Westmore · UDRP DecisionPga-international.com
The Panel ordered transfer of <pga-international.com>. It found the domain confusingly similar to the Complainant’s registered PGA mark because the mark remained recognizable despite the addition of a hyphen and the descriptive term “international.” The Respondent lacked rights or legitimate interests because the domain was used for a website found to impersonate the Complainant’s platform and solicit users’ personal information, without authorization. The Panel also found registration and use in bad faith based on deliberate targeting of the PGA mark and use of the website for deceptive purposes under paragraph 4(b)(iv) of the Policy.
The timeline behind pga-international.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 pga-international.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a trademark-plus-descriptive-term domain can reinforce rather than dispel targeting when the added term aligns with the complainant’s international activities. It also shows that an unauthorized membership website collecting personal information may simultaneously defeat legitimate-interest claims and support bad faith, particularly where the complainant operates a controlled licensing structure that the website appears to imitate.
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 The Professional Golfers’ Association Limited v. Eric van der Burg, Nomads Concepts Case No. D2026-2201 1. The Parties The Complainant is The Professional Golfers’ Association Limited, United Kingdom, represented by Keltie LLP, United Kingdom. The Respondent is Eric van der Burg, Nomads Concepts, Netherlands (Kingdom of the). 2. The Domain Name and Registrar The disputed domain name <pga-international.com> is registered with Realtime Register B.V. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 21, 2026. On May 22, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 24, 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 (Continental Professional Golfers Association) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 27, 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 28, 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 June 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 21, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 26, 2026. page 2 The Center appointed Ganna Prokhorova as the sole panelist in this matter on July 2, 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, established in 1901, is the professional body which represents the interests of teaching and club golf professionals in the United Kingdom and the Republic of Ireland. The Complainant was the first ever association of professional golfers and one of the largest in the world by membership. It has a membership of over 8,000 professionals with 1,500 working overseas in more than 80 countries worldwide. The Complainant licenses the use of its mark to national golf associations, which are authorized to use the PGA mark followed by the name of their respective country, such as PGA Polska, PGA France, and others. The Complainant is the owner of numerous trademark registrations incorporating the mark PGA, including, inter alia: - United Kingdom trademark registration PGA (word), No. UK00900348003, registered on March 15, 1999, in classes 16, 25 and 28; - European Union trademark registration PGA (word), No. 000348003, registered on March 15, 1999, in classes 16, 25 and 28; and - European Union trademark registration PGA (word), No. 001213750, registered on February 20, 2001, in class 37, 41 and 42. The Complainant has also operated the domain name <pga.info> since 2001. The disputed domain name was registered on April 6, 2024. At the time of filing of the Complaint, the disputed domain name resolved to a website presenting itself as a membership page of the “Continental Professional Golfers’ Association”. The website displayed the association’s name and logo, as well as an image of a woman holding a golf club and location in the Netherlands (Kingdom of the). The website also invited Internet users to “fill in the form to become a member” and requested personal information including the user’s first and last name, email address, postal address, country, membership preference, golf handicap, and message. As of the date of this Decision, the disputed domain name no longer resolves to an active website. 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: 1. The disputed domain name is confusingly similar to the Complainant’s trademark, since it incorporates the PGA mark in its entirety, and the addition of hyphen and the term “international” does not prevent confusion. The generic Top-Level-Domain (“gTLD”) “.com” does not prevent the confusing similarity between the disputed domain name and the Complainant’s trademark ; 2. The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not affiliated with the Complainant, has no license or authorization to use the PGA mark, and is not commonly known by “PGA”. The disputed domain name resolved to a webpage where visitors were page 3 asked to provide their sensitive information by filling out the presented form, which is not a bona fide offering of goods or services. The Respondent’s use of the disputed domain name therefore creates a false and misleading impression that it is affiliated with or is a licensee of the Complainant. Impersonating the Complainant and its authorized service negates any claim of legitimate interest. 3. The disputed domain name was registered and is being used in bad faith. The disputed domain name was registered on April 6, 2024. Registering the disputed domain name so obviously connected to a well-known mark without authorization is itself evidence of bad faith. The Respondent used the disputed domain name to resolve to a webpage containing an online form requesting customer email and home addresses as well as personal contact details. Furthermore, the Respondent’s conduct in presenting itself as the Complainant on the website reinforces this conclusion. Therefore, by using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial purposes, Internet users to its website, by creating a likelihood of confusion with the Complainant's trademark. Such conduct is clearly designed to create a misleading association with the Complainant further reinforces finding bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules provides that the Panel is to decide the Complaint on the basis of the statements and documents submitted in accordance with the Policy, the Rules, and any rules and principles of law that it deems applicable. The onus is on the Complainant to make out its case and it is apparent, both from the terms of the Policy and the decisions of past UDRP panels, that the Complainant must show that all three elements set out in paragraph 4(a) of the Policy have been established before any order can be made to transfer the disputed domain name. In UDRP cases, the standard of proof is the balance of probabilities. To succeed in a UDRP complaint, the Complainant has to demonstrate that all the elements listed in paragraph 4(a) of the Policy have been satisfied, namely: (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. The Respondent was given proper notice of the Complaint and had the opportunity to respond. Under paragraph 5(a) of the Rules, the Respondent was required to submit its response within 20 days of commencement