ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LRC Products Limited v. Mojtaba Shirazi Case No. D2025-3337 1. The Parties Complainant is LRC Products Limited, United Kingdom, represented by Studio Barbero S.p.A., Italy. Respondent is Mojtaba Shirazi, United Arab Emirates (“UAE”). 2. The Domain Name and Registrar The disputed domain name is registered with 1API GmbH (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 (WHOIStrustee.com Limited, Registrant of durexland.com) and contact information in the Complaint. The Center sent an email communication to Complainant on August 21, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on August 26, 2025. The Center verified that the Complaint together with the amendment to the 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 August 27, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 16, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on September 18, 2025.
page 2 The Center appointed Bradley A. Slutsky as the sole panelist in this matter on September 25, 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 Complainant is a United Kingdom limited company located in Slough, Berkshire, United Kingdom. Originally founded in 1915 as the London Rubber Company, the business began by selling imported condoms and barber shop supplies. The DUREX brand—an acronym for Durability, Reliability, and Excellence—was registered in 1929, with condom production commencing in the 1930s. In 2010, Complainant became a subsidiary of Reckitt Benckiser Group plc – a business that produces consumer health, hygiene, and home products. Complainant is the owner of numerous trademark registrations for the mark DUREX, including the following: Mark Goods/Services Jurisdiction Reg. No. Reg. Date DUREX 5, 10 European Union 000200923 December 8, 1999 DUREX 1, 5, 9, 10, 16, 17, 21, 25, 37, 41, 42 European Union 000200907 December 16, 1999 DUREX 18, 25, 28 European Union 002641850 September 8, 2003 DUREX 10 International 1684485 June 10, 2022 3, 5, 10 International 1648038 December 14, 2021 5, 10 International 1456119 August 29, 2018 DUREX 10 Iran 2444/3520 November 12, 1946 DUREX 5, 10 Iran 196808 December 19, 2o12 DUREX 10 UAE 3984 February 4,1996 DUREX 10 UAE 3985 February 4, 1996 DUREX 5 UAE 180197 June 10, 2014 DUREX 10 UAE 180198 June 10, 2014 Complainant asserts that “DUREX is the number 1 top-selling condom brand worldwide and is the market leader in approximately 40 countries.” Complainant’s business includes the sale and supply of condoms, lubricants, and related products. DUREX has been promoted through traditional advertising and digital platforms, including Facebook, X, Instagram, YouTube, and TikTok. Complainant has registered various domain names incorporating its DUREX trademark, including: (registered October 11, 1995) (registered October 4, 2012) (registered November 12, 1997)
page 3 These domain names lead to Complainant’s official websites where DUREX products are advertised and sold. The disputed domain name was registered on June 15, 2022. The disputed domain name redirects to a Persian-language website that features the DUREX trademark and offers purported DUREX products alongside third-party goods such as massage oils. The website does not disclaim affiliation with Complainant and uses the DUREX figurative mark as a favicon. The disputed domain name contains MX records that would allow for active email use, and Respondent’s website contains the email address [….]@durexland.com, to which Complainant successfully sent email communications (as confirmed by delivery receipts). Upon discovering the disputed domain name, Complainant issued a cease-and-desist letter to Respondent on July 4, 2025, followed by reminders and abuse reports or cease and desist letters to the Registrar, reseller, and hosting provider. Respondent did not reply to the cease-and-desist communications, and none of the other entities addressed the issues identified in Complainant’s correspondence. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Complainant contends that the disputed domain name is confusingly similar to its registered trademark, in that it incorporates the entirety of the DUREX mark with the addition of the generic term “land” and the “.com” generic Top-Level Domain (“gTLD”). Complainant further asserts that Respondent has no rights or legitimate interests in the disputed domain name. Complainant asserts that Respondent “is not a licensee, an authorized agent of Complainant or in any other way authorized to use the Complainant’s trademark DUREX”, is not commonly known by the disputed domain name, and has not made any bona fide or fair use of it. Instead, Complainant has presented evidence including screenshots indicating that Respondent has used the disputed domain name to sell purported products of Complainant as well as purported products of others, in a manner that misleads consumers into believing Respondent’s site is operated by or affiliated with Complainant. Complainant also argues that the presence of MX records and the use of the email address [….]@durexland.com further suggest commercial use and intent to impersonate. Complainant sent cease-and-desist letters or abuse reports to Respondent, the registrar, the reseller, and the hosting provider, none of whom addressed the issues identified in Complainant’s correspondence. Complainant argues that Respondent’s failure to reply to this correspondence constitutes “adoptive admission of the allegations.” Finally, Complainant contends that “misappropriation of a well-known trademark as a domain name by itself constitutes bad faith registration for the purposes of the Policy”, and that DUREX is a well-known trademark as has been recognized as such by prior UDRP decisions. Complainant argues that, given this recognition of the DUREX mark and the ways in which Respondent uses the mark in connection with Respondent’s website, it is inconceivable that Respondent was unaware of Complainant’s rights. Complainant notes that Respondent’s website “intentionally attempt[s] to attract Internet users seeking Complainant’s branded products to its own website for commercial gain, by creating a likelihood of confusion with Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of its website and the goods offered on said website”. Complainant also asserts that Respondent’s failure to reply to Complainant's cease and desist letter is further evidence of bad faith.
