Westmore · UDRP decision
WIPO · Case No. D2026-1152

Missmouths.org

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <missmouths.org>. It found the domain confusingly similar to the Complainant’s registered MISS MOUTH’S mark because it reproduced the mark apart from the apostrophe. The Respondent lacked rights or legitimate interests because there was no authorization or affiliation, the domain did not signal a reseller relationship, and the website’s inconspicuous disclaimer did not identify its operator. The Panel also found bad-faith registration and use because the domain was registered after the Complainant established its rights and was used with product photographs and trademark references in a manner intended to confuse users for commercial gain.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-08
Panelist(s)
O'Brien, Colin T.
Complainant
Frosty Dream, Inc.
Respondent
Louis Blake
Counsel
Frankfurt Kurnit Klein · Selz, PC
Disputed domain(s)
missmouths.org
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind missmouths.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 missmouths.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 missmouths.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that removing punctuation from a trademark generally does not avoid confusing similarity and that a disclaimer alone may not legitimize a trademark-form domain used for a product-focused website. The placement and content of the disclaimer, the domain’s failure to signal an independent reseller relationship, and the surrounding website presentation were central to the Panel’s conclusions.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-05-08
Panel
O'Brien, Colin T.
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Frosty Dream, Inc. v. Louis Blake Case No. D2026-1152 1. The Parties The Complainant is Frosty Dream, Inc., United States of America (“United States” or “U.S.”), represented by Frankfurt Kurnit Klein & Selz, PC, United States. The Respondent is Louis Blake, United States. 2. The Domain Name and Registrar The disputed domain name <missmouths.org> is registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 17, 2026. On March 18, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 19, 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 (Redacted For Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on the same date, 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 24, 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 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 16, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 17, 2026. The Center appointed Colin T. O'Brien as the sole panelist in this matter on April 23, 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. page 2 4. Factual Background The Complainant offers laundry and cleaning products. The Complainant is the owner of the following United States trademark registrations: - MISS MOUTH’S Reg. No. 5,203,016 registered on May 16, 2017, in Class 3 for “stain removers; stain removing preparations”; and - MISS MOUTH’S MESSY STEPPERS Reg. No. 7,824,290, registered on June 10, 2025, in Class 3 for “cleaning preparations for shoes; wipes impregnated with a cleaning preparation; disposable wipes impregnated with cleansing compounds for use on shoes.” The Complainant first commenced use of the MISS MOUTH’S trademark in U.S. commerce in 2016. The website corresponding to the disputed domain name uses the MISS MOUTH’S trademark and uses photographs of MISS MOUTH’S products, inviting users to “check prices”. The website has a disclaimer stating “This website is not affiliated with Miss Mouth's brand.” The disputed domain name was registered on August 8, 2025. 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 consists of the Complainant’s exact MISS MOUTH’S trademark, followed by the generic Top Level Domain(“gTLD”) “.org”. The Respondent is not commonly known by the disputed domain name or the MISS MOUTH’S trademark, and has not acquired any legitimate trademark or service mark rights in the disputed domain name. The Respondent’s use of the disputed domain name for the website is based on the trademark value of the MISS MOUTH’S trademark. On information and belief, the Respondent is profiting from the value of MISS MOUTH’S trademarks by using the disputed domain name for its commercial gain. The Respondent registered or acquired the disputed domain name in bad faith. Given that the website is designed to appear as a legitimate website of the Complainant, it is beyond question that the Respondent was aware of the Complainant’s rights in its MISS MOUTH’S trademarks at the time the disputed domain name was registered. The Respondent has had years of constructive notice of the Complainant’s rights in the MISS MOUTH’S Trademarks. The disputed domain name is clearly related to the Complainant’s MISS MOUTH’S trademarks and brand. On information and belief, the Respondent has intentionally attempted to attract, for its commercial gain, Internet users to the Respondent’s website by creating a likelihood of confusion with the Complainant’s MISS MOUTH’S trademarks. page 3 The bad faith of the Respondent is evidenced by its use of the Complainant’s identical MISS MOUTH’S trademark in the disputed domain name and the unauthorized and infringing use of the Complainant’s MISS MOUTH’S trademarks throughout the website to give “color of legitimacy” to its unauthorized and infringing website. The Respondent is clearly seeking to profit from the unauthorized association with the Complainant’s MISS MOUTH’S trademarks. In light of the confusing similarity between the disputed domain name and the Trademark, Internet users who encounter the disputed domain name will be confused as to the source, sponsorship, affiliation or endorsement of the disputed domain name and the website. