Westmore · UDRP DecisionArla.host + 6 more domains
The Panel ordered the transfer of all seven disputed domain names. It found the domains identical or confusingly similar to the Complainant’s ARLA trademark, found no rights or legitimate interests, and concluded that six domains were used for websites impersonating or falsely suggesting affiliation with the Complainant. The inactive <arla.host> was also found to have been registered and used in bad faith under the passive-holding doctrine. The Panel additionally permitted consolidation of the nominally different registrants based on evidence of common control and determined that English would be the language of the proceeding.
The timeline behind arla.host
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 arla.host — 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 address a coordinated portfolio of domains nominally held by different registrants. Common registration timing, shared infrastructure, similar registrant data, and coordinated website content collectively supported consolidation. It also demonstrates that an inactive domain may be assessed alongside related actively abusive domains, with the broader pattern informing both the absence of legitimate interests and the passive-holding bad-faith analysis.
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 Arla Foods Amba v. arla, arla arla, liu dehua/dehua liu, liudehua, Details Not Provided by Registrant Case No. D2026-2453 1. The Parties The Complainant is Arla Foods Amba, Denmark, represented by Abion AB, Sweden. The Respondents are arla, arla arla, Armenia; liu dehua/dehua liu, liudehua, Hong Kong, China; and Details Not Provided by Registrant. 2. The Domain Names and Registrars The disputed domain name <arla.host> is registered with July Name Limited. The disputed domain names <arla.pics>, <arla.skin>, and <arla.top> are registered with NameSilo, LLC. The disputed domain names <arlavt.co>, and <arlavt.org> are registered with Gname.com Pte. Ltd. The disputed domain name <arlavt.com> is registered with GMO Internet, Inc. d/b/a Discount-Domain.com and Onamae.com. July Name Limited, NameSilo, LLC, Gname.com Pte. Ltd., and GMO Internet, Inc. d/b/a Discount-Domain.com and Onamae.com are hereinafter referred to as the “Registrars” . 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on June 5, 2026. On June 5, 2026, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names. Between June 5, 2026, and June 11, 2026, the Registrars transmitted by email to the Center their verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (User #4ed9204a Privacy, See PrivacyGuardian.org; User #3a80fa38 Privacy, See PrivacyGuardian.org; User #a765d36c Privacy, See PrivacyGuardian.org; Redacted for Privacy, and Whois Privacy Protection Service by onamae.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 11, 2026 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) 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 disputed domain names are under common control. The Complainant filed an amended Complaint in English on June 15, 2026. page 2 On June 11, 2026, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On June 15, 2026, the Complainant confirmed its request that English be the language of the proceeding. The Respondents did not submit any comment on the Complainant’s submission. 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 in Chinese and English of the Complaint, and the proceedings commenced on June 24, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 14, 2026. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on July 15, 2026. The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on July 20, 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 is Arla Foods Amba, a Danish dairy cooperative and one of the world’s largest dairy producers. The Complainant markets and sells a wide range of dairy products under the trademark ARLA and other marks. According to the evidence, the Complainant employs approximately 22,000 people and generated global revenue of EUR 15.1 billion in 2025. The Complainant conducts business internationally and maintains an extensive online presence, including through its official website and numerous domain names incorporating its ARLA trademark. The Complainant owns a large international trademark portfolio for the mark ARLA in multiple jurisdictions. These include, but are not limited to, for example, Swedish Trademark Registration No. 165607 for ARLA, registered on December 1, 1978, and International Trademark Registration No. 731917 for ARLA, registered on March 20, 2000, designating, among others, the United States of America, Colombia, and Mexico. The Complainant also owns numerous domain names incorporating the ARLA mark, including <arla.com>. According to the public WhoIs information, the disputed domain names were all registered on March 20, 2026. According to the Complaint, at the time the Complaint was filed, the disputed domain names <arla.skin>, <arla.pics>, <arla.top>, <arlavt.org>, <arlavt.co>, and <arlavt.com> resolved to websites that prominently displayed the Complainant’s ARLA trademark and presented themselves as the Complainant or relating to the Complainant. The websites contain company-related information, including sections entitled “Company Announcement”, “Company Introduction”, “Breeder Introduction”, “Product Introduction”, and frequently asked questions, together with references to the Complainant’s business and promotional material. The Complaint further states that five of these disputed domain names resolved to substantially identical websites, while <arlavt.co> resolved to a page displaying the Complainant's figurative ARLA trademark together with the message “Please use your mobile phone to open the download”. According to the Complaint, <arla.host> was inactive. Upon the Panel’s verification prior to the issuance of this Decision, the status of the disputed domain names remained materially unchanged. 