Westmore · UDRP decision
WIPO · Case No. D2026-1772

Keepitrealservice.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <keepitrealservice.com>. Although KEEP IT REAL is a common expression with descriptive relevance to authentication services, the Panel found that the Complainant had established unregistered trademark rights through approximately five years of use for its Banksy-related authentication service, assessed in the context of Banksy's renown and the Respondent's persistent attention to the Complainant's activities. The domain was confusingly similar because it incorporated KEEP IT REAL with the descriptive term “service.” The Respondent lacked rights or legitimate interests because the Panel rejected his claim of independent descriptive adoption and found that his competing authentication service, domain name, and rat/mouse imagery targeted the Complainant. The same targeting and the likelihood of attracting users who mistakenly believed the service was connected with the Complainant established bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-19
Panelist(s)
Rothnie, Warwick A.
Complainant
Pest Control Office Ltd
Respondent
Lawrence Banksy
Disputed domain(s)
keepitrealservice.com
Citation weightrelies on 3 authorities
Domain history UDRP Intelligence

The timeline behind keepitrealservice.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 keepitrealservice.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 keepitrealservice.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a complainant may establish UDRP standing in a common, descriptively relevant expression without registered rights or conventional secondary-meaning evidence where sustained source-identifying use is reinforced by strong contextual evidence of deliberate targeting. It also shows that a respondent's potentially genuine underlying service does not create a legitimate interest where the panel finds that the domain name and associated presentation were selected to trade on the complainant's identity and service.

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
2026-06-19
Panel
Rothnie, Warwick A.
Full decision
17 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Pest Control Office Ltd v. Lawrence Banksy Case No. D2026-1772 1. The Parties The Complainant is Pest Control Office Ltd, United Kingdom, represented by Howard Kennedy LLP, United Kingdom. The Respondent is Lawrence Banksy, Norway, self-represented. 2. The Domain Name and Registrar The disputed domain name <keepitrealservice.com> is registered with Key-Systems GmbH (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 24, 2026. On April 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 28, 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 (The domain name holder of the Disputed Domain Name) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 29, 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 May 1, 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 May 4, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 24, 2026. The Response was filed with the Center on May 25, 2026. The Center appointed Warwick A. Rothnie 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. page 2 4. Factual Background The Complainant is a company which claims to represent the interests of the artist known as “Banksy”. It also claims to be the only body authorised by Banksy to authenticate Banksy’s artworks. The Complainant was incorporated under its current name on January 14, 2008. In response to a growing market in fake Banksy artworks, the Complainant established an authentication service in 2008. Through this service, owners of artworks could submit their artworks to the Complainant. If the Complainant determined the artwork was authentic, the Complainant would issue a Pest Control Office Certificate of Authentication. This service is still accessible through the Complainant’s website at “www.pestcontroloffice.com”. In 2020, the Complainant launched a new verification service called “Keeping it Real”. Through this service, a potential buyer of an artwork could submit its details to the Complainant and, if the Complainant considered the work authentic, receive verification of its legitimacy. This service was promoted and accessible through a page on the Complainant’s website at “www.pestcontroloffice.com/real.asp”. From at least November 1, 2020 until June 16, 2025, the page for featured a heading “Welcome to our ‘Keeping It Real’ service” and “How it Works...” The page also featured in the top right-hand corner an image which the Complainant says is a well-known Banksy rat holding a placard. As can be seen below, the placard bears the words “Keep it real”: Since June 2025, the heading on the page has been replaced with “Welcome to our ‘check or register artwork’ service” “How it works...”