ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Reggio Register Company, LLC v. Tammy P Bailey Case No. D2025-3879 1. The Parties Complainant is Reggio Register Company, LLC, United States of America (“United States”), represented by Butler Snow LLP, United States. Respondent is Tammy P Bailey, United States. 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 September 23, 2025. On September 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 24, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that 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 Complainant on September 25, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on September 29, 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 Respondent of the Complaint, and the proceedings commenced on September 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 20, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on October 22, 2025.
page 2 The Center appointed Jeffrey D. Steinhardt as sole panelist in this matter on October 30, 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 operates a business that for many years has created and distributed heating registers, grilles, and vents, largely through online commerce. Complainant owns United States Trademark Registration No. 1,528,096, REGGIO REGISTERS, registered March 7, 1989, in International Class 11 with a first use in commerce dating back to 1978. Complainant uses the domain name . The disputed domain name was registered on December 17, 2024, and resolves to a webpage displaying an online store that appears to offer apparel for sale. 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. Notably, Complainant contends that Respondent is using a confusingly disputed domain name that is nearly identical to Complainant’s long-established trademark for an online web shop offering goods unrelated to the goods to which the trademark refers. Complainant also alleges that Respondent’s use of the disputed domain name infringes Complainant’s intellectual property rights. Complainant avers that on July 2, 2025, Complainant’s legal counsel sent Respondent (via the Registrar) a cease and desist letter requesting transfer, to which no response was received. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings 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. 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 Panel finds that the mark is recognizable 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. The Panel finds that the first element of Policy paragraph 4(a) has been established.
page 3 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. Uncontroverted evidence submitted with the Complaint supports Complainant’s allegations that the confusingly similar disputed domain name is being used for an online store offering merchandise unrelated to the merchandise offered by Complainant under the trademark. The Panel accepts Complainant’s unopposed allegations that it has not authorized Respondent to use its trademarks and that Respondent is not commonly known by the disputed domain name. Having reviewed the available record, the Panel finds that 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. The Panel finds the second element of Policy paragraph 4(a) 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. The record shows that Respondent registered and uses a disputed domain name that is confusingly similar to Complainant’s trademark, which had been registered and in use for nearly 50 years. This strongly supports a finding of bad faith in the circumstances. The Panel agrees with Complainant that Respondent is intentionally attempting to attract, for commercial gain, Internet users by creating a likelihood of confusion with Complainant’s mark, as set forth in Policy paragraph 4(b)(iv) (examples of conduct supporting a finding of 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 also 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. The Panel also finds, under the circumstances, that Respondent’s failure to maintain accurate contact details in accordance with the registration agreement (e.g., the Complaint notification appears to have not been delivered to Respondent’s registrar-confirmed email address) and Respondent’s failure to respond to the Complaint are further evidence of bad faith. The third element of paragraph 4(a) of the Policy has been established.
page 4 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. /Jeffrey D. Steinhardt/ Jeffrey D. Steinhardt Sole Panelist Date: November 11, 2025
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