Westmore · UDRP DecisionUktempcovers.com
The Panel ordered transfer of <uktempcovers.com>. It found the domain confusingly similar to the Complainant’s registered TEMPCOVER marks, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to attract Internet users for commercial gain through confusion and purported competing temporary vehicle insurance services.
The timeline behind uktempcovers.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 uktempcovers.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a domain combining an entire trademark with a geographic term and a minor pluralizing variation can satisfy confusing similarity, particularly where the domain is used for purported services directly competing with the trademark owner. The same website use also drove the findings on legitimate interests and 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 Tempcover Ltd v. Waleed Mirza, Banterest Case No. D2026-1047 1. The Parties The Complainant is Tempcover Ltd, United Kingdom, represented by Venner Shipley LLP, United Kingdom. The Respondent is Waleed Mirza, Banterest, Pakistan. 2. The Domain Name and Registrar The disputed domain name <uktempcovers.com> (the “Disputed Domain Name”) is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 11, 2026. On March 11, 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 (Unknown) 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 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 10, 2026. page 2 The Center appointed Lynda M. Braun as the sole panelist in this matter on April 16, 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 part of the RVU Group of companies, which owns some of the best-known brands in the United Kingdom and Europe and whose services are used by millions of people every year to make home, insurance and financial services decisions. Launched in 2006, the Complainant offers products that provide car and van drivers flexible, temporary insurance for one to 14 days. The Complainant offers the aforementioned short-term car and other vehicle insurance from its website at “www.tempcover.com”. The Complainant’s services are also offered via some of the United Kingdom’s largest price comparison websites. The Complainant owns the following registered trademarks: TEMPCOVER (stylized), United Kingdom Registration No. UK00003399923, registered on August 16, 2019, in International Class 36; and TEMPCOVER.COM, United Kingdom Registration No. UK00002515637, registered on December 4, 2009, in International Class 36 (hereinafter collectively referred to as the “TEMPCOVER Mark”). The TEMPCOVER Mark has been used extensively across the United Kingdom for nearly 20 years to offer short-term insurance, and as a result of this widespread use, the TEMPCOVER Mark has acquired a significant reputation among consumers in the United Kingdom. The Disputed Domain Name was registered on December 10, 2025 and resolves to a website that purportedly offers short-term and temporary car insurance products under the name “CarCover”. The homepage of the website contains a copyright notice naming a company, CarCover Ltd, which is said to be registered “in England & Wales”, although apparently no such company exists on the United Kingdom register of companies. 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 TEMPCOVER Mark because the Disputed Domain Name contains the TEMPCOVER Mark in its entirety, albeit with an additional letter “s”, and preceded by the geographical abbreviation “uk”, and then followed by the generic Top-Level Domain (“gTLD”) “.com”, which does not prevent a finding of confusing similarity; - the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because, among other things, there is no evidence that the Respondent has ever used or made preparations to use the Disputed Domain Name in connection with any legitimate business, nor is it making a legitimate, noncommercial or fair use of the Disputed Domain Name; and - the Disputed Domain Name was registered and is being used in bad faith because, among other things, the Respondent uses the Disputed Domain Name to impersonate the Complainant and to deceive unsuspecting consumers into thinking that the Disputed Domain Name is operated by or connected to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions page 3 6. Discussion and Findings Paragraph 4(a) of the Policy requires that the Complainant prove the following three elements in order to prevail in this proceeding: (i) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and (iii) the Disputed Domain Name was registered and is being used in bad faith. A. Identical or Confusingly Similar Paragraph 4(a)(i) of the Policy requires a two-fold inquiry: a threshold investigation into whether a complainant has rights in a trademark, followed by an assessment of whether the disputed domain name is identical or confusingly similar to that trademark. The Panel concludes that in the present case, the Disputed Domain Name is confusingly similar to the TEMPCOVER Mark. 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. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. It is uncontroverted that the Complainant has established rights in the TEMPCOVER Mark based on its registered trademarks for the TEMPCOVER Mark in the United Kingdom. The registration of a mark satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case. As stated in section 1.2.1 of the WIPO Overview 3.1, “[w]here the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case”. The Panel finds that the Complainant satisfied the threshold requirement of having trademark rights in the TEMPCOVER Mark. The Disputed Domain Name consists of the Complainant’s TEMPCOVER Mark in its entirety, preceded by the geographical term “uk” and then followed by the letter “s” and the gTLD “.com”. The test for confusing similarity involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. The TEMPCOVER Mark is recognizable within the Disputed Domain Name as the TEMPCOVER Mark is used in its entirety, albeit misspelled by adding the letter “s” to the TEMPCOVER Mark. Such a minor modification to a disputed domain name is commonly referred to as “typosquatting” and seeks to wrongfully take advantage of errors by a user in typing a domain name into a web browser. The misspelling of the TEMPCOVER Mark to “tempcovers” does not prevent a finding of confusing similarity to the TEMPCOVER Mark. See WIPO Overview 3.1, section 1.9: “A domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered by panels to be confusingly similar to the relevant mark for purposes of the first element”; see also Express Scripts, Inc. v. Whois Privacy Protection Service, Inc. / Domaindeals, Domain