. The image of the rat holding the placard with the slogan “Keep it real” has continued in use. According to the Complaint, Banksy has been featuring the slogan “Keep it real” on various artworks since 2002 when Banksy released a stencil artwork featuring a frowning chimpanzee wearing a sandwich board on which the slogan was presented. According to the WhoIs record, the disputed domain name was registered on September 18, 2025. It resolves to a website which apparently offers a “Keep It Real” authentication and verification service for street and contemporary art. The slogan “Keep it Real” appears prominently on the landing page in much larger lettering than any other wording on the page and immediately underneath an image of a rat or mouse in judicial garb: page 3 According to the Complainant (and not disputed by the Respondent), the Respondent is a Norwegian, originally known as Lawrence Vindtorn. At some point, he changed his name by deed poll to his present name. The Respondent is the General Manager and Chair of a Norwegian company, Dyrehotell Pets Paradise AS. In 2011 and again in 2019, Dyrehotell Pets Paradise AS became the owner of registered trademarks in Norway for BANKSY, respectively Registered Trademark No. 261499 and 306746. Both registrations were subsequently cancelled or ceased following action taken by the Complainant. In 2017, the Respondent incorporated a company in the United Kingdom under the name Pest Controll Office Ltd describing the nature of its business as the operation of arts facilities. Following action taken by the Complainant in the Company Name Tribunal, this company was forced to change its name in 2021 to 10580762 LTD. It was subsequently dissolved on February 1, 2022. Meanwhile, in 2020, the Respondent and Dyrehotell Pets Paradise AS registered the domain names <bestcontroloffice.com> and <bestcontroloffice.net>. In March 2025, a panel subsequently found that both names had been registered and used in bad faith and ordered their transfer to the Complainant. Pest Control Office Ltd v Mr Banksy, Dyrehotell Pets Paradise AS WIPO Case No. D2025-0129. Further, in November 2021, the Respondent also registered the domain name <pestcontroloffice.org>. In January, 2025, another panel found the Respondent had also registered and used that domain name in bad faith and ordered its transfer to the Complainant: Pest Control Office Ltd v “Lawrence Banksy” WIPO Case No. D2024-4850. On November 28, 2025 and December 1, 2025, the Respondent applied to register two trademarks in the United Kingdom: (a) No UK00004302264, BANKSY; and (b) No UK00004303127, KEEP IT REAL. Both applications were in respect of a range of services in International Class 42 related to and including authentication of works of art. Both applications also gave as the Respondent’s address an address which is actually the Complainant’s address in London. The Complainant has opposed the registration of both applications and that opposition is still pending. In December 2025, the Respondent sent letters or texts to the auction house Christie’s and law firms which the Complainant uses or has used in connection with its activities. This correspondence included a letter or notice purportedly signed by Banksy terminating the Complainant’s authority to act on his behalf. Curiously, the letters appear to have been sent from the Complainant’s address in London in the United Kingdom. page 4 5. Discussion and Findings Paragraph 4(a) of the Policy provides that in order to divest the Respondent of a disputed domain name, the Complainant must demonstrate each of the following: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (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. Paragraph 15(a) of the Rules directs the Panel to decide the Complaint 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. A. Identical or Confusingly Similar The first element that the Complainant must establish is that the disputed domain name is identical with, or confusingly similar to, the Complainant’s trademark rights. 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 Selected UDRP Questions, (“WIPO Overview 3.1“), section 1.7. In this case, the Complainant does not claim to have any relevant registered trademarks and relies on what it claims are its common law rights in KEEP IT REAL and KEEPING IT REAL as unregistered trademarks arising from its use of those expressions in connection with its authentication service since 2020. 1 The Respondent accepts that unregistered rights can qualify as trademarks under the Policy but contends the Complainant has not established such rights in this case. The Respondent points out that “Keep it real” is a long-established common expression conveying meanings of authenticity, honesty and genuineness. According to the Respondent, the expression has obvious descriptive relevance to authentication-related services and the Complainant has not demonstrated acquired distinctiveness. The Panel accepts that the expression “Keep it real” is a common expression as contended by the Respondent and does have descriptive relevance to a service of the kind the Respondent claims to be offering. The Panel also acknowledges that the Complainant has not filed conventional evidence such as the number of users of its site or service of the kind referred to in WIPO Overview 3.1, section 1.3. On the other hand, the artist Banksy has a particularly high profile and renown. Public releases of Banksy works and auctions of works claimed to be Banksy originals often attract worldwide media attention. In addition, “Banksy”-imitators are frequent, as are concerns with the authenticity of works claimed to be Banksy productions. This is the context in which the Complainant’s use of the phrase “our ‘Keeping It Real’ service” and the “Keep it real” rat with placard image for around five years and the continuing use of the “Keep it real” rat with placard image fall to be assessed. These uses are clearly being used as badges of origin. 