Westmore · UDRP DecisionAndersons-belts.com
The Panel ordered transfer of <andersons-belts.com> to Anderson’s S.r.l. It found the domain confusingly similar to the ANDERSON’S trademark, that the Respondent lacked rights or legitimate interests, and that the domain had been registered and used in bad faith. The domain resolved to a commercial website promoting clothing, footwear, accessories, and belts under the name “Andersons Belts.” The Respondent filed no response.
The timeline behind andersons-belts.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 andersons-belts.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a mark with the complainant’s principal product can support both confusing similarity and a finding of deliberate targeting. The associated commercial use, allegedly counterfeit goods, absence of any demonstrated legitimate basis for the name, and respondent default collectively supported transfer.
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 Anderson’s S.r.l. v. Rachel Geula Case No. D2026-3383 1. The Parties The Complainant is Anderson’s S.r.l., Italy, represented by Bugnion S.p.A., Italy. The Respondent is Rachel Geula, United States of America. 2. The Domain Name and Registrar The disputed domain name <andersons-belts.com> (the “Disputed Domain Name”) is registered with EU Technology (HK) Limited (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on July 30, 2026. On August 3, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On August 4, 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 (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 11, 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 amendment to the Complaint in English on August 12, 2026 and an amended Complaint in English on August 14, 2026. On August 11, 2026 the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the Disputed Domain Name is Chinese. On August 14, 2026, the Complainant confirmed its request for English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. The Center verified that the Complaint together with the amendment to the Complaint and 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in English and Chinese of the Complaint, and the proceedings commenced on August 17, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 7, 2026. The Center appointed Andrew Sim as the sole panelist in this matter on September 16, 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 company founded under the laws of Italy in 1966 which designs, produces and sells leather belts and small leather goods. The Complainant has owned the domain name <anderson.it> continuously since 1999. This domain name hosts the Complainant’s website, through which it presents its history and background, and markets its leather belts. In marketing and selling its leather belts and small leather goods, the ANDERSON’S word mark (the “ANDERSON’S Mark”) has been registered since 1967. The Complainant has provided a list of its active trademark registrations in jurisdictions around the world. In particular, the Complainant holds an international trademark registration (Registration Number: 685224; Registration Date: December 12, 1997) in Classes 18 and 25, as well as the following trademark registrations: Jurisdiction Mark Registration Number Registration Date Class Covered Status European Union ANDERSON’S 691808 April 26, 1999 18 and 25 Registered Hong Kong, China ANDERSON’S 303688705 February 18, 2016 18 Registered ANDERSON’S 302056545 October 13, 2011 25 Registered Italy ANDERSON’S 362017000028699 January 16, 2018 18 and 25 Registered The ANDERSON’S Mark is also enlisted in the Italian Special Register of Historical Trademarks of National Interest, and has been continuously used since at least 1967. The Disputed Domain Name, <andersons-belts.com>, was registered on May 7, 2026. Based on the Complainant’s evidence, the Disputed Domain Name is being used to operate a website that promotes and sells clothing, footwear and accessories including belts under the name “Andersons Belts”. The website lists “ANDERSONS” in its brand directory alongside other fashion brands. However, as of the date of this Decision, the website is no longer accessible. Little information is known about the Respondent. Available information provided by the Registrar covers only the registrant’s name, postal address, telephone number, and email address. 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. page 3 First, the Complainant contends that the Disputed Domain Name is identical or confusingly similar to the ANDERSON’S Mark in which the Complainant has rights. The Disputed Domain Name incorporates the entirety of the ANDERSON’S Mark and the Complainant’s company name. The Complainant submits that the addition of the generic descriptive word “belts”, separated from “andersons” by a hyphen, does not serve to distinguish the Disputed Domain Name from the ANDERSON’S Mark, particularly as the production and sale of belts constitute the Complainant’s core and best-known business. The Complainant further submits that the omission of the apostrophe from “andersons” is a technical necessity of domain name syntax and does not affect the assessment of confusing similarity. Second, the Complainant contends that the Respondent has no rights or legitimate interests in the Disputed Domain Name for the reasons below: (a) the Complainant has not licensed, authorized, or otherwise permitted the Respondent to use the ANDERSON’S Mark, nor is the Respondent affiliated with the Complainant in any form; (b) there is no evidence that the Respondent is commonly known by the Disputed Domain Name, nor is there any evidence that the Respondent owns any trademark or trade name registrations in connection with the expressions “andersons” or “andersons belts”; (c) the Respondent is not using the Disputed Domain Name in connection with a bona fide offering of goods or services, but instead fraudulently presents itself as a legitimate business while offering counterfeit products for sale; and (d) the Respondent is using the Disputed Domain Name solely to exploit the reputation and goodwill associated with the ANDERSON’S Mark, mislead consumers and derive commercial gain at the expense of the Complainant and its brand. Third, the Complainant contends that the