Westmore · UDRP DecisionJlrworkwear.com
The Panel ordered transfer of <jlrworkwear.com> to Jaguar Land Rover Limited. It found the domain confusingly similar to the Complainant’s JLR trademark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to attract users for commercial gain by implying a relationship with the Complainant. The Respondent did not file a response.
The timeline behind jlrworkwear.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 jlrworkwear.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a supplier-affiliation fact pattern in which a domain combines a trademark with the goods formerly supplied to the trademark owner. The outcome turned not merely on the domain string, but on the prior vendor relationship, the Respondent’s connection to the vendor, and website statements implying access to or affiliation with the trademark owner’s dealership network.
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 Jaguar Land Rover Limited v. kieran pickavance Case No. D2026-3449 1. The Parties The Complainant is Jaguar Land Rover Limited, United Kingdom, represented by CMS Cameron McKenna Nabarro Olswang LLP, United Kingdom (“UK”). The Respondent is kieran pickavance, UK. 2. The Domain Name and Registrar The disputed domain name <jlrworkwear.com> is registered with 123-Reg Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 4, 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 6, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 6, 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 10, 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 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 2, 2026. page 2 The Center appointed Dr. Clive N.A. Trotman as the sole panelist in this matter on September 4, 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 manufactures cars and vehicles under the brand names JAGUAR and LAND ROVER. The marque JAGUAR dates back to the 1930s and LAND ROVER to the 1940s. The Complainant’s operations are of considerable scale with retail sales exceeding 300,000 vehicles and a revenue of over GBP 20 billion in 2025/2026. The Complainant holds a Royal Warrant and is By Appointment to HM The King Manufacturer of Motor Vehicles. Since at least as early as 2011 the name “Jaguar Land Rover” has been used in the abbreviated form “JLR” by the media and the public. The Complainant has a number of registered trademarks for JLR, of which the following are representative: JLR, word mark, United Kingdom Intellectual Property Office (“UKIPO”), registered February 24, 2012, registration number UK00002594343, in classes 12, 35, and 37; and JLR, word mark, European Union trademark, registered October 6, 2017, registration number 016826257, in classes 12, 35, and 37. The disputed domain name was registered on October 12, 2021. Presently the disputed domain name resolves to a website (the “Respondent’s website”) promoting the goods and services of a third party, Future Garments Ltd, trading as EUROX, of Smethwick, UK. The Respondent’s website purportedly supplies work clothing and accessories such as gloves, safety eye shields and high visibility jackets. At one time the Complainant had a commercial relationship with Future Garments Ltd as its vendor for branded work wear, but this relationship ended in 2019 and a new work wear provider was appointed by the Complainant. The Respondent’s LinkedIn page states that he was Director of Business Development at EUROX from November 2021 to November 2022. 5. Parties’ Contentions 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 the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights. The Complainant’s trademark for JLR is widely used internationally, particularly by the media and motor enthusiast groups, and it predates the registration of the disputed domain name. The additional words “work wear” in the disputed domain name should not prevent a finding of confusing similarity to the Complainant’s trademark. The Complainant contends that the Respondent does not have rights or legitimate interests in respect of the disputed domain name. The Complainant says the Respondent’s use of the disputed domain name cannot be for a bona fide offering of goods or services. The Respondent is not authorised by the Complainant to use the Complainant’s trademark in any way. The Respondent registered the disputed domain name after his commercial page 3 relationship with the Complainant had ended, indicating an intention to divert custom away from the Complainant’s newly appointed work wear vendor. There is no evidence that the Respondent has been commonly known by the disputed domain name and no evidence of any legitimate noncommercial or fair use by the Respondent. The claim on the Respondent’s website, “ESPECIALLY SELECTED FOR THE JAGUAR LAND ROVER NETWORK”, is stated by the Complainant to be untrue. The Complainant further contends that the disputed domain name was registered and is being used in bad faith. The Complainant’s JLR trademark predates the registration of the disputed domain name. The Complainant submits that the registration of the disputed domain name appears to have been with the intention of representing a continuing relationship between EUROX and the Complainant. The Respondent is attempting to attract Internet users to the Respondent’s website by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of the Respondent’s goods and services. The Complainant says that because of the previous commercial partnership between the Complainant and EUROX, the Respondent must have been aware of the Complainant and its business. The Respondent would have had actual or constructive knowledge of the Complainant’s rights. The goods purportedly offered by the Respondent’s website are not of the same standard as the Complainant’s goods, consequently customers may associate inferior products with the Complainant erroneously. The Complainant requests the transfer of the disputed domain name. 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 produced in evidence a list running to some four pages of trademarks for JLR showing their respective registries, registration dates and details. The Panel considers that a mere list is not sufficient. The Panel can expect the Complainant to produce copies of at least two or three relevant registration documents. In the interests of expediency the Panel has, on this occasion, verified the above- listed trademarks at their relevant registries. WIPO Overview 3.1, section 4.8. 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 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, “workwear”) 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 mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. page 4 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. The disputed domain name is found not to be in use in connection with a bona fide offering of goods or services, or for a legitimate noncommercial or fair purpose because, as discussed under the heading of Bad Faith below, the corresponding website is commercial in nature and targets the Complainant with representations that imply a relationship with the Complainant, which the Complainant refutes. There is no evidence the Respondent is known by the disputed domain name or similar. 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. Paragraph 4(b)(iv) of the Policy reads as follows: “by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location”. The Panel has viewed the Respondent’s website as the screen capture presented in evidence, and by visiting the website. The Respondent’s website, headed EUROX, presents an image of a legitimate outlet for the supply of work wear and displays a strip portraying the logo-style trademarks of 10 companies such as “Titan” and “Trakman”; the Complainant is not among them. Near the top of the home page, however, is the heading “PROVIDING WORKWEAR & PPE SOLUTIONS ACROSS THE GLOBAL JAGUAR LAND ROVER DEALERSHIP NETWORK”. A little later is the invitation “BROWSE AND ORDER OUR CORE RANGE OF WORKSHOP GARMENTS AND SHOWROOM TAILORING, ESPECIALLY SELECTED FOR THE JAGUAR LAND ROVER NETWORK”. The contact email address provided is “[...]@eurox.co.uk”. page 5 The Panel notes from its general enquiries (WIPO Overview 3.1, section 4.8) that Future Garments Ltd, trading as EUROX, has other websites in the names of Future Garments Ltd and EUROX respectively that reflect a legitimate business supplying variously branded work wear and associated items. These other websites do not mention the Complainant. Since the Respondent, according to his outline resume on LinkedIn, was Director of Business Development at EUROX, and EUROX had a previous commercial association with the Complainant, it may reasonably be concluded in the circumstances that the Respondent became aware of this prior business relationship or at least was aware of the Complainant’s trademark. The totality of the evidence points inevitably to the conclusion that the Respondent had actual knowledge of and intentionally targeted the Complainant. In the terms of paragraph 4(b)(iv) of the Policy, the Respondent is found to have attempted to attract Internet users to the Respondent’s website by confusion by the incorporation of the Complainant’s trademark in the disputed domain name. The Respondent’s website is clearly intended for commercial gain, with pages devoted to the product range and to delivery and returns. On the evidence, and on the balance of probabilities, the Panel finds the Respondent to have registered and used the disputed domain name in bad faith in the terms of paragraphs 4(b)(iv) and 4(a)(iii) of the Policy. 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 <jlrworkwear.com> be transferred to the Complainant. /Dr. Clive N.A. Trotman/ Dr. Clive N.A. Trotman Sole Panelist Date: September 18, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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