Westmore · UDRP DecisionLennnar.com
The Panel ordered transfer of <lennnar.com> to Lennar Corporation. It found the domain confusingly similar to the LENNAR mark because it merely adds an extra letter “n,” constituting an obvious misspelling. The Respondent did not rebut the Complainant’s prima facie case concerning rights or legitimate interests. The Panel found that the typosquatted domain falsely suggested affiliation and had been used first for a purported security check preceding an automatic software download and later for PPC links offering services similar to the Complainant’s. The domain’s composition, the Complainant’s prior rights, the website uses, and, in the circumstances, use of a privacy service supported the finding of bad-faith registration and use.
The timeline behind lennnar.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 lennnar.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a single repeated letter can support a straightforward typosquatting finding where the trademark remains recognizable. It is also useful for distinguishing between imperfect evidence of alleged malware and independently observed PPC use: although the submitted exhibit did not prove the software’s nature, the Panel found likely deceptive download activity and separately relied on contemporaneous PPC links related to the Complainant’s services. The decision further shows that privacy-service use was considered only in combination with the broader evidence of targeting and abusive use.
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 Lennar Pacific Properties Management, LLC and Lennar Corporation v. Domain Administrator, Fundacion Privacy Services LTD Case No. D2026-0776 1. The Parties The Complainants are Lennar Pacific Properties Management, LLC, and Lennar Corporation, United States of America (the “US”), represented by Slates Harwell Campbell, LLP, US. The Respondent is Domain Administrator, Fundacion Privacy Services LTD, Panama. 2. The Domain Name and Registrar The disputed domain name <lennnar.com> (the “Disputed Domain Name”) is registered with Media Elite Holdings Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 24, 2026. On February 24, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On February 24, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 20, 2026. The Center appointed Monica Novac as the sole panelist in this matter on April 1, 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. page 2 4. Factual Background The Complainants are Lennar Pacific Properties Management, LLC (“LPPM”) and Lennar Corporation (“Lennar”), both Delaware entities based in Miami, Florida, US. LPPM is the owner of the below mentioned US federal trademark registrations for LENNAR. Lennar is a related company and the authorized licensee of said LENNAR marks, as well as the owner and operator of the domain name <lennar.com> (registered on September 5, 1996), which resolves to the Complainants’ official website. LPPM and Lennar will hereinafter collectively be referred to as the “Complainant”. The Complainant has offered real estate management, brokerage, development, construction, mortgage and financial services under the LENNAR marks since at least as early as 1973. Furthermore, Lennar has been a homebuilder since 1954 and it develops, builds and sells homes in 21 states in the US. LPPM holds the following US federal trademark registrations for LENNAR: - US Trademark Registration No. 3,108,401 LENNAR, registered on June 27, 2006, in classes 35, 36, and 37; and - US Trademark Registration No. 3,477,143 LENNAR, registered on July 29, 2008, in classes 36 and 37. The Respondent is reportedly located in Panama. The Respondent registered the Disputed Domain Name on January 14, 2019. Via the Complaint, the Complainant claims that the Disputed Domain Name resolves to a webpage displaying “a message to download potentially malicious software”, and/or redirects to “a page to download potentially malicious software” and/or to “a virus scam site”. The Complainant files Annex 6 in support of the above allegations, however the Panel notes that this only shows that the Disputed Domain Name resolves to a “Security Check” page which supposedly precedes an automatic download of a software, without any further indications on the nature of such software. On the date of rendering this Decision, when accessed by the Panel, the Disputed Domain Name resolves to a website displaying pay-per-click (“PPC”) links that offer similar services to those promoted by the Complainants. On February 9, 2026, the Complainant’s lawyers sent a cease-and-desist letter (via e-mail) to the Registrar, demanding, among others, that the Respondent ceases the infringing acts and transfers the Disputed Domain Name to the Complainant. No reply was received from the Respondent. 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 Complainant’s LENNAR trademark; - the Respondent has no rights or legitimate interests in the Disputed Domain Name; and - the Disputed Domain Name has been registered and is being used in bad faith. The Complainant requested that the Disputed Domain Name be transferred to Lennar. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Preliminary Issue: Consolidation of the Complainants The Complaint has been filed by two Complainants, namely LPPM and Lennar. The Panel notes that the Complainants are affiliate entities since LPPM is the owner of the US federal trademark registrations for LENNAR, while Lennar is a related company and the authorized licensee of the LENNAR marks. Moreover, Lennar is the owner and operator of the domain name <lennar.com> which resolves to the Complainants’ official website. The Panel is of the opinion that the Complainants have common interests in this case and the Respondent’s conduct has affected both Complainants in a similar manner. In view of the circumstances of the case, the Panel considers that the consolidation of the Complainants is procedurally efficient, fair and equitable, and it would not be detrimental to the Respondent in any way. For all the above reasons, consolidation is ordered. B. 