Westmore · UDRP DecisionThecityelectricsupply.com
The Panel ordered transfer of <thecityelectricsupply.com>. It found the domain confusingly similar to the Complainant’s CITY ELECTRIC SUPPLY mark, that the Respondent lacked rights or legitimate interests, and that registration and use were in bad faith. The decisive conduct was use of the domain for a phishing email displaying the Complainant’s mark in logo form to impersonate the Complainant.
The timeline behind thecityelectricsupply.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 thecityelectricsupply.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that a domain formed by adding “the” to a complainant’s full mark and official domain can support findings across all three UDRP elements when accompanied by phishing and logo-based impersonation. The lack of an active website did not prevent transfer because the domain’s email use supplied direct evidence of abusive conduct.
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 City Electric Supply Company v. jun cheng koh Case No. D2026-1314 1. The Parties The Complainant is City Electric Supply Company, United States of America (“United States” or “U.S.”), internally represented. The Respondent is jun cheng koh, Singapore. 2. The Domain Name and Registrar The disputed domain name <thecityelectricsupply.com> is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 26, 2026. On March 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 27, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 31, 2026, 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 amendment to the Complaint on March 31, 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 the Respondent of the Complaint, and the proceedings commenced on April 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 27, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 30, 2026. page 2 The Center appointed Dawn Osborne as the sole panelist in this matter on May 5, 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 The Complainant conducts business under the mark CITY ELECTRIC SUPPLY, which it uses in connection with the distribution of electrical products and services. The Complainant has owned U.S. Trademark Registration No. 4,243,881 for the mark CITY ELECTRIC SUPPLY for its distribution services relating to electrical products since November 20, 2012, with first use recorded back to 1983. The Complainant operates its website at “cityelectricsupply.com”. The disputed domain name, registered on February 26, 2026, does not point to an active website, but has been used for a phishing e-mail which used the Complainant’s mark in its logo form to impersonate the Complainant. 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 is confusingly similar to the Complainant’s prior trademark incorporating the Complainant’s mark in its entirety with the addition of the generic word “the” and the generic Top-Level Domain “.com” which does not prevent said confusing similarity. The Respondent has no rights or legitimate interests in the disputed domain name, is not commonly known by it and is not authorised by the Complainant. The disputed domain name does not point to an active website and has been used for a fraudulent e-mail scheme using the Complainant’s mark and logo to deceive Internet users. Such fraudulent use of a domain name to impersonate and create a false connection with the Complainant is not a legitimate use of the domain name or a bona fide offering of goods and services. Phishing is bad faith per se. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. page 3 The Complainant has 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 the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms, here “the”, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the 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. 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. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s 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 disputed domain name differs from the Complainant’s trademark and primary domain name by the word “the” which could easily be mistaken by Internet users misremembering the Complainant’s domain name and appears to be designed to be deliberately confusing. The disputed domain name, which is confusingly similar to the Complainant’s mark and primary domain name, carries a risk of implied affiliation with the Complainant. WIPO Overview 3.1, section 2.5.1. The disputed domain name does not point to an active website but has been used for a phishing e-mail which used the Complainant’s mark in its logo form to impersonate the Complainant. Panels have held that the use of a domain name for illegal activity, here phishing, 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 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. In the present case, the Panel notes that the disputed domain name appears to be designed to be deliberately confusing, being highly similar and easily mistaken for the Complainant’s primary domain name page 4 <cityelectricsupply.com>. The Respondent has used the disputed domain name for a phishing e-mail which used the Complainant’s mark in its logo form to impersonate the Complainant. 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 held that the use of a domain name for illegal activity, here phishing, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The Panel finds that the Complainant has 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 <thecityelectricsupply.com> be transferred to the Complainant. /Dawn Osborne/ Dawn Osborne Sole Panelist Date: May 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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