Westmore · UDRP decision
WIPO · Case No. D2026-0548

Littlesedfarm.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <littlesedfarm.com>. It found the domain confusingly similar to the Complainant’s LITTLE SEED FARM mark because it omitted one letter “e,” potentially constituting typosquatting. The Respondent lacked rights or legitimate interests and used the domain for a website reproducing the Complainant’s logo, design, color scheme, and pictures. That passing-off use also demonstrated targeting and bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-27
Panelist(s)
Lee, Kathryn
Complainant
Little Seed Farm LLC
Respondent
Maci Woyat
Counsel
Bass, Berry · Sims PLC
Disputed domain(s)
littlesedfarm.com
Citation weightCited by 2 later decisions
Domain history UDRP Intelligence

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

The case combines a straightforward one-letter typo with website content that closely reproduced the Complainant’s official branding. The Panel’s conclusions did not depend on proving counterfeit sales or non-delivery; the demonstrated passing-off presentation, together with the typographical domain variation and lack of rebuttal, was sufficient to establish the second and third elements.

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
2026-03-27
Panel
Lee, Kathryn
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Little Seed Farm LLC v. Maci Woyat Case No. D2026-0548 1. The Parties The Complainant is Little Seed Farm LLC, United States of America (“United States”), represented by Bass, Berry & Sims PLC, United States. The Respondent is Maci Woyat, United States. 2. The Domain Name and Registrar The disputed domain name <littlesedfarm.com> is registered with Dominet (HK) Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 10, 2026. On February 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 11, 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 Complainant on February 11, 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 16, 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 the Respondent of the Complaint, and the proceedings commenced on February 19, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 12, 2026. page 2 The Center appointed Kathryn Lee 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 Complainant, based in Nashville, Tennessee, United States, produces premium organic soap and skincare products crafted with goat’s milk and organic herbs sourced from its family farm. The Complainant has used the LITTLE SEED FARM mark in business since June 1, 2011 and owns a trademark registration for the mark in the United States: Trademark Registration Number 5654367 registered on January 15, 2019. The Complainant also owns the domain name <littleseedfarm.com> which it has used for its official website since its registration on April 29, 2011. Based on information from the Registrar, the Respondent is an individual or entity with an address in Washington D.C., United States. The disputed domain name was registered on November 11, 2025, and resolves to a website using the LITTLE SEED FARM mark and purportedly offering Little Seed Farm goods for sale. 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. Notably, the Complainant contends that the disputed domain name is confusingly similar to the LITTLE SEED FARM mark in which it has rights. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name and confirms that it has not authorized or licensed rights to the Respondent in any respect. The Complainant contends that the Respondent uses the disputed domain name for website using the Complainant’s LITTLE SEED FARM mark and offering the Complainant’s goods while impersonating the Complainant. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The Complainant contends that the use of the disputed domain name for imitating the Complainant’s website misleads the public, disrupts the Complainant’s business operations, and damages the Complainant’s reputation, and that based on the use, it is evidence that the disputed domain name was registered in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 page 3 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. WIPO Overview 3.1, section 1.2.1. The Panel finds the mark is recognizable within the disputed domain name since the disputed domain name is identical to the disputed domain name except with a missing letter “e” in the middle of the mark. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. In addition, this small difference could represent typosquatting. Previous UDRP panels have concluded that a domain name that consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered confusingly similar to the relevant trademark for the purposes of the first element. See WIPO Overview 3.1, section 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. 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. In addition, the Respondent’s website displayed the Complainant’s logo, design, color scheme, and pictures from the Complainant’s website, and therefore, has the overall look and feel of the Complainant’s own official website at “www.littleseedfarm.com”. Panels have held that the use of a domain name for illegal activity – here, claimed passing off – 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. In the present case, the Panel notes that the Respondent used the disputed domain name for a website with similar look and feel to the Complainant’s official website, prominently displaying the Complainant’s marks page 4 and purportedly offering the Complainant’s products for sale. The authenticity of the goods offered for sale, as well as whether the ordered goods were even delivered cannot be verified, but at the very least, the Respondent passed it off as the Complainant based on the manner in which the disputed domain name was used. Panels have held that the use of a domain name for illegal activity – here, claimed passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. And based on the use of the disputed domain name, it is very likely that the Respondent targeted the Complainant and its mark when registering the disputed domain name. 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 name <littlesedfarm.com> be transferred to the Complainant. /Kathryn Lee/ Kathryn Lee Sole Panelist Date: March 27, 2026

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

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