Allinmotionco.com, Pillowforthub.com

The timeline behind allinmotionco.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

How each disputed name was decided in this proceeding.

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

DECISION Target Brands, Inc. v. Zeeshan Arain / Rizwan Shad Claim Number: FA2512002192548 PARTIES Complainant is Target Brands, Inc. ("Complainant"), represented by Jeanette Eriksson of FairWinds Partners LLC, District of Columbia, USA. Respondent is Zeeshan Arain / Rizwan Shad ("Respondent"), Pakistan. REGISTRAR AND DISPUTED DOMAIN NAMES The domain names at issue are <allinmotionco.com> and <pillowforthub.com>, registered with Spaceship, Inc. and Name.com, Inc. PANEL The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding. Paul M. DeCicco, as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on December 3, 2025; Forum received payment on December 3, 2025. On December 4, 2025, Spaceship, Inc. and Name.com, Inc. confirmed by e-mail to Forum that the <allinmotionco.com> and <pillowforthub.com> domain names are registered with Spaceship, Inc. and Name.com, Inc. and that Respondent is the current registrant of the names. Spaceship, Inc. and Name.com, Inc. have verified that Respondent is bound by the Spaceship, Inc. and Name.com, Inc. registration agreements and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy"). On December 8, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of December 29, 2025 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@allinmotionco.com, postmaster@pillowforthub.com. Also on December 8, 2025, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts. Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. On December 30, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Paul M. DeCicco as Panelist. Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent. RELIEF SOUGHT Complainant requests that the domain names be transferred from Respondent to Complainant. PRELIMINARY ISSUE: MULTIPLE RESPONDENTS Notwithstanding any differences in the domain registration records for the at-issue domain names, the at-issue domain names nevertheless appear to be effectively controlled by the same person or entity. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder." There is sufficient evidence to conclude that both at-issue domain names are registered to the same domain holder and are under common control as Complainant sets out the following well supported basis for such conclusion: The at-issue domain names use the same naming pattern (full trademark name plus a short 2-3 letter addition, with .com) and address websites with very similar layout and structure, each of which falsely claims to be "official". Next, the at-issue domain names are clearly connected and part of the same phishing and impersonation scheme. This can be seen through the fact that the website of <pillowforthub.com> has copied content straight from the website first posted on <allinmotionco.com>, even mentioning the All In Motion brand in the text. Furthermore, both domain names were registered after a UDRP complaint was filed regarding allinmotionbrand.com and resolved to near identical webpages. As such, they are all splogs, impersonating Complainant's respective owned brand with the ultimate goal of inflating traffic that can be monetized through affiliate links, and to harvest personal information through subscription and leave-a-reply fields. All factors indicate that both at-issue domain names in this present case are connected to the same registrant or controlled by the same entity. Notably, Respondent has failed to contest Complainant's contentions regarding consolidating the at-issue domain names into a single proceeding and has failed to do so by not submitting a formal response in this proceeding or otherwise objecting. Therefore, and considering the foregoing, the Panel elects to treat the at-issue domain names' nominal registrants as a single entity (Respondent) and to allow consolidation of the two at-issue domain names for the purposes s this proceeding. PARTIES' CONTENTIONS A. Complainant Complainant contends in part as follows: Complainant owns, promotes, and enforces the trademarks ALL IN MOTION and PILLOWFORT and makes extensive use of them. Several years prior to the creation of the at-issue domain names, Complainant commenced use of its marks in connection with in-store and online offering of ALL IN MOTION (activewear and sporting goods) and PILLOWFORT (kids' pillows, stuffies, home furnishings and decor) products. Since the inception of its relevant trademark, Complainant has continually used them in commerce. Complainant has many trademark registrations for the ALL IN MOTION and PILLOWFORT mark globally. The domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights. Respondent's at-issue domain name are each confusingly similar to Complainant's relevant registered marks as the addition of generic words or shortened words (here "co" and "hub") to a trademark nevertheless creates a confusingly similar domain name. Finally, the addition of the ".com" TLD does nothing to alleviate confusion between Complainant's marks and the Respondent's domain names. Respondent has no rights or legitimate interest in respect of the at-issue domain names. Section 4(c) of the Policy sets out certain circumstances which, if