Westmore · UDRP DecisionPurlsoho.mom
The Panel ordered transfer of <purlsoho.mom>. It found the domain identical to the Complainant’s registered PURL SOHO mark, found no rights or legitimate interests because the Respondent used the domain for commercial gain to misleadingly divert consumers, and found bad faith based on deliberate targeting and imitation of the Complainant’s website.
The timeline behind purlsoho.mom
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 purlsoho.mom — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a direct-targeting fact pattern in which exact incorporation of a registered mark was combined with an imitation commercial website. The website content was important beyond confusing similarity: it supported the Panel’s findings that the Respondent lacked a legitimate interest, knew of the Complainant, and intentionally sought commercial gain through confusion.
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 Purl NYC LLC dba Purl Soho v. Nikita Ivanov Case No. D2026-3900 1. The Parties The Complainant is Purl NYC LLC dba Purl Soho, United States of America (“United States” or “U.S.”), represented by Keating Muething & Klekamp PLL, U.S. The Respondent is Nikita Ivanov, Germany. 2. The Domain Name and Registrar The disputed domain name <purlsoho.mom> 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 31, 2026. On September 1, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 2, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 2, 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 the same date. 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 September 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 23, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 25, 2026. page 2 The Center appointed Francine Tan as the 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 The Complainant is a knitting and craft business operating an e-commerce website using the domain name <purlsoho.com>. The Complainant sells high-quality, exclusive knitting and craft supplies, including its own brand of hand-knitting yarns, design patterns, and knitting and crochet tools. The Complainant has since its inception in 2002 used its PURL SOHO trade mark in connection with its knitting and craft business. The Complainant states that through its continued and long use of the PURL SOHO trade mark and the superior quality of its products, the Complainant has accumulated substantial goodwill in its PURL SOHO trade mark. The Complainant’s PURL SOHO trade mark registrations include: (i) U.S. trademark registration No. 5158960, registered on March 14, 2017; and (ii) U.S. trademark registration No. 5207571, registered on May 23, 2017. The disputed domain name was registered on May 28, 2026. The disputed domain name resolves to a website that purportedly sells PURL SOHO products and contains images and text that imitate those of the Complainant’s website which is located at “www.purlsoho.com”. 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: 1. The disputed domain name is confusingly similar to the Complainant’s PURL SOHO trade mark. The disputed domain name consists entirely of the Complainant’s PURL SOHO trade mark. 2. The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not commonly known by the name “Purl Soho”; it has not acquired any trademark rights in the name; the Respondent has not been authorized by the Complainant to use the PURL SOHO trade mark in the context of the disputed domain name or for any other reason; and the Respondent is not making a legitimate noncommercial or fair use of the disputed domain name. 3. The disputed domain name was registered and is being used in bad faith, namely to attract Internet users to the Respondent’s website by creating a likelihood of confusion with the Complainant’s PURL SOHO trade mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s website by the Complainant. The Respondent’s website appears like it may be the Complainant’s official website, which is clearly an attempt by the Respondent to deceive Internet users into falsely believing that the disputed domain name is sponsored or authorized by the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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 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 identical to the 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. In particular, there is no evidence that the Respondent is commonly known by the name “Purlsoho” or “Purl Soho”. Further, based on the evidence submitted concerning the Respondent’s website, the Panel finds that the Respondent is not making a legitimate noncommercial or fair use of the disputed domain name. Rather, the disputed domain name has been used for commercial gain in a manner intended to misleadingly divert consumers. 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) 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. page 4 In this case, it is evident that the Respondent was well aware of the Complainant and its PURL SOHO trade mark, and deliberately targeted the Complainant and its trade mark for commercial gain. Among other things, the Respondent’s lack of any rights to or legitimate interests in the disputed domain name, its mimicking of the Complainant’s website, all support the conclusion that the Respondent registered and uses the disputed domain name to attract, for commercial gain, Internet users to his website by creating a likelihood of confusion with the Complainant’s PURL SOHO trade mark. WIPO Overview 3.1, section 3.1.4. Further, panels have consistently held that the use of a domain name for illegitimate purposes, including passing off, 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. 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 <purlsoho.mom> be transferred to the Complainant. /Francine Tan/ Francine Tan Sole Panelist Date: October 6, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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