Westmore · UDRP DecisionColgatepalmollve.com
The Panel ordered transfer of <colgatepalmollve.com> to Colgate-Palmolive Company. It found the domain confusingly similar to the Complainant’s COLGATE, PALMOLIVE, and CP COLGATE-PALMOLIVE COMPANY marks; found no rights or legitimate interests because the Respondent did not rebut the Complainant’s prima facie case and the domain falsely suggested affiliation; and found bad-faith registration and use based on targeted typosquatting and passive holding under the totality of the circumstances.
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This decision illustrates how a one-character substitution in one of two combined marks can establish recognizable typosquatting, particularly where the resulting domain also closely imitates the complainant’s official domain. It also shows that lack of active content does not foreclose bad faith when the domain’s composition, the marks’ reputation, and the absence of any respondent explanation collectively support targeted passive holding.
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 Colgate-Palmolive Company v. Stanley Judah Case No. D2026-3523 1. The Parties The Complainant is Colgate-Palmolive Company, United States of America (“United States”), represented by Fross Zelnick Lehrman & Zissu, PC, United States. The Respondent is Stanley Judah, United States. 2. The Domain Name and Registrar The disputed domain name <colgatepalmollve.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 7, 2026. On August 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 10, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 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 10, 2026. The Center appointed Kathryn Lee 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. page 2 4. Factual Background The Complainant is a global consumer products company offering oral care, personal care, home care, and pet nutrition products under various brands including COLGATE, PALMOLIVE, SPEED STICK, AJAX, and HILL’S . Its business traces back to 1806 when William Colgate began selling starch, soap, and candles in New York, United States. PALMOLIVE soap was introduced in 1898. Colgate & Co. merged with Palmolive & Peet in 1928, and the company adopted the shortened name Colgate-Palmolive Co. in 1953. Currently, the Complainant reports a presence in over 200 countries and territories and 2025 global sales exceeding USD 20.3 billion. Further, the Complainant was recognized by Fortune magazine as one of the world’s most admired companies in 2025. The Complainant owns and operates, directly or through affiliates, the domain names <colgate.com>, <palmolive.com>, and <colgatepalmolive.com>, and owns trademark registrations for the COLGATE, PALMOLIVE, and COLGATE PALMOLIVE marks around the world, including the following in the United States: • COLGATE –Trademark Registration Numbers 60,595 (registered on February 12, 1907), 227,647 (registered on May 10, 1927), and 427,475 (registered on February 11, 1947); • PALMOLIVE –Trademark Registration Numbers 113,591 (registered on October 24, 1916), 210,594 (registered on March 16, 1926), 317,320 (registered on September 18, 1934), 732,251 (registered on May 29, 1962), 861,145 (registered on November 26, 1968), and 1,961,815 (registered on March 12, 1996); and • CP COLGATE-PALMOLIVE COMPANY –Trademark Registration Number 5,451,267 (registered on April 24, 2018). The Respondent appears to be an individual with an address in the United States. The disputed domain name was registered on July 27, 2026, and does not resolve to any website with active content. 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 the disputed domain name is confusingly similar to the marks in which the Complainant has rights because it combines the Complainant’s COLGATE mark with a misspelled version of its PALMOLIVE mark, in which the letter “i” is replaced with the letter “l” . The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name, and that there is no evidence of the Respondent’s use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Finally, the Complainant contends that the disputed domain name was registered and is used in bad faith. The Complainant contends that it is a globally recognized company and that its marks are distinctive and well known. Therefore, the Complainant contends, the Respondent’s registration of the disputed domain name cannot be coincidental or in good faith, and the only reasonable inference is that the Respondent registered it intending to exploit the recognition and reputation associated with the mark. The Complainant also contends that non-use of the disputed domain name does not preclude a finding of bad faith use under the passive holding doctrine. page 3 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 COLGATE mark in its entirety as well as a misspelled version of its PALMOLIVE mark in which the letter “i” is replaced with the letter “l”. This substitution does not prevent the PALMOLIVE mark from being recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the marks for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.9. In addition, the text portion of the mark CP COLGATE-PALMOLIVE COMPANY is recognizable within the disputed domain name. Accordingly, the disputed domain name is also confusingly similar to this 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. Moreover, UDRP panels have found that domain names confusingly similar to a complainant’s trademark carry a risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. Here, the disputed domain name combines the Complainant’s COLGATE mark with a misspelled version of its PALMOLIVE mark and further, closely resembles the Complainant’s own domain name, <colgatepalmolive.com>. As a result, the disputed page 4 domain name suggests an affiliation with the Complainant that does not exist and does not support legitimate fair use. 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. Based on the fame of the Complainant’s COLGATE and PALMOLIVE marks, it is very unlikely for the Respondent to have registered the disputed domain name simply by chance. Rather, given that the disputed domain name combines the COLGATE mark with a misspelled version of the PALMOLIVE mark and is a typosquatting variant of the Complainant’s own domain name, <colgatepalmolive.com>, it is quite apparent that the Respondent targeted the Complainant when registering the disputed domain name with full knowledge of the Complainant and its marks. There is no evidence that the Respondent ever made use of the disputed domain name. However, panels have 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 the distinctiveness and reputation of the Complainant’s trademarks, the similarity between the Complainant’s own domain name <colgatepalmolive.com> and the disputed domain name, the composition of the disputed domain name, and the failure of the Respondent to submit a response, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under 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 <colgatepalmollve.com> be transferred to the Complainant. /Kathryn Lee/ Kathryn Lee Sole Panelist Date: September 30, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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