Westmore · UDRP DecisionFootball-greatclips.com, Greatclipsfootball.net
The Panel ordered the transfer of <football-greatclips.com> and <greatclipsfootball.net>. It found the GREAT CLIPS mark recognizable in both domain names, concluded that the Respondent had not rebutted the Complainant’s prima facie showing of no rights or legitimate interests, and found bad-faith registration and use based on the Respondent’s knowledge of the longstanding mark and use of the domains for a website impersonating the Complainant’s football coupon promotion page.
The timeline behind football-greatclips.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 football-greatclips.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The case illustrates how combining a trademark with a term tied to the trademark owner’s actual promotion can reinforce evidence of targeting. It also shows that an impersonating website may establish lack of legitimate interests and bad faith even where the published decision does not document completed phishing. Procedurally, the decision demonstrates a panel’s case-specific assessment of notice and fairness where a respondent is located in a conflict-affected jurisdiction.
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 Great Clips, Inc v. Sergach Irina Case No. D2026-0503 1. The Parties The Complainant is Great Clips, Inc., United States of America (“United States”), represented by Greenberg Traurig, LLP, United States. The Respondent is Sergach Irina, Ukraine. 2. The Domain Names and Registrar The disputed domain names <football-greatclips.com> and <greatclipsfootball.net> are registered with Nicenic International Group Co., Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 5, 2026. On February 6, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On February 7, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant February 9, 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 amended Complaint on February 13, 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 Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceeding 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 10, 2026. page 2 The Center appointed Sebastian M.W. Hughes 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 A. Complainant The Complainant is a United States company founded in 1982, and a leading provider of hair salon related goods and services under the trade mark GREAT CLIPS (the “Trade Mark”), with more than 4,400 hair salons in the United States and Canada. The Complainant also promotes its goods and services online via its website at “www.greatclips.com”, and on social media; and offers football related promotional coupons on its website. The Complainant is the owner of several registrations in the United States for the Trade Mark, the earliest, registration No. 1,341,594, with a registration date of June 11, 1985. B. Respondent The Respondent is an individual located in Ukraine. C. The Disputed Domain Names The disputed domain names <football-greatclips.com> and <greatclipsfootball.net> were registered on February 3, 2026 and January 20, 2026, respectively. D. Use of the Disputed Domain Names The disputed domain names have been used in respect of the same English language website, impersonating the football coupon promotion page from the Complainant’s website (the “Website”). 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 names. Notably, the Complainant contends that the Respondent has used the disputed domain name illegitimately in respect of the Websites, in order to impersonate the Complainant, and likely engage in phishing or other unlawful conduct. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 6.1. Procedural Issue – Location of the Respondent Under paragraph 10 of the Rules, the Panel is required to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case, and also that the administrative proceeding takes place with due expedition. The location of the Respondent disclosed by the Registrar appears to be in Ukraine, which is subject to an international conflict at the date of this Decision that may impact case notification. It is therefore appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceeding should continue. Having considered all the circumstances of the case, the Panel is of the view that it should. The record shows that the Notification of Complaint email was sent to the Respondent’s email address disclosed by the Registrar; and the Center’s postal notification was sent to the Respondent’s mailing address disclosed by the Registrar by registered mail. The Respondent thus appears to have received at least the electronic notice of the Complaint and would have been able to formulate and file a Response in the administrative proceeding it wished to do so. Furthermore, the disputed domain names were registered in 2026, during the international conflict, suggesting that the Respondent is able to access the Internet and maintain control of the disputed domain names, and reaffirms that the Respondent most likely than not received at least electronic notice of this proceeding. The Panel therefore concludes that the Respondent has been given a fair opportunity to present her case, and so that the administrative proceeding take place with due expedition, the Panel will proceed to a decision accordingly. 6.2. Substantive Issues 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 trade mark and the disputed domain names. 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 trade mark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds the mark is recognisable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here, “football”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain names and the 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 the Respondent may demonstrate rights or legitimate interests in a disputed domain name. page 4 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 names. 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 names such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name for illegal activity (here, claimed as applicable to this case: phishing 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. The Complainant has rights in the Trade Mark, established long before the registration of the disputed domain name. The Panel finds that the Respondent knew or should have known of the Complainant’s Trade Mark when registering the disputed domain name. The Respondent’s use of the disputed domain name constitutes bad faith under paragraph 4(b)(iv) of the Policy. Panels have held that the use of a domain name for illegal activity (here, claimed as applicable to this case: phishing or other types of fraud) constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 names <football-greatclips.com> and <greatclipsfootball.net> be transferred to the Complainant. /Sebastian M.W. Hughes/ Sebastian M.W. Hughes Sole Panelist Date: March 27, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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