Administrator, WIPO Case No. D2008-1302; Singapore Press Holdings Limited v. Leong Meng Yew, WIPO Case No. D2009-1080. In addition, the TEMPCOVER Mark in the Disputed Domain Name is preceded by the term “uk”, and the Panel finds that the additional term does not prevent a finding of the confusing similarity between the Mark and the Disputed Domain Name. WIPO Overview 3.1, section 1.8. Finally, the addition of a gTLD such as “.com” in a domain name is a technical requirement. Thus, it is well established that, as here, such element may typically be disregarded when assessing whether a domain name is identical or confusingly similar to a trademark. See WIPO Overview 3.1, section 1.11.1. Thus, the Panel finds that the Disputed Domain Name is confusingly similar to the Complainant’s TEMPCOVER Mark. page 4 Based on the available record, the Panel finds that 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. In this case, given the facts as set out above, the Panel finds that the Complainant has made out a prima facie case. The Respondent has not submitted any arguments or evidence to rebut the Complainant’s prima facie case. Furthermore, the Complainant has not authorized, licensed, or otherwise permitted the Respondent to use its TEMPCOVER Mark. Nor does the Complainant have any type of business relationship with the Respondent. There is also no evidence that the Respondent is commonly known by the Disputed Domain Name or by any similar name, nor any evidence that the Respondent was using or making demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services. See Policy, paragraph 4(c). The Disputed Domain Name resolves to a website displaying and allegedly selling unauthorized insurance services, and thus, the Respondent does not have rights or legitimate interests in the Disputed Domain Name. When Internet users arrive at the Respondent’s website, they will find a site in which the Respondent attempts to create a likelihood of confusion with the Complainant because it uses the Complainant’s TEMPCOVER Mark in its Disputed Domain Name, purportedly offering competing temporary vehicle insurance products to customers, if the products exist at all (as the Complainant contends 1 ). The Panel thus determines that the Respondent is not making a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the Disputed Domain Name but rather is using the Disputed Domain Name for commercial gain with the intent to mislead the Complainant’s customers into believing that they had arrived at a website which is somehow sponsored or endorsed by the Complainant. Screenshots of the Respondent’s website were submitted by the Complainant in an Annex to the Complaint to demonstrate the competing short-term insurance products that the Respondent allegedly offers. In sum, the Panel finds that the Complainant has established an unrebutted prima facie case that the Respondent lacks rights or legitimate interests in the Disputed Domain Name. The Panel concludes that the Respondent is using the Disputed Domain Name for commercial gain with the intent to mislead by potentially defrauding the Complainant or Internet users. Such use cannot conceivably constitute a bona fide offering of a product or service within the meaning of paragraph 4(c)(i) of the Policy. Based on the available record, the Panel finds that 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. The Panel finds that based on the record, the Complainant has demonstrated the existence of the 1 The Complainant claims that the insurance purportedly offered by the Respondent may not exist since the links on the homepage did not display any content when clicked. page 5 Respondent’s bad faith registration and use of the Disputed Domain Name pursuant to paragraph 4(a)(iii) of the Policy. 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. Having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy due to the Respondent’s attempt to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant and purportedly offering competing services to unwitting customers. The Respondent has attempted to create a likelihood of confusion with the Complainant by creating a website purportedly offering competing short-term insurance products, thus demonstrating bad faith. Therefore, it strains credulity to believe that the Respondent had not known of the Complainant or its TEMPCOVER Mark when registering the Disputed Domain Name. See Myer Stores Limited v. Mr. David John Singh, WIPO Case No. D2001-0763 (“a finding of bad faith may be made where the respondent ‘knew or should have known’ of the registration and/or use of the trademark prior to registering the domain name”). Rather, the Panel notes that the composition of the Disputed Domain Name, together with its use, affirms the Respondent’s intention to take unfair advantage of the likelihood of confusion between the Disputed Domain Name and the TEMPCOVER Mark as to the origin or affiliation of the website at the resolving Disputed Domain Name. In sum, the Panel finds that the Respondent had the Complainant’s TEMPCOVER Mark in mind when registering the Disputed Domain Name, another example of bad faith. The use of a domain name to intentionally attempt to attract Internet users to a respondent’s website or online location by creating a likelihood of confusion with a complainant’s mark as to the source, sponsorship, affiliation or endorsement of the registrant’s website or online location for commercial gain demonstrates registration and use in bad faith. Here, the Respondent’s registration and use of the Disputed Domain Name indicates that such registration and use had been done for the specific purpose of trading upon and targeting the reputation, name, mark, and goodwill of the Complainant. See Madonna Ciccone, p/k/a Madonna v. Dan Parisi and “Madonna.com”, WIPO Case No. D2000-0847 (“[t]he only plausible explanation for Respondent’s actions appears to be an intentional effort to trade upon the fame of Complainant’s name and mark for commercial gain.”). Moreover, the Panel concludes that the Respondent’s registration of the Disputed Domain Name was an attempt to disrupt the Complainant’s business. The Respondent’s use of the Disputed Domain Name was also likely to confuse Internet users into incorrectly believing that the Respondent was authorized by or affiliated with the Complainant. Based on the available record, the Panel finds that 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 <uktempcovers.com> be transferred to the Complainant. /Lynda M. Braun/ Lynda M. Braun Sole Panelist Date: April 23, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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