Westmore · UDRP DecisionBetterlifecleaner.net
The Panel ordered transfer of <betterlifecleaner.net>. It found the domain confusingly similar to the Complainant’s BETTER LIFE mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith through a website impersonating the Complainant and apparently participating in an Amazon affiliate program.
The timeline behind betterlifecleaner.net
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates a strong targeting pattern where a domain combines an entire trademark with a term describing the trademark owner’s products and then resolves to an impersonating, affiliate-linked website. The same facts reinforced all three UDRP elements: recognizable incorporation of the mark, absence of legitimate use, and intentional bad-faith targeting.
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 Mango Wonder, Inc. v. Valentina Vorovska Case No. D2026-2041 1. The Parties The Complainant is Mango Wonder, Inc., United States of America (“United States”), represented by Frankfurt Kurnit Klein & Selz PC, United States. The Respondent is Valentina Vorovska, Germany. 2. The Domain Name and Registrar The disputed domain name <betterlifecleaner.net> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 12, 2026. On May 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 14, 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 (Dynadot Privacy Service, Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 14, 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 15, 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 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 7, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 8, 2026. page 2 The Center appointed Vincent Denoyelle as the sole panelist in this matter on June 11, 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 the owner of the BETTER LIFE trade mark which the Complainant uses to market and sell a variety of household cleaning products. The Complainant owns the following trade mark registrations in BETTER LIFE: • United States Trade Mark BETTER LIFE, registration number 3897618, registered on December 28, 2010 and; • United States Trade Mark BETTER LIFE, registration number 6463946, registered on August 24, 2021. The disputed domain name was registered on March 19, 2025, and it points to a website impersonating the Complainant displaying the Complainant’s trade marks and logo prominently at the top of the home page and throughout the website. At the bottom of the website there is a copyright notice along with a statement indicating that the disputed domain name is a participant in the Amazon Services LLC Associates Program. 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. Notably, the Complainant contends that the disputed domain name is confusingly similar to its BETTER LIFE trade mark as it reproduces the entirety of its trade mark. The Complainant asserts that its BETTER LIFE trade mark has been firmly established before the registration of the disputed domain name. The Complainant states that the Respondent cannot claim or show any rights to the disputed domain name that are superior to the Complainant’s trade marks. The Complainant submits that the Respondent is not commonly known by the disputed domain name. The Complainant contends that the Respondent has intentionally attempted to attract, for its commercial gain, Internet users to the Respondent’s website by creating an unauthorized association and likelihood of confusion with the BETTER LIFE trade mark. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 of WIPO Panel Views on page 3 Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the BETTER LIFE trade mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the trade mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “cleaner”, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name 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. 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 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. The disputed domain name points to a website impersonating the Complainant, displaying the Complainant’s trade marks and logo prominently at the top of the home page and throughout the website. Panels have held that the use of a domain name for illegitimate activity here, claimed impersonation, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The nature of the disputed domain name incorporating the Complainant’s trade mark in its entirety, carries a risk of implied affiliation, especially when considering the impersonating nature of the content exhibited at the disputed domain name, and as such cannot be considered legitimate. See section 2.5.1 of the WIPO Overview 3.1. 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. page 4 In the present case, the Panel finds that the Respondent must have been aware of the Complainant’s BETTER LIFE trade mark and must have targeted the Complainant at the time of registration given (i) the fact that the disputed domain name reproduces the exact BETTER LIFE trade mark of the Complainant, (ii) the fact that the disputed domain name has been registered many years after the BETTER LIFE trade mark, (iii) the targeted choice of descriptive word used in the disputed domain name, “cleaner”, which corresponds to the type of product the Complainant’s trade mark is used for and (iv) the content made available on the website associated with the disputed domain name which clearly demonstrates the Respondent’s intent to specifically target the Complainant. WIPO Overview 3.1, section 3.2.1. The Panel finds that the disputed domain name was registered in bad faith. Turning to use of the disputed domain name in bad faith, panels have held that the use of a domain name for illegitimate activity here, claimed impersonation, constitutes bad faith. WIPO Overview 3.1, section 3.4. The Panel further finds that the Respondent has presumably obtained financial gain from its misleading activity, by obtaining revenues from the Amazon.com affiliate program based on purchases referred via its impersonating website. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under 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 disputed domain name <betterlifecleaner.net> be transferred to the Complainant. /Vincent Denoyelle/ Vincent Denoyelle Sole Panelist Date: June 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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