of the proceeding. The Respondent failed to do so. Pursuant to paragraph 5(f) of the Rules, in the event of such a default, the Panel shall proceed to a decision based on the Complaint. However, the Respondent’s default does not mean that the Complainant automatically prevails; the Complainant continues to bear the burden of proof on each element. The Panel may draw appropriate inferences from the Respondent’s silence, and, where appropriate, accept as true the reasonable allegations in the Complaint that are not contradicted by evidence. The Panel has reviewed the entire case file and the evidence provided. The Panel is also guided, where pertinent, by the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), which reflects consensus positions of UDRP panels on many common issues. The Panel will make reference to these consensus views in the analysis below as applicable. page 4 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 mark and the disputed domain name. WIPO Overview 3.1, section 1.7. Based on the evidence submitted by the Complainant, the Panel finds that the Complainant has shown rights in respect of its PGA mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that the Complainant’s mark is recognizable within the disputed domain name. The disputed domain name incorporates the Complainant’s PGA mark in its entirety, with the only differences being the addition of the descriptive term “international” and a hyphen. In accordance with WIPO Overview 3.1, section 1.8, addition of other terms, whether descriptive, geographical, pejorative, meaningless, or otherwise, would not prevent a finding of confusing similarity under the first element, as the Complainant’s mark remains clearly recognizable within the disputed domain name. The Panel further notes that the gTLD “.com” is required only for technical reasons and is generally ignored for the purposes of comparison of the Complainant’s mark with the disputed domain name. WIPO Overview 3.1, section 1.11.1. Accordingly, the Panel concludes that the disputed domain name is confusingly similar to the Complainant’s mark and that the first element of paragraph 4(a) of the Policy is satisfied. 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 record, the Panel finds that the Complainant has made a prima facie showing that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not filed a Response and therefore has not rebutted the Complainant’s case or provided any evidence demonstrating rights or legitimate interests under the Policy or otherwise. The evidence shows that the Respondent is not making any bona fide offering of goods or services through the disputed domain name, but instead is using it to host a website that impersonates the Complainant’s official platform and solicits sensitive user credentials. Such use demonstrates that the Respondent lacks any rights or legitimate interests in the disputed domain name and is exploiting it for deceptive and fraudulent purposes rather than any legitimate business activity. The Complainant has established rights in the PGA trademark and confirms that it has no business or other relationship with the Respondent. The Complainant has not authorized, licensed, or otherwise permitted the Respondent to use its mark. The Complainant’s evidence further shows that the use of the PGA mark by third-party associations is subject to authorization and is typically made in the form of “PGA” followed by the name of the relevant country or national association. The Respondent has produced no evidence that it is part of that licensed network, that it has been authorized to use the PGA mark, or that it has any independent page 5 right to present itself through the disputed domain name as an international PGA-related members’ platform. On the contrary, the Respondent’s use of the disputed domain name appears calculated to take advantage of the Complainant’s licensing structure and to create a misleading impression of affiliation where none exists. Furthermore, there is nothing in the record to suggest that the Respondent is commonly known by the disputed domain name or any corresponding name. Because the Respondent has chosen not to participate in these proceedings, it has failed to rebut the Complainant’s prima facie showing. In view of the above, the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain name. Accordingly, the Complainant has satisfied the requirement of paragraph 4(a)(ii) of the Policy. 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 finds that the Respondent both registered and is using the disputed domain name in bad faith under paragraph 4(b) of the Policy. The Complainant is a British professional body representing the interests of teaching and club golf professionals in the United Kingdom and the Republic of Ireland. The Complainant operates under and is widely known by the PGA name, which it uses in connection with its activities, membership services, and representation of professional golfers. Given the Complainant’s reputation internationally, the Panel finds it implausible that the Respondent was unaware of the Complainant’s rights. The registration itself, mirroring the Complainant’s trademark in full, demonstrates clear targeting. The disputed domain name incorporates the PGA in its entirety, merely adding the descriptive term “international”, a hyphen and the gTLD “.com”. Under WIPO Overview 3.1, section 3.2.1, this composition and the disputed domain name’s use strongly suggest deliberate targeting. The disputed domain name previously resolved to a fraudulent website impersonating the Complainant, reproducing the Complainant’s PGA mark, golf-related content, and prompting users to enter sensitive user credentials. This conduct falls squarely within paragraph 4(b)(iv) of the Policy, as the Respondent intentionally attempted to attract Internet users by creating a likelihood of confusion with the Complainant’s mark for deceptive purposes. Although the website has since been deactivated, this does not negate a finding of bad faith. On the contrary, the deliberate imitation of the Complainant’s website confirms that the Respondent had no bona fide use in mind, but instead sought to exploit the Complainant’s reputation, disrupt its business, and undermine user trust. The Respondent has not provided any explanation for selecting the disputed domain name, is not commonly known by it, and has not been authorized, licensed, or otherwise permitted by the Complainant to use its mark. The absence of any Response further strengthens the inference of bad faith. See WIPO Overview 3.1, section 4.3. Considering the totality of the circumstances, including the Complainant’s established trademark rights, the Respondent’s reproduction of the Complainant’s PGA mark, the use of the disputed domain name to solicit sensitive login credentials and the clear absence of any rights or legitimate interests, the Panel concludes that the disputed domain name was registered and is being used in bad faith under paragraph 4(a)(iii) of the Policy. page 6 Accordingly, the third element of paragraph 4(a) of the Policy has been established. 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 <pga-international.com> be transferred to the Complainant. /Ganna Prokhorova/ Ganna Prokhorova Sole Panelist Date: July 15, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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