Westmore · UDRP decision
WIPO · Case No. D2026-3059

Rmhcseattle.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <rmhcseattle.com> to McDonald's Corporation. It found the domain confusingly similar to the Complainant’s registered RMHC mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The bad-faith finding relied particularly on the Respondent’s actual knowledge, the domain’s close resemblance to the Seattle-area sublicensee’s <rmhcseattle.org> domain, receipt and retention of a misdirected email, the Respondent’s pattern of similar registrations targeting the Complainant’s email domains, and the Respondent’s offer to assign the domain for USD 500.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-08
Panelist(s)
William F. Hamilton
Complainant
McDonald's Corporation
Respondent
Eburg City
Disputed domain(s)
rmhcseattle.com
Citation weightrelies on 5 authorities
Domain history UDRP Intelligence

The timeline behind rmhcseattle.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for rmhcseattle.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of rmhcseattle.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates bad faith where a domain substitutes one gTLD for another in an established organizational and email domain, resulting in actual email misdirection. It also shows that unrelated criticism content may not establish fair use when it does not explain the trademark-based domain choice and is inconsistent with the respondent’s demonstrated pattern of conduct.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registered and used in bad faithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-08
Panel
William F. Hamilton
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION McDonalds Corporation v. Eburg City Case No. D2026-3059 1. The Parties The Complainant is McDonald's Corporation, United States of America (“United States”), represented by Neal, Gerber & Eisenberg LLP, United States. The Respondent is Eburg City, United States. 2. The Domain Name and Registrar The disputed domain name <rmhcseattle.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 10, 2026. On July 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 15, 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 (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 16, 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 July 22, 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 July 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 18, 2026. The Respondent sent several email communications to the Center on August 10, 2026, and August 18, 2026. page 2 The Center appointed William F. Hamilton as the sole panelist in this matter on August 25, 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 a Delaware corporation. Since 1974, the Complainant has supported the Ronald McDonald House Global organization (“RMH Global”), which provides temporary housing and emotional support for the families of seriously ill children through licensees and sublicensees operating in hundreds of locations worldwide. The Complainant owns numerous trademark registrations for RONALD MCDONALD HOUSE, RONALD MCDONALD HOUSE CHARITIES, and RMHC (an acronym for RONALD MCDONALD HOUSE CHARITIES). Of particular relevance here, the Complainant owns United States trademark Registration No. 2,274,282 for RMHC (“the Mark”), registered August 31, 1999 in International Class 36 for charitable fundraising services, together with corresponding registrations for the Mark in numerous other jurisdictions, including the European Union (Registration No. 007316508, registered June 21, 2009), Canada (Registration No. TMA677221, registered November 17, 2006), and Australia (Registration No. 1291005, registered March 23, 2009). The Complainant also owns registrations for RONALD MCDONALD HOUSE, including United States Registration No. 1,201,031 (registered July 13, 1982), and RONALD MCDONALD HOUSE CHARITIES, including United States Registration No. 2,063,024 (registered May 20, 1997), together with corresponding registrations in numerous further jurisdictions (Annex 5 to the Complaint). The Complainant’s licensee, RMH Global, and its sublicensees operate region-specific chapters, including a chapter serving Western Washington and Alaska that uses the domain name <rmhcseattle.org> and e-mail addresses ending in “@rmhcseattle.org” (Annex 6 to the Complaint). The disputed domain name was registered on March 26, 2026. The Registrar confirmed the registrant as “Eburg City” of Ellensburg, Washington, United States of America. Beginning in 2019, the Respondent registered a series of domain names closely resembling e-mail domains used internally by the Complainant. The Respondent used these domain names to receive e-mails misdirected by senders who mistyped the Complainant’s actual e-mail domains, then contacted the Complainant’s executives, on occasion copying news outlets, attaching the misdirected communications and requesting payment. This conduct was the subject of at least nine prior UDRP and United States federal court proceedings between the parties (or involving the Respondent and the Complainant’s marks), including McDonald’s Corporation v. Eburg City, WIPO Case No. D2019-2164; McDonald’s Corporation v. Hello There, NAF Claim No. 1866967; Camarata v. McDonald’s Corp., Case No. C19-6236JLR (W.D. Wash.); Camarata v. McDonald’s Corporation, Case No. 21-35455 (9th Cir.); McDonald’s Corporation v. Eburg City (Gene Camarata), WIPO Case No. D2023-1237; McDonald’s Corporation v. Eburg City, WIPO Case No. D2025-1502; and McDonald’s Corporation v. Eburg City, WIPO Case No. D2025-4097, among others, each resulting in a finding against the Respondent (Annex 7 to the Complaint). The disputed domain name resolved to a website consisting of a single static page setting out grievances against the city of Ellensburg and Kittitas County, Washington, together with an automated chat function; the page makes no reference to the Complainant, RMH Global, or either’s Seattle-area chapter (Annex 8 to the Complaint). The record reflects that e-mails intended for “@rmhcseattle.org” addresses have on at least one occasion been misdirected, through inadvertent substitution of the generic Top-Level Domain (“gTLD”), to the disputed domain name, and that the Respondent forwarded a screenshot of such a misdirected e-mail to the Complainant’s executives from the e-mail address “eburgcwu@[...]” (Annex 9 to the Complaint). page 3 5. Parties’ Contentions A. Complainant The Complainant contends that it has established each of the three elements required for transfer of the disputed domain name under the Policy. The Complainant contends that it owns registered rights in the Mark and in related RONALD MCDONALD HOUSE and RONALD MCDONALD HOUSE CHARITIES marks, and that the disputed domain name is confusingly similar to the Mark because it reproduces the Mark in its entirety, with the mere addition of the geographic term “seattle” and the “.com” gTLD, neither of which avoids a finding of confusing similarity. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name, noting that the Respondent has never been known by the disputed domain name, holds no trademark rights in the Mark, has not been authorized by the Complainant to use the Mark, and has instead used the disputed domain name to intercept e-mails misdirected by senders intending to reach the Complainant’s Seattle-area sublicensee, which the Complainant contends is neither a bona fide offering of goods or services nor a legitimate noncommercial or fair use, and that the Respondent’s redirection of the disputed domain name to a gripe site concerning an unrelated local dispute is a pretext that does not confer rights or legitimate interests. The Complainant further contends that the Respondent registered and has used the disputed domain name in bad faith, given the renown of the Mark, the Respondent’s actual knowledge of the Complainant’s rights, the Respondent’s use of the disputed domain name to receive misdirected confidential communications as part of a fraudulent scheme, and the Respondent’s established pattern of registering domain names targeting the Complainant’s marks and e-mail systems, as confirmed by numerous prior proceedings against the Respondent. The Complainant requests that the disputed domain name be transferred to the Complainant. B. Respondent The Respondent did not submit a formal Response. The Respondent sent an informal e-mail communication to the Center on August 18, 2026, asserting that the Complainant’s Seattle-area sublicensee is an independent nonprofit organization, that “Seattle” is a geographic term incapable of trademark protection, and that the Respondent registered and used the disputed domain name in good faith to alert senders and recipients to misdirected e-mails. The communication also forwarded an earlier e-mail in which the Respondent had proposed assigning the disputed domain name to the Complainant in exchange for USD 500 toward the Complainant’s refundable filing fee. 6. Discussion and Findings A. Identical or Confusingly Similar The first element functions primarily as a standing requirement. The 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 the Mark through its registered trademarks, including United States Registration No. 2,274,282, for purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The disputed domain name reproduces the Mark in its entirety, adding only the geographic term “seattle” and the “.com” gTLD. The addition of a geographic or otherwise generic term does not prevent a finding of confusing similarity where, as here, the Mark remains clearly recognizable within the disputed domain name; if anything, pairing the Mark with the name of the very city in which the Complainant’s sublicensee operates a Ronald McDonald House chapter heightens, rather than dispels, the likelihood that an Internet user would associate the disputed domain name with the Complainant. page 4 WIPO Overview 3.1, section 1.8. The gTLD is a standard registration requirement and is disregarded for purposes of this comparison. WIPO Overview 3.1, section 1.11. The Panel finds that the disputed