ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sealed Air Corporation (US) v. Name Redacted1, Name Redacted, Name Redacted, Name Redacted Case No. D2025-3335 1. The Parties The Complainant is Sealed Air Corporation (US), United States of America (“United States”), represented by Nelson Mullins Riley & Scarborough, L.L.P., United States. The Respondents2 are Name Redacted, Name Redacted, Name Redacted and Name Redacted, United States. 2. The Domain Names and Registrar The disputed domain names and are registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 19, 2025. On August 20, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name . On August 21, 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 August 26, 2025, providing the registrant and contact 1 The Respondent appears to have used the name of an employee of the Complainant, and variations of the Complainant’s business name, to register the disputed domain names. In light of the potential identity theft, the Panel has redacted these names from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the disputed domain names, which includes the names of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding, and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. 2 As discussed below in Section 6.A. dealing with consolidation, because the disputed domain names appear to be under common control, perhaps by one person using similar designations for both domain name registrations, the Panel hereinafter uses the term “Respondent” (in the singular).
page 2 information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on August 28, 2025, and the request of adding the disputed domain name . On September 2, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name . On September 3, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to the Complainant on September 4, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaints for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on September 5, 2025. The Center verified that the Complaint together with the amended Complaints 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 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 28, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 29, 2025. The Center appointed Evan D. Brown as the sole panelist in this matter on October 2, 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 in the business of providing packaging solutions. It owns the trademark SEALED AIR and enjoys the benefits of holding multiple registrations for that mark, e.g., United States Reg. No. 925,912 (registered on December 21, 1971). According to the WhoIs records, the disputed domain name was registered on July 18, 2025, and the disputed domain name was registered on August 19, 2025. The Respondent has used the disputed domain name to set up at least two email addresses and to thereby impersonate one of the Complainant’s actual employees by contacting vendors of the Complainant in an apparent attempt to engage in phishing. Though the record does not provide proof that the Respondent used the other disputed domain name to send or receive messages, the Complainant has provided evidence that the Respondent held itself out as using the domain name for email communications – in furtherance of the same sort of phishing enterprise – via a LinkedIn message sent to one of the Complainant’s vendors. The Complainant asserts that to further the phishing scheme and give the appearance of credibility to its activity, the Respondent redirected one of the disputed domain names () to the Complainant’s legitimate website. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain names are identical or confusingly similar to the Complainant’s trademark; that the Respondent has no rights or legitimate interests in respect of the disputed domain names; and that the disputed domain names were registered and are being used in bad faith.
page 3 B. Respondent The Respondent did not respond to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights, (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain names, and (iii) the disputed domain names have been registered and are being used in bad faith. The Panel finds that all three of these elements have been met in this case. A. Consolidation of Multiple Respondents There are two named Respondents (two underlying registrants disclosed by the Registrar) – one for each of the disputed domain names. The Complainant requests that both be consolidated into this matter. Consolidation is proper, so the Complainant’s request for consolidation is granted. Paragraph 10(e) of the Rules states that a “[p]anel shall decide a request by a Party to consolidate multiple domain name disputes in accordance with the Policy and these Rules”. Paragraph 10(c) of the Rules provides, in relevant part, that “the [p]anel shall ensure that the administrative proceeding takes place with due expedition”. Section 4.11.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) summarizes the consensus view of UDRP panels on the consolidation of multiple respondents and provides that where a complaint is filed against multiple respondents, panels consider whether the domain names or corresponding websites are subject to common control, and whether the consolidation would be fair and equitable to all parties. The record indicates the disputed domain names are under common control. The following facts support this conclusion: (1) both disputed domain names were registered within a short period of time, approximately one month, (2) both disputed domain names were registered using the services of the Registrar, (3) the contact information provided for each disputed domain name bears resemblances to one another, including use of the first name of an employee of the Complainant in both, and organization names each containing the words “sealed” and “air”, and (4) both disputed domain names were used to set up email addresses that impersonate the same employee of the Complainant. The multiple named Respondents have not presented any arguments as to why consolidation would be unfair or inequitable. Accordingly, conditions for proper consolidation of the disputed domain names into one matter are present here. B. Identical or Confusingly Similar This first element functions primarily as a standing requirement. WIPO Overview 3.0, section 1.7. 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. Id. This element requires the Panel to consider two issues: first, whether the Complainant has rights in a relevant mark; and second, whether the disputed domain names are identical or confusingly similar to that mark. A registered trademark provides a clear indication that the rights in the mark shown on the trademark certificate belong to its respective owner. See Advance Magazine Publishers Inc., Les Publications Conde Nast S.A. v. Voguechen, WIPO Case No. D2014-0657. The Complainant has demonstrated its rights in the SEALED AIR mark by providing evidence of its trademark registrations. See WIPO Overview 3.0, section 1.2.1.
