Westmore · UDRP DecisionMaxstudiolondonsale.shop + 4 more domains
The Panel consolidated the disputes against the nominally different registrants after finding that consolidation would be fair and equitable in light of the websites’ similar appearance, their common pattern of using the MAX STUDIO marks, and the registrants’ similar addresses. It found all five domain names confusingly similar to the Complainant’s MAX STUDIO mark, found no rights or legitimate interests, and concluded that the domain names were registered and used in bad faith to attract Internet users for commercial gain through confusion and to disrupt the Complainant’s business. Transfer of all five domain names was ordered.
The timeline behind maxstudiolondonsale.shop
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 maxstudiolondonsale.shop — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a coordinated cluster of lookalike retail domains can support both consolidation and substantive UDRP findings. Common website design, repeated trademark use, similar site language, comparable contact details, and a shared commercial presentation allowed the Panel to treat the nominally different registrants in one proceeding and reinforced the conclusion that the domains formed a common impersonation pattern.
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 Leon Max, Inc. v. tu he, niu youguo Case No. D2026-0825 1. The Parties The Complainant is Leon Max, Inc., United States of America (“United States”), represented by Fross Zelnick Lehrman & Zissu, PC, United States. The Respondents are tu he, and niu youguo, United States. 2. The Domain Names and Registrar The disputed domain names <maxstudiolondonsale.shop>, <maxstudiolondonus.shop>, <maxstudiosafe.shop>, <maxstudiousbst.shop> and <maxstudious.shop> are registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 25, 2026. On February 26, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain names. On February 27, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which dif f ered f rom the named Respondent (REDACTED FOR PRIVACY) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on March 2, 2026 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaints f or the disputed domain names associated with dif f erent underlying registrants or alternatively, demonstrate that the underlying registrants are in f act the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on March 3, 2026. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondents of the Complaint, and the proceedings commenced on March 11, 2026. In accordance with the Rules, paragraph 5, the due date f or Response was March 31, 2026. The Respondents did not submit any response. Accordingly, the Center notif ied the Respondents’ def ault on April 1, 2026. The Center appointed Elizabeth Ann Morgan as the sole panelist in this matter on April 10, 2026. The Panel f inds 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 Calif ornia corporation. Complainant is the owner of the MAX STUDIO f amily of trademarks in the United States and in select countries around the world. Led by f ashion designer Leon Max, the Complainant is a women’s luxury fashion brand bringing classic styles to modern women. Founded in 1979, the Complainant’s MAX STUDIO manufactures clothing of unwavering caliber using superior f abrics, yarns, and leather goods. In addition to the Complainant’s extensive and strong common law rights in the MAX STUDIO trademark developed through more than 40-years of use, the Complainant owns numerous U.S. trademark registrations f or the MAX STUDIO trademark and related MAX STUDIO marks, including but not limited to the f ollowing: Mark Country Class Registration No. Registration Date MAX STUDIO U.S. 25 1,358,151 September 3, 1985 MAX STUDIO U.S. 25 6,053,854 May 12, 2020 The disputed domain names were registered between June 7, 2025 and September 22, 2025. As of the registration dates, the Complainant had been using the MAX STUDIO trademarks f or decades and had secured trademark registrations for the MAX STUDIO trademarks in the United States and in jurisdictions around the world. The disputed domain names resolve to virtually identical websites. The websites do not appear to use a standard or off-the-shelf template but are intended to create the impression of being actual websites of the Complainant, using the MAX STUDIO trademarks in the banner and heading at each site and in the name of the websites, all without authorization and purporting to of f er MAX STUDIO items. Second, the language used on the sites associated with the disputed domain names appears to be almost identical. Further all websites hosted under disputed domain names list similarly f alse contact inf ormation. The Complainant has not authorized the Respondents to use the MAX STUDIO trademark in a domain name, at any website, or for any other purpose. Further, there has never been any relationship between the Complainant and the Respondents that would give rise to any license, permission, or authorization f or the Respondents to use or register the disputed domain names. Moreover, the Respondents are not and have never been an authorized seller, supplier, or manuf acturer of any of the Complainant’s products. page 3 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain names. Notably, the Complainant contends that it has rights in the MAX STUDIO trademarks; that the disputed domain names are identical or confusingly similar to the Complainant’s MAX STUDIO trademarks; that the Respondents have no rights or legitimate interests in the disputed domain names; and that the disputed domain names were registered and are being used in bad f aith. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings Consolidation: Multiple Respondents The Amended Complaint was f iled in relation to nominally dif f erent domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unf air or inequitable to any Party. Given the similar appearance of the websites and the pattern of using the MAX STUDIO marks on websites that purport to of f er MAX STUDIO branded products, and the f act that the registrants have similar addresses, the Panel exercises its discretion under paragraph 10(e) to consolidate multiple domain name disputes into a single proceeding. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 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 trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel f inds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are conf usingly similar to the mark f or the purposes of the Policy. WIPO Overview 3.1, section 1.7. The Panel f inds the f irst 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 dif f icult 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward 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 f or illegitimate activity here, claimed copycat sites, passing off, or other types of f raud can never conf er rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. In the present case, the Panel notes that the Respondent is using the disputed domain names to attract f or commercial gain Internet users by creating a likelihood of conf usion with the Complainant’s mark and to disrupt the Complainant’s business. Panels have held that the use of a domain name for illegitimate activity here, claimed copycat sides, passing of f or other types of f raud constitutes bad f aith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitute bad f aith under the Policy. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain names <maxstudiolondonsale.shop>, <maxstudiolondonus.shop>, <maxstudiosaf e.shop>, <maxstudiousbst.shop>, and <maxstudious.shop> be transf erred to the Complainant. /Elizabeth Ann Morgan/ Elizabeth Ann Morgan Sole Panelist Date: April 17, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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