Westmore · UDRP DecisionGreatstartool.com
The Panel ordered the transfer of <greatstartool.com> to the Complainant. It found the domain confusingly similar to the Complainant’s GREATSTAR mark because the mark remained recognizable despite the addition of “tool.” The Respondent lacked rights or legitimate interests, and the domain’s composition, similarity to the Complainant’s prior domain <greatstartools.com>, passive holding, and the Respondent’s failure to respond supported a finding of registration and use in bad faith.
The timeline behind greatstartool.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 greatstartool.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a domain combining an entire distinctive mark with a term describing the trademark owner’s core business can support findings across all three UDRP elements, even where the domain is passively held. The one-letter variation from the Complainant’s established official domain strengthened the evidence of targeting.
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 Hangzhou Great Star Industrial Co., Ltd. (杭州巨星科技股份有限公司) v. zhong yucong Case No. D2026-3246 1. The Parties The Complainant is Hangzhou Great Star Industrial Co., Ltd. (杭州巨星科技股份有限公司), China, represented by Beijing Chofn Intellectual Property Co., Ltd., China. The Respondent is zhong yucong, China. 2. The Domain Name and Registrar The disputed domain name <greatstartool.com> is registered with Dominet (HK) Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 23, 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 which differed from the named Respondent (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 27, 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 August 4, 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 August 6, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 26, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 27, 2026. page 2 The Center appointed Tao Sun as the sole panelist in this matter on September 3, 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 an industrial group engaged in the research, development, manufacture, and sale of hand tools, power tools, laser measuring instruments, industrial storage systems, and related hardware products. It has been listed on the Shenzhen Stock Exchange in 2010, and listed Global Depository Receipts (“GDRs”) on the SIX Swiss Exchange in 2022. Its annual revenue exceeded CNY 12.6 billion in 2022, CNY10.9 billion in 2023 and CNY 14.8 billion in 2024. There are multiple publicly available industry and investment materials recognizing the Complainant as one of the world’s top hand tool enterprises before the registration of the disputed domain name. There are also certain third parties ranking the Complainant as one of the top enterprises in China, such as one of the Top 200 Enterprises in China Light Industry (ranked 87th) and one of the Top 100 Science & Technology Enterprises in China Light Industry (ranked 51st). The Complainant owns, among others, the following registered trademarks: (i) The Chinese registration No. 5381799 GREATSTAR in international class 7, registered on May 14, 2009; (ii) The Chinese registration No. 5381801 GREATSTAR in international class 11, registered on May 7, 2009; and (iii) The International registration No. 1026628 GREATSTAR in international classes 7 and 11, registered on November 6, 2009. The Complainant also owns and operates an official website <greatstartools.com> before the registration date of the disputed domain name. The disputed domain name was registered on June 10, 2025. According to the evidence submitted by the Complainant, the disputed domain name was not in use. 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: (i) the disputed domain name is confusingly similar to the trademark in which the Complainant has rights. The disputed domain name wholly incorporates the Complainant’s GREATSTAR mark, adding only the generic, dictionary term “tool” and the “.com” generic Top-Level Domain. The addition of the term “tool” increases the likelihood of confusion in this case, because “tool” directly describes the very goods for which the Complainant’s GREATSTAR mark is registered and used. The disputed domain name is a one-letter variation of that official domain name of the Complainant. (ii) the Complainant has never licensed, authorized, or otherwise permitted the Respondent to use the GREATSTAR mark, in any form, including as part of a domain name. The Respondent is in no way page 3 affiliated with, sponsored by, or connected to the Complainant. The disputed domain name does not resolve to any active website and there is no evidence of any use, or demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services under Policy. There is no evidence that the Respondent (whether an individual, business, or other organization) has been commonly known by “GreatStar,” “Greatstartool,” or any similar name. (iii) the disputed domain name is not merely confusingly similar to the Complainant’s mark in the abstract; it is a one-letter typosquat of the Complainant’s own official, long-operated domain name <greatstartools.com>. The deliberate pairing of the Complainant’s trademark GREATSTAR with generic word “tool” is itself strong evidence that the disputed domain name was registered specifically to trade on, or create confusion with, the Complainant’s mark and business. Although the disputed domain name does not resolve to any active website, the doctrine of passive holding confirms that non-use of a domain name does not preclude a finding of bad faith. Given the fame of the GREATSTAR mark specifically within the tool industry, and the descriptive term selected by the Respondent, there is no plausible good-faith basis on which the Respondent could use, or could have intended to use, the disputed domain name that would not infringe the Complainant’s rights or trade on its goodwill. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 disputed domain name contains the Complainant’s GREATSTAR mark with the addition of “tool”. The Complainant’s mark can be easily recognized within the disputed domain name. Therefore, the disputed domain name should be considered confusingly similar to the Complainant’s trademark for purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other term may bear on assessment of the second and third elements, the Panel finds the addition of “tool” does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 page 4 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 Complainant has asserted that it has never licensed, authorized, or otherwise permitted the Respondent to use the GREATSTAR mark, in any form, including as part of a domain name. It also denied that the Respondent is affiliated with, sponsored by, or connected to the Complainant. The disputed domain name is not in use, which would not confer any rights or legitimate interests on the Respondent under the circumstances of this case. Moreover, the disputed domain name is comprised of the Complainant’s trademark GREATSTAR and the descriptive term “tool” which is also the main business of the Complainant. As such, the disputed domain name itself carries a risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. 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. 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. In the present case, the Complainant’s GREATSTAR mark is inherently distinctive and has been widely promoted and used by the Complainant. The disputed domain name contains the entirety of the Complainant’s mark with the addition of “tool” which is nothing but the description of the major business area of the Complainant. Furthermore, it has only one letter difference from the domain name <greatstartools.com> which has been priorly used by the Complainant. Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a well-known trademark, and particularly in the case of coined or fanciful marks, can by itself create a presumption of bad faith. Therefore, considering that the Respondent has no relationship with the Complainant, the Panel maintains that the Respondent was aiming at the Complainant and its trademark when registering the disputed domain name and therefore had bad faith. WIPO Overview 3.1, section 3.1.4. Panels have also found that the non-use of a domain name would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes that the Complainant’s trademark is inherently distinctive and has acquired high reputation, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent the finding of bad faith under the Policy. The fact that the Respondent fails to respond to this Complaint also supports the finding of bad faith. page 5 The Panel finds that the disputed domain name was registered and is being used in bad faith, and that the Complainant has established the third element of the Policy. 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 <greatstartool.com> be transferred to the Complainant. /Tao Sun/ Tao Sun Sole Panelist Date: September 17, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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