Westmore · UDRP DecisionUspossinilighting.com
The Panel ordered transfer of <uspossinilighting.com>. It found the domain confusingly similar to Complainant’s registered POSSINI marks because POSSINI remained recognizable despite the addition of “us” and “lighting.” Respondent lacked rights or legitimate interests because the domain was used for a deceptive ecommerce website displaying Complainant’s marks, copied product photographs, and purported discounted products without authorization. The Panel also found registration and use in bad faith under Policy paragraphs 4(b)(iii) and 4(b)(iv), concluding that Respondent knew of and targeted Complainant and used the site to attract Internet users for commercial gain through confusion and to disrupt Complainant’s business.
The timeline behind uspossinilighting.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 uspossinilighting.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a strong impersonation and deceptive-ecommerce fact pattern in which the same website evidence supported both the absence of legitimate interests and bad faith. The copied marks, identical product photographs, purported discounted sales, and brand-plus-industry domain collectively connected the registration directly to Complainant rather than merely showing abstract similarity.
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 Lamps Plus, Inc. v. Shorta Angelo Case No. D2026-1480 1. The Parties Complainant is Lamps Plus, Inc., United States of America (“U.S.” or “United States”), represented by Sheppard, Mullin, Richter & Hampton, LLP, United States. Respondent is Shorta Angelo, United States. 2. The Domain Name and Registrar The disputed domain name <uspossinilighting.com> (the “Domain Name”) 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 April 7, 2026. On April 8, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On April 9, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to Complainant on April 9, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. 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 Respondent of the Complaint, and the proceedings commenced on April 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 3, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on May 7, 2026. page 2 The Center appointed John C. McElwaine as the sole panelist in this matter on May 11, 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 Complainant is a United States-based company in the lighting, home furnishing and décor industry, founded in 1976 and headquartered in Chatsworth, California, U.S. Complainant sells lighting, lamps, and related products and has operated an ecommerce business from their official website at “www.lampsplus.com” since 1997. Relevant to this matter, Complainant owns the following trademark registrations incorporating the term POSSINI: - POSSINI, U.S. Registration No. 2,627,737, registered October 1, 2002, in International Classes 11 and 21; and - POSSINI EURO DESIGN, Registration No. 5,605,588, registered November 13, 2018, in International Class 11. These registered trademarks are referred to herein as the “POSSINI Marks”. The Domain Name was registered on June 19, 2025. It resolves to an ecommerce website that prominently uses Complainant’s POSSINI Marks and photographs of Complainant’s products. The website incorporates POSSINI Marks on its landing page, in product descriptions, and on product tags. The website moreover reproduces product images identical to those on Complainant’s official site, and Respondent purports to sell Complainant’s products at a highly discounted price. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. With respect to the first element of the Policy, Complainant contends that the Domain Name is confusingly similar to trademarks in which Complainant has rights. Complainant asserts that it has longstanding trademark rights in POSSINI Marks through both use and registration, and it argues that the Domain Name incorporates the distinctive term “possini” in its entirety. According to Complainant, Respondent’s addition of terms “us” and “lighting” to the Domain Name and registration as a “.com” do not prevent a finding of confusing similarity with Complainant’s POSSINI Marks. Indeed, Complainant argues that Respondent added the “us” and “lighting” terms to the Domain Name to connect the site to Complainant’s brand and confuse Internet users. With respect to the second element of the Policy, Complainant asserts that Respondent has no rights or legitimate interests in the Domain Name. Complainant states that it has never authorized or licensed Respondent to use the POSSINI Marks and that Respondent is not affiliated with Complainant in any way. Complainant also notes that there is no evidence that Respondent was commonly known by “US Possini Lighting” when it registered the Domain Name. According to Complainant, Respondent is using POSSINI Marks to trade on Complainant’s goodwill and divert traffic from Complainant’s site to Respondent’s site, which is not a bona fide offering of goods or services. In support of this, Complainant provides evidence that Respondent prominently displays POSSINI Marks on its landing page and in product descriptions, and that Respondent purports to sell unauthorized or counterfeit products at a highly discounted price. page 3 Complainant specifically notes that Respondent displays photographs taken from Complainant’s website onto its site (such as the “Possini Castille 22” “Wide Bronze Rustic Modern Pendant Light for $99.99”). Moreover, Complainant argues that Respondent includes terms “us” and “lighting” in the Domain Name to impersonate or imply an affiliation with Complainant. In Complainant’s view, Respondent seeks to deceive customers and divert business, which cannot establish any right or legitimate interest in the Domain Name. Lastly, with respect to the third element of the Policy, Complainant contends that Respondent registered and is using the Domain Name in bad faith. Complainant’s POSSINI Marks are distinctive, trademarked terms that it has used in commerce for over 25 years prior to Respondent’s registration of the Domain Name in June of 2025. Complainant argues that Respondent’s prominent display of photographs of Complainant’s products on its landing page evidences Respondent’s actual knowledge of POSSINI Marks prior to registering the Domain Name. Complainant further argues that Respondent’s use of POSSINI Marks in their entirety in the Domain Name and Respondent’s registration of the Domain Name under a registration privacy service indicate Respondent’s bad faith. Complainant emphasizes that Respondent seeks to impersonate Complainant, confuse Internet users, and divert traffic away from Complainant’s official channels. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Even though Respondent has defaulted, paragraph 4 of the Policy requires that, in order to succeed in this UDRP proceeding, Complainant must still prove its assertions with evidence demonstrating: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the Domain Name; and (iii) the Domain Name has been registered and is being used in bad faith. Because of Respondent’s default, the Panel may accept as true the reasonable factual allegations stated within the Complaint and may draw appropriate inferences therefrom. See St. Tropez Acquisition Co. Limited v. AnonymousSpeech LLC and Global House Inc., WIPO Case No. D2009-1779; Bjorn Kassoe Andersen v. Direction International, WIPO Case No. D2007-0605; see also paragraph 5(f) of the Rules (“If a Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the complaint”). Having considered the Complaint, the Policy, the Rules, the Supplemental Rules, and applicable principles of law, the Panel’s findings on each of the above- cited elements are as follows. 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 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. Complainant has established its rights in the POSSINI and POSSINI EURO DESIGN trademarks through its U.S. trademark registrations (U.S. Reg. No. 2,627,737 for POSSINI and U.S. Reg. No. 5,605,588 for POSSINI EURO DESIGN). Ownership of a nationally registered trademark is generally sufficient to establish a complainant’s rights in the mark under the Policy, irrespective of the jurisdiction of registration or the extent of the complainant’s geographic business. WIPO Overview 3.1, section 1.2.1. page 4 Here, the Domain Name incorporates Complainant’s distinctive POSSINI mark with the additional “us” prefix and “lighting” term at the end of the Domain Name. Complainant’s POSSINI trademark is clearly recognizable within the Domain Name, and the inclusion of other terms does not prevent a finding of confusing similarity for the purposes of the Policy. See WIPO Overview 3.1, section 1.8; See also Barclays Bank PLC v. David Neilson, WIPO Case No. D2012-0511. Consequently, the Panel finds that the Domain Name is confusingly similar to Complainant’s POSSINI Marks for which Complainant owns valid trademark rights. Complainant has satisfied paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Under the Policy’s second element, paragraph 4(a)(ii), Complainant has the burden of establishing that Respondent has no rights or legitimate interests in the Domain Name. Complainant needs to make a prima facie showing on this element, at which point the burden of production shifts to Respondent to present evidence that it has rights or legitimate interests in the Domain Name. If Respondent has failed to do so, Complainant is deemed to have satisfied its burden under paragraph 4(a)(ii) of the Policy. See Vicar Operating, Inc. v. Domains by Proxy, Inc. / Eklin Bot Systems, Inc., WIPO Case No. D2010-1141. In this case, Complainant has put forward a compelling prima facie case that Respondent has no rights or legitimate interests in the Domain Name. Complainant states that it has never authorized or permitted Respondent to use the POSSINI Marks, and there is no evidence of a relationship between the Parties that would give rise to any license or permission for Respondent to use these trademarks. Respondent is not known by the Domain Name or by any name corresponding to “possini” or “uspossinilighting”. The only name associated with Respondent is “Shorta Angelo”, which has no connection to the term “possini” or the Domain Name. There is likewise no evidence that Respondent has acquired any trademark or service mark rights in “uspossinilighting” or any similar term. Respondent has not rebutted Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the Domain Name, such as those enumerated in the Policy 1 or otherwise. Instead, the record demonstrates that Respondent has engaged in conduct that negates any claim to legitimate interests. Specifically, Respondent has operated a website that impersonates or suggests an association with Complainant by using the POSSINI Marks in the Domain Name and photographs, identical to those on Complainant’s website, purporting to sell Complainant’s products at a discounted price, thereby misleading Internet users into believing there is an affiliation with or authorization by Complainant. Such impersonation is inconsistent with bona fide use and constitutes clear evidence of an intent to capitalize on Complainant’s reputation and goodwill. Panels have consistently held that impersonation of a complainant or its business through a domain name and associated website negates any claim to rights or legitimate interests. See On AG, On Clouds GmbH v. Nguyen Luu, Withheld for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf, Vuong Hoang, AN NGUYEN, NEO CORP., and Ngoc Tam Nguyen, WIPO Case No. D2021-1714 (“a [disputed domain name’s] use cannot be deemed bona fide if the disputed domain names constitute trademark infringement”), citing Sai Machine Tools Pvt. Ltd. v. Mr. Sudhir Jaiswal, Shree Sai Extrusion Technik Pvt. Ltd, WIPO Case No. D2018-2560 (“bona fide use is predicated on honest adoption of the name” and respondent failed to show such honest adoption; rather, respondent’s use was infringing and therefore not bona fide). 