5. Parties’ Contentions A. Complainant page 3 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 disputed domain names are identical or confusingly similar to its ARLA trademark. It submits that <arla.skin>, <arla.pics>, <arla.top>, and <arla.host> all incorporate the ARLA mark in its entirety, while <arlavt.org>, <arlavt.co>, and <arlavt.com> incorporate the ARLA mark together with the additional letters “vt”, which do not prevent a finding of confusing similarity. The Complainant further submits that the applicable Top-Level Domains should be disregarded for the purposes of the first element. The Complainant contends that the Respondents have no rights or legitimate interests in respect of the disputed domain names. It submits that it has not authorised the Respondents to use the ARLA trademark, that the Respondent is not commonly known by the disputed domain names and does not own corresponding trademark rights, and that the disputed domain names falsely suggest an affiliation with the Complainant. The Complainant further submits that most of the disputed domain names have been used for websites prominently displaying the ARLA trademark and company-related materials associated with the Complainant, while one disputed domain name has remained inactive, and that such use cannot constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. The Complainant contends that the disputed domain names were registered and are being used in bad faith. It submits that the ARLA trademark is well known and predates the registration of the disputed domain names, such that the Respondents must have been aware of the Complainant’s rights when registering them. The Complainant further argues that the Respondents intentionally sought to create a likelihood of confusion with the Complainant by using most of the disputed domain names for websites displaying the ARLA trademark and company-related content, and that the passive holding of <arla.host> also supports a finding of bad faith in the circumstances of this case. B. Respondents The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Preliminary Issues A. Consolidation of the 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 entity or mere alter egos of each other, or are 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. The Panel has carefully reviewed all elements of this case, giving particular weight to the following elements and facts: (a) all seven disputed domain names incorporate the Complainant’s ARLA trademark, either page 4 alone or together with the letters “vt”, thereby exposing a pattern; (b) all disputed domain names were registered on the same day, namely March 20, 2026; (c) the six active disputed domain names resolve to the same IP address; (d) the disputed domain names use related name server configurations, with <arla.skin>, <arla.pics>, and <arla.top> using the same name server, and <arlavt.org>, <arlavt.co>, and <arlavt.com> using another same name server; (e) <arla.skin>, <arla.pics>, <arla.top>, <arlavt.org>, and <arlavt.com> resolve to substantially similar websites, while <arlavt.co> resolves to a page displaying the Complainant’s figurative ARLA trademark and the message “Please use your mobile phone to open the download”, and <arla.host> is inactive, thereby exposing, on the balance of probability, a pattern of common control; (f) following registrar verification, the disclosed registrant information revealed certain commonalities and substantially similar registrant details and contact information (including, but not limited to the email address) across several of the disputed domain names; and (g) the Respondents did not submit any arguments and did not contest this request for consolidation. 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. B. Language of the Proceeding The language of the Registration Agreements for the disputed domain name <arla.host> is Chinese, while the language of the Registration Agreements for the remaining disputed domain names is English. Pursuant to paragraph 11(a) of the Rules, in the absence of an agreement between the Parties or unless otherwise specified in the Registration Agreement, the language of the administrative proceeding shall be the language of the Registration Agreement. The Complaint and the Amended Complaint were filed in English. The Complainant requested that English be the language of the proceeding, submitting, among other arguments, that the disputed domain names comprise Latin characters only, that the majority of the disputed domain names are subject to Registration Agreements in English, and that requiring a translation of the Complaint into Chinese would entail significant additional costs and delay. The Respondent did not make any submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the Registration Agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both Parties, taking into account all relevant circumstances of the case, including matters such as the Parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview 3.1, section 4.5.1). Having considered all the matters above, including that six out of the seven disputed domain names are subject to Registration Agreements in English, that the disputed domain names are composed of Latin characters, that the websites associated with the active disputed domain names contain English-language content, that the Center notified the Respondent in both Chinese and English regarding the commencement of the proceeding, and advised them that they could file a Response in either language, and that the