Westmore · UDRP decision
WIPO · Case No. D2026-1852

Lennarstate.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <lennarstate.com> to Lennar Corporation. It found the domain confusingly similar to the registered LENNAR mark because it incorporated the mark in full with the dictionary term “state.” Although the Respondent demonstrated that an Egyptian company named Lennar for Real Estate Marketing predated the domain registration, the Panel found that the company name and domain were selected primarily to take unfair advantage of the Complainant’s trademark rights. The unexplained adoption of the coined and distinctive term “Lennar,” the complementary real estate activities, and elements of the Respondent’s website supported findings that the Respondent lacked rights or legitimate interests and had registered and used the domain in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-17
Panelist(s)
Maier, Steven A.
Complainant
Lennar Corporation Lennar Pacific Properties Management, LLC
Respondent
Mohamed Bahaa
Disputed domain(s)
lennarstate.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

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

The decision illustrates that a respondent cannot necessarily establish rights or legitimate interests merely by forming and operating a company under the disputed name before registering the domain. Where the adopted name is a coined, distinctive trademark and the respondent operates in a complementary sector without explaining the name’s selection, a panel may examine whether the company identity itself was created to exploit trademark value. The case also confirms, in the Panel’s analysis, that bad-faith unfair advantage does not depend on proof of actual customer confusion.

