Westmore · UDRP DecisionHalorecessedlighting.com
The Panel ordered the transfer of <halorecessedlighting.com> to Signify Holding B.V. It found the domain confusingly similar to the Complainant’s HALO trademark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The domain resolved to an affiliate website presenting HALO-branded recessed-lighting content and redirecting users to Amazon listings without clearly disclosing the absence of affiliation with the Complainant.
The timeline behind halorecessedlighting.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates how an ostensibly informational product website can fail the rights-or-legitimate-interests test when its presentation suggests official affiliation and its content operates as a vehicle for affiliate revenue. The decision also shows that Oki Data principles may not assist an operator that does not directly sell the relevant goods, omits a conspicuous non-affiliation disclaimer, and uses trademark-owner branding and history to drive click-through traffic.
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 Signify Holding B.V. v. Maymunah Maymunah Case No. D2026-3125 1. The Parties The Complainant is Signify Holding B.V., Netherlands (Kingdom of the), represented by Signify Intellectual Property, Netherlands (Kingdom of the). The Respondent is Maymunah Maymunah, Ukraine. 2. The Domain Name and Registrar The disputed domain name <halorecessedlighting.com> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 16, 2026. On July 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 17, 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 (“REDACTED FOR PRIVACY, Super Privacy Service LTD c/o Dynadot”) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 17, 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 17, 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 21, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 10, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 12, 2026. page 2 The Center appointed Reyes Campello Estebaranz as the sole panelist in this matter on August 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. Further Procedural Considerations Under Paragraph 10 of the Rules, the Panel is required to ensure that the Parties are treated with equality, that each Party is given a fair opportunity to present its case, and that the administrative proceeding takes place with due expedition. The Respondent’s physical address is located in Ukraine, which is currently affected by an ongoing international conflict that may impact the delivery of physical case notifications. Accordingly, the Panel considers it appropriate to determine, pursuant to its discretion under Paragraph 10 of the Rules, whether this proceeding should continue. Having considered all relevant circumstances, the Panel concludes that it should proceed to a decision. Although the courier service was unable to deliver the written notice to the Respondent’s physical address in Ukraine, the Center successfully transmitted the Complaint and notifications to the Respondent’s email address on record with the Registrar, with no delivery failures reported. Furthermore, the Panel notes that the Complainant submitted to the jurisdiction of the courts at the location of the principal office of the concerned Registrar, Dynadot Inc., located in the United States of America (“United States”) for any challenge to this Decision. It is moreover noted that, for the reasons set out later in this Decision, the Panel considers that the Respondent registered and has used the disputed domain name in bad faith and with the intention of unfairly targeting the Complainant’s goodwill in its trademark and misleading consumers. Therefore, balancing the need to ensure due process with the mandate to conduct administrative proceedings with due expedition, the Panel is satisfied that the Respondent was provided a fair opportunity to present its case, and proceeding to a decision on the merits is appropriate. 5. Factual Background The Complainant is a limited liability company organized and existing under the laws of the Netherlands (Kingdom of the) that produces and supplies lighting products worldwide, reporting sales of EUR 6.1 billion in 2024, employing approximately 29,000 people, and maintaining a presence in over 70 countries. In 2020, the Complainant acquired Cooper Lighting Solutions, including the HALO trademark, which the Complainant’s predecessors-in-interest first used in 1956 to offer recessed lighting products. Today, various lighting products are commercialized under the HALO trademark across physical stores and online marketplaces, with recessed lighting remaining a core product offered under the mark. The Complainant holds various trademark registrations for the HALO trademark, including United States Trademark Registration No. 662854, HALO (word), registered on June 10, 1958, in Class 11; and United States Trademark Registration No. 3486960, HALO (word), registered on August 19, 2008, in Class 11 (hereinafter collectively referred to as the “HALO Mark”). The Complainant further owns the domain name <cooperlighting.com> (registered on October 21, 1997), which resolves to Cooper Lighting Solutions’ corporate website, providing information about the products offered under the HALO Mark. page 3 The disputed domain name was registered on November 7, 2025. It resolves to an English-language website that displays the term HALO in black capital letters at its header. This website contains information about the “Halo Recessed Lighting Brand” and the company “Cooper Lighting Solutions,” stating that this brand has led the industry since 1956 and describing the company as “the most trusted name among builders and contractors, earning its reputation by blending professional-grade reliability with remarkably simple installation.” The website displays various lighting products with photographs and descriptions, as well as a video entitled “Halo LED RL56 Wireless Installation.” Product descriptions include clickable buttons to check prices, which redirect Internet users via affiliate links to commercial pages on “www.amazon.com.” The website also features product categories, customer reviews, and a Frequently Asked Questions (“FAQ”) section. The website does not disclose information regarding its owner or the registrant of the disputed domain name, nor does it state that it lacks any relationship with the Complainant, Cooper Lighting Solutions, or the HALO Mark. The footer of the website includes the statement: “Halo (halorecessedlighting.com) is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to amazon.com.” The copyright notice on the site reads: “Copyright © 2026 – Halo.” 6. 