Strongtiee.com

The timeline behind strongtiee.com

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

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 Simpson Strong-Tie Company Inc. v. Dawn Cummings Case No. D2026-1682 1. The Parties Complainant is Simpson Strong-Tie Company Inc., United States of America (“United States”), represented by Shartsis Friese LLP, United States. Respondent is Dawn Cummings, United States. 2. The Domain Name and Registrar The disputed domain name <strongtiee.com> (the “Domain Name”) is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 21, 2026. On April 21, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On April 21, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to Complainant on April 23, 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 24, 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 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 17, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on May 18, 2026. page 2 The Center appointed Kimberley Chen Nobles as the sole panelist in this matter on May 22, 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 supplier of structural building products. Since the 1980s, Complainant has used its house mark SIMPSON STRONG-TIE in connection with structural connectors, fasteners, power tools, epoxies, and related construction products and services. Complainant owns numerous registered trademarks for SIMPSON STRONG-TIE, as well as families of trademarks with the STRONG and STRONG-TIE marks, including: - United States registered trademark number 801188 for the STRONG-TIE word mark, registered on January 4, 1966, with a first use date of July 15, 1956; - United States registered trademark number 1,833,650 for the SIMPSON STRONG-TIE word mark, registered May 3, 1994; and - United States registered trademark number 1,502,792 for the SIMPSON STRONG-TIE word and design mark, registered on September 6, 1988, with a first use date of June 1986. Complainant also owns and operates the domain name <strongtie.com> as well as numerous other domain names with the STRONGTIE or STRONG-TIE mark. The Domain Name was registered on March 19, 2026, and resolved to an inactive website. However, it was configured and used to facilitate the sending of emails to Complainant’s client, and passed off as originating from Complainant’s employee, in an attempt to send fraudulent communications so as to impersonate Complainant and to divert invoice payments from Complainant’s client to an account controlled by Respondent. 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. Notably, Complainant contends that (i) the Domain Name is confusingly similar to Complainant’s trademark; (ii) Respondent has no rights or legitimate interests in the Domain Name; and (iii) Respondent registered and is using the Domain Name in bad faith. In particular, Complainant contends that it has trademark registrations and rights for STRONG-TIE and that Respondent registered and is using the Domain Name, with the intention to confuse Internet users looking for Complainant’s bona fide and well-known services. Complainant notes that it has no affiliation with Respondent, nor authorized Respondent to register or use a domain name which includes Complainant’s trademark, and that Respondent has no rights or legitimate interests in the registration and use of the Domain Name. Rather, Complainant contends that Respondent has acted in bad faith in acquiring and setting up the Domain Name, when Respondent clearly knew of Complainant’s rights. Specifically, Complainant argues that Respondent used the Domain Name to impersonate Complainant, in furtherance of an illegal scheme to impersonate or pose as an employee of Complainant, so as to induce Complainant’s customers to direct future payments to a billing account under Respondent’s control. page 3 B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed Complainant must satisfy the Panel that: (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 was registered and is being used in bad faith. Section 4.3 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) states that failure to respond to complainant’s contentions would not by itself mean that complainant is deemed to have prevailed; a respondent’s default is not necessarily an admission that complainant’s claims are true. Thus, although in this case Respondent has failed to respond to the Complaint, the burden remains with Complainant to establish the three elements of paragraph 4(a) of the Policy by a preponderance of the evidence. A. Identical or Confusingly Similar Complainant has provided evidence of its rights in the STRONG-TIE trademark, as noted above. Complainant has therefore proven that it has the requisite rights in the STRONG-TIE trademark. With Complainant’s rights in the STRONG-TIE trademark established, the remaining question under the first element of the Policy is whether the Domain Name, typically disregarding the Top-Level Domain in which it was registered (in this case, “.com”), is identical or confusingly similar to Complainant’s trademark. See, e.g., B & H Foto & Electronics Corp. v. Domains by