Westmore · UDRP decision
WIPO · Case No. D2026-1537

Sprichard.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sprichard.com>. It found that S.P. Richards Company had established unregistered trademark rights in S.P. RICHARDS through longstanding use and evidence of secondary meaning, including website use since at least 1998. The Domain Name omitted only the final letter “s” and remained confusingly similar. The Panel found no rights or legitimate interests because Respondent offered no bona fide explanation and the website used Complainant’s mark in its tab and source code. It also found bad-faith targeting for illegitimate commercial gain through confusion. The apparent use on the website of contact details belonging to an actual print-services and workflow-optimization company provided a further indication of bad faith, although that company’s relationship to Respondent or the Domain Name was unclear.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-15
Panelist(s)
Badgley, Robert A.
Complainant
S.P. Richards Company
Respondent
Kristi Holtorf
Disputed domain(s)
sprichard.com
Domain history UDRP Intelligence

The timeline behind sprichard.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for sprichard.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of sprichard.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how longstanding commercial and online use can establish unregistered trademark rights and how website-level configuration can demonstrate deliberate targeting. Even though the public-facing site was apparently incomplete, use of the mark in the tab and source code, combined with a near-identical domain and unexplained third-party contact information, supplied evidence beyond the domain string itself.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-15
Panel
Badgley, Robert A.
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION S.P. Richards Company v. Kristi Holtorf Case No. D2026-1537 1. The Parties Complainant is S.P. Richards Company, United States of America (“United States”), represented by Central National Gottesman Inc., United States. Respondent is Kristi Holtorf, United States. 2. The Domain Name and Registrar The disputed domain name <sprichard.com> (the “Domain Name”) is registered with Automattic Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 10, 2026. On April 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On April 13, 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 (Knock Knock WHOIS Not There, LLC) and contact information in the Complaint. The Center sent an email to Complainant on April 15, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on the same day. 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 April 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 7, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on May 19, 2026. Respondent was afforded an additional five-day period to participate in the proceedings on May 21, 2026. Respondent did not submit any response. page 2 The Center appointed Robert A. Badgley as the sole panelist in this matter on June 3, 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 According to the Complaint: “Complainant owns and uses the domain [name] [<sprichards.com>], which directly corresponds to Complainant’s trade name and brand ‘S.P. Richards’ (the ‘Complainant’s Mark’). Founded in 1848, Complainant has over 175 years of continuous operations as a major wholesaler. For more than a century, Complainant has used the Complainant’s Mark in connection with its national wholesale distribution and logistics services, including the wholesale distribution of office supplies, janitorial and sanitation products, furniture, technology accessories, paper, and related business products, as well as associated warehousing, fulfillment, delivery, sales, dealer support, and supply-chain services.” “Through long-standing, continuous, and extensive use, the Complainant’s Mark has acquired distinctiveness and secondary meaning, and functions to identify the Complainant as the source of these services. For example, the Complainant has owned and continuously operated the domain [name] [<sprichards.com>] since the domain [name]’s registration on August 6, 1997, and has prominently displayed the Complainant’s Mark on this domain [name] since (as evidenced by Wayback Machine archives, included in an annex hereto), demonstrating decades-long use of the Complainant’s Mark in commerce and longstanding Internet presence associated exclusively with the Complainant.” [...] “The likelihood of confusion is further heightened by the Respondent’s use of the Complainant’s Mark within multiple configured fields of the Respondent’s associated website, including site titles and page metadata, including: - The homepage, - The HTML page title, and - The WordPress site title (visible via the Subscribe widget). These entries are not incidental metadata, but manually configured fields. That is, these fields require affirmative configuration by the site operator, and are not generated automatically by the registrar or hosting provider. Repeated, deliberate use of the Complainant’s Mark in multiple website configuration fields is inconsistent with any good-faith explanation. Instead, this affirmative configuration demonstrates intentional use of the Complainant’s Mark to convey a false affiliation with, and to pass itself off as, the Complainant. Rather than distinguishing the site from the Complainant, the Respondent’s conduct reinforces the false and misleading impression that the disputed domain and website are affiliated with, endorsed by, or operated by the Complainant.” Annexed to the Complaint are screenshots demonstrating Complainant’s use of the S.P. RICHARDS mark in commerce on its website since 1998. The Domain Name was registered on December 19, 2025. The Domain Name currently resolves to a website apparently incomplete which indicates that the business is located in Chicago, Illinois, and which invites visitors to “Contact Us”. The main