ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION CWI, LLC v. Megan Starr Case No. D2025-2595 1. The Parties The Complainant is CWI, LLC, United States of America (“United States”), represented by Neal & McDevitt, United States. The Respondent is Megan Starr, Afghanistan. 2. The Domain Name and Registrar The disputed domain name is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 2, 2025. On July 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 4, 2025, 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 July 11, 2025, 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 July 15, 2025. 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 July 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 19, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 20, 2025.
page 2 The Center appointed Anne-Virginie La Spada as the sole panelist in this matter on August 22, 2025. 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 company based in Illinois, United States, which operates a network of recreational vehicle sales, equipment and accessories and service centers in the United States. The Complainant was historically headquartered in Bowling Green, Kentucky, United States. It has today more than 185 retail and service locations in North America. Among other registrations, the Complainant is the owner of the following United States trademark registrations: - registration no. 4,536,313 for CAMPING WORLD, registered on May 27, 2014, in classes 35 and 37; - registration no. 0,930,179 for CAMPING WORLD, registered on February 29, 1972, in class 42 - registration no. 4,536,315 for CAMPING WORLD & device, registered on May 27, 2014, in classes 35 and 37 The Complainant also owns and operates a domain name . The disputed domain name was registered on May 19, 2025. At the time of filing of the Complaint, the disputed domain name resolved to a website displaying the CAMPING WORLD trademark next to a logo similar to the Complainant’s logo and offering for sale camping related goods as well as different camping related guides. The Respondent’s website included at the bottom of each page the mention of the Complainant’s original address in Bowling Green, Kentucky, United States. 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 identical to its CAMPING WORLD registered trademark, which has been used for over 60 years. The Complainant further contends that the Respondent has no rights or legitimate interests in the disputed domain name, as the Respondent is not authorized by the Complainant to use the disputed domain name, and there is no indication that the Respondent is known under the disputed domain name. Additionally, according to the Complainant, the disputed domain name is not being used in connection with a bona fide offering of goods and services as the Respondent is using the disputed domain name to intentionally attract Internet users to its website by creating a likelihood of confusion with Complainant’s CAMPING WORLD marks for its own financial gain. Finally, the Complainant contends that the Respondent has used and registered the disputed domain name in bad faith. According to the Complainant, the disputed domain name reproduces the Complainant’s well-known trademark in its entirety, the Respondent adopted a logo that is similar to the logo present in the CAMPING WORLD trademarks and it also used the Complainant’s former address in connection with a website to confuse consumers and/or drive traffic to its own website.
page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 4(a) of the Policy, a complainant must assert and prove each of the following: (i) the domain name registered by the respondent is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and (ii) the respondent has no rights or legitimate interests in respect of the domain name; and (iii) the domain name has been registered and is being used in bad faith. 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 Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, 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 3.0, 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 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 3.0, 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 the present case, the composition of the disputed domain name identically reproducing the Complainant’s trademark CAMPING WORLD along with the use of the disputed domain name create a risk of confusion. Based on the information submitted by the Complainant, the Complainant has not granted the Respondent authorization to use its trademarks within the disputed domain name. Moreover, there is no evidence indicating that the Respondent is commonly known by the disputed domain name. Instead, based on the
page 4 evidence provided by the Complainant, it appears that the Respondent used the disputed domain name in connection with a website offering recreational equipment for sale overlapping with the Complainant’s goods and services. The web page connected to the disputed domain name displayed a logo similar to the one contained in the Complainant’s semi-figurative trademarks for CAMPING WORLD. Furthermore, the address indicated at the bottom of each page and in the contacts section of the website site mentions the city of Bowling Green in Kentucky, where the Complainant had its initial headquarters. These elements create the impression of an official website, operated or at least endorsed by the Complainant. Finally, the Respondent did not file a Response to the Complaint. The Panel may draw from the lack of a Response the inferences that it considers appropriate, according to the Rules, paragraph 14(b). 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. Given the longstanding use of the Complainant’s trademark, and the circumstances of the use of the disputed domain name (see below), the Panel finds it implausible that the Respondent chose the disputed domain name without having the Complainant’s mark in mind. The Panel therefore accepts that the disputed domain name was registered in bad faith. Under paragraph 4(b)(iv) of the Policy, the use of a disputed domain name to intentionally attempt to attract, for commercial gain, Internet users to a website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of a web site or location or of a product or service on the website or location, amounts to evidence of registration and use in bad faith. In the present case, the Panel notes that the Respondent registered the disputed domain name well after the Complainant’s trademark had been registered and widely used. In addition, the Respondent used the disputed domain name in connection with a website offering goods and services directly competing with the Complainant’s goods and services, and displayed prominently at the top of each page of such website the trademark CAMPING WORLD with a logo resembling the Complainant’s logo. In addition, the Respondent used on its website the Complainant’s original headquarters address. Such use was apt to create the false impression that the Respondent’s website was operated or endorsed by the Complainant. Consequently, by using the disputed domain name in such manner, the Panel finds that Respondent intentionally attempted to attract Internet users to its website by creating a likelihood of confusion with the Complainant’s mark as to the source and affiliation of its website. Such behavior constitutes use in bad faith under paragraph 4(b)(iv) of the Policy. The Panel finds the third element of the Policy has been established. 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 be transferred to the Complainant. /Anne-Virginie La Spada/ Anne-Virginie La Spada Sole Panelist Date: September 5, 2025
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