Westmore · UDRP DecisionSincerlyour.com
The Panel ordered transfer of <sincerlyour.com>. It found the domain confusingly similar to Complainant’s SINCERELY YOURS mark because the mark remained recognizable despite the misspelling. Complainant established an unrebutted prima facie case that Respondent lacked rights or legitimate interests, and the copycat website could not confer such rights or interests. Bad faith registration and use were established from the website’s close imitation of Complainant’s website, prominent display of the mark without an affiliation disclaimer, and cited prior UDRP cases indicating a pattern of impersonating trademark holders.
The timeline behind sincerlyour.com
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The decision illustrates how direct website imitation can establish targeting and bad faith even when the complainant’s trademark registration issued after the disputed domain was registered. The Panel relied on the claimed earlier commercial use, the pending application, and especially the content of the copycat website as evidence that Respondent knew of and targeted Complainant at registration.
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 Sincerely Yours, Inc. v. Maci Woyat Case No. D2026-2315 1. The Parties Complainant is Sincerely Yours, Inc., United States of America (“United States”), represented by Sideman & Bancroft, LLP, United States. Respondent is Maci Woyat, United States. 2. The Domain Name and Registrar The disputed domain name <sincerlyour.com> is registered with Dominet (HK) Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 28, 2026. On May 29, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 1, 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 Unknown) and contact information in the Complaint. The Center sent an email communication to Complainant on June 1, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amen ded Complaint on June 6, 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 Respondent of the Complaint, and the proceedings commenced on June 8, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 28, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on June 29, 2026. page 2 The Center appointed Lorelei Ritchie 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 Complainant is a company based in the United States. Founded in 2025, Complainant offers beauty and skincare products under the mark SINCERELY YOURS. Complainant owns a registration for its SINCERELY YOURS mark, United States Registration No. 8266088 (registered May 19, 2026). The application has a filing date of October 17, 2024 and claims first use in commerce on September 6, 2025. Complainant advertises its products to consumers online via a website located at <sincerely- yours.com>. The disputed domain name was registered on April 3, 2026. Respondent has used the URL associated with the disputed domain name to resolve to a website that mimics Complainant's website, including prominent display of Complainant's marks without any disclaimer of affiliation. Respondent has no affiliation with Complainant, and no authorization to use Complainant's marks. 5. Parties’ Contentions A. Complainant Complainant contends that (i) the disputed domain name is identical or confusingly similar to Complainant’s trademarks, (ii) Respondent has no rights or legitimate interests in the disputed domain name; and (iii) Respondent registered and is using the disputed domain name in bad faith. Complainant contends that it owns rights int the SINCERELY YOURS mark, which although relatively new, is “distinctive” and has a “strong following of brand loyalists throughout the world ”. Complainant contends that the disputed domain name clearly references Complainant's SINCERELY YOURS mark, with a simple “misspelling” thereof. Complainant asserts that Respondent lacks rights or legitimate interest in the disputed domain name, and rather has registered and is using it in bad faith, presumably for Respondent’s own commercial gain, in an attempt at impersonating Complainant's official retail website, and with “fraudulent copying of substantial portions of Complainant's website”. Complainant further asserts that Respondent has engaged in a pattern of similar bad faith behavior, as found by prior UDRP panels and cited Little Seed Farm LLC v. Maci Woyat, WIPO Case No. D2026-0548 and Nominal LLC v. Maci Woyat, WIPO Case No. D2026-0704. B. Respondent Respondent did not reply to 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 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. Complainant has shown rights page 3 in respect of the SINCERELY YOURS mark, for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel finds that despite the misspelling, the SINCERELY YOURS mark is recognizable within the disputed domain name. The disputed domain name is therefore confusingly similar to Complainant’s trademark. 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 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 Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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. Panels have held that the use of a domain name for illegitimate activity such as operation of a copycat website, 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 There are several ways that a complainant can demonstrate that a domain name was registered and used in bad faith. As noted in Section 4 of this Panel’s decision, the record includes evidence that Respondent has used the URL associated with the disputed domain name to resolve to a website that mimics Complainant’s own website, with prominent display of Complainant's mark, and with no disclaimer of affiliation or lack thereof. The Panel thus finds sufficient evidence that Respondent was aware of Complainant’s mark at the time of registering the disputed domain name. The Panel notes that, while Complainant’s trademark registration had not yet issued as of April 3, 2026, when the disputed domain name was registered (the registration did not issue until May 19, 2026), Complainant had a pending trademark application on file since October 17, 2024, with a claim of first use in commerce as of September 6, 2025. Respondent’s conduct -including the creation of a website that closely mimics Complainant’s website and prominently displays Complainant’s mark - is consistent with prior knowledge of Complainant and its mark and constitutes sufficient evidence of Respondent’s awareness of Complainant’s rights at the time of registration. WIPO Overview 3.1, section 3.4. This is further evidenced by the UDRP cases referenced in Section 5, which indicate a bad faith pattern by Respondent of registering domain names and using them to set up websites impersonating the mark holder. The Panel finds the third element of the Policy has been established. page 4 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 <sincerlyour.com> be transferred to Complainant. /Lorelei Ritchie/ Lorelei Ritchie Sole Panelist Date: July 16, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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