proven by the evidence presented, may demonstrate Respondent's rights or legitimate interests in the at-issue domain names. None of those circumstances apply to Respondent in the present dispute and Complainant need only make out a prima facie case that none of the circumstances apply to Respondent in the present dispute. With respect to Policy ¶ 4(c)(ii), the concerned Registrar has disclosed that the owner of the at-issue domain names is Zeeshan Arain a/k/a Rizwan Shad. Upon information and belief, Respondent is not commonly known by the at-issue domain names or variations of ALL IN MOTION or PILLOWFORT, nor does Respondent operate a legitimate business or other organization under any of Complainant's marks and Respondent does not own any trademark or service mark rights in any relevant names. Complainant has not licensed, authorized, or permitted Respondent to register domain names incorporating Complainant's ALL IN MOTION and/or PILLOWFORT trademarks. Respondent is using the at-issue domain names to imply affiliation with the Complainant and for hosting what is deceitfully made to appear as informational sites but are merely a vehicle for financial gain through affiliate links to unauthorized or competing products – i.e. what has commonly come to be known as a spam blog or a "splog". Knowingly copying a registered trademark for the purpose of posting a splog to divert traffic away from a complainant's legitimate website through impersonation and passing off for Respondent's own financial gain, has been held not to be a bona fide use of such mark. Thus, the appearance of Respondent's websites being a "official" website offering information is merely a sham pretext by Respondent. The real purpose of the at-issue domain names is to divert traffic from Complainant's legitimate page through passing off, and then financially profit from affiliate links, or simply to harvest users' personal information through the "Subscribe" and "Leave a Reply" fields that can later be used for phishing, sold to a third-party, or other bad faith activity. More importantly, the at-issue domain names all resolve to webpages claiming to be the official ALL IN MOTION and PILLOWFORT website, respectively, all passing themselves off as the respective targeted brand and all of which is not, in any way, licensed or authorized by Complainant. The websites of the at-issue domain names are further displaying "leave a reply" fields presumably with the sole purpose to harvest personal information as part of a phishing attempt or perhaps for the sale of such personal information to a third party. None of this blatant impersonation activity can possibly be bona fide. Next, Respondent is not making a legitimate noncommercial or fair use of the at-issue domain names without intent for commercial gain, and so its actions do not fall within Policy ¶ 4(c)(iii). Impersonation of a Complainant in an at-issue domain name's associated webpage may not qualify as either a bona fide offer of goods and services, nor is it a legitimate noncommercial or fair use, under Policy ¶¶ 4(c)(i) or (iii). The Respondent uses domain names that are confusingly similar Complainant's marks, and uses them to confuse the Complainant's customers into believing that the resulting websites are owned by, or affiliated with Complainant, when this is not the case. Respondent has not been in any way authorized by Complainant, nor is at-issue domain names or any of its associated websites or unauthorized Amazon.com listings to which they link authorized, endorsed or sponsored by Complainant. The at-issue domain names are not being used for any generic or descriptive meaning, or for any meaning other than to resemble Complainant's marks, and any other explanation by the Respondent would clearly be a wholly manufactured post-dispute explanation. Rather, Respondent uses the at-issue domain names to confuse and misleadingly divert consumers, and to tarnish Complainant's registered trademark. Such use cannot be considered fair and it also does not fit into any accepted category of fair use such as news reporting, commentary, political speech, education, nominative use, etc. Regardless of the website to which the at-issue domain names resolve, the domain name themselves impersonate the ALL IN MOTION and PILLOWFORT marks. Finally, Respondent's use has tarnished and diluted Complainant's marks. As a result of its use of the domain names in association with impersonation websites masquerading as official informational pages but in reality being an unauthorized, fraudulent site intended to deceive internet users, inflate SEO rankings, harvest personal information that can be sold to third-parties or used for other cybercrimes, and ultimately redirect internet users for financial gain, Respondent has harmed the brand reputation of Complainant's marks and diminished the public's capacity to associate the marks with the quality products and services offered by Complainant. At a minimum, Respondent's use creates the very real risk that Complainant's trademarks are being associated with products, services or activities over which Complainant has no quality control. The at-issue domain names were registered and are being used in bad faith. The Policy explains that bad faith can be found where a Respondent, by using a domain name, intentionally