page displays a “coming soon” message. page 3 According to Complainant: “Respondent’s bad faith is further evidenced by its continued use of the disputed domain name after Complainant provided notice of violation of Complainant’s rights and raised impersonation concerns. Prior to the filing of this Complaint, Complainant reported the Respondent’s conduct through multiple abuse and security channels, including notifications to the registrar and hosting provider regarding impersonation and misrepresentation associated with the disputed domain, as well as content-abuse reports submitted to the platform hosting the infringing website. (See, Annexes 8 and 9) Despite these notices, the Respondent failed to respond or to take corrective action and continued to use the disputed domain in a manner calculated to trade on the goodwill associated with the Complainant’s Mark.” [...] “Next, the disputed domain has active M[ail Exchange] records configured, including authorization for third-party mail servers to send email on behalf of the domain [name]. Such configuration is unnecessary for a passive or informational site and is consistent with preparation for impersonation-based email communications, a recognized indicator of bad faith under the Policy.” Annexed to the Complaint are screenshots corroborating the foregoing allegations. Respondent has not disputed any of the foregoing allegations or challenged any of the evidence submitted by Complainant. 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. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Name: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (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. A. Identical or Confusingly Similar The Panel finds that Complainant has unregistered rights in the trademark S.P. RICHARDS through use demonstrated in the record. In this respect, Complainant has provided evidence that its mark has acquired sufficient relevant secondary meaning in connection with Complainant’s services offered under the mentioned sign, including through the use of its website since at least 1998. The Panel also finds that the Domain Name is confusingly similar to that mark. The Domain Name incorporates the mark but omits the letter “s”. In the Panel’s view, the mark is clearly recognizable within the Domain Name. page 4 Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests Pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Name, among other circumstances, by showing any of the following elements: (i) before any notice to you [Respondent] 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 [Respondent] (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 [Respondent] 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. The Panel concludes that Respondent has no rights or legitimate interests in respect of the Domain Name. Respondent has not come forward to articulate, much less prove, any bona fide reason for registering this Domain Name which closely resembles Complainant’s longstanding trademark. The possibility that the Domain Name could have been registered as a mere coincidence strikes the Panel as exceedingly improbable. Rather, on this undisputed record showing, notably, the use of Complainant’s mark in the website tab and the page source code, the Panel finds it more likely than not that Respondent targeted Complainant and its mark when registering the Domain Name. Complainant has established Policy paragraph 4(a)(ii). C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy provides that the following circumstances, “in particular but without limitation”, are evidence of the registration and use of the Domain Name in “bad faith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Domain Name registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of its documented out of pocket costs directly related to the Domain Name; or (ii) that Respondent has registered the Domain Name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) that by using the Domain Name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel concludes, on the record provided here, that Respondent has registered and used the Domain Name in bad faith. The Panel incorporates herein its findings above in connection with the second element under the Policy. Specifically, the Panel finds it more likely than not that Respondent targeted Complainant’s mark for purposes for deriving illegitimate commercial gain by creating a likelihood of confusion with Complainant, as envisaged in the above-quoted Policy paragraph 4(b)(iv). page 5 The Panel further notes that the postal address and email address listed on the Domain Name website appear to correspond to an actual company that is in the business of print services and workflow optimization. 1 It is unclear whether this company is related to, aware of, or involved with, the Domain Name or Respondent. The apparent use of that company’s contact details is, on balance, a further indication of Respondent’s registration and use of the Domain Name in bad faith. Noting the fact that this company appears to conduct business via its own website, there is no apparent reason why it would register or use the Domain Name that is so confusingly similar to Complainant’s own website and unregistered trademark rights. Complainant has established Policy paragraph 4(a)(iii). 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 <sprichard.com> be transferred to Complainant. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: June 15, 2026 1 Noting in particular the general powers of a panel articulated inter alia in paragraphs 10 and 12 of the Rules, it has been accepted that a panel may undertake limited factual research into matters of public record if it would consider such information useful to assessing the case merits and reaching a decision, in particular to affirm or corroborate a party’s contention. WIPO Overview 3.1, section 4.8.

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

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