Westmore · UDRP DecisionAmcricangirl.it.com + 15 more domains
The Panel consolidated the proceeding against nine nominal registrants after finding that the 16 disputed domain names and associated websites were under common control. It found every domain identical or confusingly similar to the AMERICAN GIRL mark, found no rights or legitimate interests, and found registration and use in bad faith. Fifteen domains had previously resolved to substantially similar copycat websites displaying the mark and purported AMERICAN GIRL products; the remaining domain was inactive. The Panel ordered all 16 domains transferred to Complainant.
The timeline behind amcricangirl.it.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 amcricangirl.it.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a panel may consolidate numerous nominal registrants where technical, naming, timing, targeting, and website-use evidence collectively establishes common control. It also shows that a coordinated portfolio of exact-match and typo domains used for copycat sites can support all three UDRP elements, and that subsequent inactivity does not erase evidence of prior impersonation or prevent a passive-holding finding based on the totality of circumstances.
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 American Girl , LLC v. Katie Lords, Edgar Valladares, Kristin Segerman, Heather Smith, Jonathan Ossman, Levi Blackwell, Laila Downer, jool yunna, Jennifer Blanchard Case No. D2026-3416 1. The Parties Complainant is American Girl , LLC, United States of America (“United States”), represented by Convey Srl, Italy. Respondents are Katie Lords, United States, Edgar Valladares, United States, Kristin Segerman, United States, Heather Smith, United States, Jonathan Ossman, United States, Levi Blackwell, United States, Laila Downer, United States, jool yunna, United States, and Jennifer Blanchard, United States. 2. The Domain Names and Registrar The disputed domain names <amcricangirl.it.com>, <ameircangirl.it.com>, <amercangirl.it.com>, <amercangirls.it.com>, <americangirl.it.com>, <americangirls.it.com>, <americangirlss.it.com>, <americansgirl.it.com>, <americansgirls.it.com>, <americargirl.it.com>, <americarngirl.it.com>, <americarsgirl.it.com>, <americengirl.it.com>, <americnagirl.it.com>, <americnagirls.it.com>, and <americnagirluys.it.com> are registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 30, 2026. On August 7, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On August 11, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Private Person) and contact information in the Complaint. The Center sent an email communication to Complainant on August 11, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. Complainant filed an amended Complaint on August 13, 2026. page 2 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 Respondent 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. One of the Respondents sent email communications to the Center on August 11, 2026, August 17, 2026, and September 8, 2026. The Center appointed Scott R. Austin as the sole panelist in this matter on September 14, 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 following facts appear from the Complaint (as amended) and its attached Annexes, which have not been contested by Respondent, and provides evidence sufficient to support: Complainant is a United States company known for the development, marketing, and sale of dolls, accessories, books, and related consumer products under the trademark AMERICAN GIRL (the “AMERICAN GIRL Mark”). The AMERICAN GIRL brand was created in 1986 by Pleasant Company and was acquired by Mattel, Inc. in 1998. Complainant markets its products through retail stores and online, including through its official website at “www.americangirl.com” (the “Official AMERICAN GIRL Website”). Complainant owns numerous trademark registrations for the AMERICAN GIRL Mark in the United States and other jurisdictions including: - United States Trademark Registration No. 2200654 for AMERICAN GIRL, registered on October 27, 1998, in International Class 28; - United States Trademark Registration No. 3116340 for AMERICAN GIRL (combined mark), registered on July 18, 2006, in International Class 28; and - European Union Trademark Registration No. 005925961 for AMERICAN GIRL, registered on February 27, 2008, in International Classes 16, 25, and 28. Complainant also owns and uses the domain names incorporating the AMERICAN GIRL Mark, including <americangirl.com>, created on March 25, 1997, and used for its principal online platform, the Official AMERICAN GIRL Website, as well as <americangirl.org>, registered on October 6, 1999. The sixteen disputed domain names were registered between December 16, 2025, and May 6, 2026. Each disputed domain name consists either of the AMERICAN GIRL Mark in its entirety or of an obvious typographical variation of that mark. The record shows that, before the filing of the Complaint, 15 of the disputed domain names resolved to websites that prominently displayed the AMERICAN GIRL Mark, offered purported AMERICAN GIRL products, and closely imitated the layout, branding, visual presentation, and overall look and feel of Complainant’s Official AMERICAN GIRL Website. As regards the disputed domain name <americansgirl.it.com>, the record shows that it did not resolve to any active website. At the time of filing, the disputed domain names no longer resolved to active websites and appeared to be inactive. page 3 At the time of filing the original Complaint, the publicly available WhoIs records identified the registrant of the disputed domain names as “Private Person” and concealed the remaining registrant information. Registrar verification later disclosed nine nominal registrants associated with the 16 disputed domain names. Complainant filed its Amended Complaint naming those disclosed registrants and requesting consolidation. 