Westmore · UDRP DecisionLeennar.com
The Panel ordered transfer of <leennar.com> to Lennar Corporation. It found the domain confusingly similar to the registered LENNAR mark because it reproduced the mark with one additional letter “e”. The Complainants established a prima facie case that the Respondent lacked rights or legitimate interests, which the Respondent did not rebut. After reviewing the record concerning typosquatting, phishing, and fraudulent email use, the Panel also found registration and use in bad faith.
The timeline behind leennar.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 leennar.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates that an inactive website does not prevent a bad-faith finding where the domain is allegedly used behind the scenes for deceptive email. It also presents a straightforward single-letter typosquatting pattern directed at a company that conducts business through email addresses matching its principal domain.
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 Corporation v. rg sudardd Case No. D2026-1104 1. The Parties Complainants are Lennar Pacific Properties Management, LLC, and Lennar Corporation, United States of America (“United States”), represented by Slates Harwell Campbell, LLP, United States. Respondent is rg sudardd, United States. 2. The Domain Name and Registrar The Disputed Domain Name <leennar.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 13, 2026. On March 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On March 17, 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 (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainants on March 17, 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 17, 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 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 9, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on April 10, 2026. page 2 The Center appointed Richard W. Page as the sole panelist in this matter on April 22, 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 Since 1954, Complainants have developed, built, and sold homes in twenty-one (21) states in the United States. Complainants have offered real estate management, brokerage, development, construction, mortgage, and financial services under the LENNAR Mark since at least as early as 1973. In connection with these services, Complainants own and operate a website utilizing the LENNAR Mark, located at “www.lennar.com”. In addition, Complainants use the “[domain]@lennar.com” to conduct all email correspondence for the entirety of their business. Complainants are the owners of the following trademark registrations for the LENNAR Mark: United States Registration No. 3,108,401 for LENNAR on June 27, 2006 in international classes 35, 36, and 37; and United States Registration No. 3,477,143 for LENNAR on July 29, 2008 in international classes 36 and 37. Respondent’s registration of the Disputed Domain Name is virtually identical and/or confusingly similar to the LENNAR Mark in its entirety, with the addition of the letter “e” to “lennar”. The Disputed Domain Name was registered on February 3, 2026 and does not resolve to an active website. Further, it was utilized to send fraudulent emails impersonating the Complainants. 5. Parties’ Contentions A. Complainants Complainants contend that this is a typical case of typosquatting with a dose of phishing through fraudulent emails. Complainants submit that Respondent has made no bona fide offering of goods or services or legitimate use of the Disputed Domain Name. In addition, Respondent has not been commonly known by the Disputed Domain Name. Complainants allege that Respondent purports to offer services similar to those offered by Complainants in the regular course of their business. The Disputed Domain Name alone illustrates bad faith and an effort to fraudulently mislead consumers into believing that Respondent offers services that are offered by Complainants. Moreover, it is well settled that the practice of typosquatting itself constitutes evidence of bad faith. Complainants further allege that Respondent has been using the Disputed Domain Name in bad faith to spoof legitimate email addresses and to impersonate employees of Complainants, presumably to fraudulently redirect funds and/or materials and parts. Specifically, the Disputed Domain Name and related email addresses are being used to send email correspondence impersonating employees of Complainants to Complainants’ vendors. Complainants contend that they have satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. page 3 B. Respondent Respondent did not reply to the Complainants’ contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs the Panel as to the principles the Panel is to use in determining the dispute: “A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any rules and principles of law that it deems applicable.” Even though Respondent has failed to file a Response or to contest Complainants’ assertions, the Panel will review the evidence proffered by Complainants to verify that the three essential elements of the claims are met. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.3. Paragraph 4(a) of the Policy directs that Complainants must prove each of the following three elements: i) that the Disputed Domain Name registered by Respondent is identical or confusingly similar to the LENNAR Mark in which Complainants have rights; and, ii) that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and, iii that the Disputed Domain Name has been registered and is being used in bad faith. A. Identical or Confusingly Similar WIPO Overview 3.1, section 1.2.1 states that registration of a trademark, here the LENNAR Mark prima facie satisfies the threshold requirement of Complainants having trademark rights for purposes of standing to file a UDRP case. Complainants have shown rights in respect of the LENNAR Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. 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 LENNAR Mark and the Disputed Domain Name. WIPO Overview 3.1, section 1.7. The entirety of the LENNAR Mark is reproduced within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the LENNAR Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms, here the addition of the letter “e” to “lennar”, may bear on assessment of the second and third elements, the Panel finds the addition of such letter does not prevent a finding of confusing similarity between the Disputed Domain Name and the LENNAR Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. The Panel finds the first element of the Policy has been established. page 4 B. Rights or Legitimate Interests Paragraph 4(c) of the Policy allows three nonexclusive methods for the Panel to conclude that Respondent has rights or a legitimate interest in the Disputed Domain Name: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Disputed Domain Name or a name corresponding to the Disputed Domain Name in connection with a bona fide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Disputed Domain Name, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the LENNAR Mark. Although the overall burden of proof in UDRP proceedings is on Complainants, panels have recognized that proving that Respondent lacks rights or legitimate interests in the Disputed Domain Name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of Respondent. As such, where Complainants make out a prima facie case that Respondent lacks rights or legitimate interests, the burden of production on this element shifts to Respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the Disputed Domain Name (although the burden of proof always remains on Complainants). If Respondent fails to come forward with such relevant evidence, Complainants are deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds 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. Panels have held that the use of the Disputed Domain Name for illegitimate activity, here alleged to be typosquatting, phishing, and fraudulent email, 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 Paragraph 4(b) of the Policy sets forth four nonexclusive criteria for Complainants to show bad faith registration and use the Disputed Domain Name: (i) circumstances indicating that you [Respondent] have registered or you have acquired the Disputed Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Disputed Domain Name registration to Complainants who are the owners of the LENNAR Mark or to a competitor of Complainants, for valuable consideration in excess of your documented out-of-pocket costs directly related to the Disputed Domain Name; or (ii) you [Respondent] have registered the Disputed Domain Name in order to prevent the owner of the LENNAR Mark from reflecting the LENNAR Mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you [Respondent] have registered the Disputed Domain Name primarily for the purpose of disrupting the business of a competitor; or page 5 (iv) by using the Disputed Domain Name, you [Respondent] have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with the LENNAR Mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product on your website or location. 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 the Disputed Domain Name in bad faith. Panels have held that the use of the Disputed Domain Name for purposes other than to host a website may constitute bad faith. Such active (“behind the scenes”) uses are considered distinct from the passive holding doctrine, and can include a range of bad faith activity or scams such as typosquatting, phishing and sending email. Many such cases involve respondent’s use of the disputed domain name to send deceptive emails, e.g., to obtain sensitive or confidential personal information from actual or prospective customers and payment of fraudulent invoices. WIPO Overview 3.1, section 3.4. Panels have held that the use of the Disputed Domain Name for illegitimate activity, here claimed as typosquatting, phishing, and fraudulent email, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. The Panel finds that Complainants have established the third element 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 <leennar.com> be transferred to Lennar Corporation. /Richard W. Page/ Richard W. Page Sole Panelist Date: May 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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