page 4 B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Pursuant to paragraph 15(a) of the Rules, a panel in UDRP proceedings “shall 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”. Under paragraph 4(a) of the Policy, Complainant must prove the following: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed 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 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. 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 Complainant’s DUREX 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 3.0, section 1.7. Although the addition of another term (here, “land”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The addition of the “.com” gTLD also does not avoid confusing similarity. The gTLD in a domain name “is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test.” WIPO Overview 3.0, section 1.11.1. Accordingly, 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 Respondent may demonstrate rights or legitimate interests in a disputed domain name. “Any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate [Respondent’s] rights or legitimate interests to the domain name[s] for purposes of paragraph 4(a)(ii): (i) before any notice to [Respondent] of the dispute, [Respondent’s] use of, or demonstrable preparations to use, the [disputed] domain name or a name corresponding to the [disputed] domain name in connection with a bona fide offering of goods or services; or
page 5 (ii) [Respondent] (as an individual, business, or other organization) [has] been commonly known by the [disputed] domain name, even if [Respondent has] acquired no trademark or service mark rights; or (iii) [Respondent is] making a legitimate noncommercial or fair use of the [disputed] domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue”. Policy, paragraph 4(c).” Although the overall burden of proof in UDRP proceedings is on 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 Respondent. As such, where a complainant makes out a prima facie case that Respondent lacks rights or legitimate interests, the burden of production on this element shifts to Respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on Complainant). If Respondent fails to come forward with such relevant evidence, 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 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. There is no evidence that Respondent has used or prepared to use the disputed domain name in connection with a bona fide offering or goods or services or has been commonly known by the disputed domain name, or is making a legitimate noncommercial or fair use of the disputed domain name. The only evidence of Respondent’s use of the disputed domain name is its redirection to a Persian-language website that displays Complainant’s DUREX trademarks and offers purported DUREX products for sale alongside third-party goods. The website does not disclaim affiliation with Complainant and uses Complainant’s figurative mark as a favicon – reinforcing the false impression of association with Complainant. Such use does not constitute a bona fide offering of goods or services or legitimate noncommercial or fair use. See WIPO Overview 3.0, section 2.5 (“a respondent’s use of a domain name will not be considered ‘fair’ if it falsely suggests affiliation with the trademark owner”) and section 2.8.1 (“the respondent must use the site to sell only the trademarked goods or services”); see also Moncler S.R.L. v. World Top Sale Inc / WTS, WIPO Case No. D2012-2537 (“the content of the Respondent’s websites appears designed to reinforce the Internet user’s impression that the Domain Names belong to the Complainant. The websites are presented as if they are official websites of the Complainant. ‘Use which intentionally trades on the fame of another cannot constitute a bona fide offering of goods or services’”). Moreover, in the circumstances of this case, the lack of any authorization for Respondent to use Complainant’s trademark, and Respondent’s failure to respond to Complainant’s cease-and-desist communications, further supports the absence of rights or legitimate interests. See LEGO Holding A/S v. TAN VAN LE, Legotalk, WIPO Case No. D2025-2877 (finding a lack of rights or legitimate interests where, among other things, “the Complainant has demonstrated that it has not granted the Respondent any license, authorization or permission to use the LEGO trademark in the disputed domain name, [n]or is the Complainant otherwise affiliated with the Respondent”); Fenix International Limited c/o Walters Law Group v. Jason Salinas, Jason Shop, WIPO Case No. D2021-2075 (“Respondent’s failure to file a Response, and its failure to respond to Complainant’s cease-and-desist letter, permit the Panel to make an inference that Respondent has no rights or legitimate interests in the Disputed Domain Name.”). Accordingly, the Panel finds the second element of the Policy has been established.
