Westmore · UDRP DecisionGrohegermany.com
The Panel ordered transfer of <grohegermany.com> after finding all three UDRP elements established. The domain incorporated the GROHE mark with the geographic term “Germany” and resolved to a German-language website purporting to be an official Grohe website. The Panel found that the site impersonated the Complainant, offered trademarked products at substantially discounted prices, used apparently misappropriated product images, and provided only a generic email address. Based in part on the Complainant’s test-purchase claim that payment was collected but no goods were delivered, the Panel inferred that the Respondent was soliciting payments for products it did not possess or intend to provide. This conduct conferred no rights or legitimate interests and constituted bad-faith registration and use, including under paragraph 4(b)(iv) of the Policy.
The timeline behind grohegermany.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 grohegermany.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a trademark-plus-geographic-term domain can reinforce implied affiliation when paired with a website that presents itself as an official brand store. The decision also shows how multiple website indicators—discounted pricing, apparently copied imagery, limited contact information, and a claimed paid order without delivery—can collectively support findings of illegitimate activity and bad faith, even where the Respondent defaults.
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 Grohe AG v. yanling lv Case No. D2026-2248 1. The Parties The Complainant is Grohe AG, Germany, represented by Wolpert Rechsanwälte, Germany. The Respondent is yanling lv, China. 2. The Domain Name and Registrar The disputed domain name <grohegermany.com> is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 26, 2026. On May 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 27, 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 (“Privacy service provided by Withheld for Privacy ehf”) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 28, 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 May 29, 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 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 23, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 24, 2026. The Center appointed David Taylor as the sole panelist in this matter on June 30, 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. page 2 4. Factual Background Founded in 1936 by Friederich Grohe, the Complainant is a German manufacturer of sanitary fittings and water solutions, including bathroom fittings, shower systems, faucets and kitchen fittings. The Complainant is the owner of a number of trademarks for GROHE, including: - European Union Trade Mark No. 000226662 GROHE, registered on December 7, 1999; and - International Registration No. 1384073, GROHE, registered on September 5, 2017. The Complainant is also the registrant of the domain name <grohe.com>, which resolves to its official consumer-facing website. The disputed domain name was registered on October 29, 2024. The Respondent appears to be an individual located in China. The disputed domain name resolves to a website (the “Respondent’s website”) in German that purports to be an official website of the Complainant, offering for sale products bearing the Complainant’s trademark. Prior to filing the Complaint, the Complainant attempted to purchase several products through a test purchase conducted by a representative. According to the Complainant, payment was processed for the ordered products; however, no goods were delivered. 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. The Complainant asserts rights in the GROHE trademark and submits that the disputed domain name is confusingly similar to its trademark. The Complainant submits that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant asserts that it has no relationship with the Respondent, and that the Respondent has not been authorized to use its trademark. The Complainant states that the Respondent has no trademark rights in “GROHE”, and that the Respondent is using the disputed domain name to impersonate the Complainant. The Complainant submits that the Respondent registered and is using the disputed domain name in bad faith. The Complainant asserts that the Respondent is holding itself out as the Complainant, purporting to sell products under the Complainant’s name and trademark, without any authorization from the Complainant. The Complainant further argues that the Respondent is operating a fake web store and is attempting to obtain commercial gain by creating a likelihood of confusion with the Complainant, thereby damaging the Complainant’s reputation. The Complainant requests transfer of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings In order to prevail, the Complainant must demonstrate that it has satisfied the requirements of paragraph 4(a) of the Policy: (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 was 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 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 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 the geographic term “Germany” may bear on the assessment of the second and third elements, t he Panel finds that the addition of such a 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. The evidence shows that the Respondent is using the disputed domain name to hold itself out as the Complainant. The Panel notes that the goods offered via the Respondent’s website are listed at substantially discounted prices, that the Respondent’s website displays product images that appear to have been misappropriated from the Complainant’s website, and that the Respondent’s website does not contain contact information other than a generic email address. The Panel further notes the Complainant’s claim that a test purchase resulted in payment being collected without delivery of the purchased goods. The Panel therefore infers that the Respondent is using the disputed domain name to solicit payments for products that the Respondent either does not possess or does not intend to provide. Prior UDRP panels have consistently page 4 held that the use of a domain name for such illegitimate activity can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel further notes that the nature of the disputed domain name itself, being composed of the Complainant’s GROHE trademark followed by the geographic term “Germany”, is such that it tends to suggest sponsorship or endorsement by the Complainant. WIPO Overview 3.1, section 2.5.1. 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 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. It is clear from the nature of the disputed domain name, coupled with the contents of the Respondent’s website, that the Respondent had the Complainant and its GROHE trademark in mind when registering the disputed domain name. The Panel finds that the Respondent, having no relationship with the Complainant or authorization to use the Complainant’s trademark, registered the disputed domain name, carrying a risk of implied affiliation with the Complainant, with a view to engaging in activity aimed at misleading Internet users, in bad faith. Panels have held that the use of a domain name for illegitimate activity, here in the form of a purported impersonation site aimed at defrauding potential customers of the Complainant, constitutes bad faith. WIPO Overview 3.1, section 3.4. The evidence before the Panel indicates that the Respondent has used the disputed domain name to impersonate the Complainant and to attract Internet users for commercial gain by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website, amounting to bad faith pursuant to paragraph 4(b)(iv) of the Policy. Having reviewed the record, the Panel finds that the Respondent’s registration and use of the disputed domain name constitute bad faith under the Policy. 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 <grohegermany.com> be transferred to the Complainant. /David Taylor/ David Taylor Sole Panelist Date: July 15, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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