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
Maier, Steven A.
Full decision
15 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Lennar Pacific Properties Management, LLC, Lennar Corporation v. Mohamed Bahaa Case No. D2026-1852 1. The Parties The Complainants are Lennar Pacific Properties Management, LLC (the “First Complainant”) and Lennar Corporation (the “Second Complainant”), United States of America (“United States”), represented by Slates Harwell Campbell, LLP, United States. The Respondent is Mohamed Bahaa, Egypt. 2. The Domain Name and Registrar The disputed domain name <lennarstate.com> is registered with CloudFlare, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 29, 2026. On April 30, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 30, 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) and contact information in the Complaint. The Center sent an email communication to the Complainants on May 1, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainants to submit an amendment to the Complaint. The Complainants filed an amendment to the Complaint on May 1, 2026. The Center verified that the Complaint together with the amendment to the 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 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 25, 2026. The Response was filed with the Center on May 6, 2026. On May 27, 2026, the Center informed the Parties that it would proceed with panel appointment. page 2 The Center appointed Steven A. Maier 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. Consolidation of Complainants The two named Complainants are associated legal entities, the First Complainant is the owner of the LENNAR trademarks referred to below, and the Second Complainant is the licensee of those trademarks and operator of a website at “www.lennar.com”. The Panel considers in these circumstances that (i) the Complainants have a specific common grievance against the Respondent, or the Respondent has engaged in common conduct that has affected the Complainants in a similar fashion, and (ii) it would be equitable and procedurally efficient to permit the consolidation (see WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.1). The Complaints will therefore be consolidated for the purposes of this proceeding, and the Complainants together will be referred to as “the Complainant” in the remainder of this Decision. 5. Factual Background The Complainant is a United States homebuilder, founded in 1954 and offering homes in at least 21 states of the United States. The Complainant is the owner of various trademark registrations for the mark LENNAR, including for example United States trademark registration number 3477143 for the word mark LENNAR, registered on July 29, 2008, in International Classes 36 and 37. The Complainant operates a website at “www.lennar.com”. That website includes the logo depicted below in its top left-hand corner: The website includes a heading: “Let us help you find your dream home.” It features new homes for sale in numerous regions of the United States, and also refers to partner services enabling buyers to sell their existing home, and to pre-qualification mortgage services. The Respondent is the Chief Technology Officer of an Egyptian registered company, whose name in English is “Lennar for Real Estate Marketing”, with an incorporation date of December 29, 2024. For convenience, the Respondent and that entity will be referred to together as “the Respondent” in the remainder of this Decision. The Respondent registered the disputed domain name on March 28, 2026. The Respondent operates a website at “www.lennarstate.com”, which is headed: “Find Your Dream Property. Discover the best rental, sale, and under-construction in Egypt.” The website features, in particular, properties for sale in various Egyptian resorts. According to the evidence provided by the Parties, the website included the logo depicted below in its top left-hand corner: page 3 6. 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. The Complainant relies on its LENNAR trademark. It notes that the disputed domain name adopts that trademark in its entirety, and contends that the addition of the descriptive word “state” does not prevent the disputed domain name from being confusingly similar to the trademark. The Complainant submits that the Respondent has no rights or legitimate interests in respect of the disputed domain name. It states that the Respondent has not commonly been known by the disputed domain name, and that it is making neither bona fide commercial use nor legitimate noncommercial or fair use of the disputed domain name. The Complainant submits that, instead, the Respondent is using the disputed domain name to impersonate the Complainant, for commercial gain, by diverting Internet users to a website hosting competing property-related content. The Complainant contends that the disputed domain name was registered and is being used in bad faith, by taking unfair advantage of its distinctive and famous LENNAR trademark. The Complainant submits, in particular, that the Respondent’s website is confusingly similar to its own, for example, by adopting its LENNAR trademark, including a logo similar in appearance and colour to its own, and adopting the term “dream properties”. It adds that the Respondent includes nothing on its website which is intended to prevent confusion with the Complainant. The Complainant exhibits a “cease and desist” letter from its representative dated March 31, 2026, addressed to “Whom It May Concern” and to “Contact Domain Holder” at a URL associated with the Registrar and the disputed domain name. The Complainant states that no reply was received to that communication, which further evidences the Respondent’s bad faith in the matter. The Complainant requests the transfer of the disputed domain name. B. Respondent The Respondent submits that it registered and has used the disputed domain name to support its pre- existing Egyptian real estate business, and that it had no knowledge of the Complainant at the time the disputed domain name was registered. The Respondent acknowledges that the disputed domain name includes the word “lennar”, but denies that it represents “typosquatting” or any other attempt to mislead Internet users. It states that “Lennar” is the Respondent’s company name, which is combined with “state” in order to reference real estate, producing a deliberate, descriptive compound name which is independent of the Complainant. The Respondent exhibits various official documents to evidence that it operates a duly registered Egyptian company, including a Commercial Registry extract, a VAT registration certificate and an Egyptian tax card. The Respondent submits that it operates exclusively in the Egyptian real estate market, that it is a broker and not a developer or builder, that it maintains its website in both Arabic and English, with an Egypt-based phone number, and that it serves a “different primary customer base” to that of the Complainant, i.e. Egyptian buyers. It states that it has never had any operations in the United States, and had never advertised or held itself out as being connected with the Complainant. page 4 As to website content, the Respondent states that its logo is materially different to the Complainant’s, as only its first letter “L” is in upper case, whereas the whole of “[t]he Complainants’ famous LENNAR Marks” are represented in upper case. The Respondent also submits that blue is the most commonly used colour in business and real estate websites worldwide, and that the Complainant has no trademark rights in respect of that colour. The Respondent adds that the phrase “dream properties” is generic and ubiquitous, as used by tens of thousands of real estate businesses, and that it has nowhere adopted the Complainant’s well-known slogan (and trademark) “Everything’s Included”. The Respondent denies having received any “cease and desist” correspondence from the Complainant. It notes that the Complainant provides no evidence of how the communication was supposedly sent, and states that it has searched all possible email addresses including spam folders. It adds that the Registrar’s contact-forwarding channel is working correctly, and that had the Complainant sent any communication via that channel, then the Respondent would have received it. The Respondent adds that its prompt response to the present proceeding indicates its good faith intent. The Respondent submits that it has no history of cybersquatting, or of registering any other domain names which might prevent the Complainant from reflecting its trademarks online. It states that it has never sought to sell the disputed domain name to the Complainant. It adds that the registration of the disputed domain name behind a privacy service was by the Registrar’s default, and cannot be viewed as evidence of any intent by the Respondent to conceal its identity. The Respondent requests the denial of the Complainant accordingly. 