Westmore · UDRP DecisionPanavisionincorporated.com
The Panel ordered transfer of <panavisionincorporated.com> to Panavision International, L.P. It found the domain confusingly similar to the PANAVISION mark because it incorporated the mark in full with the term “incorporated”; found that Complainants established an unrebutted prima facie case that Respondent lacked rights or legitimate interests; and found bad-faith registration and use under the passive-holding doctrine. The bad-faith assessment relied on the mark’s well-known and distinctive character, the longstanding registrations, the domain’s reinforced connection to Panavision Inc., Respondent’s failure to submit a response, concealment of identity in the publicly available WhoIs, and the implausibility of any good-faith use.
The timeline behind panavisionincorporated.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 panavisionincorporated.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a distinctive mark with a corporate-form term can strengthen, rather than diminish, the apparent connection to a trademark owner. It also demonstrates application of passive-holding principles where the domain has no substantive website but the surrounding circumstances—including longstanding rights, mark distinctiveness, composition of the domain, default, identity concealment, and lack of plausible good-faith use—support bad faith.
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 Panavision International, L.P. and Panavision Inc. v. Jane Nkamate, panavisionincorporated.com Case No. D2026-0830 1. The Parties Complainants are Panavision International, L.P. United States of America (“United States”) and Panavision Inc., United States, represented by Bryan Cave Leighton Paisner LLP, United States. Respondent is Jane Nkamate, panavisionincorporated.com, United States. 2. The Domain Name and Registrar The disputed domain name <panavisionincorporated.com> is registered with Squarespace Domains II LLC (“Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (“Center”) on February 26, 2026. On February 26, 2026, the Center transmitted by email to Registrar a request for registrar verification in connection with the disputed domain name. On February 26, 2026, Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from that in the Complaint (e.g., the Complaint named “The RDAP server redacted the value” as Respondent). The Center sent an email communication to Complainants on February 27, 2026, providing the registrant and contact information disclosed by Registrar and inviting Complainants to submit an amendment to the Complaint. Complainants filed an amended Complaint on March 2, 2026. The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (“Policy”), the Rules for Uniform Domain Name Dispute Resolution Policy (“Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (“Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on March 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 23, 2026. Respondent did not submit a response. Accordingly, the Center notified Respondent’s default on March 25, 2026. On April 2, 2026, the Respondent sent two email communications to the Center. page 2 On April 9, the Center sent an email communication to the parties concerning possible settlement. On April 13, 2026, Complainants requested a suspension of the proceeding to explore settlement. On April 14, 2026, the Center issued a Notification of Suspension, suspending the proceeding until May 13, 2026 for the purpose of settlement discussions. On May 13, 2026, Complainants requested that the suspension be continued for an additional 30-day period. On May 15, 2026, the Center issued a Notification of Extension to Suspension, further suspending the proceeding until June 13, 2026. On June 16, 2026, the Center sent an email communication to the parties concerning the expiration of the suspension. On the same day , Complainants requested that the proceeding resume. On June 17, 2026, the Center issued a Reinstitution of Proceeding notice indicating that the proceeding would move forward. The Center appointed Debra J. Stanek as the sole panelist in this matter on June 22, 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 Complainants are apparently related companies. Along with other related companies and licensees 1 , they provide digital imaging and cinematographic equipment around the world under the PANAVISION marks, which have been used since at least 1954 in connection motion picture cameras and related equipment. Complainant Panavision International, L.P. owns the following registrations for the PANAVISION mark: - United States Reg. No. 627,362 registered May 22, 1956, for optical devices for taking and projecting motion pictures. - United States Reg. No. 834,705, registered September 5, 1967, for motion picture cameras and lenses and related equipment. Complainant Panavision Inc. also owns at least the following registration for the PANAVISION mark: - United States Reg. No. 1,160,790, registered July 14, 1981, for television cameras. Since 1998, one of the Complainants or its licensees or related companies has owned and operated a website at the <panavision.com> domain name, which was registered in 1998, to promote PANAVISION offerings. The disputed domain name was registered on December 26, 2025. Both at the time the Complaint was filed and at the time of this Decision, it resolves to an inactive webpage displaying an “under construction” notice. 