page 6 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. Specifically, “the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith: (i) circumstances indicating that [Respondent has] registered or [Respondent has] acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of [Respondent’s] documented out-of-pocket costs directly related to the domain name; or (ii) [Respondent has] registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that [Respondent has] engaged in a pattern of such conduct; or (iii) [Respondent has] registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, [Respondent has] intentionally attempted to attract, for commercial gain, Internet users to [Respondent’s] 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 [Respondent’s] website or location or of a product or service on [Respondent’s] website or location.” Policy, paragraph 4(b). “Given that the scenarios described in UDRP paragraph 4(b) are non-exclusive and merely illustrative, even where a complainant may not be able to demonstrate the literal or verbatim application of one of the above scenarios, evidence demonstrating that a respondent seeks to take unfair advantage of, abuse, or otherwise engage in behavior detrimental to the complainant’s trademark would also satisfy complainant’s burden.” WIPO Overview 3.0, section 3.1. In the present case, the Panel notes the extensive use of the Complainant’s DUREX trademark for nearly a century before Respondent registered the disputed domain name, and Respondent’s use of the disputed domain name for a website that purports to sell Complainant’s products (among other products). These facts indicate Respondent was aware of the Complainant’s trademark at the time of registration, and intentionally registered and is using the disputed domain name to “intentionally attempt[] to attract, for commercial gain, Internet users to [Respondent’s] 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 [Respondent’s] website”. Such activity is indicative of bad faith under paragraph 4(b) of the Policy. See WIPO Overview 3.0, section 3.1.4; Swarovski Aktiengesellschaft v. Jun Qiao, WIPO Case No. D2013-1617 (finding bad faith where “SWAROVSKI is a well-known trademark in relation to jewelry and related goods. It is, as the Complainant submits, inconceivable that the Respondent was not aware of the Complainant’s mark and its reputation in the field of jewelry at the time of registration. The mark is distinctive and has no inherent or generic meaning in the present context. Further, the fact that purported Swarovski goods were offered at the relevant website indicates that the Respondent was fully aware of the Swarovski mark’s distinct reputation and association with the Complainant. There is no reason to choose such a distinctive mark, and also to include other terms in a domain name that are suggestive of the very business of the Complainant, other than a bad faith attempt to ride on the coattails of the trademark owner.”). Respondent’s failure to respond to cease-and-desist communications and its continued use of the disputed domain name despite repeated warnings reinforce the conclusion that the disputed domain name was registered and is being used in bad faith. See Fenix International Limited c/o Walters Law Group v. Jason Salinas, Jason Shop, supra (“Respondent failed to answer the Complaint and failed to respond to a cease-and-desist letter from Complainant. From these circumstances the Panel may therefore draw an inference that Respondent was aware of Complainant’s
page 7 Marks and website and chose the Disputed Domain Name in an effort to capitalize on its confusing similarity to the Marks and the reputation of Complainant’s Marks. Therefore, the Panel finds that Respondent has registered and is using the Disputed Domain Name in bad faith.”). Accordingly, the Panel finds that 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 be transferred to Complainant. /Bradley A. Slutsky/ Bradley A. Slutsky Sole Panelist Date: October 9, 2025
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