Proxy, Inc. / Joseph Gross, WIPO Case No. D2010-0842. Here, the Domain Name is confusingly similar to Complainant’s STRONG-TIE trademark. The STRONG-TIE trademark is recognizable in the Domain Name. The absence of a hyphen between the letter “g” and “t” and the addition of an extra letter “e” between the letters “i” and “e” in the Domain Name does not prevent a finding of confusing similarity between the Domain Name and the STRONG-TIE trademark. See section 1.9 of the WIPO Overview 3.1. Thus, the Panel finds that Complainant has satisfied the first element of the Policy. B. Rights or Legitimate Interests Under paragraph 4(a)(ii) of the Policy, a complainant must make a prima facie showing that a respondent possesses no rights or legitimate interests in a Domain Name. See, e.g., Malayan Banking Berhad v. Beauty, Success & Truth International, WIPO Case No. D2008-1393. Once a complainant makes such a prima facie showing, the burden of production shifts to respondent, though the burden of proof always remains on complainant. If respondent fails to come forward with relevant evidence showing rights or legitimate interests, complainant will have sustained its burden under the second element of the UDRP. From the record in this case, it is evident that Respondent was, and is, aware of Complainant and its STRONG-TIE trademark and does not have any rights or legitimate interests in the Domain Name. Complainant has confirmed that Respondent is not affiliated with Complainant, or otherwise authorized or licensed to use the STRONG-TIE trademark or to seek registration of any domain name incorporating this page 4 trademark. Respondent is also not known to be associated with the STRONG-TIE trademark and there is no evidence showing that Respondent has been commonly known by the Domain Name. The registration of the Domain Name is an attempt in “typosquatting”, whereby the Domain Name is clearly intended to confuse Internet users into believing the Domain Name belongs to Complainant. See e.g., Debevoise & Plimpton LLP v. Keyword Marketing, Inc. / Web Advertising, Corp., WIPO Case No. D2007-1679 (explaining “typosquatting” is “a form of cybersquatting in which a respondent registers and uses a domain name in order to take advantage of typographical errors made by Internet users seeking complainant’s commercial website”). In addition, Respondent has not used the Domain Name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use. Rather, the record shows that the Domain Name was configured to set up email communications capability, with email addresses that closely resemble Complainant’s legitimate email addresses at Complainant’s <strongtie.com> domain name, which enable Respondent to send fraudulent emails to Complainant’s customers, purporting to provide the customers with new banking account information to which future payments may be directed, in an attempt to divert payments to an account under Respondent’s control. Complainant confirmed that this email was not sent or authorized by Complainant and submitted it was sent to impersonate Complainant to fraudulently obtain payment. From the record in this case, it is evident that Respondent was, and is, aware of Complainant and its STRONG-TIE trademark and does not have any rights or legitimate interests in the Domain Name. Complainant has confirmed that Respondent is not affiliated with Complainant, or otherwise authorized or licensed to use the STRONG-TIE trademark or to seek registration of any domain name incorporating the trademark. Respondent is also not known to be associated with STRONG-TIE trademark and there is no evidence showing that Respondent has been commonly known by the Domain Name. The Domain Name resolves to an inactive website, however there is evidence showing that it has been used to send fraudulent emails. UDRP panels have consistently held that use of a domain name for illegal activity — such as impersonation or passing off or the sending of fraudulent invoices — can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Accordingly, Complainant has provided evidence supporting its prima facie showing that Respondent lacks any rights or legitimate interests in the Domain Name. Respondent has failed to produce countervailing evidence of any rights or legitimate interests in the Domain Name. Thus, the Panel concludes that Respondent does not have any rights or legitimate interests in the Domain Name and Complainant has met its burden under paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Panel finds that Respondent’s actions indicate that Respondent registered and is using the Domain Name in bad faith. Paragraph 4(b) of the Policy provides a non-exhaustive list of circumstances indicating bad faith registration and use on the part of a respondent, namely: “(i) circumstances indicating that you have registered or you have 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 your documented out-of-pocket costs directly related to the domain name; or (ii) you have 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 you have engaged in a pattern of such conduct; or page 5 (iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with