Westmore · UDRP DecisionNltravelex.com + 7 more domains
The Panel consolidated the proceeding against the nominally different registrants after finding indicators of common control and no unfairness or inequity. All eight domain names were confusingly similar to the TRAVELEX mark, the Respondent failed to rebut the Complainant's prima facie case on rights or legitimate interests, and bad faith was established through impersonation/passing off at three domain names and passive holding of the remaining five. The Panel ordered all eight domain names transferred to the Complainant.
The timeline behind nltravelex.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 nltravelex.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
This decision illustrates how a panel may consolidate multiple nominal registrants where a record contains several converging indicators of common control. It also shows the combined treatment of actively abusive and inactive domain names within the same coordinated registration pattern: direct impersonation/passing off supported bad faith for three names, while the relationship between those names and five inactive variants contributed to a passive-holding finding for the remainder.
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 Travellers Exchange Corporation Limited v. tiffany fisher, John Rahm, Michael Page Case No. D2026-2288 1. The Parties The Complainant is Travellers Exchange Corporation Limited, United Kingdom, represented by Addleshaw Goddard, United Kingdom. The Respondents are tiffany fisher, John Rahm, and Michael Page, United States of America (“United States”). 2. The Domain Names and Registrars The disputed domain names <nltravelex.com>, <travelexnl.com>, <travelexnlswap.com>, <travelexnlswop.com>, <travelexpl.com> and <travelexswop.com> are registered with NameSilo, LLC; and the disputed domain names <nltravelexswap.com> and <switchtravelex.com> are registered with Gname.com Pte. Ltd. (collectively, the “Registrar(s)”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 27, 2026. On May 28, 2026, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names. On May 28, 2026, and May 29, 2026, the Registrars transmitted by email to the Center their verification responses disclosing registrant and contact information for the disputed domain names which differed from the named Respondents (“Redacted for privacy / “Privacy User #78028531” / “Privacy User #7301e9cf” / “Privacy User #917d8f56” / “Privacy User #0b527200” / “Privacy User #50e95aeb”) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 1, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaints for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on June 2, 2026. page 2 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 Respondents of the Complaint, and the proceeding commenced on June 10, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 30, 2026. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on July 2, 2026. The Respondents sent email communications to the Center on June 10, 2026, July 2, 2026, and July 6, 2026. The Center appointed Sebastian M.W. Hughes as the sole panelist in this matter on July 9, 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 A. Complainant The Complainant is a company incorporated in the United Kingdom and a leading provider since 1976 of foreign currency exchange related services globally under the trade mark TRAVELEX (the “Trade Mark”). The Complainant is the owner of several registrations in jurisdictions worldwide for the Trade Mark, including United States registration No. 1,694,803, with a registration date of June 16, 1992; and United States registration No. 7,282,688, with a registration date of January 23, 2024. The Complainant also operates several websites under the Trade Mark, including at “www.travelex.com”. B. Respondents The Respondents are apparently individuals resident in the United States. C. The Disputed Domain Names The disputed domain name <nltravelex.com> was registered on January 29, 2026. The disputed domain name <travelexnl.com> was registered on December 31, 2025. The disputed domain name <travelexnlswap.com> was registered on February 2, 2026. The disputed domain name <travelexnlswop.com> was registered on February 8, 2026. The disputed domain name <travelexpl.com> was registered on March 19, 2026. The disputed domain name <travelexswop.com> was registered on November 14, 2025. The disputed domain name <nltravelexswap.com> was registered on February 7, 2026. The disputed domain name <switchtravelex.com> was registered on January 16, 2026. page 3 D. Use of the Disputed Domain Name Five of the disputed domain names have not resolved to an active website. The Complainant claims that the disputed domain names <travelexnlswop.com>, <nltravelexswap.com> and <travelexnl.com> have resolved to the same, identical website, featuring prominently the Trade Mark, apparently offering foreign exchange services, and with a link to a website apparently operated by a competitor of the Complainant and offering foreign exchange services (the “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 names. Notably, the Complainant contends that the Respondents have registered and used the disputed domain names in bad faith, by using three of the disputed domain names in respect of the Website; and that in all the circumstances the passive holding of the remaining disputed domain names also constitutes bad faith under the Policy. B. Respondents The Respondents did not formally reply to the Complainant’s contentions. The registrant of the disputed domain name <travelexswop.com> sent emails to the Center in which it stated that it does not intend to file a formal Response. 6. Discussion and Findings Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same person or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.2. As regards common control, the Panel notes that: (i) Six of the disputed domain names are registered in the name of the same individual; (ii) The disputed domain names were registered within a four month period; (iii) Six of the disputed domain names share the same Registrar; page 4 (iv) Five of the disputed domain names have not been resolved to an active website, but the other three have resolved to the same Website; (v) There are similarities between the email addresses provided in the WhoIs searches for some of the disputed domain names. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. 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 trade mark and the disputed domain name. 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 Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are 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, “nl”, “swap”, “swop”, “pl” and “switch”) may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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 names. 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 names such as those enumerated in the Policy or otherwise. page 5 Panels have held that the use of a domain name for illegal activity (here, impersonation/passing off for three of the disputed domain names) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. 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. In the present case, the Panel finds that the use of three of the disputed domain names in respect of the Website constitutes bad faith under paragraph 4(b)(iv) of the Policy. Panels have held that the use of a domain name for illegal activity (here, impersonation/passing off) constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of three of the disputed domain names constitutes bad faith under the Policy. In respect of the remaining five disputed domain names, panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s Trade Mark, the composition of the disputed domain names, and the use of the remaining three disputed domain names in bad faith in respect of the Website, and finds that in the circumstances of this case the passive holding of these five disputed domain names does not prevent a finding of 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 names <nltravelex.com>, <nltravelexswap.com>, <switchtravelex.com>, <travelexnl.com>, <travelexnlswap.com>, <travelexnlswop.com>, <travelexpl.com> and <travelexswop.com> be transferred to the Complainant. /Sebastian M.W. Hughes/ Sebastian M.W. Hughes Sole Panelist Date: July 20, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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