Westmore · UDRP DecisionDailymail-uk.com
The Panel ordered transfer of <dailymail-uk.com>. It found the domain confusingly similar to the Complainant’s DAILY MAIL mark, that the Respondent had no rights or legitimate interests, and that the domain was registered and used in bad faith. The domain incorporated the mark with the geographical term “-uk” and redirected to the Complainant’s own website. The Respondent did not file a response.
The timeline behind dailymail-uk.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 dailymail-uk.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that redirecting a trademark-formative domain to the trademark owner’s own website does not, without more, establish rights or legitimate interests and may contribute to a bad-faith finding. It also shows that adding a geographical term such as “-uk” does not prevent confusing similarity where the trademark remains recognizable.
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 Associated Newspapers Limited v. Devon Guzzie Case No. D2026-2097 1. The Parties The Complainant is Associated Newspapers Limited, United Kingdom, represented by Adlex Solicitors, United Kingdom. The Respondent is Devon Guzzie, United States of America. 2. The Domain Name and Registrar The disputed domain name <dailymail-uk.com> 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 May 15, 2026. On May 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 18, 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 (Registration Private, Domains By Proxy, LLC DomainsByProxy.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 19, 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 20, 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 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 12, 2026. page 2 The Center appointed Tobias Zuberbühler as the sole panelist in this matter on June 17, 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 was incorporated in the United Kingdom on April 1, 1905, and is the management company and publisher of a range of publications in the United Kingdom including two national newspapers: the Daily Mail, and The Mail on Sunday. The Complainant owns various DAILY MAIL trademarks, including United Kingdom trademark registration No. 1207666 registered on November 22, 1983. The disputed domain name was registered on March 19, 2014, and has always been redirected to the Complainant’s own website “www.dailymail.co.uk”. 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 has not submitted any 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 Select UDRP Questions (“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 mark DAILY MAIL is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here the geographical term “-uk”) 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 that the first element of the Policy has been established. page 3 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 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 that 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 Panel finds that the composition of the disputed domain name incorporating the Complainant’s trademark, coupled with the use of the disputed domain name to redirect to the Complainant’s website, does not amount to a bona fide offering of goods or services. The Panel finds that the second element of the Policy has been established. C. Registered and Used in Bad Faith Under the circumstances of this case, including the composition and use of the disputed domain name incorporating the Complainant’s mark together with the term “-uk”, it can be inferred that the Respondent was aware of the Complainant’s mark when registering the disputed domain name. The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, 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. Having reviewed the available record, and noting the composition of the disputed domain name, under the circumstances of this case, the Panel finds that the use of the disputed domain name creates a likelihood of confusion with the Complainant’s trademark under paragraph 4(b)(iv) of the Policy. Therefore, the disputed domain name was registered and is being used in bad faith. The Panel finds that the Complainant has established the third element 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 disputed domain name <dailymail-uk.com> be transferred to the Complainant. /Tobias Zuberbühler/ Tobias Zuberbühler Sole Panelist Date: July 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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