complainant’s mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product or service on your website or location.” The Panel finds that Complainant has provided ample evidence to show that registration and use of the STRONG-TIE trademark predate the registration of the Domain Name. Complainant is also well established and known; indeed, the record shows that Complainant’s STRONG-TIE trademark and related products and services are known and recognized for purposes of the Policy. Therefore, and also noting the use analysis below, Respondent was clearly aware of the STRONG-TIE trademark when it registered the Domain Name. Moreover, the Domain Name’s inclusion of Complainant’s trademark STRONG-TIE almost entirely, further reflects the awareness that Respondent had of Complainant and its trademark at the time of registration. Complainant also owns and operates its website at the domain name <strongtie.com>. Such adoption of Complainant’s trademark at the time of registration of the Domain Name illustrates Respondent’s effort to mislead Internet users looking for Complainant. In addition, there is no indication or evidence that Respondent is preparing to use the Domain Name for any other alternate purpose. The Panel therefore finds that Respondent’s awareness of Complainant’s trademark rights at the time of registration suggests bad faith. See Red Bull GmbH v. Credit du Léman SA, Jean-Denis Deletraz, WIPO Case No. D2011-2209; Nintendo of America Inc v. Marco Beijen, Beijen Consulting, Pokemon Fan Clubs Org., and Pokemon Fans Unite, WIPO Case No. D2001-1070; and BellSouth Intellectual Property Corporation v. Serena, Axel, WIPO Case No. D2006-0007. In addition, the Domain Name’s inclusion of Complainant’s trademark almost entirely, with absence of a hyphen between the letter “g” and “t” and the addition of an extra letter “e” between the letters “i” and “e” in the Domain Name as discussed above, is clearly an attempt in “typosquatting”, whereby the Domain Name is clearly intended to confuse Internet users into believing the Domain Name belongs to Complainant. Such adoption of Complainant’s trademark at the time of registration of the Domain Name is a common tactic for fraud and phishing schemes, where individuals seek to pass themselves off as prominent companies or entities in the hopes of seeking confidential information and, ultimately, transfers of funds from current or potential clients of those companies or entities. See, e.g., Gibson, Dunn & Crutcher, LLP v. Jason Leonardo, WIPO Case No. D2025-2989; Latham & Watkins LLP v. Name Redacted, WIPO Case No. D2021-2877; Ropes & Gray LLP v. matthew rolland, ropes gray, WIPO Case No. D2023-0288. Also noted above, Respondent registered and is using the Domain Name to confuse and mislead consumers looking for bona fide and well-known STRONG-TIE products and services of Complainant. In particular, at the time of filing of the Complaint, the record shows that the Domain Name was configured to set up email communications capability, which enabled Respondent to send fraudulent emails to Complainant’s customers, purporting to provide the customers with new banking account information to which future payments may be directed, in an attempt to divert funds legitimately due to Complainant, to an account under Respondent’s control. In particular, Respondent impersonated an actual employee of Complainant to lend credibility to the fraudulent communications, including the employee’s actual name, title, email and contact information in the signature block. The record also shows additional customer reports of such fraudulent emails. Complainant confirmed that this email was not sent or authorized by Complainant and submits it was sent to impersonate Complainant to fraudulently obtain payment, or obtain confidential financial information or trade secrets. Complainant notes that it has no affiliation with Respondent. page 6 UDRP panels have consistently held that a respondent’s use of a domain name to trade off goodwill in a complainant’s well-known trademark and impersonate complainant, as here, constitutes bad faith. See Philip Morris Products S.A. v. homn mohmoodi, WIPO Case No. D2022-4158. Moreover, such use of the Domain Name may potentially result in tarnishing Complainant’s reputation and goodwill. Finally, the Panel also notes the failure of Respondent to submit a response, and Respondent’s use of what appears to be false underlying contact information to register the Domain Name. The Panel thus considers such factors as strong further evidence of Respondent’s registration and use of the Domain Name constitutes bad faith. In the present circumstances, considering the reputation of the STRONG-TIE trademark, the Panel finds that Respondent registered and is using the Domain Name in bad faith. Therefore, the Panel finds that Complainant succeeds under the third element of paragraph 4(a) 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 <strongtiee.com> be transferred to Complainant. /Kimberley Chen Nobles/ Kimberley Chen Nobles Sole Panelist Date: June 3, 2026

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