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 names. Complainant holds numerous trademark registrations for the AMERICAN GIRL Marks across many jurisdictions around the world. Complainant shows in its annexes that it owns registered trademark rights, including those set out in Section 4 above. Complainant further relies on the goodwill and recognition that has been attained under the AMERICAN GIRL Marks, which have become a well-known distinctive identifier for its products and services for over 27 years. Complainant shows that its AMERICAN GIRL Marks are well-recognized by the public around the world. Complainant asserts that the disputed domain names are confusingly similar to the AMERICAN GIRL Mark because each of the disputed domain names clearly incorporate either Complainant’s AMERICAN GIRL Mark in its entirety or minor misspellings thereof, resulting from omitted, transposed, substituted, duplicated, or additional letters, which constitute classic examples of typosquatting and do not dispel confusing similarity between the disputed domain names and Complainant’s Mark, nor do the applicable “.it.com” extensions which as a technical requirement of registration are disregarded under the first element of the Policy. Complainant submits that there are no rights or legitimate interests held by Respondent in respect of the disputed domain names. No Respondent is commonly known by any of the disputed domain names, nor does any Respondent have any authorization or license from Complainant to use the AMERICAN GIRL Mark or to register any of the disputed domain names. Complainant contends that the fact that each disputed domain name contains either the AMERICAN GIRL Mark in its entirety or an intentional misspelling thereof shows that the aim of Respondent in each case is to confuse Internet users searching for Complainant’s products or services into thinking that they had arrived at Complainant’s website or take advantage of typically common spelling errors by users and to create a false link between Complainant’s AMERICAN GIRL Marks and each of the disputed domain names. Respondent is not making a legitimate noncommercial or fair use of any of the disputed domain names. Rather Respondent is using all sixteen disputed domain names to create a false association with Complainant’s brand to redirect consumers to copycat websites selling products under Complainant’s name. Such use does not amount to a bona fide offering of goods and services and can never confer rights or legitimate interests on a respondent, nor can such unauthorized impersonation to sell goods constitute a legitimate noncommercial or fair use of any of the disputed domain names. None of the original resolving sites contained disclaimers accounting for their connection (or lack thereof) to Complainant. The fact that each disputed domain name is currently inactive does not change the result. Respondent’s current non-use of the passively held disputed domain names does not confer it with a legitimate interest. Complainant contends that the disputed domain names were registered and are being used in bad faith. First, Complainant asserts that the AMERICAN GIRL Marks are recognized worldwide and therefore Respondent must have been aware that it would be registered as a trademark in various jurisdictions worldwide. Complainant’s earliest AMERICAN GIRL Mark registration also predates the registration of all of the disputed domain names by 27 years. Complainant submits, therefore, that Respondent knowingly registered each of the disputed domain names in bad faith with the intention of targeting Complainant’s AMERICAN GIRL Marks to trade off the goodwill and reputation attaching to Complainant’s AMERICAN GIRL Marks. Complainant contends that Respondent’s use of the disputed domain names is to capitalize on the reputation of Complainant’s trademark by diverting Internet users seeking Complainant’s services to its page 4 websites for financial gain, by intentionally creating a likelihood of confusion with Complainant’s registered trademarks as to the source, sponsorship, affiliation, or endorsement of its websites and/or the goods and services offered or promoted originally through the respective copycat websites. Complainant contends, therefore, that Respondent’s conduct amounts to registration and use of each of the disputed domain names in bad faith. Complainant requests that the proceedings for each of the disputed domain names be consolidated on the basis that they are all under common control based on factors relied upon by prior UDRP panels in ruling upon such requests. Complainant’s support for these factors is provided in substantial and detailed evidence submitted in the amendment to its Complaint which is considered by the Panel in Section 6.1 below. Accordingly, Complainant requests transfer of all 16 of the disputed domain names. B. Respondent Respondents provided no formal response to Complainant’s contentions. One of the Respondents sent informal email communications to the Center on August 11, 2026, August 17, 2026, and September 8, 2026, each time making the same statement “Hiya you, I’m so glad I saw your message before I logged off. I rarely use this inbox anymore... but I don’t want to lose this match. Just shoot me a message here,” providing a link to a location purportedly to leave a message, but no formal response to the Complaint. 