knowledge of and targeting of the Complainant and its trademark. Accordingly, the Panel finds that, on the balance of probabilities, the circumstances of this case indicate that the Respondent registered the disputed domain name with the Complainant and its trademark in mind in bad faith. With respect to the use of the disputed domain name, panels have found that the non-use of a domain name (including a blank or “coming soon” page) does not, in itself, prevent a finding of bad faith under the doctrine of passive holding. On the contrary, when assessing the totality of the circumstances in a given case, panels have found that the registration and non-use or passive holding of a domain name may still constitute bad faith for the purposes of the Policy (WIPO Overview 3.1, section 3.3). 1 Noting in particular the general powers of a panel articulated, inter alia, in paragraphs 10 and 12 of the UDRP Rules, it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision. WIPO Overview 3.1, section 4.8. page 5 Having reviewed the available record, the Panel notes the distinctiveness and longstanding use of the Complainant’s trademark for nearly 20 years, its significant presence on the Internet, and the composition of the disputed domain name. In these circumstances, the Panel finds that the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Accordingly, the Panel finds that the Complainant has established the third element of the Policy. 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 <powellgillbert.com> be transferred to the Complainant. /Reyes Campello Estebaranz/ Reyes Campello Estebaranz Sole Panelist Date: March 20, 2026

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

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