Westmore · UDRP decision
WIPO · Case No. D2026-1079

Lennarttle.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <lennarttle.com> to Lennar Title, LLC. It found the domain confusingly similar to the LENNAR and LENNAR TITLE marks, held that Respondent lacked rights or legitimate interests, and concluded that the omission of the letter “i” from LENNAR TITLE constituted targeting through typosquatting. Use of the domain for third-party advertising links, together with Respondent’s failure to answer the cease-and-desist letter or participate in the proceeding, supported the finding of bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-30
Panelist(s)
Steinhardt, Jeffrey D.
Complainant
Lennar Pacific Properties Management, LLC Lennar Title, LLC
Respondent
James Patel, Compass
Disputed domain(s)
lennarttle.com
Domain history UDRP Intelligence

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

The decision illustrates a straightforward typosquatting case in which a single omitted character from a registered mark, combined with commercial advertising links and an unrebutted record, supported transfer. It also shows that a panel may decide the case on reliably evidenced website use without adopting more serious allegations of phishing or malicious redirects.

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
2026-04-30
Panel
Steinhardt, Jeffrey D.
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Lennar Pacific Properties Management, LLC, Lennar Title, LLC v. James Patel, Compass Case No. D2026-1079 1. The Parties Complainants are Lennar Pacific Properties Management, LLC, United States of America (“United States”), Lennar Title, LLC, United States, represented by Slates Harwell Campbell, LLP, United States. Respondent is James Patel, Compass, United States. 2. The Domain Name and Registrar The disputed domain name <lennarttle.com> is registered with NameCheap, Inc. (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 16, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent (Unknown, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainants on March 16, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainants to submit an amendment to the Complaint. Complainants 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 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 6, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on April 9, 2026. page 2 The Center appointed Jeffrey D. Steinhardt as 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 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 for LENNAR, registered June 27, 2006 in international classes 36 and 37, with a first use in commerce date of May 1973; and United States Trademark Registration No. 6,817,154 for LENNAR TITLE, registered August 16, 2022 in international classes 36 and 45. The disputed domain name was registered July 1, 2025 and presently routes to a webpage displaying links to third-party websites unrelated to Complainants’ areas of activity. 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 21 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 Complainant Lennar Title, LLC is a related company and authorized licensee of the LENNAR marks that owns and operates the domain name and website “www.lennartitle.com”. Complainants aver that on February 9, 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 Title, LLC. Notably, Complainants represent that the disputed domain name “appears to and/or has at one point in time redirected visitors to a malicious pop-up scam with illegal streaming content and/or virus scam site” and elsewhere they contend that Respondent’s website was used as a part of a phishing scheme. 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(e). 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 a complainant’s trademark and the disputed domain name. WIPO Overview 3.1, section 1.7. Complainants have shown rights in respect of trademarks or service marks for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the LENNAR 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. With respect to the LENNAR TITLE mark, the Panel finds that the mark is recognizable within the disputed domain name, despite the omission of the letter “i”. This is generally considered to be confusing similar for purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.9 (typosquatting). 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 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. Reliable evidence in this case shows that the disputed domain name routes to a webpage with third-party advertising links that have no relation with the marks. Such a use is not, the Panel finds, bona fide. 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, 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 Policy paragraph 4(a) 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 a disputed domain name that is nearly identical to the LENNAR TITLE mark, omitting only a single character, and used the disputed domain name for a webpage with third-party advertising links. This targeting of Complainant Lennar Pacific Properties Management, LLC’s marks in a typical case of typosquatting 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. Respondent’s failure to reply to Complainant Lennar Pacific Properties Management, LLC’s cease and desist letter and the notification of these proceedings provides further evidence of bad faith. The Panel finds that Complainants have established the third element of paragraph 4(a) of 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 name <lennarttle.com> be transferred to Complainant Lennar Title, LLC. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: April 30, 2026

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

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