6. Discussion and Findings 6.1 Procedural Issue: Consolidation of Multiple Respondents The Amended Complaint was filed against nine nominally different registrants responsible for registration of a total of 16 disputed domain names and Complainant requests consolidation of the disputes concerning the registrants for all 16 disputed domain names. Where a complaint is filed against multiple respondents, panels consider whether (i) the disputed domain names or corresponding websites are subject to common control, and (ii) consolidation would be fair and equitable to all parties; procedural efficiency also informs that determination. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.11.2. See also Speedo Holdings B.V. v. Programmer, Miss Kathy Beckerson, John Smitt, Matthew Simmons, WIPO Case No. D2010-0281. The Panel finds the record sufficient to establish common control. The disputed domain names were registered through the same Registrar during a relatively short period; use the same nameservers; follow the same naming pattern by reproducing or misspelling the AMERICAN GIRL Mark; target the same Complainant and mark; and 15 of the disputed domain names were used initially for substantially similar websites reproducing Complainant’s branding, products, layout, and visual presentation. Several of the Registrar-disclosed registrant names are themselves associated with multiple disputed domain names. These circumstances, considered together, support a finding that the disputed domain names and corresponding websites are subject to common control. The Panel also finds consolidation fair and equitable. The factual and legal issues are materially the same for all disputed domain names, the Center provided notice to all disclosed registrants, and no Respondent has submitted a substantive Response contesting consolidation or otherwise identifying prejudice from a consolidated proceeding. Consolidation also promotes procedural efficiency. Accordingly, the Panel grants Complainant’s request and will refer to the nominally different registrants collectively as “Respondent”. page 5 6.2 Substantive Issues In view of Respondent’s failure to submit any Response, the Panel shall decide these administrative proceedings on the basis of Complainant’s undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations and inferences set forth in the Complaint as true unless the evidence is clearly contradictory. See Talk City, Inc. v. Michael Robertson, WIPO Case No. D2000-0009; see also Microsoft Corporation v. Freak Films Oy, WIPO Case No. D2003-0109. Where no Response is filed, however, Complainant must still make out its case in all respects under paragraph 4(a) of the Policy. To succeed, Complainant must demonstrate that all the elements listed in paragraph 4(a) of the Policy have been satisfied. The standard of proof under the Policy is often expressed as the “balance of probabilities” or “preponderance of the evidence” standard. Under this standard, an asserting party needs to establish that it is more likely than not that the claimed fact is true. See WIPO Overview 3.1, section 4.2. Thus, for Complainant to succeed it must prove within the meaning of paragraph 4(a) of the Policy and on balance of the probabilities that: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) the disputed domain names have been registered and are being used in bad faith. The Panel finds that Complainant has met its burden in all three elements of the Policy and will deal with each of these elements in more detail below. A. Identical or Confusingly Similar Ownership of a nationally or regionally registered trademark prima facie satisfies the threshold requirement of trademark rights for purposes of standing under paragraph 4(a)(i) of the Policy. WIPO Overview 3.1, section 1.2.1. Complainant has demonstrated registered rights in the AMERICAN GIRL Mark, including United States and European Union registrations. The first element functions principally as a standing requirement and involves a straightforward comparison between the trademark and the disputed domain name. WIPO Overview 3.1, section 1.7. The AMERICAN GIRL Mark is recognizable within the disputed domain names. Each disputed domain name either reproduces the AMERICAN GIRL Mark or contains a readily recognizable typographical variation of it. A domain name consisting of a common, obvious, or intentional misspelling of a trademark is normally considered confusingly similar where the mark remains recognizable. WIPO Overview 3.1, section 1.9. See also Edmunds.com, Inc. v. Digi Real Estate Foundation, WIPO Case No. D2006-1043, and Wachovia Corporation v. Peter Carrington, WIPO Case No. D2002-0775. The applicable Second-Level Domain and Top-Level Domain “.it.com” is generally disregarded in the confusing similarity test. WIPO Overview 