Westmore · UDRP DecisionPyebarkerf.cam + 3 more domains
The Panel consolidated proceedings involving four nominally different registrants after finding prima facie evidence that the disputed domain names were under common control. It found all four domain names confusingly similar to Complainant’s PYE-BARKER mark, found no rights or legitimate interests, and found bad-faith registration and use based on Respondent’s awareness of Complainant’s prior distinctive mark, the pattern and composition of the registrations, passive holding, nonresponse, and pay-per-click use of one domain. The Panel ordered all four domain names transferred to Complainant.
The timeline behind pyebarkerf.cam
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 pyebarkerf.cam — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a panel may consolidate nominally different registrants where closely timed, similarly composed registrations and unrebutted identity-related allegations provide prima facie evidence of common control. It also shows that inactivity does not prevent a bad-faith finding when the mark predates the registrations, the registration pattern points to awareness and targeting, and the respondent offers no explanation.
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 Pye-Barker Fire & Safety, LLC v. Name Redacted Case No. D2026-1632 1. The Parties Complainant is Pye- by Nelson Mullins Riley & Scarborough, LLP, United States. Respondents are Name Redacted. 1 2. The Domain Names and Registrars The disputed domain names <pyebarkerf.cam>, <pyebarkerfs.cam>, and <pyebarkersfs.com> are registered with NameCheap, Inc. The disputed domain name <pyebarkerfs.org> is registered with 3. Procedural History On April 17, 2026, the Center transmitted by email to NameCheap, Inc. a request for registrar verification in connection with the disputed domain names <pyebarkerf.cam> and <pyebarkerfs.cam>. On April 20, 2026, NameCheap, Inc. transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names <pyebarkerf.cam> and <pyebarkerfs.cam> which differed from the named Respondent (Redacted for Privacy, Privacy Service Provided by Withheld For Privacy Ehf) and contact information in the Complaint. 1 The Respondents appear to have used the name of third parties when registering the disputed domain names. In light of the potential identity theft, the Panel has redacted the Respondents name from this Decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrars regarding transfer of the disputed domain names, which includes the name of the Respondents. The Panel has authorized the Center to transmit Annex 1 to the Registrars as part of the order in this proceeding, and has indicated Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 The Center sent an email communication to Complainant on April 21, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by NameCheap, Inc., requesting Complainant to either file separate complaint(s) for the disputed domain names <pyebarkerf.cam> and <pyebarkerfs.cam> associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. Complainant filed an amendment to the Complaint on April 28, 2026, requesting the addition of the disputed domain names <pyebarkersfs.com> and <pyebarkerfs.org> to the Complaint. On April 28, 2026, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names <pyebarkersfs.com> and <pyebarkerfs.org>. On April 28, 2026, the Registrars transmitted by email to the Center their verification responses disclosing registrant and contact information for the disputed domain names <pyebarkersfs.com> and <pyebarkerfs.org> which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to Complainant on April 30, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. Complainant filed an amended Complaint on May 5, 2026. The Center verified that the Complaint together with the amendment to the Complaint and amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondents of the Complaint, and the proceedings commenced on May 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 7, 2026. Respondents did not submit any response. Accordingly, the Center notified Respondents default on June 11, 2026. The Center appointed Lorelei Ritchie as the sole panelist in this matter on June 16, 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 A. Complainant Complainant is a limited liability company based in the United States. For a number of years prior to the registration of the disputed domain names, Complainant has offered various fire and safety-related goods and services under the mark PYE-BARKER, along with several stylized and design composite variants thereof. In this regard, Complainant is the owner of several registrations for its PYE-BARKER mark. These include, among others, United States Registration No. 7436794 (registered July 9, 2024). B. Respondent The disputed domain names <pyebarkerf.cam> and <pyebarkerfs.cam> were registered on April 1, 2026. The disputed domain name <pyebarkersfs.com> was registered on April 21, 2026. The disputed domain name <pyebarkerfs.org> was registered on April 17, 2026. page 3 The disputed domain names are not currently linked to active websites, but previously the disputed domain name <pyebarkersfs.com> resolved to a pay-per-. 