1 The Complaint does draw attention to the artist’s use of the slogan from 2002. At least on the basis of the limited way that use has been presented in this proceeding, however, the Panel does not think it can be considered use of the expression in a trademark sense. Rather, the expression is being used both to amplify the type of satirical or sardonic message associated with the artist’s works, but not in the trademark sense it has been used on the authentication service pages since 2020. page 5 Further, while it must be accepted that the phrases have obvious descriptive relevance to an authentication service, the history of the Respondent’s conduct since at least 2011 outlined above means that any suggestion the Respondent has not adopted the disputed domain name to target the Complainant and its trademark is not credible. Having regard to the context in which the Complainant’s use has taken place and the clear targeting of the Complainant and its trademark, the Panel finds that the Complainant has sufficiently demonstrated trademark rights in the expression(s) KEEPING IT REAL or KEEP IT REAL for the purposes of the Policy. The comparison of the disputed domain name to the Complainant’s trademark simply requires a visual and aural comparison of the disputed domain name to the proven trademarks. This test is narrower than and thus different to the question of “likelihood of confusion” under trademark law. See e.g., WIPO Overview 3.1, section 1.7. In undertaking that comparison, it is permissible in the present circumstances to disregard the generic Top- Level Domain (gTLD) component as a functional aspect of the domain name system. WIPO Overview 3.1, section 1.11. Further, in the case of the “Keep it real” rat with placard image, it is also appropriate to apply the usual rule disregarding the design elements. The rat and placard image are clearly important elements but the placard serves as a sign board promoting the slogan “Keep it real”. WIPO Overview 3.1, section 1.10. Disregarding the “.com” gTLD, therefore, the disputed domain name differs from the Complainant’s trademark only by the addition of the descriptive term “service”. 2 As this requirement under the Policy is essentially a standing requirement, the addition of this term does not preclude a finding of confusing similarity. See WIPO Overview 3.1, section 1.8. Apart from anything else, the Complainant’s trademark remains visually and aurally recognisable within the disputed domain name. Accordingly, the Panel finds that the Complainant has established that the disputed domain name is at least confusingly similar to the Complainant’s trademark and the requirement under the first limb of the Policy is satisfied. B. Rights or Legitimate Interests The second requirement the Complainant must prove is that the Respondent has no rights or legitimate interests in the disputed domain name. Paragraph 4(c) of the Policy provides that the following circumstances can be situations in which the Respondent has rights or legitimate interests in a disputed domain name: (i) before any notice to the Respondent of the dispute, the Respondent’s use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or (ii) the Respondent (as an individual, business, or other organization) has been commonly known by the disputed domain name, even if the Respondent has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. 2 For this purpose, the Panel treats the difference between “keeping” and “keep”, while potentially having grammatical significance, as trivial. page 6 These are illustrative only and are not an exhaustive listing of the situations in which a respondent can show rights or legitimate interests in a domain name. While 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 often impossible 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. 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. There is no dispute between the Parties that: (1) The Respondent registered the disputed domain name after the Complainant began using the expression as the name of its service in 2020; (2) The Respondent is not affiliated with the Complainant; (3) The Complainant has not otherwise authorised the Respondent to use the disputed domain name; (4) The disputed domain name is not derived from the Respondent’s name. Nor is there any suggestion of some other name by which the Respondent is commonly known from which the disputed domain name could be derived. These factors are usually sufficient to establish a prima case that the Respondent does not have rights or legitimate interests in a disputed domain name. On the other hand, the Respondent emphasises that he (or his company) is providing a genuine authentication service and the expression “Keep it real” has an obvious descriptive connection with a service of that kind. The Respondent further contends that the visual