Westmore · UDRP DecisionSttimothyswilson.org
The Panel ordered transfer of <sttimothyswilson.org>. It found unregistered rights in ST. TIMOTHY’S WILSON based on the Complainant’s longstanding use and the Respondent’s targeting and impersonation. The Respondent lacked rights or legitimate interests because it did not rebut the Complainant’s prima facie case and had used the domain for a copycat site. Bad faith was established by the site’s impersonation of the Complainant, solicitation of donations, and use of confusion for commercial gain. Changing the site to gambling-related content after notice of the dispute did not cure the bad faith and was viewed as further indicating awareness of improper conduct.
The timeline behind sttimothyswilson.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 sttimothyswilson.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a complainant can recover a lapsed former domain despite relying on an unregistered mark. The Panel treated longstanding use together with the respondent’s highly specific targeting as sufficient to establish standing. It also demonstrates that changing an impersonating website after receiving notice of a UDRP complaint does not erase earlier bad-faith use and may reinforce an inference that the respondent understood the impropriety of the 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 Saint Timothy’s Episcopal Church v. anggi laricci Case No. D2026-1428 1. The Parties The Complainant is Saint Timothy’s Episcopal Church, United States of America (“United States”), represented by Smith, Anderson, Blount, Dorsett, Mitchell & Jernigan, LLP, United States. The Respondent is anggi laricci, Indonesia. 2. The Domain Name and Registrar The disputed domain name <sttimothyswilson.org> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 2, 2026. On April 4, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 7, 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, DomainsByProxy.com”) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 8, 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 amended Complaint on April 10, 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 April 14, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 4, 2026. The Respondent did not file a formal response but sent email communications to the Center on April 16, 2026. page 2 The Center appointed David Stone as the sole panelist in this matter on May 7, 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 is one of the oldest churches in Wilson, North Carolina, United States of America and has been providing religious, educational and pastoral services for generations. The Complainant has used the ST. TIMOTHY’S WILSON mark (the “Mark”) when providing its various religious, educational and pastoral services for at least two decades. The disputed domain name was registered on September 24, 2003. From 2003 to 2025, the Complainant owned the disputed domain name, and which previously hosted the Complainant’s official website. The Complainant asserts it lost control of the disputed domain name when it missed the deadline to renew the disputed domain name in late 2025. Despite the Complainant’s efforts to reclaim the disputed domain name once it realized its error, the Registrar sold the disputed domain name to the Respondent. The Complainant now owns the domain <sttimothyswilson.com>, which currently hosts the Complainant’s official website. The Respondent seemingly acquired the disputed domain name after the Complainant registration lapsed in 2025. The Complainant has provided evidence that the Respondent previously hosted at the disputed domain name a website that was highly similar in formatting and content to the Complainant’s official website, including displaying the Complainant’s name, address and telephone number and a photograph of the Complainant’s church building. As of April 14, 2026, that website remained accessible via the disputed domain name. At the date of this Decision, the disputed domain name now hosts a different website that contains no reference to the Complainant but rather redirects to a gambling website. 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. Under the first element, the Complainant contends that the disputed domain name is identical or confusingly similar to the Mark. Under the second element, the Complainant contends that the Respondent is not commonly known by the disputed domain name and does not hold any trademark or service marks in the disputed domain name. Further, the Complainant contends that the website hosted by the Respondent at the disputed domain name has a donation link that could be used to divert Internet users’ funds that are intended for the Complainant and the Respondent is thereby using the disputed domain name to redirect Internet users to the disputed domain name for commercial gain. Under the third element, the Complainant contends that the Respondent has intentionally attempted to attract Internet users to its website by creating a likelihood of confusion with the Mark including because the Respondent falsely lists the Complainant’s addresses and phone number on the website hosted at the disputed domain name. The Complainant contends that this demonstrates intentional deception and bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions but instead stated in its submission to the Center on April 16, 2026 “could you please double check again, because content of this domain already page 3 remake” and attached a screenshot. This screenshot showed that the content of the website hosted at the disputed domain name had changed so that it no longer contained references to the Complainant and no longer had significant similarities to the Complainant’s official website. The content of the new website hosted at the disputed domain name related to online gambling. 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. The Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. This is in view of: (i) the Complainant’s long-standing use of the Mark, including between 2003 and 2025 in relation to the disputed domain name; and (ii) the Respondent's own conduct in targeting the Mark and impersonating the Complainant, including copying in large part the Complainant’s website and listing on that website the Complainant’s address and phone number. WIPO Overview 3.1, section 1.3. The entirety of the Mark is reproduced within the disputed domain name (albeit without an apostrophe which for technical reasons is unable to be reproduced in a domain name). Accordingly, the disputed domain name is identical to the Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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. Further, panels have held that the use of a domain name for illegitimate activity, here, a claimed copycat site, passing off, or other types of fraud 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. page 4 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 Respondent used the disputed domain name to host a website that appeared to impersonate the Complainant and request donations on its behalf. Upon being notified of the Complaint, the Respondent promptly changed the website hosted at the disputed domain name so that its content was unrelated to 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. The Panel finds that the content of the website previously hosted at the disputed domain name is strongly suggestive of bad faith because it is evidence of the Respondent seeking to cause confusion. The nature of the Respondent’s previous website and its purporting to request donations on behalf of the Complainant shows an intention of the Respondent to confuse and thereby attract users to its website for commercial gain. Further, panels have held that the use of a domain name for illegitimate activity, here a claimed copycat site, passing off, or other types of fraud constitutes bad faith. WIPO Overview 3.1, section 3.4. Furthermore, the Respondent has not substantively rebutted any of the Complainant's contentions, which casts additional doubt on the nature of its conduct. WIPO Overview 3.1, section 3.2.1. Having reviewed the record, the Panel concludes that the actions of the Respondent in choosing the disputed domain name were aimed at attracting, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s Mark. The fact that the Respondent changed the content of the website at the disputed domain name after being notified of this dispute does not alter the Panel’s finding as such continues to indicate that the Respondent is trading off the Complainant’s Mark for financial gain and, if anything, the prompt change demonstrates that the Respondent was aware of the improper nature of its conduct. The Panel therefore concludes that the disputed domain name was registered and used in bad faith. 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 <sttimothyswilson.org> be transferred to the Complainant. /David Stone/ David Stone Sole Panelist Date: May 21, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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