Disputed Domain Name was registered and is being used in bad faith for the reasons below: (a) the Respondent is using the Disputed Domain Name to operate a commercial website offering goods which fall within the same product categories as those offered by the Complainant, thereby competing with and/or imitating the Complainant while creating the false impression that the Respondent is associated with or endorsed by the Complainant; (b) the website fraudulently uses the identity of a third party, being one of the Complainant’s clients, in its legal sections, making it impossible for consumers to identify the true operator of the website; (c) the Respondent failed to respond to the Complainant’s cease-and-desist letters; and (d) the Respondent is intentionally using the Disputed Domain Name to attract Internet users to its website for commercial gain by creating a likelihood of confusion with the ANDERSON’S Mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website, or of the products offered thereon. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 4 6. Discussion and Findings Language of the Proceeding The language of the Registration Agreement for the Disputed Domain Name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that there is evidence that the Respondent is familiar with the English language, the website associated with the Disputed Domain Name is entirely in English, and the Complainant’s authorized representative does not master Chinese. Accordingly, conducting the proceedings in Chinese would impose an unfair and disproportionate burden on the Complainant. The Respondent did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. Substantive Analysis Paragraph 4(a) of the Policy states that, in an administrative proceeding, the Complainant must prove each of the following three elements: (a) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (b) the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and (c) the Disputed Domain Name has been registered and is being used in bad faith. For the below reasons, support for the Complainant can be found due to the satisfaction of the three conditions for the Disputed Domain Name. 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 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 entirety of the ANDERSON’S Mark is reproduced within the Disputed Domain Name. Although the addition of the term “belts”, separated from “andersons” by a hyphen, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the Disputed Domain Name and the ANDERSON’S Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. page 5 The generic Top-Level Domain (“gTLD”) “.com” is typically disregarded in the confusing similarity test. WIPO Overview 3.1, section 1.11.1. Accordingly, the Disputed Domain Name is confusingly similar to the ANDERSON’S Mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. 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 demonstrating rights or legitimate interests in the Disputed Domain Name such as those enumerated in the Policy or otherwise. From the available record, there is no evidence to suggest that the Respondent is commonly known by the Disputed Domain Name, which could demonstrate its rights or legitimate interests (see, e.g., World Natural Bodybuilding Federation, Inc. v. Daniel Jones TheDotCafe, WIPO Case No. D2008-0642). Particularly in regard to the three illustrative examples of legitimate interest in paragraph 4(c) of the Policy, the Panel finds that: (a) the Respondent has not used the Disputed Domain Name in connection with a bona fide offering of goods and services, as the Respondent’s website is being used with the intent to fraudulently present itself as a legitimate business and offer allegedly counterfeit products for sale; (b) there is no evidence that the Respondent is itself commonly known by or is operating any business or organization with similar name as the Disputed Domain Name; and (c) the Respondent’s use of the Disputed Domain Name does not fall within the scope of legitimate noncommercial or fair use. Panels have held that the use of a domain name for illegal activity, including the sale of counterfeit goods and other types of fraud, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Accordingly, the Panel also finds that the Respondent has no rights or legitimate interests in using the ANDERSON’S Marks in the Disputed Domain Name. The Panel finds the second element of the Policy has been established. page 6 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 circumstances of registering and using the Disputed Domain Name clearly demonstrate the Respondent’s bad faith and have constituted the situation as specified in paragraph 4(b) of the Policy: (a) the ANDERSON’S Mark has been continuously used since 1967 and registered since 1968, long before the Respondent’s registration of the Disputed Domain Name which is confusingly similar to the ANDERSON’S Mark; (b) given the significant reputation and long period of use of the ANDERSON’S Mark by the Complainant, choice of additional term “belts” in the Disputed Domain Name, and use of the Complainant’s mark to offer competing or counterfeit goods, the Panel finds that the Respondent was most likely aware of the Complainant’s rights when registering the disputed domain name; (c) by using the Disputed Domain Name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website. WIPO Overview 3.1, section 3.1.4; and (d) the Respondent did not respond to the Complainant’s cease-and-desist letters, nor did it deny the assertions of bad faith made by the Complainant in these proceedings. Panels have held that the use of a domain name for illegal activity, including the sale of counterfeit goods and other types of fraud, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. Inference of bad faith is also drawn in accordance with paragraph 14(b) of the Rules for the Respondent’s failure to file a response as required in paragraph 5(a) of the Rules in the absence of exceptional circumstances. The Panel finds 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 <andersons-belts.com> be transferred to the Complainant. /Andrew Sim/ Andrew Sim Sole Panelist Date: October 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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