Westmore · UDRP DecisionPrlotion.net
The Panel ordered transfer of <prlotion.net>. It found the domain identical to Complainant’s registered PR LOTION mark, found no rights or legitimate interests because the associated website attempted to impersonate Complainant using its AMP HUMAN mark and PR LOTION product images, and found bad-faith registration and use based on an intentional effort to attract Internet users for commercial gain through confusion with Complainant’s marks.
The timeline behind prlotion.net
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
This decision illustrates a straightforward exact-match trademark case strengthened by website content that copied an additional complainant mark and branded product images. The case did not rest solely on the domain string: the Panel treated the associated commercial website as attempted impersonation or passing off, which was decisive for both the second and third elements.
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 AmpHP, Inc. v. TC LIN Case No. D2026-2373 1. The Parties Complainant is AmpHP, Inc., United States of America (“United States”), represented by McGrath North Mullin & Kratz, PC LLO, United States. Respondent is TC LIN, United States. 2. The Domain Name and Registrar The disputed domain name <prlotion.net> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 2, 2026. On June 2, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 2, 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 (User #78e28722 Privacy, See PrivacyGuardian.org) and contact information in the Complaint. The Center sent an email communication to Complainant on June 3, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on June 3, 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 Respondent of the Complaint, and the proceedings commenced on June 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 25, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on June 26, 2026. page 2 The Center appointed Timothy D. Casey 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. 4. Factual Background Complainant sells a topical product designed to support athletic performance. Complainant first began using PR LOTION as a trademark for medicated topical preparations for the delivery of supplements as early as 2018, and owns the following registration (the “PR LOTION Mark”): Mark Jurisdiction Class(es) Registration No. Registration Date PR LOTION United States 5 6,217,293 December 8, 2020 Complainant also owns the United States Registration No. 5928599 for AMP HUMAN, registered on December 3, 2019, in Class 5. The disputed domain name was registered on January 3, 2024. Complainant provided evidence indicating that at least as of June 1, 2026, the disputed domain name resolved to a website, displaying Complainant’s AMP HUMAN mark and providing an online retail store purportedly selling Complainant’s sports lotion under the PR LOTION Mark. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, Complainant contends that it has rights in the PR LOTION Mark as evidenced herein, and that the disputed domain name is identical or confusingly similar to the PR LOTION Mark because the disputed domain name shares the identical and dominant wording of the PR LOTION Mark. Complainant contends Respondent should be considered to have no rights or legitimate interests in the disputed domain name. Complainant asserts Respondent is not commonly known by the disputed domain name and Complainant has never authorized, licensed, or otherwise permitted Respondent to use the PR LOTION Mark. Complainant contends Respondent’s use of the disputed domain name is not in connection with a bona fide offering of goods or services but rather appears designed to misappropriate the goodwill associated with the PR LOTION Mark. Complainant contends the disputed domain name should be considered to have been registered and used in bad faith because: (1) Respondent’s website offers goods for sale using the PR LOTION Mark that directly compete with Complainant’s goods and such improper use does not constitute a legitimate noncommercial or fair use of the disputed domain name, but instead demonstrates an intent by Respondent to capitalize on the reputation and consumer recognition of Complainant; (2) Respondent’s actions are intentionally designed to mislead consumers into believing that its website and products are affiliated with, sponsored by, or endorsed by Complainant, when no such relationship exists; (3) there is no evidence that Respondent has made any preparations to use the disputed domain name in connection with a bona fide offering of goods or services prior to notice of the dispute; (4) Respondent’s conduct indicates an intent to exploit Complainant’s trademark rights for commercial gain; and (5) Respondent’s registration and use of the disputed domain name incorporates the entirety of the PR LOTION Mark, which strongly suggests an attempt to trade off Complainant’s goodwill and established reputation in the marketplace. page 3 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 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 PR LOTION Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 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 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. The website at the disputed domain name attempts to impersonate Complainant by using Complainant’s AMP HUMAN mark and Complainant’s product images bearing the PR LOTION Mark. Panels have held that the use of a domain name for illegal activity, here, attempted impersonation/passing off, 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. page 4 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 Respondent’s registration and use of the disputed domain name for an impersonating website, featuring Complainant’s AMP HUMAN mark and Complainant’s product images bearing the PR LOTION Mark, disrupts the business of Complainant, which demonstrate that Respondent has intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with Complainant’s marks. Panels have held that the use of a domain name for illegal activity, here, attempted impersonation/passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The Panel finds that 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 <prlotion.net> be transferred to Complainant. /Timothy D. Casey/ Timothy D. Casey Sole Panelist Date: July 14, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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