Westmore · UDRP DecisionGlemnede.com
The Panel ordered transfer of <glemnede.com>. It found the domain confusingly similar to the GLENMEDE mark because it merely inverted the letters “n” and “m”; found no rights or legitimate interests because the unauthorized website displayed the GLENMEDE mark and logo while purporting to offer financial services without disclosing its lack of affiliation; and found bad-faith registration and use because the Respondent used the domain to attract Internet users for commercial gain through confusion with the Complainant’s mark.
The timeline behind glemnede.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 glemnede.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a direct typosquatting and impersonation pattern in which a two-letter transposition was combined with a website reproducing the trademark owner’s branding and offering services in the same field. The case is particularly useful because the Panel did not rely solely on the misspelled domain: the copied mark and logo, financial-services offering, lack of affiliation disclosure, priority of rights, and absence of a rebuttal collectively supported all three UDRP elements.
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 The Glenmede Trust Company, N.A. v. chikezie Egbo, chikeziedev Case No. D2026-1607 1. The Parties The Complainant is The Glenmede Trust Company, N.A., United States of America (“United States”), represented by Cozen O'Connor, United States. The Respondent is chikezie Egbo, chikeziedev, Nigeria. 2. The Domain Name and Registrar The disputed domain name <glemnede.com> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 15, 2026. On April 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 16, 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 (Unknown Registrant) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 17, 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 20, 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 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 12, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 13, 2026. The Center appointed Manuel Wegrostek as the sole panelist in this matter on May 18, 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 is a leading independent wealth and investment management firm headquartered in Philadelphia, Pennsylvania and is operating across several major cities. Founded in 1956, the Complainant has grown into a financial institution serving high-net worth individuals, families, endowments, foundations, and institutional clients. The Complainant offers customized financial planning, fiduciary, and investment advisory services. The Complainant is the owner of the following trademark registration for GLENMEDE (“GLENMEDE Trademark”): - United States Trademark Registration No. 2199741, registered on October 27, 1998. More specifically, the trademark register lists “The Glenmede Corporation” as the holder of the GLENMEDE Trademark, an entity affiliated with the Complainant. The Complainant is also the owner of the domain name <glenmede.com>, incorporating the GLENMEDE Trademark, registered on November 14, 1995. The disputed domain name was registered on January 20, 2026. At the time of the Decision, and when the Complaint was filed, the disputed domain name resolved to an active website prominently displaying the GLENMEDE Trademark as well as the blue-colored GLENMEDE logo, purporting to offer financial services. 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. On the first element of the Policy, the Complainant claims that the disputed domain name is confusingly similar to the GLENMEDE Trademark. The disputed domain name is nearly identical to the GLENMEDE Trademark and Complainant’s domain name. The only distinction is the inversion of the letters “n” and “m”, resulting in “glemnede” instead of “glenmede.” This minor difference does nothing to distinguish the disputed domain name from the GLENMEDE Trademark, and in fact increases the likelihood of confusion. On the second element of the Policy, the Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. To the contrary, the Respondent has registered the disputed domain name for illegitimate purposes, namely to intentionally trade off of the goodwill in the GLENMEDE Trademark and associated services, to confuse consumers into believing that that website linked to the disputed domain name is associated with the Complainant, and to scam consumers out of their money by purportedly selling legitimate wealth management services. The Respondent has anonymously registered the disputed domain name in an effort to evade the consequences of registering the disputed domain name for which he/she has no rights or legitimate interests. The Respondent is not commonly known as “Glenmede” and there is no evidence of any connection between the Respondent and the disputed domain name. The Complainant has not authorized, licensed, or endorsed the Respondent’s use of the GLENMEDE Trademark, or any confusingly similar mark, in the disputed domain name. The Respondent’s use of the disputed domain name is neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use. In fact, the disputed domain name resolves to a website with infringing content, prominently featuring trademarks and designs of the Complainant, and purporting to offer the Complainant’s own services. On the third element of the Policy, the Complainant asserts that the Respondent has registered and used the disputed domain name in bad faith. The Respondent’s adoption and use of the disputed domain name is in willful infringement of Complainant’s prior rights. The Respondent has attempted to take commercial page 3 advantage of the GLENMEDE Trademark and commercial reputation to trick and defraud unsuspecting consumers. The disputed domain name resolves to a website purporting to sell Complainant’s services, which indicate