7. Discussion and Findings In order to succeed in the Complaint, the Complainant is required to show that all three of the elements set out under paragraph 4(a) of the Policy are present. Those elements are that: (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. 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 demonstrated that it is the owner of registered trademark rights in the mark LENNAR. The disputed domain name incorporates that trademark in full, together with the dictionary term “state”, the inclusion of which does not prevent the Complainant’s trademark from being recognizable within the disputed domain name. The Panel therefore finds that the first element under the Policy is 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. page 5 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. In rebuttal, the Respondent relies on having established and operated an Egyptian company, named Lennar for Real Estate Marketing, some 14 months prior to its registration of the disputed domain name. While the Panel accepts the Respondent’s evidence that it has registered and operated an Egyptian company under the stated name, the mere registration of a company is not sufficient, of itself, to establish rights or legitimate interests for the purposes of the Policy. Indeed, should the facts of the case indicate that the company was registered as a pretext for taking unfair advantage of third party trademark rights, then the respondent is unlikely to be found to have obtained rights or legitimate interests (see, e.g., WIPO Overview 3.1, section 2.12.2, and Philip Morris USA Inc. v. Domains By Proxy, LLC / Robert Simpson, Covetrus Group Ltd, WIPO Case No. D2021-2187). In this case, for the reasons set out in detail in connection with the third element, below, the Panel finds on balance that the Respondent registered both its real estate brokerage business under the name “Lennar”, and the disputed domain name, primarily for the purpose of taking unfair advantage of the Complainant’s trademark rights. In these circumstances, the Panel finds that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The second element under the Policy is therefore established. C. Registered and Used in Bad Faith As indicated above, the Panel accepts that the Respondent registered an Egyptian company named Lennar for Real Estate Marketing, which has operated a website, located at the disputed domain name, mainly offering real estate in Egypt for rental and sale. However, the Panel does not accept that this company name was registered without an intention of taking unfair advantage of the Complainant’s trademark rights. The Panel reaches this conclusion for the following reasons. First, the Respondent has provided no explanation whatsoever for its selection of the name “Lennar” in connection with its real estate brokerage business: it merely makes the self-serving assertion that the disputed domain name corresponds with its company name. The Panel finds the name and mark LENNAR to have been coined by the Complainant, to be distinctive, and to have no dictionary meaning or association in commerce with any business other than the Complainant’s. In these circumstances, some explanation from the Respondent for the choice of name is clearly required, in view particularly of its use of the disputed domain name in a complementary (if not identical) business sector to that of the Complainant. The Panel also doubts the Respondent’s explanation for its addition of the term “state” to the LENNAR mark within the disputed domain name. While the Respondent asserts that this represents “estate”, as in real estate, the Panel finds there to be no independent evidence of the use of the abbreviated term “state” for that purpose. page 6 Secondly, the Panel finds there are elements of the Respondent’s website which cast significant doubt on its claim to have established that website without knowledge of, or any reference to, the Complainant. Most notable in this regard is the Respondent’s use of a blue “Lennar” logo at the top left-hand corner of its website. While the Respondent points out that its logo is not fully in upper case, and that the Complainant has no monopoly over the colour blue, the inclusion of this logo raises a clear inference of bad faith in all the circumstances of the case. The Panel also notes the Respondent’s inclusion on its website of the term “Find Your Dream Property”, and also its references to its offering properties “under construction” (as per the Complainant’s primary business). While neither of these elements is conclusive in itself of bad faith intent, both matters contribute to the overall impression of the Respondent’s website implying some level of connection with the Complainant and its business. The Respondent argues that there is no realistic prospect of confusion between its website and the Complainant’s business, because the Respondent operates in Egypt alone, serves a “different primary customer base” in a different industry segment, uses Egyptian contact details, and has no business in the United States. However, the Panel does not find these factors to be conclusive of an absence of bad faith. For one matter, while the Respondent may be based in Egypt and offer only Egyptian properties, there is no evidence that its website is unavailable in the United States, or that it would not come to the attention of United States-based buyers who might be seeking a property in an Egyptian resort: indeed, the Respondent’s reference to its “primary” customer base being Egyptian clearly leaves open this possibility. In the view of the Panel, a United States-based Internet user encountering the Respondent’s website would be likely to make an association between it and the Complainant. In any event, the Panel does not find that a likelihood of customer confusion is a necessary constituent of taking unfair advantage of a trademark. As discussed, e.g., in WIPO Overview 3.1, section 3.1, the specific circumstances set out under paragraph 4(a) of the Policy are illustrative only, and the overall test is whether the Respondent has sought to take unfair advantage of the Complainant’s trademark rights. In the view of the Panel, such unfair advantage can be taken where a respondent seeks to benefit from an association with the cachet or attractive power of a third party trademark, regardless of whether actual customer confusion can be demonstrated. The Panel finds that to have been the Respondent’s likely intention in this case, and notes in this regard that the Respondent refers in the Response to “[t]he Complainants’ famous LENNAR Marks”, although at the same time denying any prior knowledge of those marks. The Panel makes no finding as to whether or not the Complainant’s “cease and desist” communication was duly communicated to the Respondent, which matter would not affect the outcome of this proceeding. The Panel concludes, in the circumstances, that the disputed domain name was registered and has been used by the Respondent to take unfair advantage of the Complainant’s established trademark rights, which constitutes bad faith. The third element under the Policy is therefore established. 8. 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 <lennarstate.com> be transferred to the Lennar Corporation Complainant. /Steven A. Maier/ Steven A. Maier Sole Panelist Date: June 17, 2026

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

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