presentation of his legitimate service is very different to the Complainant’s website. According to the Respondent, there is no copying of the Complainant’s alleged visual branding and the naming of the Respondent’s service, and the disputed domain name, were independent. Having regard to the history of the Respondent’s activities since 2011, the Panel does not accept that the Respondent has adopted the disputed domain name independently of the Complainant’s use of KEEP IT REAL for the Complainant’s own authentication service. While the prior conduct did involve different trademarks – BANKSY and PEST CONTROL OFFICE, it demonstrates a close and persistent attention to the activities of the artist and the business of the Complainant. It may also be accepted that the image of the mouse or rat in judicial garb on the Respondent’s website is different to the Complainant’s “Keep it real” rat with placard image. The difference, however, misses the point. Why has the Respondent chosen to use a murine image at all? The Complainant’s own name has associations with the control of pests such as rats and the image of the rat is closely associated with the Complainant’s service. Against this, t he Response does not provide a basis for finding that rats and mice are commonly, or even frequently, associated with authentication services. As a result, the Panel concludes that, while being a different presentation, the Respondent has chosen to use the rat/mouse image because of the Complainant’s use of the “Keep it real” rat with placard image. In these circumstances, the Panel considers it cannot be suggested credibly that the Respondent adopted the disputed domain name independently of the Complainant’s use. Given that, while the Respondent may be offering a “real” service, the adoption and use of a name so closely resembling the name of the Complainant’s service and trademark cannot be described as being in good faith. page 7 Accordingly, the Panel finds the Complainant has established the second requirement under the Policy also. C. Registered and Used in Bad Faith Under the third requirement of the Policy, the Complainant must establish that the disputed domain name has been both registered and used in bad faith by the Respondent. These are conjunctive requirements; both must be satisfied for a successful complaint: see e.g., Group One Holdings Pte Ltd v. Steven Hafto WIPO Case No. D2017-0183. Generally speaking, a finding that a domain name has been registered and is being used in bad faith requires an inference to be drawn that the respondent in question has registered and is using the disputed domain name to take advantage of its significance as a trademark owned by (usually) the complainant. For the reasons set out above, the Panel finds that the Respondent was well aware that the Complainant was already using the trademark KEEP IT REAL when the Respondent adopted the disputed domain name. While the Respondent claims to have adopted it independently of the Complainant and solely for its descriptive connotation, the Panel does not accept that claim. The close and persistent targeting of the Complainant’s trademark, albeit different trademarks to that in issue in this proceeding, shows the Respondent had and has a very close understanding of the Complainant and its activities and demonstrates a consistent pattern of attempts to disrupt the Complainant’s business. As discussed above, the Panel finds that the Respondent chose the disputed domain name to target the Complainant’s trademark. The Panel finds, therefore, that the disputed domain name has been registered in bad faith. While the Respondent may very well be offering an authentication service, the use of the disputed domain name which is confusingly similar to the Complainant’s trademark in connection with that service constitutes use in bad faith under the Policy. It appears to be an intentional attempt to attract to the Respondent’s service members of the public in the mistaken belief it is the Complainant’s service or in some way sponsored or associated with the Complainant. Accordingly, the Panel finds that the Respondent has both registered and subsequently used the disputed domain name in bad faith. In reaching these conclusions, the Panel has not had regard to the communications sent to Christie’s and the law firms in December 2025. They appear to relate to a dispute about whether the Complainant does in fact have authority to act for Banksy. Whether or not that is the case (which is not a dispute the Panel needs to, and does not purport to, resolve), the correspondence does not bear on the right to use the trademark KEEP IT REAL at least for the reasons that the Complainant is the person that has nbeen using the trademark and, further, the Respondent does not claim any entitlement from Banksy to use the expression. Accordingly, the Complainant has established all three requirements under the Policy. 6. 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 <keepitrealservice.com> be transferred to the Complainant. /Warwick A. Rothnie/ Warwick A. Rothnie Sole Panelist Date: June 19, 2026

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

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