they are being used for fraudulent activity. The Respondent clearly had the Complainant in mind when registering the disputed domain name, because the Respondent had constructive notice of the GLENMEDE Trademark as the Complainant owns the GLENMEDE Trademark and the disputed domain name contains the identical mark. Upon viewing the website located at the disputed domain name, it becomes even more apparent that Respondent had full knowledge of Complainant’s rights in the GLENMEDE Trademark. The website prominently features the GLENMEDE Trademark and logo of the Complainant, and purports to offer Complainant’s services. Bad faith is further evidenced by the Respondent concealing its true identity by registering the disputed domain name through a privacy service. The Respondent registered the disputed domain name long after the Complainant first began advertising and using its GLENMEDE Trademark in connection with its aforementioned services. The disputed domain name was registered in 2026, which post-dates the Complainant’s registration for and use of the GLENMEDE Trademark. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules requires that the Panel’s decision be made “on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. The Complainant must evidence each of the three elements required by paragraph 4(a) of the Policy in order to succeed on the Complaint with respect to each disputed domain name, namely that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. 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 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 disputed domain name contains the GLENMEDE Trademark in its entirety, with the only difference of the inversion of the letters “n” and “m”. The Panel finds the mark is recognizable within the disputed domain name. WIPO Overview 3.1, section 1.7. Further, a domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.1, section 1.9. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. page 4 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. Panels have categorically held that the use of a domain name for illegal activity (e.g., the sale of counterfeit goods or (unlicensed) pharmaceuticals, phishing/identity theft, distributing malware, unauthorized account access/hacking, impersonation/passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13. The Complainant has not authorized, licensed, or permitted the Respondent to register or use the disputed domain name or to use the GLENMEDE Trademark. The Panel finds that there are no indications that the Respondent is commonly known by the disputed domain name or otherwise has any rights to or legitimate interests in the disputed domain name. Further, the disputed domain name is not used for a bona fide offering of goods or services. Rather, the disputed domain name resolves to an active website prominently displaying the GLENMEDE Trademark as well as the blue-colored GLENMEDE logo, purporting to offer financial services. The website linked to the disputed domain name does not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant, thus creating the false impression that the Respondent might be authorized by or affiliated with the Complainant. 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 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. Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. Panels also have held that the use of a domain name for illegitimate activity (as applicable here: impersonation/passing off) can never confer rights or legitimate interests on a respondent, such behavior is manifestly considered evidence of bad faith. WIPO Overview 3.1, section 3.1.4. Further, panels have found the following types of evidence to support a finding that a respondent has registered a domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s mark: (i) actual confusion, (ii) seeking to cause confusion page 5 (including by technical means beyond the domain name itself) for the respondent’s commercial benefit, even if unsuccessful, (iii) the lack of a respondent’s own rights to or legitimate interests in a domain name, (iv) redirecting the domain name to a different respondent-owned website, even where such website contains a disclaimer, (v) redirecting the domain name to or mimicking the complainant’s (or a competitor’s) website, and (vi) absence of any conceivable good faith use. WIPO Overview 3.1, section 3.1.4. Moreover, 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. In the present case the disputed domain name incorporates the GLENMEDE Trademark in its entirety, with the only difference of the inversion of the letters “n” and “m”, whereas this trademark was registered decades before the registration of the disputed domain name. Considering the distinctiveness and public presence of the GLENMEDE Trademark, Internet users may think the disputed domain name is connected to the Complainant and would resolve to a website related to the Complainant. Further, the disputed domain name resolves to an active website prominently displaying the GLENMEDE Trademark as well as the blue-colored GLENMEDE logo, purporting to offer financial services. Moreover, the website linked to the disputed domain name did not accurately and prominently disclose the relationship, or rather the lack thereof, between the Respondent and the Complainant. As shown above, the Respondent lacks rights or legitimate interests in the disputed domain name. Therefore, the evidence leads to the conclusion that the Respondent has registered and used the disputed domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the GLENMEDE Trademark. 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 <glemnede.com> be transferred to the Complainant. /Manuel Wegrostek/ Manuel Wegrostek Sole Panelist Date: June 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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