Westmore · UDRP decision
WIPO · Case No. D2026-1681

Hotqwire.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <hotqwire.com> to Expedia, Inc. The domain was a close misspelling of the HOTWIRE mark, adding the letter “q.” The Respondent lacked authorization and offered no evidence of rights or legitimate interests. Its use to route users through an advertising network to the Complainant’s official website, and later for PPC links, demonstrated knowledge of the mark and bad-faith use. The Respondent’s involvement in other misspelling-based UDRP cases further supported a pattern of targeting third-party trademarks.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-17
Panelist(s)
Köklü, Kaya
Complainant
Expedia, Inc.
Respondent
Zhichao
Disputed domain(s)
hotqwire.com
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind hotqwire.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 hotqwire.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of hotqwire.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a one-letter insertion into a recognizable mark, combined with redirection to the trademark owner’s own website, can provide strong evidence across all three UDRP elements. The redirection was not treated as benign: because it passed through an advertising network and targeted the official HOTWIRE site, it supported findings of knowledge, lack of legitimate interests, and an attempt to capitalize on confusion. The Panel also relied on prior misspelling-based cases as evidence of a broader targeting pattern.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-17
Panel
Köklü, Kaya
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Expedia, Inc. v. Zhichao Case No. D2026-1681 1. The Parties The Complainant is Expedia, Inc., United States of America (“United States” or “U.S.”), represented by Kilpatrick Townsend & Stockton LLP, United States. The Respondent is Zhichao, China. 2. The Domain Name and Registrar The disputed domain name <hotqwire.com> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 20, 2026. On April 21, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 23, 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 (Redacted For Privacy, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 24, 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 28, 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 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 20, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 26, 2026. page 2 The Center appointed Kaya Köklü 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 The Complainant is a widely known internationally active online travel company. Among other things, the Complainant offers online services for airline tickets, hotel rooms, rental cars, and vacation packages. The Complainant owns the HOTWIRE trademark. Among numerous others, the Complainant is the owner of the United States Trademark Registration No. 76151387, registered on January 28, 2003, for HOTWIRE, covering protection for various travel related services as protected in classes 39 and 42. The Complainant further operates its related services at <hotwire.com>. The Respondent is reportedly located in China. The Respondent has apparently been involved in more than 20 other disputed under the UDRP as a respondent before, where panels have found bad faith conduct on the part of the Respondent. The disputed domain name was registered on July 5, 2025. Based on undisputed evidence provided by the Complainant, the disputed domain name initially went through an advertising network system before ultimately reaching the Complainant’s official website at <hotwire.com>. Later, the disputed domain name resolved to a landing page with pay-per-click (“PPC”) links to services unrelated to the Complainant’s business. At the time of the Decision, the disputed domain name resolves to a landing page containing a security warning stating that the associated website may be compromised. 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. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 15(a) of the Rules, the Panel shall decide the Complaint in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the following three elements is satisfied: (i) the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights; page 3 (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. As per paragraph 4(a) of the Policy, the complainant bears the burden of proving that all these requirements are fulfilled, even if a respondent has not substantively replied to the complainant’s contentions. Stanworth Development Limited v. E Net Marketing Ltd., WIPO Case No. D2007-1228. Concerning the uncontested information provided by a complainant, the Panel may, where relevant, accept the provided reasonable factual allegations in a complaint as accurate. Section 4.3 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”). It is further noted that the Panel has taken note of the WIPO Overview 3.1 and, where appropriate, will decide consistently with the consensus views captured therein. 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 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 Panel finds the mark HOTWIRE is recognizable within the disputed domain name. The disputed domain name consists of a close misspelling of the Complainant’s HOTWIRE trademark, differing only by way of an added letter “q” in the middle. Accordingly, the disputed domain name is confusingly similar to the HOTWIRE 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 Complainant has credibly submitted that the Respondent is not affiliated with the Complainant and has not been authorized or licensed to use the Complainant’s HOTWIRE trademark. 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. page 4 Moreover, the Panel notes that the disputed domain name was used to divert Internet users through an advertising network, before ultimately redirecting them to the Complainant’s official website at the domain name <hotwire.com>. Such use cannot confer rights or legitimate interests upon the Respondent in the disputed domain name. 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. 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 Panel finds that the circumstances indicate that the Respondent was aware of the Complainant and its HOTWIRE trademark when registering the disputed domain name. In this regard, the Panel notes that the disputed domain name is a close misspelling of the Complainant’s HOTWIRE trademark, and the Respondent used it to divert Internet users from its own website at the disputed domain name to the Complainant’s official website at <hotwire.com>. In view of the Panel, this demonstrates that the Respondent must have been aware of the Complainant and its HOTWIRE trademark when registering the disputed domain name. The fact that the Respondent used the disputed domain name in this manner not only demonstrates prior knowledge of the Complainant and its HOTWIRE trademark, but also constitutes evidence of bad faith use, as the Respondent obviously sought to capitalize on the confusion created by the disputed domain name and the goodwill associated with the Complainant’s mark. The Respondent’s use of the disputed domain name both to redirect to the Complainant’s website and to resolve to a website with PPC links constitutes bad faith under paragraph 4(b)(iv) of the Policy. The Panel further notes that the Respondent was involved in many other UDRP proceedings as a respondent, many of which related to domain names comprising misspellings of third-party trademarks like in the present case, such as Laboratoires M&L v. Zhichao, WIPO Case No. D2026-0966. In view of the Panel, this additionally indicates a pattern of targeting third-party trademarks by way of misspellings, which constitutes further evidence of bad faith within the meaning of the Policy. The Panel also notes that the disputed domain name currently resolves to a landing page displaying a security warning stating that the associated website may be compromised. This reinforces the Panel’s overall finding of bad faith on the part of the Respondent. Accordingly, the Panel finds that the Respondent registered and has used the disputed domain name in bad faith. The Panel finds that the Complainant has established the third element of the Policy. page 5 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 <hotqwire.com> be transferred to the Complainant. /Kaya Köklü/ Kaya Köklü Sole Panelist Date: June 17, 2026

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

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