5. Parties’ Contentions A. Complainant Complainants contends that they have satisfied each of the elements required under the Policy for a transfer of the disputed domain name. In particular: 1 The Complaint uses the term “Complainant” to collectively refer to the two named Complainants as well as unnamed “related companies and licensees”—making the factual allegations and arguments confusing and, in some cases, unintelligible. See, e.g., Amended Complaint, paragraph 12, section B., fourth paragraph (“identical to Complainant’s corporate name, Panavision Inc.”); Amended Complaint, paragraph 13 (requesting transfer of the disputed domain name “to Complainant.”). Under the Rules, “Complainant means the party initiating a complaint concerning a domain-name registration,” see Rules, paragraph 1, s.v. “Complainant.” In this case, therefore, “Complainants” is used to refer only to the two entities named in the Complaint. page 3 - The disputed domain name is “identical” [sic] to “Panavision Inc.,” which is the name of the corporate parent entity of one or more of the named Complainants or one or both of the licensees or related companies of each 2 . - The disputed domain name includes the PANAVISION mark with the addition of “incorporated,” which is abbreviated as “Inc.” - On information and belief, Respondent has not been authorized to use the well-known PANAVISION mark. - Respondent is not using the disputed domain name in connection with any bona fide offering. - Respondent must have known of the well-known PANAVISION mark when it registered the disputed domain name. - Respondent’s use of a privacy shield further demonstrates bad faith. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings The Complaint identifies two Complainants, Panavision International, L.P. and Panavision Inc. Neither the Policy nor the Rules provide for multiple Complainants and Complainants have not requested consolidation. The Complaint establishes that each of the Complainants owns at least one registration for the PANAVISION mark and the two entities appear to be part of the same corporate family. Therefore, the Panel, consistent with the consensus view, determines that consolidation is appropriate given that these two parties have a common grievance against Respondent, and it is equitable and efficient to do so. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.1. To prevail under the Policy a complainant must prove, as to the domain name at issue, that: (a) it is identical or confusingly similar to a mark in which the complainant has rights, (b) respondent has no rights or legitimate interests in respect to it, and (c) it has been registered and is being used in bad faith. Policy, paragraph 4(a). A respondent’s failure to respond does not automatically result in a finding for the complainant; the complainant continues to have the burden of establishing each element. Rules, paragraphs 5(f) and 14(a); see also WIPO Overview 3.1, section 4.3. The Panel may, however, draw appropriate inferences from the default. See Rules, paragraph 14(b). The Panel determines that “Jane Nkamate, panavisionincorporated.com” is the appropriate Respondent. See WIPO Overview 3.1, section 4.4.5 (in cases involving a privacy service, Panel has discretion to determine appropriate respondent). 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 Complainant’s trademark and the disputed domain name. WIPO Overview 3.1, section 1.7. Each of the Complainants 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. 2 It is not clear whether this “corporate parent entity” is a named Complainant. page 4 The disputed domain name is not identical to the PANAVISION mark. However, the entirety of the mark is included in the disputed domain name, followed by “incorporated.” The Panel finds the PANAVISION mark readily recognizable. Although the addition of other terms may bear on assessment of the other elements, the Panel finds the addition here does not prevent a determination that the disputed domain name is confusingly similar to 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 Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in proceedings under the Policy is on the complainant, panels have recognized that proving 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 remains on the complainant). If the respondent fails to come forward with relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. The Panel finds Complainants have established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted Complainants’ 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. 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. Other panels have found that the non-use of a domain name does not prevent a finding of bad faith. WIPO Overview 3.1, section 3.3. In the present case, the Panel finds that the passive holding of the disputed domain name does not prevent such a finding here. In doing so, the Panel takes into account: Complainants’ PANAVISION mark is well-known and distinctive; Complainants’ trademark registrations long predate registration of the disputed domain name; the disputed domain name combines the PANAVISION mark in its entirety followed by the word “incorporated,” which reinforces a connection with Complainant Panavision Inc. and in any case does not meaningfully differentiate the disputed domain name from the PANAVISION mark; Respondent did not submit a response; Respondent concealed its identity in the publicly-available WhoIs; and the implausibility of any good faith use to which the disputed domain name could be put. The Panel finds the third element of the Policy has been established. page 5 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 <panavisionincorporated.com> be transferred to Complainant Panavision International, L.P. /Debra J. Stanek/ Debra J. Stanek Sole Panelist Date: July 9, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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