attempts to attract, for commercial gain, internet users to its website or other on-line location, by creating a likelihood of confusion with the complainant's mark as to source, sponsorship, affiliation, or endorsement of the website or location, or of a product or service on the website or location. Respondent intentionally uses Complainant's marks without consent from Complainant. Respondent was on actual notice of Complainant's rights in the ALL IN MOTION and PILLOWFORT marks because of Complainant's extensive use of the marks which predate the date on which Respondent acquired the domain names. Furthermore, the at-issue domain names are clearly intended to give the impression that Respondent is Complainant's official websites for its ALL IN MOTION and PILLOWFORT marks. Finally, Respondent's websites incorporates numerous claims and wordings chosen specifically to pass itself off as the Complainant, frequent use of Complainant's ALL IN MOTION and PILLOWFORT logos and the full trademark names and as such, the Respondent can only have created the at-issue domain names upon its knowledge of, and in violation of, Complainant's trademark rights. Respondent's creation of websites that impersonate Complainant and its ALL IN MOTION and PILLOWFORT marks alone constitutes bad faith as it disrupts Complainant's business and seeks to capitalize on confusion with the ALL IN MOTION and PILLOWFORT marks respectively. Respondent's unauthorized use of a confusingly similar domain names, the unauthorized use of the full trademarks and logos numerous times across the corresponding websites together with blatant impersonation and redirection of internet users, the lack of any disclaimers, use of "Leave a reply" forms to harvest user information (to sell or otherwise exploit user information or to promote certain other websites), and numerous affiliate links is indicative of Respondent's intent to confuse users for its own commercial gain and to disrupt Complainant's business by drawing users to the at-issue domain names and its associated sites. Whether or not Respondent itself is compensated is irrelevant. ICANN Panels have held that there only needs to be commercial gain sought by some party for the use to be commercial. The at-issue domain names in this present case have thus been registered and used in bad faith under the well-accepted theory of initial interest confusion. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant has rights in the ALL IN MOTION and PILLOWFORT trademarks. Respondent is not affiliated with Complainant and had not been authorized to use Complainant's trademarks in any capacity. Respondent registered the at-issue domain name after Complainant acquired rights in the <allinmotionco.com> and <pillowforthub.com> trademarks. The at-issue domain names address websites that attempts to pass off as Complainants genuine website and is used for a spam blog. DISCUSSION Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable." Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint"). Identical and/or Confusingly Similar The at-issue domain name is confusingly similar to a trademark in which Complainant has rights. Complainant's USPTO registration for ALL IN MOTION and for PILLOWFORT, as well as any other trademark registrations for such marks worldwide, are sufficient to demonstrate Complainant's rights in a mark under Policy ¶ 4(a)(i). See BGK Trademark Holdings, LLC & Beyoncé Giselle Knowles-Carter v. Chanphut / Beyonce Shop, FA 1626334 (Forum Aug. 3, 2015) (asserting that Complainant's registration with the USPTO (or any other governmental authority) adequately proves its rights under Policy ¶ 4(a)(i)). Respondent's <allinmotionco.com> and <pillowforthub.com> domain names each contains one of Complainant's trademarks, either ALL IN MOTION (less its domain name impermissible spaces) or PILLOWFORT, followed by a short term, either "co" or "hub," with all followed by the ".com" top-level. The differences between Respondent's domain names and Complainant's trademarks are insufficient to distinguish either domain name from one of Complainant's trademarks for the purposes of Policy ¶ 4(a)(i). Therefore, the Panel concludes that Respondent's at-issue domain names are each confusingly similar to a trademark in which Complainant has rights. See Wiluna Holdings, LLC v. Edna Sherman, FA 1652781 (Forum Jan. 22, 2016) (finding the addition of a generic term and gTLD is insufficient in distinguishing a disputed domain name from a mark under Policy ¶ 4(a)(i)). Rights or Legitimate Interests Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006). Respondent is not authorized to use Complainant's trademarks in any capacity and as discussed below, there are no Policy ¶ 4(c) circumstances from which the Panel might find that Respondent has rights or interests in respect of the at-issue domain name. See Charter Communications Holding Company, LLC v. Taha Shaikh / Tskdesigners, FA 1814475 (Forum Nov. 25, 2018) (finding no rights or legitimate interests in <spectrumfeature.com> because complainant never gave respondent permission to use the mark in any manner and Panels may use these assertions as evidence that no rights or legitimate interests exist in a disputed domain name."). The WHOIS information for the at-issue domain name leads to the identification of "Zeeshan Arain – Rizwan Shad" as the domain name's registrant and the record before the Panel contains no evidence that tends to prove that the domain name's registrant is commonly known by the at-issue domain name. The Panel therefore concludes that Respondent is not commonly known by <allinmotionco.com> or <pillowforthub.com> or any combination or variant thereof for the purposes of Policy ¶ 4(c)(ii). See Coppertown Drive-Thru Sys., LLC v. Snowden, FA 715089 (Forum July 17, 2006) (concluding that the respondent was not commonly known by the <coppertown.com> domain name where there was no evidence in the record, including the WHOIS information, suggesting that the respondent was commonly known by the disputed domain name). Respondent's <allinmotionco.com> and <pillowforthub.com> domain names address or redirect traffic to, a fake blog commonly known as a spam blog. The spam blog is used to promote affiliated websites purportedly to improve search engine ranking or to sell links and or advertising. The at-issue domain names' referenced content has monetized ads and affiliate links to products and services. Indeed, such content includes a "Leave a Reply" field that may be used to harvest personal information from website visitors who input such information with the false expectation of reaching Complainant. Thus, Respondent fails to use the domain name to promote a bona fide offering of goods or services or a legitimate noncommercial or fair use per Policy ¶¶ 4(c)(i) or (iii). See Ripple Labs Inc. v. NGYEN NGOC PHUONG THAO, FA 1741737 (Forum Aug. 21, 2017) ("Respondent uses the [disputed] domain name to divert Internet users to Respondent's website… confusing them into believing that some sort of affiliation exists between it and Complainant… [which] is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i) nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii)."); see also, Enterprise Holdings, Inc. v. I S / Internet Consulting Services Inc., FA 1785242 (Forum June 5, 2018)("On its face, the use of a domain name that is confusingly similar to the mark of another in order to facilitate a phishing scheme cannot be described as either a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶4(c)(iii)."). Given the foregoing, Respondent lacks rights and lacks legitimate interests in <allinmotionco.com> and in <pillowforthub.com>. Registration and Use in Bad Faith As discussed below without being exhaustive, Respondent acted in bad faith. As mentioned above, Respondent uses its confusingly similar domain name to direct internet traffic to Respondent's <allinmotionco.com> and <pillowforthub.com> referenced web content. There, Respondent displays Complainant's trademarks and impersonates Complainant. The content appears to be a spam blog or "splog." Such sites are used to attempt to increase the search engine ranking of associated sites by causing visitors to navigate through circular links and/or to profit from the sale of links or advertising. Respondent's use of <allinmotionco.com> and <pillowforthub.com> and their associated content are thus disruptive to Complainant's business and capitalize on the confusion Respondent creates between Complainant's trademarks and Respondent's domain names. Therefore, the Panel finds that Respondent registered and uses the at-issue domain name in bad faith pursuant Policy ¶ 4(b)(iii) and Policy ¶ 4(b)(iv). See Allianz of Am. Corp. v. Bond, FA 680624 (Forum June 2, 2006) (finding bad faith registration and use under Policy ¶ 4(b)(iv) where the respondent was diverting Internet users searching for the complainant to its own website and likely profiting). Moreover, Respondent had actual knowledge of Complainant's rights in the ALL IN MOTION and PILLOWFORT marks before it registered <allinmotionco.com> and <pillowforthub.com> as domain names. Respondent's prior knowledge is evident from the notoriety of Complainant and Complainant's ALL IN MOTION and PILLOWFORT trademarks, and from Respondent's inclusion of Complainant's trademarks in web content referenced by the domain names. Respondent's registration and use of the confusingly similar domain names with knowledge of Complainant's trademark rights in ALL IN MOTION and PILLOWFORT further demonstrates Respondent's bad faith pursuant to the Policy. See Lemon Inc. v. Sumer Singh, FA 2110519 (Forum September 5, 2024 ("registration of a disputed domain name with actual knowledge of another's trademark rights is sufficient to establish bad faith, and can be shown by the notoriety of the mark and the use the Respondent makes of the disputed domain name"); see also, Minicards Vennootschap Onder FIrma Amsterdam v. Moscow Studios, FA 1031703 (Forum Sept. 5, 2007) (holding that respondent registered a domain name in bad faith under Policy ¶ 4(a)(iii) after concluding that respondent had actual knowledge of Complainant's mark when registering the disputed domain name). DECISION Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED. Accordingly, it is Ordered that the <allinmotionco.com> and <pillowforthub.com> domain names be TRANSFERRED from Respondent to Complainant. Paul M. DeCicco, Panelist Dated: January 2, 2025 Click Here to return to the main Domain Decisions Page. 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Source of record: FORUM . Reproduced for research; FORUM is the authoritative source.