Lennarttitle.com

The timeline behind lennarttitle.com

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

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 Lennar Pacific Properties Management, LLC, Lennar Title, LLC v. Morgan Bolden, lennarttitle.com Case No. D2026-1082 1. The Parties Complainants are Lennar Pacific Properties Management, LLC, United States of America (“United States”), and Lennar Title, LLC, United States, represented by Slates Harwell Campbell, LLP, United States. Respondent is Morgan Bolden, lennarttitle.com, United States. 2. The Domain Name and Registrar The disputed domain name <lennarttitle.com> 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 that differed from the named Respondent (“Redacted”) 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 14, 2026. page 2 The Center appointed Jeffrey D. Steinhardt as sole panelist in this matter on April 20, 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 January 19, 2024 and does not presently resolve to an active webpage. 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. 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 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 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 addition of an extra letter “t”. 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. The record in this case shows that the disputed domain name does not resolve to an active webpage. The Panel finds that such non-use 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. Respondent’s use of “lennarttitle.com” as the organization name when registering the disputed domain name does not confer rights or legitimate interests on Respondent under the circumstances of this case. 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, adding only a single character in a typical case of typosquatting. This targeting of Complainant Lennar Pacific Properties Management, LLC’s marks is clear evidence of bad faith. The Panel finds that Respondent has taken unfair advantage of 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 would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in 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 Property 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 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 <lennarttitle.com> be transferred to Complainant Lennar Title, LLC. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: May 4, 2026

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