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. WIPO Overview 3.1, section 1.2.1. The Panel finds that the Complainant’s LENNAR mark is recognizable within the Disputed Domain Name. The only difference between the Complainant’s trademark and the Disputed Domain Name is the addition of the letter “n” in the Disputed Domain Name, which is an obvious misspelling of the Complainant's mark. UDRP panels held that a domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.1, section 1.9. According to the WIPO Overview 3.1, section 1.11.1, the generic Top-Level Domain “.com” in the Disputed Domain Name is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. The Panel finds the first element of the Policy has been established. C. 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 page 4 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. It is accepted by the Panel that the Respondent has not acquired any trademark or service mark rights over the designation LENNAR. Moreover, there is no evidence that the Respondent is commonly known by the Disputed Domain Name. The Disputed Domain Name is a typosquatted version of the Complainant’s LENNAR trademark which reflects the Respondent’s ultimate intent to confuse Internet users into believing that the Disputed Domain Name is operated by or associated with the Complainant. In this sense, it has been established that “a respondent’s use of a domain name will not be considered ‘fair’ if it falsely suggests affiliation with the trademark owner; the correlation between a domain name and the complainant’s mark is often the central starting point to this inquiry”. WIPO Overview 3.1, section 2.5. As per the Complainant’s allegations, the Disputed Domain Name resolves to a webpage displaying “a message to download potentially malicious software”. The evidence submitted by the Complainant shows that the website displayed the following statement: “By clicking the button above, you’ll go through a standard security check to prove that you are a human, after which you will be able to continue to automatically download the software”. Noting that the Disputed Domain Name consists of a misspelled version of the Complainant’s trademark, the Panel finds it more likely than not that the Respondent intended to confuse Internet users in order to lure them into downloading likely malicious software. The use of a domain name for illegitimate activity, such as here, claimed distribution of malware and/or a virus scam site, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel notes that on the date of rendering this Decision, the Disputed Domain Name resolves to a website displaying PPC links that offer similar services to those promoted by the Complainant. Panels have found that “the use of a domain name to host a parked page comprising PPC links does not represent a bona fide offering where such links compete with or capitalize on the reputation and goodwill of the complainant’s mark or otherwise mislead Internet users”. WIPO Overview 3.1, section 2.9. The Respondent did not respond to the Complainant’s contentions, thus the Respondent did not present any evidence for supporting any rights or legitimate interests in the Disputed Domain Name. The Panel finds the second element of the Policy has been established. D. 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 notes that the Complainant registered and used its LENNAR trademark before the Respondent registered the Disputed Domain Name. In view of the long-lasting presence of the Complainant, as well as the composition of the Disputed Domain Name, it is unlikely that the Respondent was not aware of the Complainant’s trademark and business when registering the Disputed Domain Name. The Panel considers that the Respondent’s registration of the Disputed Domain Name which is a typosquatted variation of the Complainant’s trademark signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainant and it is a clear proof of the Respondent’s bad faith. Moreover, in view of the nature of the Disputed Domain Name, the Panel considers that the Respondent targeted the Complainant when registering the Disputed Domain Name. Further to the Complainant’s allegations in respect to the use of the Disputed Domain Name as of the date of filing the Complaint (as detailed above), the Panel contends that such use for illegitimate activity, such as here, claimed distribution of malware and/or a virus scam site, constitutes bad faith. WIPO Overview 3.1, section 3.4. As for the PPC links displayed on the website to which the Disputed Domain Name resolves as of the date of this Decision, although these might be automatically generated, this does not prevent a finding of bad faith under the Policy. As it is stated in WIPO Overview 3.1, section 3.5, “[p]articularly with respect to ‘automatically’ generated pay-per-click links or website content [...], panels have held that a respondent cannot disclaim responsibility for content appearing on the website associated with its domain name (nor would such links ipso facto vest the respondent with rights or legitimate interests). The fact that such links or content may be generated by a third party such as a registrar or auction platform (or their affiliate), or the fact that the respondent itself may not have directly profited, is a relevant consideration but would not by itself prevent a finding of bad faith”. The Panel also notes the use of the name of a privacy registration service company as the underlining registrant for the Disputed Domain Name, in an extra effort to hide the Respondent’s identity. As per WIPO Overview 3.1, section 3.6, there are recognized legitimate uses of privacy and proxy registration services, however the Panel is of the opinion that in view of all circumstances of this case, the Respondent’s use of privacy service constitutes further evidence of bad faith registration and use of 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 <lennnar.com> be transferred to Lennar Corporation. /Monica Novac/ Monica Novac Sole Panelist Date: April 15, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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