Westmore · UDRP decision
WIPO · Case No. D2026-0960

Hunting-realtree.com + 3 more domains

TransferWIPO-indexed · informational, not legal advice

The Panel ordered the transfer of all four disputed domain names. It granted consolidation after finding that the domains and corresponding websites were under common control. Each domain incorporated the Complainant’s registered REALTREE mark, the Respondents failed to rebut the Complainant’s prima facie case concerning rights or legitimate interests, and the domains were used for websites that impersonated the Complainant’s legitimate website for commercial gain. Fabricated contact details and the Respondents’ default provided additional support for the findings.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-05
Panelist(s)
Brown, Evan D.
Complainant
Jordan Outdoor Enterprises Ltd
Respondent
Hernandez Mark Houghtons Robbie Lannon Joseph Quiroz Jeffery
Counsel
Nelson Mullins Riley · Quiroz Jeffery · Scarborough, L.L.P., United States. The Respondents are Lannon Joseph, Hernandez Mark, Houghtons Robbie,
Disputed domain(s)
hunting-realtree.com, realtreecamogear.com, realtreeoutdoorlife.com, realtreeshop.com
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind hunting-realtree.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for hunting-realtree.com…
Outcome by domain

How each disputed name was decided in this proceeding.

hunting-realtree.comTransferred
realtreecamogear.comTransferred
realtreeoutdoorlife.comTransferred
realtreeshop.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of hunting-realtree.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates consolidation of multiple nominal registrants where technical, operational, design, and registration-data similarities collectively demonstrate common control. It also shows how copied branding and website presentation can support both the absence of legitimate interests and bad-faith commercial impersonation.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-05
Panel
Brown, Evan D.
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Jordan Outdoor Enterprises Ltd v. Lannon Joseph, Hernandez Mark, Houghtons Robbie, Quiroz Jeffery Case No. D2026-0960 1. The Parties The Complainant is Jordan Outdoor Enterprises Ltd, United States of America (“United States”), represented by Nelson Mullins Riley & Scarborough, L.L.P., United States. The Respondents are Lannon Joseph, Hernandez Mark, Houghtons Robbie, and Quiroz Jeffery, United States. 2. The Domain Names and Registrar The disputed domain names <hunting-realtree.com>, <realtreecamogear.com>, <realtreeoutdoorlife.com>, and <realtreeshop.com> are registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 5, 2026. On March 6, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On March 9, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 9, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on March 17, 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on March 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 9, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 14, 2026. The Center appointed Evan D. Brown as the sole panelist in this matter on April 21, 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 is in the business of creating and licensing camouflage patterns for use on a wide range of outdoor lifestyle products, sold through retail chains, independent retailers, and e-commerce channels. It owns the trademark REALTREE, for which it enjoys the benefits of registration, including United States Reg. No. 1736108, registered on December 1, 1992. According to the WhoIs records, the disputed domain names were registered on the following dates: <realtreecamogear.com> on November 30, 2024; <hunting-realtree.com> on January 6, 2025; <realtreeoutdoorlife.com> on August 13, 2025; and <realtreeshop.com> on January 19, 2026. The Respondents have used the disputed domain names to operate what the Complainant asserts are imposter websites that mimic the Complainant’s legitimate website at “www.realtree.com”, misappropriating the Complainant’s branding, logos, and images to deceive consumers into believing they are dealing with an authorized Realtree retailer, and either selling counterfeit products or collecting payment from consumers without delivering any goods. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain names are identical or confusingly similar to the Complainant's trademark; that the Respondents have no rights or legitimate interests in respect of the disputed domain names; and that the disputed domain names were registered and are being used in bad faith. B. Respondents The Respondents did not respond to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights, (ii) the Respondents have no rights or legitimate interests in respect of the disputed domain names, and (iii) the disputed domain names have been registered and are being used in bad faith. The Panel finds that all three of these elements have been met in this case. page 3 A. Procedural Issue – Consolidation of Multiple Respondents There are four named Respondents (four underlying registrants disclosed by the Registrar) – one for each of the disputed domain names. The Complainant requests that all four be consolidated into this matter. Consolidation is proper, so the Complainant’s request for consolidation is granted. Paragraph 10(e) of the Rules states that a “[p]anel shall decide a request by a Party to consolidate multiple domain name disputes in accordance with the Policy and these Rules”. Paragraph 10(c) of the Rules provides, in relevant part, that “the [p]anel shall ensure that the administrative proceeding takes place with due expedition”. Section 4.11.2 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) summarizes the consensus view of UDRP panels on the consolidation of multiple respondents and provides that where a complaint is filed against multiple respondents, panels consider whether the domain names or corresponding websites are subject to common control, and whether the consolidation would be fair and equitable to all parties. The record indicates the disputed domain names are under common control. The following facts support this conclusion: all four disputed domain names were registered with the same Registrar, Gname.com Pte. Ltd.; all four were registered within approximately one year of each other; all four share the same name servers; all four corresponding websites display the same general layout and images copied from the Complainant's legitimate website; all four sets of registrant contact details appear to be fabricated, including false physical addresses; and all four registrant email addresses follow the same naming convention of first name, middle initial, and last name, suggesting they were created by the same individual. The Respondents have not presented any arguments as to why consolidation would be unfair or inequitable. Accordingly, conditions for proper consolidation of the disputed domain names into one matter are present here. B. Identical or Confusingly Similar This first element functions primarily as a standing requirement. WIPO Overview 3.1, section 1.7. 