ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION NetJets Inc. v. John Deecon, TrafficDomains INC Case No. D2025-3524 1. The Parties The Complainant is NetJets Inc., United States of America, represented by Standley Law Group LLP, United States of America. The Respondent is John Deecon, TrafficDomains INC, Malaysia. 2. The Domain Name and Registrar The disputed domain name is registered with Mat Bao Corporation (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 29, 2025. On September 1, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 8, 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 (Domain Admin, Whoisprotection.cc) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 8, 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 September 11, 2025. The Center verified that 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 17, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 7, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 13, 2025.
page 2 The Center appointed Knud Wallberg as the sole panelist in this matter on October 23, 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, NetJets Inc., provides private jet aviation services around the world, including fractional aircraft ownership services, jet transportation services, aircraft charter services, and aircraft management services. The Complainant is the owner of trademark registrations for the NETJETS mark in many jurisdictions including: NETJETS, Malaysia Trademark Registration No. 2012009514, registered on January 19, 2018, for services in international class 36; NETJETS, Viet Nam Trademark Registration No. 217193, registered on December 26, 2013, for services in international classes 35, 36 and 39, and NETJETS, European Union Trademark Registration No. 010887404, registered on February 1, 2013, for services in international classes 12, 35, 36 and 39. The Complainant advertises its services on the website “www.netjets.com” and has done so for many years. The disputed domain name was registered on March 3, 2025, and resolves to a website on which it is stated that “This website has been reported for potential phishing”. 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 confusingly similar to the Complainant’s NETJETS mark within the meaning of paragraph 4(a)(i) of the Policy. The disputed domain name incorporates the Complainant’s mark in its entirety, with only a minor alteration: adding an additional letter “e” in “jets” to form “netjeets.” This minimal change does not avoid the finding of confusing similarity. Visually, the disputed domain name retains the same dominant element of the Complainant’s mark and only differs from Complainant’s mark by the addition of a duplicative vowel (“e”). Such minor spelling variations, referred to as “typosquatting,” have consistently been found insufficient to dispel confusing similarity under paragraph 4(a)(i) of the Policy (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.9). Phonetically, “netjets” and “netjeets” sound nearly identical. The difference between the short vowel in “jets” and the long vowel in “jeets” is subtle and easily overlooked in ordinary speech. Many consumers, particularly in oral communications or in rapid speech, would be unable to distinguish between the two. Conceptually, the disputed domain name evokes the same commercial impression as the Complainant’s mark. The term “jeets” has no independent meaning. The substantial similarity to “jets” leads Internet users to associate the disputed domain name with the Complainant’s brand, especially in contexts relating to aviation, travel, or related services. Furthermore, the Complainant contends that it has not authorized, licensed, or otherwise permitted Respondent to use its NETJETS trademark, nor to register any domain name incorporating that mark. There is no evidence that Respondent is commonly known by the name “netjeets” or by any similar name. The
page 3 disputed domain name is not being used in connection with a bona fide offering of goods or services. Rather, the disputed domain name has been and is being used in connection with a website that states “About NetJets” at the top, discusses the Complainant’s services, and makes repeated use of the Complainant’s mark – NETJETS. Given its near-identical similarity to the Complainant’s mark, and current use of the associated website, the Respondent’s use of the disputed domain name is calculated to mislead Internet users into believing that it is associated with, sponsored by, or endorsed by the Complainant, and such use does not constitute a legitimate noncommercial or fair use under the Policy. Accordingly, the Respondent has no rights or legitimate interests in the disputed domain name. Finally, the Complainant contends that the Respondent has registered and is using the disputed domain name domain name in bad faith under paragraph 4(a)(iii) of the Policy. The deliberate substitution of “jets” with the phonetically and visually similar “jeets” is a classic example of typo squatting, designed to take advantage of Internet users’ typographical errors or imperfect recollection of the Complainant’s mark. The Respondent has used the disputed domain name for a website, which appears to have been used to distribute malicious code. The website thus contains a warning stating that “This website has been reported for potential phishing.” The Respondent’s use of the Complainant’s mark to distribute malicious code to unsuspecting users is significant evidence of bad faith use of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions 6. Discussion and Findings According to paragraph 15(a) of the Rules the Panel shall decide the Complaint in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. Paragraph 4(a) of the Policy directs that a complainant must prove each of the following: (i) that the disputed 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) that the respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. Paragraph 4(a) of the Policy states that the burden of proving that all these elements are present lies with the Complainant. At the same time, in accordance with paragraph 14(b) of the Rules, if a party, in the absence of exceptional circumstances, does not comply with any provision of, or requirement under, the Rules, or any request from the Panel, the Panel shall draw such inferences therefrom as it considers appropriate. 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 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 disputed domain name is confusingly similar to the mark for the purposes of the Policy, since the disputed domain name “consists of a common, obvious, or intentional misspelling” of the trademark. WIPO Overview 3.0, sections 1.7 and 1.9.
page 4 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 absence of any explanation by the Respondent, the Panel finds that the misspelling of the Complainant’s trademark in the disputed domain name signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainant. 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 3.0, section 3.2.1. In the present case, the Panel notes that the Respondent has not offered any explanation for having registered a domain name that is quasi-identical to the Complainant’s distinctive trademark. Given the circumstances of the case, it is inconceivable to the Panel in the current circumstances that the Respondent registered the disputed domain name without prior knowledge of the Complainant and the Complainant’s mark. The Panel further notes that the named Respondent’s has previously been involved in similar proceedings under the UDRP. The Panel therefore finds that the disputed domain name was registered in bad faith. Panels have held that the use of a domain name for illegitimate activity here, claimed impersonation and phishing, constitutes bad faith. WIPO Overview 3.0, 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. Noting that the disputed domain name incorporates a well-known trademark, that the Respondent has failed to participate in these proceedings, that there appears to be no conceivable good faith use that could be made by the Respondent of the disputed domain name, and considering all the facts and evidence, the Panel finds that the requirements of paragraph 4(a)(iii) of the Policy are also fulfilled in this case.
page 5 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. /Knud Wallberg/ Knud Wallberg Sole Panelist Date: November 9, 2025
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