domain name is confusingly similar to the Mark and 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 the disputed domain name. Although the overall burden of proof rests with the Complainant, where the Complainant makes out a prima facie case that the Respondent lacks rights or legitimate interests, the burden of production shifts to the Respondent to come forward with relevant evidence demonstrating such rights. WIPO Overview 3.1, section 2.1. The Complainant has established a prima facie case. The Respondent has never been known by the disputed domain name, holds no trademark rights in the Mark, and has not been authorized by the Complainant to use the Mark. The Respondent has not come forward with evidence of rights or legitimate interests of the kind enumerated in the Policy or otherwise; the informal communication described in Section 5B above asserts good intentions but does not establish any right to register or use the disputed domain name. The Panel notes that the nature of the disputed domain name, pairing the Mark with the name of the very city in which the Complainant’s sublicensee operates a Ronald McDonald House chapter, carries a risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. Moreover, the record shows the disputed domain name has been used to receive e-mails misdirected by senders intending to reach the Complainant’s sublicensee. In the context of this case, and noting the Parties’ prior disputes, the Panel does not consider such use supports a finding of rights or legitimate interests. The fact that the disputed domain name resolved to a page airing grievances against Ellensburg and Kittitas County, Washington does not assist the Respondent. That content has no connection whatsoever to the Complainant, the Mark, or the Respondent’s stated dispute with either. A criticism site directed at a third party is not fair use of a domain name confusingly similar to the Complainant’s Mark, and its incongruity with the domain name itself is more consistent with a pretext than with any genuine noncommercial purpose. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy sets out a non-exhaustive list of circumstances that, if found, are evidence of registration and use of a domain name in bad faith. Other circumstances may also support a finding of bad faith. WIPO Overview 3.1, section 3.2.1. The Respondent registered the disputed domain name with actual knowledge of the Complainant’s rights. The Mark is well known. Moreover, the Panel observes that the Complainant’s sublicensee has used RMHCSEATTLE for its Seattle-area Ronald McDonald House chapter. The Complainant in this context has provided evidence on using this trademark in its social media and consumer channels. The Respondent has also been a named party in at least nine prior UDRP and United States federal court proceedings arising from his registration of domain names closely resembling the Complainant’s e-mail domains. Each of those proceedings resulted in a finding against the Respondent. The Respondent cannot credibly claim ignorance of the Complainant’s rights in this proceeding. WIPO Overview 3.1, section 3.2.2. page 5 The disputed domain name is part of the same pattern. It closely resembles the Complainant’s sublicensee’s own domain name, <rmhcseattle.org>, differing only in the gTLD. The record shows that e- mails intended for “@rmhcseattle.org” addresses have already been misdirected to the disputed domain name as a result of this resemblance, and that the Respondent has retained and forwarded at least one such misdirected e-mail. This is consistent with the Respondent’s prior conduct, in which he registered domain names resembling the Complainant’s actual e-mail domains, intercepted misdirected communications, and then contacted the Complainant’s executives regarding the intercepted material. A pattern of registering domain names to target the Complainant and receive communications intended for the Complainant, with clear knowledge of the Complainant’s rights and objection to such activities, supports a finding of bad faith in this case. The Respondent’s redirection of the disputed domain name to a page unrelated to the Complainant does not change this. If anything, a criticism page with no connection to the Complainant or the Mark is difficult to reconcile with any purpose other than the one the Complainant alleges. The Respondent’s own communication in this proceeding undercuts his stated position further. Rather than maintaining that the disputed domain name serves some independent public-interest purpose, the Respondent offered to assign it to the Complainant for USD 500. The Panel finds the Respondent registered and has used the disputed domain name in bad faith, and that the third element of the Policy has been established. 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 <rmhcseattle.com> be transferred to the Complainant. /William F. Hamilton/ William F. Hamilton Sole Panelist Date: September 8, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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