page 4 The disputed domain names incorporate the SEALED AIR mark in its entirety with the addition of the geographic term “usa” (with and without a hyphen), which does not prevent a finding of confusing similarity between the disputed domain names and the Complainant’s SEALED AIR mark. See WIPO Overview 3.0, section 1.8. The SEALED AIR mark remains recognizable for a showing of confusing similarity under the Policy. It is standard practice when comparing a disputed domain name to a complainant’s trademarks, to not take the extension into account. See WIPO Overview 3.0 at 1.11.1. The Panel finds that the Complainant has established this first element under the Policy. C. Rights or Legitimate Interests The Panel evaluates this element of the Policy by first looking to see whether the Complainant has made a prima facie showing that the Respondent lacks rights or legitimate interests in respect of the disputed domain names. If the Complainant makes that showing, the burden of production of demonstrating rights or legitimate interests shifts to the Respondent (with the burden of proof always remaining with the Complainant). See WIPO Overview 3.0, section 2.1; AXA SA v. Huade Wang, WIPO Case No. D2022-1289. On this point, the Complainant asserts, among other things, that: (1) the Respondent is not commonly known by the Complainant’s SEALED AIR mark or the disputed domain names, despite having used contact information to register the disputed domain names that incorporate or partially incorporate the company name of the Complainant and one of its employees, (2) the Complainant has not authorized or licensed the Respondent to use the SEALED AIR mark, and (3) the Respondent has not made a bona fide use of the disputed domain names nor engaged in any demonstrable preparations to use the disputed domain names in connection with a bona fide offering of goods or services. Instead, as the Complainant asserts, the Respondent registered the disputed domain names solely for the purpose of impersonating the Complainant in furtherance of a scam targeting logistics vendors, capitalizing on the reputation and goodwill associated with the SEALED AIR mark to gain the trust of and then defraud the Complainant’s vendors with offers of potential freight hauling partnerships through impersonation of one of the Complainant’s actual employees. The Panel finds that the Complainant has made the required prima facie showing. The Respondent has not presented evidence to overcome this prima facie showing. And nothing in the record otherwise tilts the balance in the Respondent’s favor. The use of a domain name for illegal activity such as impersonation or passing off, can never confer rights or legitimate interests on a respondent. Société des Produits Nestlé S.A. v. Great Homes, jobs-nestle.com, WIPO Case No. D2024-2911; WIPO Overview 3.0, section 2.13.1. Accordingly, the Panel finds that the Complainant has established this second element under the Policy. D. Bad Faith Registration and Use The Policy requires a complainant to establish that the disputed domain names were registered and are being used in bad faith. The Panel finds that the Respondent registered and used the disputed domain names in bad faith. The record shows that the Respondent: targeted the Complainant specifically, used privacy services to obfuscate its identity, sent fraudulent emails impersonating the Complainant, and otherwise sought to hold itself out as the Complainant by redirecting at least one of the disputed domain names to the Complainant’s legitimate website, thereby intentionally attempted to attract, for commercial gain, Internet users to its online location by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s activity.
page 5 By using the disputed domain names to send phishing emails impersonating the Complainant and redirecting traffic to the Complainant’s legitimate website to bolster the scheme’s credibility, the Respondent demonstrated an intent to deceive third parties for commercial gain. This in and of itself constitutes bad faith under paragraph 4(b)(iv) of the Policy. The Panel finds that the Complainant has established this third element under 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 names and be transferred to the Complainant. /Evan D. Brown/ Evan D. Brown Sole Panelist Date: October 16, 2025
Full & Egal Universal Law Academy