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 the disputed domain name is confusingly similar to its HALO Mark. It emphasizes that the disputed domain name incorporates the mark in its entirety with the addition of the terms “recessed lighting,” which, far from dispelling confusion, heightens the similarity by directly referencing the core products commercialized under the mark. The generic Top-Level Domain (“gTLD”) “.com” is disregarded under the confusing similarity test. The Complainant further asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent holds no contractual or proprietary rights in the HALO Mark, is not affiliated with the Complainant, and has never been authorized or licensed to use the mark or register the disputed domain name. Furthermore, the Respondent is not commonly known by the disputed domain name, holds no registered trademark rights for HALO, and uses the site for commercial gain through affiliate referrals rather than for a legitimate noncommercial or fair use. Although resellers or distributors may claim a bona fide offering under certain conditions (Oki Data Americas, Inc. v. ASD Inc., WIPO Case No. D2001- 0903), the Complainant submits that the Respondent fails the cumulative requirements of that test by omitting a clear and prominent disclaimer regarding the absence of any relationship with the trademark owner. Moreover, the site creates a strong likelihood of confusion by: (i) prominently displaying the HALO Mark using the Complainant’s exact stylized font; (ii) incorporating historical and descriptive text referencing the brand’s origins since 1956 and its ownership by Cooper Lighting Solutions; and (iii) displaying a copyright notice in the name of “Halo” alongside an Amazon affiliate disclosure, falsely implying an official connection. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The disputed domain name was registered long after the first use and registration of the HALO Mark. Knowledge of the mark at the time of registration is evidenced by the pairing of HALO Mark with the descriptive terms “recessed lighting,” which directly reference the Complainant’s core product line, demonstrating targeted opportunistic registration. The Respondent intentionally attempts to attract Internet users for commercial gain by creating a likelihood of confusion as to source, sponsorship, affiliation, or endorsement under Paragraph 4(b)(iv) of the Policy. Specifically, the Respondent misleads consumers by: (i) operating a commercial affiliate website linking to Amazon products; (ii) prominently displaying the HALO Mark in the Complainant’s exact stylized font; and (iii) failing to disclose the lack of any official relationship or authorization between the Parties. page 4 B. Respondent The Respondent did not reply to the Complainant’s contentions. 7. Discussion and Findings The Complainant has made the relevant assertions required under the Policy, and the dispute properly falls within its scope. The Panel has the authority to decide the dispute by examining the three elements set forth in paragraph 4(a) of the Policy, taking into account all relevant evidence, annexed materials, and allegations, and may conduct limited independent research pursuant to the general powers of the Panel, as articulated, inter alia, in paragraph 10 of the Rules. 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, namely the HALO Mark. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the Panel finds the mark is recognizable within the disputed domain name, and the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “recessed lighting,” may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. Furthermore, the generic Top-Level Domain (“gTLD”) “.com” is a standard registration requirement typically disregarded for purposes of the confusing similarity analysis. WIPO Overview 3.1, section 1.11. Consequently, 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 name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence page 5 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Panel notes that the Respondent’s name shares no similarity with the terms incorporated in the disputed domain name. The Panel has further verified that, consistent with the Complainant’s allegations, the Respondent holds no trademark rights over the terms “halo” or “halo recessed lighting.” 