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The Complainant has demonstrated it owns registered trademark rights in the MISS MOUTH’S mark. The disputed domain name reproduces the Complainant’s mark almost entirely, save the apostrophe. The gTLD “.org” is viewed as a standard registration requirement and as such is typically disregarded under the first element confusing similarity test. Accordingly, the disputed domain name is confusingly similar to a mark in which the Complainant has rights. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), sections 1.7 and 1.11.1, and Hoffmann-La Roche AG v. Domain Admin, Privacy Protection Service INC d/b/a PrivacyProtect.org / Conan Corrigan, WIPO Case No. D2015-2316. Accordingly, the Panel finds that the Complainant has satisfied paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests The Complainant has presented a prima facie case that the Respondent has no rights or legitimate interests in respect of the disputed domain name and has not been commonly known by the disputed domain name. The There is no evidence that the Respondent was ever authorized to sell the Complainant’s products nor was it ever affiliated with the Complainant. Further, the Respondent’s use of the disputed domain name does not comply with Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. Although the website at the disputed domain name features a disclaimer of no affiliation with the Complainant at the bottom of the page, such disclaimer is far from prominent and does not actually disclose the operator of the website. Moreover, the disputed domain name itself does not signal a reseller relationship but merely removes an apostrophe from the Complainant’s trademark. Rather it appears the Respondent has set up the website in order to take unfair advantage of the likelihood of confusion with the Complainant as regards the source or endorsement of the website. After a complainant has made a prima facie case, the burden of production shifts to a respondent to present evidence demonstrating rights or legitimate interests in the domain name. See, e.g., Croatia Airlines d.d. v. Modern Empire Internet Ltd., WIPO Case No. D2003-0455; and WIPO Overview 3.1, section 2.1. Here, the Respondent has provided no evidence of any rights or legitimate interests in the disputed domain name. page 4 In the absence of any evidence rebutting the Complainant’s prima facie case indicating the Respondent’s lack of rights or legitimate interests in respect of the disputed domain name, the Panel finds that the Complainant has satisfied paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The disputed domain name was registered years after the Complainant first registered and used the MISS MOUTH’S marks. The evidence on the record provided by the Complainant is sufficient to satisfy the Panel that, at the time the disputed domain name was registered, the Respondent undoubtedly knew of the Complainant’s MISS MOUTH’S mark. Further, the Panel finds the use of the disputed domain name by the Respondent is in bad faith. Paragraph 4(b)(iv) of the Policy states that evidence of bad faith may include a respondent’s use of a domain name to intentionally attempt to attract, for commercial gain, Internet users to the respondent’s website or other online location, by creating a likelihood of confusion with the complainant’s mark. The evidence – including the website content and composition of the disputed domain name – shows that the Respondent has created a website at the disputed domain name with the intention to confuse unsuspecting Internet users into believing that the disputed domain name is operated by the Complainant. In the absence of any evidence or explanation from the Respondent, the Panel finds that the registration and use of the disputed domain name has been for bad faith purposes. Accordingly, the Panel finds that the Complainant has satisfied paragraph 4(a)(iii) 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 <missmouths.org> be transferred to the Complainant /Colin T. O'Brien/ Colin T. O'Brien Sole Panelist Date: May 8, 2026

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

Beyond the decision

What Westmore sees around missmouths.org

The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

Connected to Westmore UDRP Intelligence
116,042 decisions · citations · panelists · parties · domain history
Eleanor · UDRP intelligence
Ask Eleanor about this decision
Ask Eleanor about this decision

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.

Unlocking Eleanor for this case uses 1 of your complimentary Intelligence unlocks· 3 remaining

Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.

Westmore Professional · Unlock the intelligence

The decision is only the beginning.

You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.

Citation Intelligence
How this decision is cited and treated across the corpus.
Panelist Intelligence
The panel's tendencies, outcomes and reasoning patterns.
Domain History
Ownership chronology — creation vs. respondent acquisition.
Opposing-Party Research
Complainant, counsel and portfolio context.
Independent Case Review
Eleanor challenges your filing before the other side does.
Professional Matters
Open, research and manage matters end to end.
$395/month
Unlock Westmore Professional Annual & firm seats available · cancel anytime
Take the next step
Westmore UDRP · find the right service

Westmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

Essential cookies only. Nothing is sold or shared.