Westmore · UDRP DecisionLpl-enterprisellc.com
The Panel ordered transfer of <lpl-enterprisellc.com>. It found the domain confusingly similar to Complainant’s LPL mark, that Respondent lacked rights or legitimate interests, and that the registration and use were in bad faith. Decisive circumstances included the domain’s prior use for a website impersonating Complainant’s affiliate, unauthorized use of LPL marks and the affiliate’s address, Respondent’s earlier adverse UDRP decision involving <lplenterprisellc.com>, and incorrect registrar contact details.
The timeline behind lpl-enterprisellc.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 lpl-enterprisellc.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a trademark with the name of the trademark owner’s affiliate can support a strong impersonation case. It also shows the significance of an earlier proceeding against the same respondent involving a nearly identical domain: the Panel used that history to establish a pattern of bad-faith conduct under paragraph 4(b)(ii), while prior impersonation and incorrect contact details independently reinforced 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 LPL Financial LLC v. John Patterson Case No. D2026-3801 1. The Parties Complainant is LPL Financial LLC, United States of America (“United States”), represented by Hogan Lovells Cadwalader (Paris) LLP, France. Respondent is John Patterson, United States. 2. The Domain Name and Registrar The disputed domain name <lpl-enterprisellc.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 25, 2026. On August 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 27, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on August 27, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on August 31, 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 Respondent of the Complaint, and the proceedings commenced on September 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 21, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on September 23, 2026. page 2 The Center appointed Jeffrey D. Steinhardt as sole panelist in this matter on October 1, 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 Complainant is an independent broker-dealer founded in 1989. Its parent company, LPL Financial Holdings Inc., is publicly traded on the NASDAQ exchange as “LPLA”. Complainant provides financial services to approximately 32,000 investment advisors at approximately 570 registered investment advisor firms, managing USD 2.6 trillion in advisory and brokerage assets. Complainant owns several trademark registrations for the LPL mark, including United States Trademark Registration No. 1,801,076, registered in International Class 36 on October 26, 1993; United Kingdom Trademark Registration No. UK00003753607, registered in International Classes 36 and 42 on May 13, 2022; and European Union Trademark Registration No. 018653022, registered in International Class 36 on May 26, 2022. LPL Enterprise LLC (LPLE) is an affiliate of Complainant. Complainant and its affiliates operate several websites for the public and its customers using a variety of LPL-derivative domain names. The disputed domain name was registered on July 8, 2026, and currently does not resolve to an active webpage. However, evidence shows that the disputed domain name previously routed to a website purporting to offer financial advisory and other trading-related services, using Complainant’s registered trademarks and the South Carolina address of Complainant’s affiliate LPL Enterprise LLC for the contact address listed on Respondent’s website. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for transfer of the disputed domain name. Notably, Complainant avers that Respondent on its website represents that “LPL Enterprise LLC is a public/private crossover firm that was founded as an affiliate of LPL Financial LLC”. Complainant also avers that: “Until 12 August 2026, the Domain Name resolved to a website titled ‘LPL ENTERPRISE LLC’ that impersonated LPLE (the Respondent's website). The Respondent's website purported to offer a broad range of financial services, identifying itself as ‘an SEC registered broker-dealer and member of FINRA’ and featuring the FINRA ‘BrokerCheck’ logo in the website footer.” Complainant also alleges that the address listed by Respondent with the Registrar appears not to exist and that the registrant phone number belongs to the Queens Public Library. Complainant also notes that in a previous UDRP case, Respondent used a similar domain name that included Complainant’s LPL marks (<lplenterprisellc.com>). The Panel in that proceeding ordered transfer of the disputed domain name to Complainant. LPL Financial LLC v. John Patterson, WIPO Case No. D2025- 3410. page 3 B. Respondent Respondent did not reply to 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 Complainant’s trademark and the disputed domain name. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. 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, “-enterprisellc”) may bear on assessment of the second and third elements, the Panel finds the addition of the hyphen, this word, and additional characters 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 paragraph 4(a) of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on 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. Complainant has provided unopposed evidence that the website to which the disputed domain name previously resolved was used for impersonation, including unauthorized use of Complainant’s LPL marks, references to Complainant’s business, and misleading use of the registered address of Complainant’s affiliate, LPL Enterprise LLC. The Panel accepts Complainant’s uncontroverted allegations that Respondent is not commonly known by the disputed domain name and that Respondent is not making bona fide use of the disputed domain name. Having reviewed the available record, the Panel finds that Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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. page 4 Panels have held that the use of a domain name for illegitimate activity (here, alleged impersonation, passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds that the second element of paragraph 4(a) 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. As noted by Complainant, Respondent has clearly and repeatedly targeted Complainant’s business with registration and use of domain names that are confusingly similar to Complainant’s marks. In 2025, Respondent was found by a UDRP panel to have registered and used the LPL marks in bad faith. LPL Financial LLC v. John Patterson, WIPO Case No. D2025-3410 (<lplenterprisellc.com>; transfer ordered). In the Panel’s view, this is precisely the sort of pattern of bad-faith conduct intended to be reached by the application of paragraph 4(b)(ii) of the Policy. While 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, other circumstances may also 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. Panels have held that the use of a domain name for illegitimate activity (here, alleged impersonation, passing off, or other types of fraud) constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds that Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The Panel finds that Respondent’s use of incorrect address and telephone contact details with the Registrar are further indications of bad faith. The Panel finds that Complainant has established the third element of paragraph 4(a) 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 <lpl-enterprisellc.com> be transferred to Complainant. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: October 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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