1 The Policy, paragraph 4(c), provides a non-exhaustive list of circumstances in which a respondent could demonstrate rights or legitimate interests in a disputed domain name: “(i) before any notice to you of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or (ii) you (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or (iii) you are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.” page 5 Respondent, having defaulted, has not submitted any evidence to rebut Complainant’s prima facie case. There is nothing in the record to suggest that any of the circumstances enumerated in Policy, paragraph 4(c) (or any other basis for rights or legitimate interests) would apply. Respondent’s use of the Domain Name is not in connection with a bona fide offering of goods or services, but rather in connection with a deceptive ecommerce site that infringes on Complainant’s rights and sells either an unauthorized or counterfeit product. Respondent is not making any legitimate noncommercial or fair use of the Domain Name but rather seeks to mislead Internet users for commercial gain. The Panel concludes that Complainant’s unrebutted evidence establishes that Respondent has no rights or legitimate interests in the Domain Name. Therefore, the second element of the Policy is satisfied. C. Registered and Used in Bad Faith Under paragraph 4(a)(iii) of the Policy, Complainant must show that Respondent registered and is using the Domain Name in bad faith. The Policy provides a non-exhaustive list of circumstances that shall be considered evidence of bad faith (Policy, paragraph 4(b)). Two of these illustrative circumstances are directly relevant here. First, paragraph 4(b)(iii) considers it evidence of bad faith if a respondent has registered a domain name primarily for the purpose of disrupting the business of a competitor. Second, paragraph 4(b)(iv) provides that bad faith is demonstrated where a respondent, by using the domain name, has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the website or of a product or service on that website. Bad faith registration can exist when a respondent “knew or should have known” of a complainant’s trademark rights and nevertheless registered a domain name in which it had no right or legitimate interest. See Accor S.A. v. Kristen Hoerl, WIPO Case No. D2007-1722. Here, the incorporation of Complainant’s unique and trademarked brand term, “Possini”, paired with the nature of Respondent’s website featuring photographs of Complainant’s products, identical to those on Complainant’s website, available at a discounted price leaves no doubt that Respondent knew of and targeted Complainant’s mark when it registered the Domain Name in June of 2025. Respondent’s choice of the Domain Name was not coincidental; it plainly intended to give Internet users the false impression that the Domain Name and corresponding website are owned by, operated by, or affiliated with Complainant. In the view of the Panel, Respondent’s deliberate impersonation of Complainant demonstrates that Respondent registered the Domain Name with Complainant’s trademark firmly in mind and with the intention of exploiting it. This supports a finding of bad faith registration. See WIPO Overview 3.1, section 3.2.2 (noting that panels may find bad faith where a respondent knew or should have known of a complainant’s mark and nevertheless registered a domain name incorporating that mark). There is no explanation for Respondent to have chosen to register the Domain Name other than to intentionally trade off the goodwill and reputation of Complainant’s trademark or otherwise create a false association with Complainant. With no response from Respondent, Complainant’s claim concerning Respondent’s scheme is undisputed. Turning to the use of the Domain Name, by operating an online store that closely imitates Complainant’s official website, Respondent exhibits an intent to confuse and mislead Internet users for commercial gain. Respondent’s website prominently displays Complainant’s POSSINI Marks, offers Complainant’s exact products, uses photographs from Complainant’s website, and generally creates a false impression of being a legitimate ecommerce site. Internet users are thus likely to be lured to Respondent’s site on the pretense that they are visiting a genuine store associated with Complainant, when in fact they are dealing with an unrelated entity. This is bad faith use of a domain name within the meaning of Policy, paragraph 4(b)(iv). In addition, such conduct inevitably disrupts Complainant’s business (e.g., by diverting potential sales or damaging customer trust), which is also evidence of bad faith under Policy, paragraph 4(b)(iii). See also WIPO Overview 3.1, section 3.1.4 (evidence of mimicking the complainant’s website is evidence that a respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark). page 6 As detailed above, the Panel finds on the record before it that Respondent’s intention in registering the Domain Name was to attract, for commercial gain, Internet users to Respondent’s website by creating a likelihood of confusion with the POSSINI Marks as to the source, sponsorship, affiliation, or endorsement of its website or location or of a product or service on its website or location, and its use has the likely effect of disrupting Complainant’s business. The panel also notes that Respondent’s failure to assert any defense or claim of entitlement to the Domain Name underscores Respondent’s failure to assert any rights or legitimate interests in the Domain Name. Thus, the Panel holds that Complainant has met its burden of providing sufficient evidence that Respondent registered and is using the Domain Name in bad faith under paragraphs 4(b)(iii) and (iv) of the Policy. Accordingly, 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 Domain Name, <uspossinilighting.com>, be transferred to Complainant. /John C McElwaine/ John C McElwaine Sole Panelist Date: May 25, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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