1 Consequently, the Panel finds no evidence on the record to suggest that the Respondent is commonly known by the disputed domain name. The Panel further observes that the disputed domain name is used to host a promotional website that generates commercial profit through the Amazon Associates affiliate program. The Respondent’s website does not directly commercialize any goods or services; rather, it displays information regarding the Complainant’s products and trademark to redirect Internet users to various e-commerce listings within the Amazon marketplace. The Respondent’s business scheme is therefore similar to the sites displaying pay-per-click links. Panels have consistently held that operating affiliate or pay-per-click schemes does not represent a bona fide offering of goods or services where such links capitalize on the reputation and goodwill of a complainant’s mark or otherwise mislead consumers. See Sugartown Worldwide, LLC v. Registration Private, Domains By Proxy, LLC / Justin Pennington, Avoiding Costly Auto Repair, WIPO Case No. D2022-3166; see also, Shahnaz Husain v. Saxena Dinesh O, WIPO Case No. D2006-1132; The Clorox Company v. WhoisGuard Protected, WhoisGuard, Inc. / Enos Villanueva, Melissa Rosenberg, Yang Ming, WIPO Case No. D2021- 0603; and WIPO Overview 3.1, section 2.9. The Panel finds that the Respondent’s website induces consumer confusion and creates a false impression of affiliation with the Complainant, its corporate entity Cooper Lighting Solutions, and the HALO Mark. Specifically, the website: (i) prominently displays the HALO Mark in its header and content using the Complainant’s exact stylized capital font; (ii) incorporates historical and descriptive text referencing the brand’s origins since 1956 and its ownership by Cooper Lighting Solutions; (iii) displays a copyright notice under the name “Halo” alongside an Amazon affiliate statement; and (iv) omits any disclosure regarding the true identity of the site operator, the disputed domain name registrant, or the absence of any corporate relationship with the Complainant. The website is plainly configured to pass itself off as endorsed by or affiliated with the Complainant. Rather than making a legitimate use of the disputed domain name, the Respondent capitalizes on the reputation of the HALO Mark to divert web traffic for commercial gain through an affiliate referral program. As a result, the principles of nominative fair use applicable to resellers or distributors under the Oki Data test do not apply (Oki Data Americas, Inc. v. ASD Inc., supra; see also WIPO Overview 3.1, section 2.8.1). Not only does the Respondent fail the cumulative requirements by omitting a clear and conspicuous disclaimer regarding the lack of relationship or affiliation, but the site’s content and composition also actively generate a likelihood of confusion and false affiliation. Furthermore, the Respondent does not offer goods or services directly, but merely operates as a click-through portal to third-party listings on Amazon. Finally, while the Respondent’s website displays informational content, such as FAQs and product descriptions, the Panel wishes to emphasize that non-commercial fair use or commentary exceptions under Paragraph 4(c)(iii) of the Policy do not apply where such content serves merely as a pretext to generate affiliate referral fees. The presence of commercial affiliate links to Amazon defeats any claim to purely noncommercial or fair use. Accordingly, the Panel finds that the Complainant has satisfied the second element under Paragraph 4(a)(ii) 1 Under the general powers articulated in paragraphs 10 and 12 of the Rules, a panel may undertake limited factual research into public records if such information is useful to assessing the case merits and reaching a decision. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), WIPO Overview 3.1, section 4.8. page 6 of the Policy. 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 HALO Mark enjoys a strong reputation within the lighting industry. The Panel notes the continuous and extensive use of the HALO Mark for lighting products spanning seven decades (since 1956), as well as its widespread online presence. 2 Remarkably, the Respondent itself expressly recognized the reputation of the mark on its website, stating: “Leading the industry since 1956, HALO has defined the standard for North American recessed and track lighting through nearly seven decades of innovation. This Cooper Lighting Solutions powerhouse remains the most trusted name among builders and contractors, earning its reputation by blending professional-grade reliability with remarkably simple installation.” The Panel finds that the overall circumstances clearly demonstrate both the registration and use of the disputed domain name in bad faith. The composition of the disputed domain name - combining the HALO Mark with terms directly referring to the core products commercialized under the mark - coupled with the content of the Respondent’s website, conclusively establishes that the Respondent was fully aware of the Complainant’s rights and specifically targeted those rights upon registering and using the disputed domain name. The Panel finds particularly telling the Respondent’s replication of the HALO Mark using the exact capital font, the inclusion of detailed historical text regarding the brand, and the omission of any disclaimer clarifying the lack of affiliation with the trademark owner. By operating a commercial website that redirects web traffic to Amazon through an affiliate program, the Respondent has intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of its website and the products listed therein. This conduct falls squarely within Paragraph 4(b)(iv) of the Policy. Finally, the Respondent’s failure to submit a Response or offer any explanation or counter-evidence for its adoption and use of the disputed domain name supports an inference that the Respondent lacks any legitimate justification, further fortifying the finding of bad faith. Accordingly, the Panel finds that the Complainant has established the third element under Paragraph 4(a)(iii) of the Policy. 8. 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 <halorecessedlighting.com> be transferred to the Complainant. /Reyes Campello Estebaranz/ Reyes Campello Estebaranz Sole Panelist Date: August 26, 2026 2 Pursuant to Paragraphs 10 and 12 of the Rules, the Panel conducted limited independent research over the Internet.
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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