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. Id. This element requires the Panel to consider two issues: first, whether the Complainant has rights in a relevant mark; and second, whether the disputed domain names are identical or confusingly similar to that mark. A registered trademark provides a clear indication that the rights in the mark shown on the trademark certificate belong to its respective owner. See Advance Magazine Publishers Inc., Les Publications Conde Nast S.A. v. Voguechen, WIPO Case No. D2014-0657. The Complainant has demonstrated its rights in the REALTREE mark by providing evidence of its trademark registrations. See WIPO Overview 3.1, section 1.2.1. Each of the disputed domain names incorporates the REALTREE mark in its entirety, with the addition of terms such as “camogear,” “shop,” “outdoorlife,” and “hunting-,” none of which prevent a finding of confusing similarity between the disputed domain names and the Complainant's REALTREE mark. See WIPO Overview 3.1, section 1.8. The REALTREE mark remains clearly recognizable in each of the disputed domain names for a showing of confusing similarity under the Policy. The Panel finds that the Complainant has established this first element under the Policy. C. Rights or Legitimate Interests The Panel evaluates this element of the Policy by first looking to see whether the Complainant has made a prima facie showing that the Respondents lack rights or legitimate interests in respect of the disputed domain names. If the Complainant makes that showing, the burden of production of demonstrating rights or legitimate interests shifts to the Respondents (with the burden of proof always page 4 remaining with the Complainant). See WIPO Overview 3.1, section 2.1; AXA SA v. Huade Wang, WIPO Case No. D2022-1289. On this point, the Complainant asserts, among other things, that: (1) the Respondents are not commonly known as REALTREE or by any of the disputed domain names; (2) the Complainant has not authorized the Respondents to use the REALTREE mark in any manner; (3) the Respondents are neither licensees nor authorized retailers of the Complainant; (4) the Respondents cannot satisfy the Oki Data test for resellers, having failed at minimum to prominently disclose their relationship with the Complainant and having registered four domain names in an apparent effort to corner the market on domain names reflecting the REALTREE mark; and (5) the Respondents cannot establish bona fide use prior to notice of the dispute because the imposter websites were deliberately designed to imitate the Complainant’s official website and confuse consumers for the Respondents’ financial gain. The Panel finds that the Complainant has made the required prima facie showing. The Respondents have not presented evidence to overcome this prima facie showing. And nothing in the record otherwise tilts the balance in the Respondents’ favor. The use of a domain name for illegal activity such as impersonation or passing off can never confer rights or legitimate interests on a respondent. Société des Produits Nestlé S.A. v. Great Homes, jobs-nestle.com, WIPO Case No. D2024-2911; WIPO Overview 3.1, section 2.13.1. Accordingly, the Panel finds that the Complainant has established this second element under the Policy. D. Registered and Used in Bad Faith The Policy requires a complainant to establish that the disputed domain names were registered and are being used in bad faith. The evidence of bad faith here is compelling. The Respondents registered domain names incorporating the entirety of the Complainant’s REALTREE mark, a mark that has been in continuous and extensive use for several decades and enjoys a high degree of distinctiveness and recognition in the outdoor lifestyle and camouflage products market. There is no plausible explanation for the Respondents’ choice to register domain names built around the REALTREE mark other than to trade off the Complainant’s goodwill and reputation. The Respondents knew, or should have known, of the Complainant’s well-established rights in the REALTREE mark at the time of registration. See WIPO Overview 3.1, section 3.2.2. The evidence of bad faith use is equally compelling. The Respondents have used the disputed domain names to operate imposter websites that deliberately mimic the Complainant’s legitimate website at “www.realtree.com”, misappropriating the Complainant’s branding, logos, color scheme, and images to create a false impression of affiliation with or endorsement by the Complainant. This conduct falls squarely within the bad faith scenario described in paragraph 4(b)(iv) of the Policy. The Respondents have intentionally attempted to attract, for commercial gain, Internet users to their websites by creating a likelihood of confusion with the Complainant’s REALTREE mark as to the source, sponsorship, affiliation, or endorsement of those websites. See WIPO Overview 3.1, section 3.1.4. The Respondents’ use of apparently fictitious registrant identities and contact information across all four domain name registrations provides additional evidence of bad faith. The use of false contact information is a recognized indicator of bad faith under the Policy. The Respondents’ failure to submit a response to the Complaint further supports this conclusion, as it leaves unrebutted the Complainant’s well-supported contentions and permits the Panel to draw appropriate inferences. See WIPO Overview 3.1, section 4.3. page 5 Accordingly, the Panel finds that the Complainant has established this third element under 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 <hunting-realtree.com>, <realtreecamogear.com>, <realtreeoutdoorlife.com>, and <realtreeshop.com> be transferred to the Complainant. /Evan D. Brown/ Evan D. Brown Sole Panelist Date: May 5, 2026

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

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