5. Parties Contentions A. Complainant Complainant contends that (i) the disputed domain names are identical or confusingly similar to Complainants trademark, (ii) Respondents have no rights or legitimate interests in the disputed domain names; and (iii) Respondents registered and are using the disputed domain names in bad faith. Specifically, Complainant contends that it owns rights to the PYE-BARKER mark, which it has used since 1978, based on the combined sunames of its founders. Complainant contends that it has accrued extensive common-law rights as well as several trademark registrations, as the largest fully integrated and full-service fire protection, life safety, and security services provider in the United States, and [w]ith hundreds of locations and 9,000 team members across 47 states. Complainant contends that Respondents have incorporated in full PYE-BARKER mark into each of the disputed domain names, with only the omission of the hyphen and the inclusion of the letters f or fs in each. Complainant contends that the letters f or fs are easily understood as a reference to Complainant's trade name, Pye-Barker Fire & Safety, LLC, as well as to the fire and safety services offered by Complainant under the PYE-BARKER mark. Complainant contends that Respondents lacks rights or legitimate interest in the disputed domain names, having registered multiple domain names that incorporate Complainant's PYE-BARKER mark. Complainant alleges that although the disputed domain names are not linked to active websites, Respondents have registered and used them in bad faith to disrupt Complainants business, presumably for Respondents own commercial gain. B. Respondents Respondents 6. Discussion and Findings A. Preliminary Matter - Consolidation The registration information provided by the Registrars for each of the disputed domain names identifies different registrants. Complainant nevertheless alleges that the disputed domain name registrants are the same entity or are otherwise under common control. Complainant thus requests consolidation of the Complaint against the listed registrants of the disputed domain names pursuant to paragraphs 3(c) and 10(e) of the Rules. Pursuant to WIPO Overview of WIPO Panel Views on Select UDRP Questions WIPO Overview 3.1, section 4.11.2, the Panel considers whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. Two of the disputed domain names were registered on the same day with the same registrar. A third disputed domain name was registered with that same registrar a day after Complainant filed this UDRP complaint. The fourth disputed domain name was registered a few days later, when the Center sent notice of the Complaint. All four were registered during the month of April 2026 and share similar composition. Further, Complainant has asserted that it suspects Respondents have used stolen identities of actual individuals to register the disputed domain names, a charge Respondents have not rebutted. page 4 The Panel finds that Complainant has shown prima facie evidence of common control, which the listed registrants (hereinafter named collectively as Respondent have neither addressed nor rebutted. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. The request to consolidate the Complaint as to the four disputed domain names is granted. B. 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 isputed domain name. WIPO Overview 3.1, section 1.7. Complainant has shown rights in respect of the PYE-BARKER mark, for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that the PYE-BARKER mark is recognizable within the disputed domain names. Although the omission of the hyphen and the addition of other terms (here f ) may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names 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. C. 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 a respondent lacks rights or legitimate interests in a domain name may result in the difficult mation 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. Complainant has established rights in its distinctive mark incorporated in the disputed domain names. Respondent has not put forward any claims or evidence that would suggest rights or legitimate interests for purposes of the Policy, nor are any apparent for the inherently misleading disputed domain names. The rebutted. The Panel finds the second element of the Policy has been established. D. Registered and Used in Bad Faith There are several ways that a complainant can demonstrate that a domain name was registered and Decision, the disputed domain names are not currently linked to active websites, and three of the four disputed domain names were inactive at the time of filing of the Complaint. It is nevertheless well established that passive holding of a domain name does not necessarily shield a respondent from a finding of bad faith. See WIPO Overview 3.1, section 3.3, - page 5 , including, for example, whether a complainant has a well-known trademark, and whether a respondent conceals his/her identity and/or replies to the complaint. Complainant has established prior rights in the distinctive PYE-BARKER mark, as well as a pattern by Respondent in the registration and composition of the disputed domain names. Respondent did not submit any reply to Complainants contentions in this proceeding. The Panel finds sufficient evidence that Respondent was aware of Complainants prior, existing right to the PYE-BARKER mark, and that Respondent registered the disputed domain names with an intent to disrupt the business of Complainant, presumably for Respondents own commercial gain. Regarding the PPC use of the disputed domain name <pyebarkersfs.com>, the Panel finds that the respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a The Panel finds the third element of the Policy has been established. 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 names <pyebarkerf.cam>, <pyebarkerfs.cam>, <pyebarkersfs.com>, and <pyebarkerfs.org> be transferred to Complainant. /Lorelei Ritchie/ Lorelei Ritchie Sole Panelist Date: June 30, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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