Westmore · UDRP DecisionLkqcorporation.net
The Panel ordered transfer of <lkqcorporation.net>. It found the domain identical to the Complainant’s LKQ CORPORATION mark, found no rights or legitimate interests, and concluded that the Respondent registered and used the domain in bad faith through an impersonating website and communications with a potential vendor indicating a likely attempt to divert payment fraudulently. The domain’s subsequent passive holding did not prevent a finding of bad faith.
The timeline behind lkqcorporation.net
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates how exact incorporation of a corporate mark, combined with a matching business-themed website and vendor communications, can establish all three UDRP elements. It also shows that disabling the website before a decision does not neutralize evidence of prior impersonation or likely fraudulent use.
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 LKQ Corporation v. Kristian Trompiz Case No. D2026-2556 1. The Parties The Complainant is LKQ Corporation, United States of America (“United States”), represented by Irwin IP LLP, United States. The Respondent is Kristian Trompiz, United States. 2. The Domain Name and Registrar The disputed domain name <lkqcorporation.net> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 11, 2026. On June 12, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 14, 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 (Registration Private, Domains by Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 15, 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 amended Complaint on June 19, 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 the Respondent of the Complaint, and the proceedings commenced on June 23, 2026. In accordance with the Rules, paragraph 5, the due date for the Response was July 13, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Parties of the Respondent’s default on July 22, 2026. page 2 The Center appointed Ingrīda Kariņa-Bērziņa as the sole panelist in this matter on July 24, 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, an American company registered in Delaware and headquartered in Chicago, Illinois, is a provider of alternative and specialty parts for automobiles and other vehicles. It is the proprietor of the following trademarks: - United States Trademark Registration No. 3589998 for LKQ CORPORATION (device mark), registered on March 17, 2009, for services in class 35, claiming a date of first use in 2007; - United States Trademark Registration No. 4221221 for LKQ (word mark), registered on October 9, 2012, for services in class 35, claiming a date of first use in 1998. The Complainant operates its primary business website at the domain name <lkqcorp.com>. The disputed domain name was registered on October 20, 2025. At the time of this Decision, it did not resolve to an active website. The record contains evidence that it previously resolved to a website stating “LKQ CORPORATION. Your Trusted Source for Auto Parts” above a box inviting Internet users to enter their name and email address to send a message. After the website was disabled, an email was sent from a Gmail address to an event provider, allegedly representing the Complainant. A subsequent email message in the exchange displayed an email address reflecting the disputed domain name in the signature block. 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. Notably, the Complainant contends that it has been conducting business under the LKQ name since the mid- to late 1990s in the United States and today operates in 25 countries. The Complainant’s business model is to purchase used vehicles for salvaging as spare parts. It purchases more than 600,000 vehicles annually. Through this extensive and lengthy business activity, the Complainant’s LKQ mark has acquired considerable goodwill. The disputed domain name is identical to the Complainant’s LKQ CORPORATION mark and wholly incorporates its LKQ mark. It is also nearly identical to the Complainant’s domain name. The Respondent has no rights or legitimate interests in the disputed domain name and is not affiliated with the Complainant. The Respondent used the disputed domain name to impersonate the Complainant in its website, and later attempted to defraud a vendor by purporting to act on behalf of the Complainant in an apparent phishing and fraudulent payment-diversion scheme. 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 Paragraph 4(a) of the UDRP requires the Complainant to make out all three of the following: (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 Respondent has registered and is using the disputed domain name in bad faith. Under paragraph 15(a) of the Rules, “[a] Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. 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 Complainant’s LKQ CORPORATION 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 that 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 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. page 4 In particular, the Panel notes that the disputed domain name reflects the entirety of the Complainant’s LKQ CORPORATION mark. Such a composition signals an intention on the part of the Respondent to mislead users into believing the disputed domain name is affiliated with the Complainant and cannot lead to a finding that the Respondent has rights or legitimate interests in the disputed domain name. WIPO Overview 3.1, section 2.5.1. The Panel does not find that the record supports a finding that the Respondent is commonly known by the disputed domain name nor is making legitimate noncommercial use of it. The record indicates that the disputed domain name previously resolved to a website featuring the Complainant’s mark and purportedly offering the same products marketed by the Complainant. The record also contains evidence of email in which the Respondent purported to be acting on behalf of the Complainant to request services of a vendor. Panels have held that the use of a domain name for illegitimate activity (here, claimed passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds that 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 Respondent has intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. The Complainant’s rights in the LKQ CORPORATION mark predate the registration of the disputed domain name by more than 15 years. The inherently misleading disputed domain name creates a risk of confusion reinforced by the use of the disputed domain name for a website posing as the Complainant. Accordingly, the Panel finds that the disputed domain name was registered in bad faith. WIPO Overview 3.1, section 3.1.4. The record reviewed by the Panel leaves no doubt that the Respondent selected the disputed domain name that reflects the Complainant’s earlier mark and proceeded to use it for a website purportedly related to the Complainant. Further, the record indicates that the Respondent used the disputed domain name to impersonate the Complainant in communication with a potential vendor, indicating a likely attempt to fraudulently divert payment. Panels have held that the use of a domain name for illegitimate activity (here, claimed passing off, and other types of fraud) constitutes bad faith. WIPO Overview 3.1, section 3.4. The current passive holding of the disputed domain name does not prevent a finding of bad faith in the circumstances of this case. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 5 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 <lkqcorporation.net> be transferred to the Complainant. /Ingrīda Kariņa-Bērziņa/ Ingrīda Kariņa-Bērziņa Sole Panelist Date: August 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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