Respondent elected not to participate in this proceeding, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 6.2 Findings on the Merits 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 names. WIPO Overview 3.1, section 1.7. page 5 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 Panel finds that the Complainant’s ARLA trademark is clearly recognizable within each of the disputed domain names. Accordingly, the disputed domain names <arla.skin>, <arla.pics>, <arla.top>, and <arla.host> are identical to the Complainant’s ARLA trademark, while the disputed domain names <arlavt.org>, <arlavt.co>, and <arlavt.com> are confusingly similar to the Complainant’s ARLA trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of another term here, the letters “vt”, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain names <arlavt.org>, <arlavt.co>, and <arlavt.com> 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. The Panel notes that the Complainant has not licensed, authorized or otherwise permitted the Respondent to use its ARLA trademark or to register any domain name incorporating that trademark. Further, there is no evidence that the Respondent is affiliated with the Complainant in any way, or that it has been commonly known by the disputed domain names within the meaning of paragraph 4(c)(ii) of the Policy. The Panel also finds that there is no evidence that the Respondent has used, or made demonstrable preparations to use, the disputed domain names in connection with a bona fide offering of goods or services. Instead, based on the evidence, the disputed domain names <arla.skin>, <arla.pics>, <arla.top>, <arlavt.org>, <arlavt.co>, and <arlavt.com> resolve to websites prominently reproducing the Complainant’s ARLA trademark and company-related information, including the Complainant’s figurative trademark and materials likely protected by copyright, in a manner that falsely suggested an affiliation with the Complainant. Panels have held that the use of a domain name for illegitimate activity, here, impersonation or passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13. As to the fact that <arla.host> resolves to an inactive page, the Panel finds that holding this disputed domain name passively, without making any active use of it, also does not confer any rights or legitimate interests in the disputed domain name on the Respondent in the circumstances of this case (see, in this regard, earlier UDRP decisions such as Bollore SE v. 赵竹飞 (Zhao Zhu Fei), WIPO Case No. D2020-0691; and Vente- Privee.Com and Vente-Privee.com IP S.à.r.l. v. 崔郡 (jun cui), WIPO Case No. D2021-1685). page 6 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, on the balance of probabilities, the Respondent registered the disputed domain names with knowledge of the Complainant and its ARLA trademark. The ARLA trademark had already been registered and used for many decades before the registration of the disputed domain names and has previously been recognized by UDRP panels as being well-known (see for instance Arla Foods Amba v. Fredrik Enghall, WIPO Case No. D2016-1205). While each case must be decided on its own facts, the Panel considers that the evidence in the present case supports a finding that the Complainant’s ARLA trademark enjoyed a high degree of recognition at the time the disputed domain names were registered, giving rise to a presumption that the Respondent was aware of the Complainant's rights when registering the disputed domain names. Additionally, a simple trademark database or Internet search conducted prior to registration would easily have disclosed the Complainant’s longstanding trademark rights. This conclusion is further confirmed by the Respondent’s subsequent use of six of the disputed domain names for websites prominently displaying the Complainant’s ARLA trademark and company-related information. Such use confirms that the Respondent was aware of the Complainant and its trademark when registering the disputed domain names. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. Based on the use made of the websites at the disputed domain names as described above, the Panel finds that the Respondent has used the disputed domain names <arla.skin>, <arla.pics>, <arla.top>, <arlavt.org>, <arlavt.co>, and <arlavt.com> to intentionally attract, for commercial gain, Internet users to the associated websites by creating a likelihood of confusion with the Complainant’s ARLA trademark as to the source, sponsorship, affiliation, or endorsement of those websites. In the circumstances of the case, the Panel finds that such conduct falls within the scope of paragraph 4(b)(iv) of the Policy, which constitutes direct evidence of bad faith under the Policy. In addition, panels have consistently held that the use of a domain name for illegal activity, including the operation of impersonating websites or falsely suggesting an affiliation with the complainant, constitutes evidence of bad faith. See WIPO Overview 3.1, section 3.4. As to the fact that <arla.host> resolves to an inactive page, 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 reputation of the Complainant’s ARLA trademark, the composition of the disputed domain name, and use of the other six disputed domain names and finds that, in the circumstances of this case, the passive holding of this disputed domain name 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. page 7 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 <arla.host>, <arla.pics>, <arla.skin>, <arla.top>, <arlavt.co>, <arlavt.com>, and <arlavt.org> be transferred to the Complainant. /Deanna Wong Wai Man/ Deanna Wong Wai Man Sole Panelist Date: July 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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