Westmore · UDRP DecisionRealtreeoutdoor.com
The Panel ordered transfer of <realtreeoutdoor.com> to Jordan Outdoor Enterprises Ltd. The domain incorporated the REALTREE mark in its entirety with the term “outdoor.” Based on evidence that the domain had been used for a website displaying the Complainant’s marks, offering goods under those marks, and impersonating the Complainant’s business, the Panel found all three UDRP elements established. The Respondent did not file a response.
The timeline behind realtreeoutdoor.com
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 realtreeoutdoor.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that historical screenshots of an impersonating retail website can establish lack of legitimate interests and bad faith even when the domain no longer resolves at the time of the decision. It also distinguishes supported impersonation evidence from more serious fraud and phishing allegations that lacked evidentiary support.
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 Jordan Outdoor Enterprises Ltd. v. WardBecky Case No. D2026-3233 1. The Parties Complainant is Jordan Outdoor Enterprises Ltd., United States of America (“United States”), represented by Nelson Mullins Riley & Scarborough, LLP, United States. Respondent is WardBecky, United States. 2. The Domain Name and Registrar The disputed domain name <realtreeoutdoor.com> is registered with West263 International Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 22, 2026. On July 23, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 24, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent (Registration Private) and contact information in the Complaint. The Center sent an email communication to Complainant on July 27, 2026, providing the registrant and contact information disclosed by the Registrar and inviting Complainant to submit an amendment to the Complaint. Complainant filed the first amended Complaint on August 3, 2026, and the second and the third amended Complaints on August 6, 2026. The Center verified that the Complaint together with the amended Complaints 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 Respondent of the Complaint, and the proceedings commenced on August 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 27, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on August 28, 2026. page 2 The Center appointed Jeffrey D. Steinhardt as sole panelist in this matter on September 8, 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 Complainant designs, licenses, and markets photorealistic camouflage patterns for hunting clothing, outdoor gear, and apparel. Complainant owns various registrations for its REALTREE marks, including, for example United States Trademark Registration No. 1736108, registered on December 1, 1992 in classes 8, 13, 18, 25 and 28; and United States Trademark Registration No. 74464267, registered on April 18, 1995 in classes 9, 13 and 25. The disputed domain name was registered on July 8, 2026 and does not presently resolve to an active webpage. Annexes to the Complaint show that the disputed domain name has been used for a website prominently featuring Complainant’s registered trademarks and logos, purporting to offer Complainant’s products for sale. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, Complainant contends that Respondent (1) displays Complainant’s trademarks without permission, (2) is using the disputed domain to sell counterfeit or unlicensed products, or (3) that Respondent uses the disputed domain name for a scheme to defraud Internet users by taking payments and personal information from customers without providing the purchased goods. Complainant provides screen captures of Respondent’s web pages (discussed below) but does not provide evidence to support its fraud and phishing allegations. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Language of Proceedings The Complaint was submitted in English. Complainant presents extensive arguments supporting its contention that these proceedings should be in the English language. Since the Registrar has confirmed that the Registration Agreement is in English, the Panel rules that English-language proceedings are appropriate, without addressing Complainant’s language contentions. Rules, paragraph 11(a). 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 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. page 3 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 mark is reproduced within the disputed domain name. Accordingly, 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, “outdoor”) may bear on the assessment of the second and third elements, t he Panel finds the addition of that 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 Panel finds that the first element of paragraph 4(a) of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which 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. Credible evidence submitted by Complainant shows use of the disputed domain name for a website that displays Complainant’s trademarks, offers goods under Complainant’s registered marks, and impersonates Complainant’s business. The Panel accepts Complainant’s unopposed allegations that Respondent is not a licensee and is not authorized to make use of Complainant’s trademarks. Moreover, the composition of the disputed domain name, comprising Complainant’s mark together with the term “outdoor”, carries a risk of implied affiliation. Having reviewed the available record, the Panel finds that Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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. Panels have held that the use of a domain name for illegitimate activity (here, impersonation/passing off as Complainant) 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 paragraph 4(a) 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 notes that Respondent used Complainant’s trademark in the disputed domain name for a website that impersonates Complainant’s REALTREE business. The Panel finds that page 4 Respondent has “intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the complainant’s mark” in the sense of paragraph 4(b) of the Policy. Panels have held that the use of a domain name for illegitimate activity (here, impersonation/passing off as Complainant) constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds that Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. 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. In the Panel’s view, Respondent’s failure to respond to the Complaint in this proceeding is further evidence of bad faith. The Panel finds that the third element of paragraph 4(a) 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 <realtreeoutdoor.com> be transferred to Complainant. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: September 18, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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