Westmore · UDRP decision
WIPO · Case No. D2026-3436

Garelickmarine.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered the transfer of garelickmarine.com to Navico Group Americas LLC. It found the domain confusingly similar to the GARELICK mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The domain resolved to a website copying the look and feel of the Complainant’s official website and purportedly offering its products at discounted prices without indicating any lack of affiliation.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-28
Panelist(s)
Tobias Zuberbühler
Complainant
Navico Group Americas LLC
Respondent
David Sokolov
Counsel
Nelson Mullins Riley · Scarborough, L.L.P
Disputed domain(s)
garelickmarine.com
Domain history UDRP Intelligence

The timeline behind garelickmarine.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 garelickmarine.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of garelickmarine.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining an entire trademark with a term closely associated with the trademark owner’s business can support confusing similarity and, when paired with an imitation storefront lacking an affiliation disclaimer, findings of no legitimate interest and bad faith. It also records the Panel’s procedural treatment of conflict-related notification concerns where electronic notice was delivered.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registration and use 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
2026-09-28
Panel
Tobias Zuberbühler
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Navico Group Americas LLC v. David Sokolov Case No. D2026-3436 1. The Parties The Complainant is Navico Group Americas LLC, United States of America (“United States”), represented by Nelson Mullins Riley & Scarborough, L.L.P., United States. The Respondent is David Sokolov, Ukraine. 2. The Domain Name and Registrar The disputed domain name <garelickmarine.com> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 3, 2026. On August 4, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 5, 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 5, 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 on August 5, 2026. The Center verified that the Complaint together with the amendment to the 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 19, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 8, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 10, 2026. page 2 The Center appointed Tobias Zuberbühler as the sole panelist in this matter on September 22, 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 United States company founded in 1952 selling marine hardware. The Complainant owns numerous GARELICK trademarks, including United States Trademark No. 6448419 registered on August 10, 2021. The disputed domain name was registered on March 21, 2025, and resolves to a website purporting to mirror the Complainant’s official website and offering the Complainant’s products using the GARELICK trademark at discounted prices. 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. B. Respondent The Respondent has not submitted any response to the Complainant’s contentions. 6. Discussion and Findings 6.1 Procedural Issue – Location of the Respondent Under paragraph 10 of the Rules, the Panel is required to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case, and also that the administrative proceedings take place with due expedition. The location of the Respondent disclosed by the Registrar appears to be in Ukraine, which is subject to an international conflict at the date of this Decision that may impact case notification. It is therefore appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceedings should continue. Having considered all the circumstances of the case, the Panel is of the view that the proceedings should continue. The Panel notes that the Center notified the Respondent of the Complaint using all available means including by electronic means to all available email addresses and Registrar contact forms, as well as by postal means. While the record suggests that the postal record was undelivered because the recipient was absent, the above-mentioned electronic notifications were delivered. The Panel concludes that the Parties have been given a fair opportunity to present their case, and so that the administrative proceeding takes place with due expedition, the Panel will proceed to a Decision accordingly. page 3 6.2 Substantive Issues 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 trademark GARELICK 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 “marine”) may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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 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 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 that 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. The Panel finds that the composition of the disputed domain name incorporating the Complainant’s trademark together with the term “marine”, coupled with the use of the disputed domain name to resolve to a website purporting to offer the Complainant’s goods at discounted prices without any indication that it is not affiliated with the Complainant, and generally copying the look and feel of the Complainant’s official site, using the Complainant’s mark, does not amount to a bona fide offering of goods or services as it effectively impersonates or suggests sponsorship or endorsement by the Complainant. The Panel finds that the second element of the Policy has been established. page 4 C. Registered and Used in Bad Faith Under the circumstances of this case, it can be inferred that the Respondent was aware of the Complainant’s mark when registering the disputed domain name, considering the disputed domain name is composed of the Complainant’s GARELICK mark in its entirety together with the additional term “marine”. The Panel notes that, for the purposes of paragraph 4(a)(iii) of 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. Having reviewed the available record and noting the composition of the disputed domain name and the use made thereof, under the circumstances of this case, the Panel finds that the use of the disputed domain name creates a likelihood of confusion with the Complainant’s trademark under paragraph 4(b)(iv) of the Policy. In particular, the Respondent’s use of the disputed domain name to purportedly offer for sale and promote the Complainant’s goods at discounted prices, while using the Complainant’s trademarks without any indication that it is not affiliated with the Complainant, demonstrates an intention to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s trademarks. Therefore, the disputed domain name was registered and is being used in bad faith. 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 <garelickmarine.com> be transferred to the Complainant. /Tobias Zuberbühler/ Tobias Zuberbühler Sole Panelist Date: September 28, 2026

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

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