Westmore · UDRP decision
WIPO · Case No. D2026-1014

Midatlantictimberframes.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <midatlantictimberframes.com>. Although the Complainant's submitted evidence of common-law rights consisted only of a current website screenshot and was insufficient by itself, the Panel conducted limited public-record research and found that the MID-ATLANTIC TIMBER FRAMES mark was exclusively associated with the Complainant in initial search results, had meaningful social-media followings, and had been used consistently at the disputed domain for at least 14 years. The Panel found unregistered trademark rights and confusing similarity. It also found no rights or legitimate interests because the unrebutted record indicated impersonation. For bad faith, the Panel treated the Respondent's likely November 2025 auction acquisition following expiry—not the domain's original 2011 registration—as the relevant date. The Respondent's active DNS configuration of a replica of the Complainant's former website supported deliberate impersonation for likely commercial gain under Policy paragraph 4(b)(iv).

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-03
Panelist(s)
Speres, Jeremy
Complainant
Mid-Atlantic Timberframes LLC
Respondent
Fadli Nur, PT. Fadli Ramdani
Disputed domain(s)
midatlantictimberframes.com
Domain history UDRP Intelligence

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

This decision illustrates how an expired-domain acquisition may constitute a new registration for bad-faith analysis and how technical evidence of active DNS reconfiguration can distinguish deliberate impersonation from accidental continuation of a former owner's website settings. It also shows both the evidentiary risk of relying on minimal proof of common-law rights and the limited circumstances in which a panel may supplement the record through public-record research.

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
2026-05-03
Panel
Speres, Jeremy
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Mid-Atlantic Timberframes LLC v. Fadli Nur, PT. Fadli Ramdani Case No. D2026-1014 1. The Parties The Complainant is Mid-Atlantic Timberframes LLC, United States of America (“United States”), represented by Barley Snyder LLP, United States. The Respondent is Fadli Nur, PT. Fadli Ramdani, Indonesia. 2. The Domain Name and Registrar The disputed domain name <midatlantictimberframes.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 9, 2026. On March 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 12, 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 March 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 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 17, 2026. page 2 The Center appointed Jeremy Speres as the sole panelist in this matter on April 24, 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 uncontested facts are as follows. The Complainant, based in Paradise, Pennsylvania, United States, has, since at least as early as 2011, produced and sold timber for residential and commercial building construction under the MID-ATLANTIC TIMBER FRAMES mark, in respect of which the Complainant has no registered trademarks but claims common law rights. The disputed domain name was registered on October 18, 2011, and currently resolves to a website entitled “Mid-Atlantic Timberframes”, ostensibly for a timber business based in Paradise, Pennsylvania, United States. 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 was registered and has been used in bad faith in order to impersonate the Complainant for the Respondent’s commercial gain. 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 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 claims common law trademark rights, but the only evidence supplied in this respect in the Complaint was a screenshot of the Complainant’s current website, which is, on its own, insufficient to establish common law rights. WIPO Overview 3.1, section 1.3. Nevertheless, as discussed below in relation to bad faith, this appears to be a clear-cut case of impersonation of the Complainant with ongoing potential for significant harm. In the interests of justice, and in accordance with its duty to conduct these proceedings with due expedition as set out in paragraph 10(c) of the Rules, the Panel has independently 1 conducted brief Internet searches for the Complainant’s claimed MID-ATLANTIC TIMBER FRAMES mark. The results reveal that this mark is exclusively associated with the Complainant across the first few pages of results. The Panel also notes various social media pages associated with the Complainant under this mark that have attracted meaningful followings. 1 In accordance with its powers articulated inter alia in paragraphs 10 and 12 of the Rules, the Panel is entitled to conduct limited independent research into matters of public record. WIPO Overview 3.1, section 4.8. page 3 As discussed further below in relation to bad faith, the Complainant previously operated its website at the disputed domain name, and Internet Archive records indicate that the Complainant consistently used its mark at that website for at least 14 years. These findings support the conclusion that the mark has acquired distinctiveness through use. In the circumstances, the Panel finds the Complainant has unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.1, section 1.3. The Panel finds the mark is nearly identical to, and easily recognizable within, the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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. For the reasons discussed in relation to bad faith below, it is likely that the Respondent’s intention was to impersonate the Complainant. Panels have held that the use of a domain name for illegitimate activity such as impersonation, as in this case, 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. For the following reasons, the Panel finds that it is more likely than not that the Respondent registered and has used the disputed domain name to take advantage of confusion with the Complainant’s mark for the Respondent’s commercial gain, falling squarely within paragraph 4(b)(iv) of the Policy. page 4 The Complainant claims to have previously owned the disputed domain name but inadvertently allowed it to lapse. The Panel’s viewing of publicly available WhoIs history, Internet Archive, and domain name sales records for the disputed domain name support this conclusion. The disputed domain name has resolved to a website relating to the Complainant’s business since at least as early as 2011. Changes to the disputed domain name’s nameservers and hosting IP addresses suggest that a change in control of the disputed domain name occurred between October and December 2025. The disputed domain name’s erstwhile expiry date was in October 2025. Domain name sales records indicate that the disputed domain name was purchased at an auction of expired domain names held by the Registrar in November 2025. In the circumstances, and without any evidence from the Respondent to the contrary, it appears likely that the Respondent purchased the disputed domain name at auction in November 2025 upon its expiry, before which the disputed domain name was controlled by the Complainant. The Panel considers November 2025 the relevant date for assessing bad faith. WIPO Overview 3.1, section 3.9. By that stage, the Complainant’s business had been in existence for at least 14 years and appears to have enjoyed substantial goodwill within its industry. The Panel notes that after the Respondent acquired the disputed domain name, its name servers changed. This means, in effect, that the Respondent would have had to actively insert new Domain Name System (DNS) records into the new name servers to cause the disputed domain name to resolve to the present website. The Respondent would thus have actively chosen to configure the disputed domain name to resolve to the current website, which appears to be a replica of the Complainant’s previous website to which the disputed domain name resolved in the past. This is thus not a case of the Respondent inadvertently retaining the name servers and thus DNS records of the previous owner of the disputed domain name. By actively choosing to configure the disputed domain name to resolve to the present replica website, the Respondent deliberately sought to impersonate the Complainant. In the absence of any evidence to the contrary from the Respondent, it appears likely that this was intended to be for the Respondent’s commercial gain; why else impersonate the Complainant? Panels have held that the use of a domain name for illegitimate activity such as impersonation, as in this case, constitutes bad faith. WIPO Overview 3.1, section 3.1.4. In the circumstances of this case, the Panel draws an adverse inference from the Respondent’s failure to take part in the present proceeding where an explanation is certainly called for. WIPO Overview 3.1, section 4.3. The Panel finds the third element of the Policy has been established. 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 <midatlantictimberframes.com> be transferred to the Complainant. /Jeremy Speres/ Jeremy Speres Sole Panelist Date: May 3, 2026

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

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