Westmore · UDRP decision
WIPO · Case No. D2026-0487

Lennardurham.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <lennardurham.com> to Lennar Corporation. It found the domain confusingly similar to the LENNAR mark because it reproduced the mark in full and merely added the geographic term “durham”. The Respondent had no demonstrated rights or legitimate interests, and the composition of the domain, the reputation of the mark, the Complainant’s operations in the Raleigh/Durham area, the passive holding of the domain, and the absence of a Response supported a finding of registration and use in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-07
Panelist(s)
Moi, Sok Ling
Complainant
Lennar Corporation Lennar Pacific Properties Management, LLC
Respondent
yin dong liang
Disputed domain(s)
lennardurham.com
Domain history UDRP Intelligence

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

The decision illustrates how a domain combining a trademark with a geographic term can support both confusing similarity and an inference of targeting when the geographic term corresponds to an area where the trademark owner operates. It also shows that an inactive domain may satisfy the bad-faith element where the overall record—including the mark’s reputation, the domain’s composition, and the absence of any respondent explanation—supports passive holding in bad faith.

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
2026-04-07
Panel
Moi, Sok Ling
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Lennar Pacific Properties Management, LLC, Lennar Corporation v. yin dong liang Case No. D2026-0487 1. The Parties The Complainants are Lennar Pacific Properties Management, LLC, United States of America (“United States” or “US”) (the “First Complainant”), and Lennar Corporation, United States (the “Second Complainant”), represented by Slates Harwell Campbell, LLP, United States. The Respondent is yin dong liang, China. 2. The Domain Name and Registrar The disputed domain name <lennardurham.com> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on February 4, 2026. On February 5, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 6, 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 the Complainants on February 8, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainants to submit an amendment to the Complaint. The Complainants filed an amendment to the Complaint in English on February 9, 2026. On February 8, 2026, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On February 9, 2026, the Complainants confirmed their request that English be the language of the proceeding. The Respondent did not submit any comment on the Complainants’ submission. 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 in Chinese and English of the Complaint, and the proceedings commenced on February 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 9, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 15, 2026. The Center appointed Sok Ling MOI as the sole panelist in this matter on March 19, 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 Complainants have been one of the US leading homebuilders since 1954 and develop, build, and sell homes in 21 states in the United States. The Complainants have offered real estate management, brokerage, development, construction, mortgage and financial services under the LENNAR brand since at least as early as 1973. The Complainants also have an operational division of their business in the Raleigh/Durham area of North Carolina. The Complainants own and operate a website at “www.lennar.com” to provide information for its business, having registered the domain name on September 4, 1996. The Complainants own the following trade mark registrations for LENNAR in the United States: ⁃ US Registration No. 3,108,401 for the word mark LENNAR in Classes 35, 36, and 37, registered on June 27, 2006; and ⁃ US Registration No. 3,477,143 for the word mark LENNAR in Classes 36 and 37, registered on July 29, 2008. The disputed domain name was registered on December 21, 2025, long after the Complainants have used and registered their LENNAR trade marks. The disputed domain name does not resolve to any active website and is being passively held. 5. Parties’ Contentions A. Complainants The Complainants contend that they have satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainants contend that by combining “lennar” with “durham”, the disputed domain name seeks to mislead consumers that it is authorised to offer services under the LENNAR brand in the Durham area of North Carolina. B. Respondent The Respondent did not reply to the Complainants’ contentions. 6. Discussion and Findings 6.1. Procedural Issues A. Consolidation of Multiple Complainants The Complaint was filed by two Complainants against a single respondent. Both Complainants form part of the same corporate group. The First Complainant is the owner of trade mark registrations and also owns and operates the website “www.lennar.com”, while the Second Complainant is the authorized licensee of the LENNAR trade marks. The Panel finds that the Complainants have a common legal and commercial interest in the LENNAR trade marks and hence a common grievance against the Respondent’s registration and use of the disputed domain name, such that it is equitable and procedurally efficient to permit the consolidation of their complaints. Therefore, the Complainants are referred to collectively as “the Complainant” below except as otherwise indicated. See section 4.11.1 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”). B. Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that the “lennar” and “durham” are not Chinese words or names, and the Respondent is therefore presumed to understand English. The Respondent did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview 3.1, section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 6.2. Substantive Issues Paragraph 4(a) of the Policy directs that a complainant must prove each of the following three elements to obtain an order for the disputed domain name to be transferred: (i) the disputed domain name registered by the respondent is identical or confusingly similar to a trade mark or service mark in which the complainant has rights; (ii) the respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) 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. 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. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name. Although the addition of other terms may bear on assessment of the second and third elements, the Panel finds the addition of such term (particularly here, “durham”, a geographical location) does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 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 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. The Complainant has confirmed that the Respondent is not in any way affiliated with the Complainant or otherwise authorized or licensed to use the LENNAR trade mark or to seek registration of any domain name incorporating the LENNAR trade mark. The Respondent appears to be an individual by the name of “yin dong liang”. There is no evidence suggesting that the Respondent is commonly known by the name “Lennar” or “Durham” or “Lenna Durham”, or has any rights in the term “Lennar” or “Durham” or “Lennar Durham”. There is also no evidence suggesting that the Respondent is using the disputed domain name for a bona fide offering of goods or services, or for a legitimate noncommercial or fair use. Instead, the disputed domain name does not resolve to any active website but is being passively held. 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 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. In the present case, the Panel notes that the disputed domain name comprises of the Complainant’s LENNAR trade mark and the geographical term “Durham”. This has the potential of causing confusion to Internet users who may be misled into thinking that the disputed domain name belongs to the Complainant to target its consumers based in the Durham, North Carolina region of the United States in which the Complainant operates its business. This suggests that it is more likely than not that the Respondent registered the disputed domain name in bad faith targeting of the Complainant and/or its trade mark rights. Panels have found that the non-use of a domain name 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 reputation of the Complainant’s LENNAR trade mark, the composition of the disputed domain name, as well as the lack of the Response, 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 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 <lennardurham.com> be transferred to the Second Complainant, Lennar Corporation. /Sok Ling MOI/ Sok Ling MOI Sole Panelist Date: April 7, 2026

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

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