Westmore · UDRP decision
WIPO · Case No. D2026-3181

Rollsroycejets.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered the transfer of <rollsroycejets.com> to Rolls-Royce Plc. It found the domain confusingly similar to the ROLLS-ROYCE mark, that the Respondent had not demonstrated rights or legitimate interests, and that the domain had been registered and used in bad faith through a website impersonating the Complainant and purporting to offer business aviation services. Although the Respondent requested additional time after missing communications, no substantive submission was filed even after the Panel granted a further opportunity to respond.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-17
Panelist(s)
Andrea Mondini
Complainant
Rolls-Royce Plc
Respondent
Nickson Mwangi
Disputed domain(s)
rollsroycejets.com
Domain history UDRP Intelligence

The timeline behind rollsroycejets.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 rollsroycejets.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of rollsroycejets.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining a famous mark with a term closely related to the complainant's industry can support findings beyond confusing similarity. Here, "jets" reinforced the implied association with an aerospace business, while the corresponding website use supplied evidence of impersonation, lack of legitimate interests, and commercial-gain bad faith. It also shows that an unsupported assertion of a legally registered business will not rebut a prima facie case, particularly where the respondent fails to use an expressly granted opportunity to submit evidence.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-17
Panel
Andrea Mondini
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Rolls-Royce Plc v. Nickson Mwangi Case No. D2026-3181 1. The Parties The Complainant is Rolls-Royce Plc, United Kingdom (“UK”), represented by Cleveland Scott York LLP, UK. The Respondent is Nickson Mwangi, Kenya. 2. The Domain Name and Registrar The disputed domain name <rollsroycejets.com> is registered with OwnRegistrar, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 20, 2026. On July 21, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 22, 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 (WhoisSecure) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 22, 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 24, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 13, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 16, 2026. On August 16, 2026, the Center received an email communication from the Respondent basically stating that he had not seen the Center’s communications relating to this proceeding as they had apparently been directed to his spam folder and requesting additional time to review the matter. page 2 The Center appointed Andrea Mondini as the sole panelist in this matter on August 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. In order to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case and pursuant to paragraph 10(b) of the UDRP Rules, on September 7, 2026, the Panel issued Administrative Panel Procedural Order No. 1, allowing the Respondent to submit its comments to this proceeding by no later than September 12, 2026, and the Complainant to file comments to the Respondent’s eventual submission by September 14, 2026. The Center did not receive any submissions from the Parties within these deadlines. 4. Factual Background The Complainant was founded in 1906, and is active in the fields of aerospace, defence, marine and energy. The Complainant owns numerous trademark registrations in several jurisdictions, including: TRADEMARK JURISDICTION REGISTRATION NUMBER REGISTRATION DATE ROLLS-ROYCE UK UK00000302443 April 22, 1908 ROLLS-ROYCE International Registration 1215839 January 17, 2014 The Complainant holds the domain name <rolls-royce.com> which hosts its main website. The disputed domain name was registered on November 15, 2025. According to the evidence submitted with the Complaint, the disputed domain name resolves to a website prominently displaying the Complainant’s trademark and purporting to offer business aviation services. 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 as follows: The trademark ROLLS-ROYCE has been extensively used to identify the Complainant and its products, and is one of the most famous brands worldwide. The disputed domain name is confusingly similar to the trademark in which the Complainant has rights, because it incorporates this trademark in its entirety, and the addition of the generic term “jets” as well as the omission of the hyphen are not sufficient to prevent a finding of confusing similarity. The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent has not been authorized by the Complainant to use this trademark, is not commonly known by the disputed domain name, and is not using the disputed domain name in connection with a bona fide offering of goods and services. The disputed domain name was registered in bad faith because it is obvious that the Respondent had page 3 knowledge of both the Complainant and its famous trademark ROLLS-ROYCE at the time it registered the disputed domain name. The Respondent is using the disputed domain name in bad faith, by impersonating the Complainant and purporting to offer aviation related services. B. Respondent The Respondent did not reply to the Complainant’s contentions. In its email communication to the Center of August 16, 2026, the Respondent stated “I had not seen this email until now as it was in spam folder. Kindly allow us some time to check this issue with my client as we have been operating this business for quite some time and we are registered business operating legally. Please reply only to this email to what needs to be done.“ However, the Respondent failed to submit any arguments within the additional deadline granted by the Panel. 6. Discussion and Findings According to paragraph 4(a) of the Policy, in order to succeed, a complainant must establish each of the following elements: (i) the disputed domain name is identical or confusingly similar to the 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 disputed domain name has been registered and is being used in bad faith. 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 Panel finds the entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Complainant’s trademark. Although the addition of other terms such as here “jets” may bear on assessment of the second and third elements, the Panel finds that in the present case the addition of such term 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. The omission of the hyphen between the trademark elements “ROLLS” and “ROYCE” in the disputed domain name is considered a variation of the Complainant’s mark and does not prevent a finding of confusing similarity under the Policy. WIPO Overview 3.1, section 1.9. The addition of the generic Top-Level Domain (“gTLD”) “.com” in the disputed domain name is a standard registration requirement and as such may be disregarded under the confusing similarity test under the Policy, paragraph 4(a)(i). WIPO Overview 3.1, section 1.11.1. page 4 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 for a complainant to prove 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, although the Respondent stated he had operating a business related to the disputed domain name, the Respondent failed to 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 Complainant has shown that the website posted under the disputed domain name intends to pass off as the Complainant as it purports to offer business aviation services under the Complainant’s famous ROLLS- ROYCE trademark. Panels have held that the use of a domain name for illegal activity, such as here impersonating and/or passing off as the Complainant, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Furthermore, the composition of the disputed domain name itself suggests a connection or implied affiliation between the Complainant and the disputed domain name which in fact does not exist. WIPO Overview 3.1, section 2.5.1. Based on the available record, 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. WIPO Overview 3.1, section 3.2.1. In the view of the Panel, noting that the Complainant’s trademark registration predates the registration of the disputed domain name and considering that the Complainant’s trademark is famous, it is inconceivable that the Respondent could have registered the disputed domain name without knowledge of the Complainant’s famous trademark. In the circumstances of this case, this is evidence of registration in bad faith. The impression given by the website posted under the disputed domain name would cause Internet users to believe that the Respondent is somehow associated with the Complainant when, in fact, it is not. The Panel holds that by using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its web site, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of its web site in the sense of Policy, paragraph 4(b)(iv). page 5 Moreover, Panels have held that the use of a domain name for illegal activity, such as in the present case impersonating the Complainant, constitutes bad faith. WIPO Overview 3.1, section 3.4. Based on the available record, the Panel finds that the Complainant has established the third element of the Policy with regard to the disputed domain name. 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 <rollsroycejets.com> be transferred to the Complainant. /Andrea Mondini/ Andrea Mondini Sole Panelist Date: September 17, 2026

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

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