Westmore · UDRP DecisionShimanosales.com
The Panel ordered transfer of <shimanosales.com> to Shimano Inc. The domain incorporated the SHIMANO trademark in full with the term “sales” and resolved to an online store displaying the mark and offering purported SHIMANO-branded cycling products at discounted prices without an affiliation disclaimer. The Panel found confusing similarity, no rights or legitimate interests, and registration and use in bad faith through impersonation and intentional attraction of Internet users for commercial gain.
The timeline behind shimanosales.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 shimanosales.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a straightforward impersonation-store fact pattern in which a famous or well-known brand is combined with a sales-related term and used for a website presenting itself as a brand outlet. The domain composition supported confusing similarity, while the website’s content—rather than the domain string alone—was decisive for the findings on legitimate interests and bad faith.
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 Shimano Inc. v. Dongmei Zhang Case No. D2026-3692 1. The Parties The Complainant is Shimano Inc., Japan, represented by Illovsky Gates & Calia, LLP, United States of America (“United States”). The Respondent is Dongmei Zhang, China. 2. The Domain Name and Registrar The disputed domain name <shimanosales.com> (the “Disputed Domain Name”) is registered with Name.com, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 11, 2026. On August 18, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On August 19, 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 (“John Doe”) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 20, 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 20, 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 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 14, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 18, 2026. page 2 The Center appointed Michael D. Cover as the sole panelist in this matter on September 23, 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 well-known manufacturer of cycling components, fishing tackle and related equipment and has traded under the SHIMANO trademark for decades. The Complainant is the proprietor of a worldwide portfolio of registrations of its SHIMANO trademark, including the following: United States No. 989,509 SHIMANO registered July 30, 1974 Class 12; United States No. 1,606,477 SHIMANO registered July 17, 1990 Classes 25 and 28; and United States No. 1,771,463 SHIMANO registered May 18, 1993 Classes 18 and 25. The Disputed Domain Name was created on August 23, 2022, and resolves to a website that presents itself as an online store for cycling related products, “ SHIMANO STEPS -for urban, hiking”, prominently displaying the SHIMANO trademark and offering SHIMANO-branded products for sale at, at times, steeply-discounted prices, without any disclaimer of affiliation, as set out in Annex 5 to the Complaint. 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. Identical or Confusingly Similar The Complainant states that it owns registered rights in the SHIMANO trademark, as evidenced by the registrations that it has identified, the earliest of which has been registered since 1974, decades before the Disputed Domain Name was created and submits that these registrations are sufficient to establish the Complainant’s standing under the first element (of the Policy). The Complainant then submits that the Disputed Domain Name is identical or confusingly similar to the SHIMANO trademark, in that it reproduces the SHIMANO trademark in its entirety and only adds the descriptive term “sales”. The Complainant continues that, under settled UDRP practice, where the mark is recognizable within the disputed domain name, the addition of a descriptive term, such as “sales”, does not prevent a finding of confusing similarity and also that the “.com” Top-Level Domain is disregarded for the purposes of this analysis and cites WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1.”) sections 1.7, 1.8 and 1.11. The Complainant concludes that the first element of Paragraph 4(a) of the Policy is satisfied. Rights or Legitimate Interests The Complai nant submits that the Respondent lacks any rights or legitimate interests in the Disputed Domain Name and that the website at the Disputed Domain Name presents itself as a “Shimano Sales Shop”, prominently displaying the SHIMANO mark and offering SHIMANO-branded products for sale at page 3 steeply discounted prices, without any disclaimer of affiliation and in a manner designed to appear as an official or authorized SHIMANO outlet. The Complainant continues that the Complainant has no relationship with the Respondent and has not authorized, licensed or otherwise permitted the Respondent to use the SHIMANO mark, to sell any SHIMANO branded products or to register any domain name incorporating the SHIMANO mark. The Complainant then submits that the Respondent’s website has been designed to deceive the public into believing that the Disputed Domain Name is affiliated with the Complainant and includes numerous indicia of fraudulent conduct, including, says the Complainant, a purported entity, DessHead LTD, an entity that the Complainant says it is unable to confirm exists. The Complainant states that the Respondent’s website lists a purported physical address in Virginia, United States, which does not appear to correspond to any verifiable business or property location, inconsistent with the Sichuan, China registrant location reflected in the WhoIs record. Registered and Used in Bad Faith The Complainant submits that the Disputed Domain Name was both registered and is being used in bad faith within the meaning of Paragraph 4(b) of the Policy and, in that connection, the Complainant notes that the Disputed Domain Name was created on August 23, 2022, decades after the Complainant first registered and began using the SHIMANO trademark. The Complainant also submits that, given the international renown of the SHIMANO trademark and the Complainant’s longstanding registrations, the Respondent cannot credibly claim to have been unaware of the Complainant's rights, when the Respondent registered a domain name wholly incorporating the SHIMANO trademark and appending only the term “sales”, which, says the Complainant, directly evokes the commercial sale of the Complainant’s goods. The Complainant submits that the Respondent’s website’s presentation as a “Shimano Sales Shop”, its display of the SHIMANO mark and SHIMANO product imagery and its offering purported SHIMANO goods at implausibly low prices demonstrate a deliberate effort to trade on the Complainant’s mark for commercial gain by creating a likelihood of confusion as to source or affiliation. The Complainant also notes what it describes as additional circumstances of bad faith, including the Complainant’s use of a privacy service and the implausibility of any good faith use of the famous SHIMANO mark. The Remedy requested by the Complainant The Complainant requests that the Panel issues a Decision that the Disputed Domain Name be transferred to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The Complainant must establish on the balance of probabilities, cumulatively, that the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; that the Respondent has no rights or legitimate interests in the Disputed Domain Name; and that the Disputed Domain Name has been registered and is being used in bad faith. page 4 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 its SHIMANO trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the Complainant’s SHIMANO trademark is reproduced within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to that trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms, here “sales”, 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. In addition, it is well-established in prior UDRP decisions that the applicable Top-Level-Domain (“gTLD”), in this case “.com”, is a standard registration requirement and may be ignored in considering confusing similarity, as seen in WIPO Overview 3.1 section 1.11.1, and this was the approach that the Panel has adopted in this Decision. 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 Di sputed Domain Name such as those enumerated in the Policy or otherwise. The Respondent has not demonstrated, before notice of the dispute, use or demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services, or that the Respondent is making legitimate noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain misleadingly to divert consumers or to tarnish the reputation of the Complainant’s SHIMANO trademark. Panels have held that the use of a domain name for illegitimate activity, here, passing off, impersonation, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. page 5 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. In the present case, the Panel notes that the Respondent has been using the Disputed Domain Name to impersonate the Complainant and to offer purported SHIMANO-branded products for sale at discounted prices. The Panel further finds that the Respondent has intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s trademark. Panels have also held that the use of a domain name for illegitimate activity, here, claimed passing off, impersonation, 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 and 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 <shimanosales.com> be transferred to the Complainant. /Michael D. Cover/ Michael D. Cover Sole Panelist Date: October 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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