3.1, section 1.11. The Panel therefore finds that the disputed domain names are identical or confusingly similar to a trademark in which Complainant has rights and that Complainant has established the first element of the Policy. page 6 B. Rights or Legitimate Interests Paragraph 4(c) of the Policy sets out circumstances in which a respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof remains on Complainant, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production shifts to the respondent. WIPO Overview 3.1, section 2.1. Complainant states that it has not licensed, authorized, or otherwise permitted Respondent to use the AMERICAN GIRL Mark or to register domain names incorporating that mark or confusingly similar variations. Nothing in the record indicates that Respondent is commonly known by any of the disputed domain names. Nor does the record show use or demonstrable preparations to use the disputed domain names in connection with a bona fide offering of goods or services, or any legitimate noncommercial or fair use. To the contrary, the record shows that 15 of the disputed domain names were used for websites reproducing the AMERICAN GIRL Mark, displaying purported AMERICAN GIRL products, and closely imitating Complainant’s official website so as to create the false impression of an official, authorized, or affiliated site. Panels have categorically held that use of a domain name for illegitimate activity such as copycat sites, passing off, or fraud cannot confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. See also Prada S.A. v. Domains For Life, WIPO Case No. D2004-1019, and Twitter, Inc. v. Moniker Privacy Services/ accueil des solutions inc, WIPO Case No. D2013-0062. Complainant has therefore established a prima facie case. Respondent has not submitted a substantive Response or otherwise produced evidence rebutting that case. The Panel finds that Complainant has established the second element of the Policy. C. Registered and Used in Bad Faith For purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) sets out non-exclusive circumstances that, if found by the Panel, constitute evidence of registration and use of a domain name in bad faith. The Panel finds that Respondent registered the disputed domain names with knowledge of and intent to target Complainant and the AMERICAN GIRL Mark. Complainant’s trademark rights long predate the registrations of the disputed domain names. The nature of the disputed domain names — one reproducing the mark exactly and the others consisting of obvious typographical variants — together with the content of the associated websites reproducing Complainant’s mark, products, and visual presentation, leaves no plausible basis on this record to conclude that the registrations were coincidental. These circumstances are among the factors panels consider in assessing bad-faith registration. WIPO Overview 3.1, section 3.2.1. The record also establishes bad-faith use. Fifteen of the disputed domain names were used for websites designed to impersonate Complainant and create confusion over source, sponsorship, affiliation, or endorsement. Such use supports a finding that Respondent intentionally attempted to attract Internet users by creating a likelihood of confusion with Complainant’s mark for Respondent’s apparent commercial gain, within the meaning of paragraph 4(b)(iv) of the Policy. The use of domain names for copycat or passing off activity is also recognized as evidence of bad faith. WIPO Overview 3.1, section 3.4. See Publix Asset Management Company v. WhoisGuard, Inc. / Entrep, David Levey / Mr. Dunaway, WIPO Case No. D2013- 1349, and Accor v. SANGHO HEO / Contact Privacy Inc., WIPO Case No. D2014-1471. The fact that the disputed domain name <americansgirl.it.com> has not been used for any active website, and that the 15 disputed domain names later became inactive does not alter this conclusion. Panels have found that non-use of a domain name does not by itself prevent a finding of bad faith; the totality of circumstances remains controlling. WIPO Overview 3.1, section 3.3. Here, the prior active copycat use of 15 of the disputed domain names, the distinctive and long-established AMERICAN GIRL Mark, the pattern of registrations, Respondent’s failure to provide a substantive explanation, and the implausibility of a good-faith use of these particular disputed domain names lead to the Panel’s finding that the non-use of the disputed domain names does not prevent a finding of bad faith under the circumstances of this case. Accordingly, the Panel finds that Complainant has established that the disputed domain names were registered and are being used in bad faith and has satisfied the third element of the Policy. page 7 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 names <amcricangirl.it.com>, <ameircangirl.it.com>, <amercangirl.it.com>, <amercangirls.it.com>, <americangirl.it.com>, <americangirls.it.com>, <americangirlss.it.com>, <americansgirl.it.com>, <americansgirls.it.com>, <americargirl.it.com>, <americarngirl.it.com>, <americarsgirl.it.com>, <americengirl.it.com>, <americnagirl.it.com>, <americnagirls.it.com>, and <americnagirluys.it.com> be transferred to Complainant. /Scott R. Austin/ Scott R. Austin Sole Panelist Date: September 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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