Westmore · UDRP decision
WIPO · Case No. D2026-1078

Lennar-com.org

TransferWIPO-indexed · informational, not legal advice

The Panel permitted consolidation of the two Complainants and ordered transfer of <lennar-com.org> to Lennar Corporation. It found the domain confusingly similar to the LENNAR mark because it reproduced the mark in full with only “-com” added. Respondent lacked rights or legitimate interests because the inactive website was not a bona fide use, Respondent was not commonly known by the domain, and no authorization or rebuttal was established. Bad faith was found from the deliberate targeting of the LENNAR mark, the domain’s composition, passive holding, and Respondent’s failure to answer the cease-and-desist letter or participate in the proceeding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-01
Panelist(s)
Steinhardt, Jeffrey D.
Complainant
Lennar Corporation Lennar Pacific Properties Management, LLC
Respondent
Stefanie Nayder, lenner
Disputed domain(s)
lennar-com.org
Domain history UDRP Intelligence

The timeline behind lennar-com.org

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 lennar-com.org — 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 lennar-com.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how exact incorporation of a registered mark with the addition of “-com” can satisfy confusing similarity and support an inference of direct targeting. It also shows that an under-construction page does not prevent a bad-faith finding when the Panel considers the mark’s distinctiveness and reputation, the domain’s composition, passive holding, and the respondent’s silence together.

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
2026-05-01
Panel
Steinhardt, Jeffrey D.
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Lennar Pacific Properties Management, LLC and Lennar Corporation v. Stefanie Nayder, lenner Case No. D2026-1078 1. The Parties Complainants are Lennar Pacific Properties Management, LLC and Lennar Corporation, United States of America (the “United States”), represented by Slates Harwell Campbell, LLP, United States. Respondent is Stefanie Nayder, lenner, United States. 2. The Domain Name and Registrar The disputed domain name <lennar-com.org> is registered with Squarespace Domains II LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 12, 2026. On March 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 13, 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 (The RDAP server redacted the value) and contact information in the Complaint. The Center sent an email communication to Complainant on March 16, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on March 16, 2026. The Center verified that the Complaint together with the amendment to the 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 Respondent of the Complaint, and the proceedings commenced on March 23, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 12, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on April 15, 2026. page 2 The Center appointed Jeffrey D. Steinhardt as 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 Complainants offer real estate management, brokerage, development, construction, mortgage, and financial services. Complainant Lennar Pacific Properties Management, LLC owns various registered trademarks for its LENNAR marks including, for example, United States Trademark Registration No. 3,108,401, registered on June 27, 2006, in international classes 35, 36 and 37, with a first use in commerce date of May 1973; and United States Trademark Registration No. 3,477,143, registered on July 29, 2008, in international classes 36 and 37. The disputed domain name was registered January 30, 2026, and resolves to a webpage stating that the website is under construction. 5. Parties’ Contentions A. Complainants Complainants aver that they have been one of America’s leading homebuilders since 1954 and build and sell homes in twenty-one states in the United States. Complainants allege that they have a common legal interest in rights that are affected by Respondent’s registration and use of the disputed domain name; Complainants allege that Lennar Corporation is a related company and authorized licensee of the LENNAR marks that owns and operates the website at www.lennar.com. Complainants further aver that on February 5, 2026, a cease and desist letter was sent to Respondent, to which no reply has been received. Complainants contend that they have satisfied each of the elements required under the Policy for transfer of the disputed domain name to Complainant Lennar Corporation. B. Respondent Respondent did not reply to Complainants’ contentions. 6. Discussion and Findings As an initial matter, the Panel has determined that this case may proceed through consolidation of both Complainants in this single proceeding. See Policy paragraph 10(a). The Panel agrees that Complainants have a specific common grievance against Respondent, and that Respondent has engaged in common conduct that has affected both Complainants in a similar fashion. The Panel finds that permitting this case to go forward with two Complainants favors due expedition, equity and fairness, without any resulting prejudice to Respondent. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.1. page 3 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 3.1, section 1.7. Complainants have 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 entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here, “-com”) may bear on assessment of the second and third elements, t he Panel finds the addition of these terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for purposes of the Policy. WIPO Overview 3.1, section 1.8. The Panel finds that the first element of Policy paragraph 4(a) 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. The evidence in this case shows that the disputed domain name does not resolve to an active webpage. The Panel finds that such nonuse cannot be bona fide in the sense of the Policy. The Panel accepts Complainants’ undisputed allegations that Respondent is not commonly known by the disputed domain name and has no authorization or right to use Complainant Lennar Pacific Properties Management, LLC’s marks. Having reviewed the available record, the Panel finds that 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 that the second element of paragraph 4(a) 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. page 4 In the present case, Respondent deliberately registered the disputed domain name that fully includes the LENNAR mark, adding only the term “-com” to the mark. This direct targeting of Complainant Lennar Pacific Properties Management, LLC’s marks is clear evidence of bad faith. The Panel finds that Respondent has “intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the complainant’s mark” in the sense of paragraph 4(b) 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. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of Complainant Lennar Pacific Properties Management, LLC’s trademark and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Respondent’s failure to reply to Complainants’ cease and desist letter and the notification of these proceedings provides further evidence of bad faith. The Panel finds that the third element of paragraph 4(a) of the Policy has also 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 <lennar-com.org> be transferred to Complainant Lennar Corporation. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: May 1, 2026

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

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