Westmore · UDRP DecisionLloyd-canada.com
The Panel ordered transfer of <lloyd-canada.com>. It found the domain confusingly similar to the Complainant’s LLOYD trademark, held that the Respondent lacked rights or legitimate interests because the domain was used to offer similar or competing products under the mark without disclosing any lack of relationship with the Complainant, and found registration and use in bad faith under Policy paragraph 4(b)(iv). The Panel did not rely on the asserted use of a privacy service or allegedly false contact information.
The timeline behind lloyd-canada.com
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The decision illustrates a direct trademark-targeting pattern in which a mark is combined with a geographic term corresponding to a jurisdiction where the complainant owns rights, then used for a commercial website offering similar or competing goods. It also shows that a panel may find bad faith from the domain composition and website use without relying on weaker allegations concerning privacy services or inaccurate contact information.
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 LLOYD Lifestyle GmbH v. Sarah M Wulf, Sarah M Wulf Case No. D2026-2152 1. The Parties The Complainant is LLOYD Lifestyle GmbH, Germany, represented by Bird & Bird LLP, Germany. The Respondent is Sarah M Wulf, Sarah M Wulf, Germany. 2. The Domain Name and Registrar The disputed domain name <lloyd-canada.com> is registered with Mat Bao Corporation (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 19, 2026. On May 19, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 20, 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 (Registrant details not provided, Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 22, 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 amendment to the Complaint on June 8, 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 June 9, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 29, 2026. On June 11, 2026, the Complainant submitted a Supplemental Filing. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 1, 2026. page 2 The Center appointed Pascal Böhner as the sole panelist in this matter on July 8, 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 a German shoe manufacturer, with a corporate history dating back to 1905. The Complainant sells footwear as well as bags, wallets, and clothing through stationary retail stores and its online presence at “www.lloyd.com”. The Complainant or its affiliates are the owners of numerous trademark registrations consisting of or containing the term LLOYD, including: - LLOYD, European Union Trademark No. 019103392, registered on March 14, 2025; - LLOYD, Canadian Trademark No. TMA922052, registered on December 2, 2015; - LLOYD GERMANY 1888 (device), International Registration No. 1722617, registered on November 17, 2022, designating inter alia Canada, the European Union, Japan, United Kingdom, and the United States of America. The disputed domain name was registered on November 19, 2025. The disputed domain name has been used to for a website featuring an image of a LLOYD store and offering for sale competing or similar goods under the trademark LLOYD to consumers. 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 LLOYD trademarks, that the Respondent has no rights or legitimate interests in respect of the disputed domain name, and that the disputed domain name has been registered and is being used in bad faith. The Complainant further submits that the Respondent’s use of a privacy service and the allegedly false registrant contact data disclosed by the Registrar support a finding of bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings On June 11, 2026, the Complainant submitted a Supplemental Filing providing evidence that its letter dispatched to the Respondent at the postal address disclosed by the Registrar returned undelivered. The Panel admits the Complainant’s Supplemental Filing as it provides evidence that was unavailable to the Complainant at the time the Complaint was filed. 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. page 3 The Complainant has shown rights in respect of a trademark LLOYD for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark 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 geographic term “canada”, 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 use of the disputed domain name to offer for sale similar or competing products under the LLOYD mark, without disclosing the website’s lack of relationship with the Complainant, is not a bona fide offering. 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. In the present case, the Panel notes that the disputed domain name was registered many years after the Complainant’s registration of the LLOYD trademarks, including in Canada. The disputed domain name fully incorporates the Complainant’s LLOYD mark together with the geographic term “canada”, corresponding to a jurisdiction in which the Complainant holds trademark rights. In the circumstances of this case, the Panel finds that the Respondent registered the disputed domain name with knowledge of the Complainant and its trademark, and with the intention of targeting the Complainant. Moreover, the disputed domain name has been used to intentionally attempt to attract, for commercial gain, Internet users to a website by creating a likelihood of confusion with the Complainant’s mark as to the page 4 source, sponsorship, affiliation, or endorsement of the website or of a product or service on the website, within the meaning of paragraph 4(b)(iv) of the Policy. The Complainant has further invoked the Respondent’s use of a privacy service and the allegedly falsified registrant contact information as indicators of bad faith. As to the former, the Panel notes that there exist recognized legitimate uses of privacy and proxy registration services, and that the mere use of such a service alone is not, without more, indicative of bad faith. WIPO Overview 3.1, section 3.6. As to the latter, the Panel finds the evidence submitted – a returned postal letter – does not show the recipient’s address which it had been dispatched to and thus does not support the Complainant’s assertion. Neither argument, however, is, in any event, necessary to the Panel’s finding of bad faith in the present case. 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 <lloyd-canada.com> be transferred to the Complainant. /Pascal Böhner/ Pascal Böhner Sole Panelist Date: July 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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