ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LPL Financial LLC v. Navy Sheree, Stacie Dusty, Miracle Gay, Malvina Lorelai Case No. D2025-3897 1. The Parties The Complainant is LPL Financial LLC, United States of America (“United States”), represented by Hogan Lovells (Paris) LLP, France. The Respondents are Navy Sheree, Uruguay, Stacie Dusty, United States, Miracle Gay, Saudi Arabia, and Malvina Lorelai, Albania. 2. The Domain Names and Registrar The disputed domain names , , , and (collectively referred to as the “Domain Names”) are registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 24, 2025. On September 25, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On September 25, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Names 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 October 1, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the 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 October 6, 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”).
page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on October 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 29, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on October 31, 2025. The Center appointed Piotr Nowaczyk as the sole panelist in this matter on November 6, 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 financial services company and an independent broker-dealer. Founded in 1989, it provides brokerage and investment advisory services, technology, research, clearing, compliance, and practice-management support to financial advisors and institutions. The Complainant provides a platform of brokerage and investment advisory services to more than 28,000 investment advisors, managing over USD 1.7 trillion in advisory and brokerage assets. The Complainant employs more than 7,700 people and operates from several major offices across the United States. In the fourth quarter of 2024, its gross profit exceeded USD 1.2 billion, with a net income of USD 255 million. The Complainant is the owner of numerous LPL and LPL FINANCIAL trademark registrations, including: - the United Kingdom Trade Mark Registration for LPL (word) No. UK00003753607, registered on May 13, 2022; - the European Union Trade Mark Registration for LPL (word) No. 018653022, registered on May 26, 2022; and - the European Union Trade Mark Registration for LPL FINANCIAL (figurative) No. 018653024, registered on November 11, 2022. The Complainant also owns the domain name , which incorporates its LPL trademark and serves as its official website. The Domain Names were registered on July 31, 2025. At the time the Complaint was filed, the disputed domain names and did not resolve to any active websites. In contrast, the disputed domain name resolved to a website branded “LPL Finance,” which presented itself as an online trading platform offering a web-based trader, account plans, and services in global financial markets, and featured a “Start Trading” button that redirected to a login page requiring an email and password. The disputed domain name likewise resolved to a webpage displaying a login window labeled “LPL Finance,” with fields for an email and password. As of the date of this Decision, the Domain Names resolve to the same websites as they did at the time of filing the Complaint. 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 Domain Names.
page 3 First, the Complainant contends that the Domain Names are confusingly similar to the trademark in which the Complainant has rights. Second, the Complainant argues that the Respondent has neither rights nor legitimate interests in the Domain Names. Third, the Complainant submits that the Domain Names were registered and are being used in bad faith. B. Respondent The Respondents did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1. Preliminary Issue - Consolidation of Multiple Respondents The amended Complaint was filed in relation to nominally different Domain Name registrants. The Complainant alleges that the Domain Name registrants are the same entity or mere alter egos of each other, or under common control. The Domain Name registrants did not comment on the Complainant’s request for consolidation. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing the Complainant’s request, the Panel will consider whether (i) the Domain Names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See section 4.11.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). As regards common control, the Panel notes the following. First, the Domain Names were registered on the same day, namely July 31, 2025. Second, all of the Domain Names follow similar naming patterns, as each consists of the Complainant’s LPL trademark combined with an additional term and either the “.com” or “.net” generic Top-Level Domain (“gTLD”). Third, all of the Domain Names were registered with the same Registrar. Fourth, all of the Domain Names were registered using the same proxy service. Fifth, the Domain Names have been used in a similar manner. As indicated above, the disputed domain names and do not resolve to any active websites. In contrast, the disputed domain name resolves to a website branded “LPL Finance,” which presented itself as an online trading platform featuring a “Start Trading” button that redirected to a login page. The disputed domain name likewise resolved to a webpage displaying a login window labeled “LPL Finance”. Thus, all the Domain Names are employed in a manner connected to the Complainant’s LPL trademark, either by being left inactive or by directing users to websites branded “LPL Finance.” Lastly, the Respondents have not denied that the Domain Names are under a common control. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party.
page 4 Accordingly, the Panel decides to consolidate the disputes regarding the nominally different Domain Name registrants (referred to below as “the Respondent”) in a single proceeding. 6.2. Substantive Issue - Three Elements Paragraph 4(a) of the Policy places a burden on the Complainant to prove the presence of three separate elements, which can be summarized as follows: (i) the 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 the Domain Names; and (iii) the Domain Names have been registered and are being used in bad faith. The requested remedy may only be granted if the above criteria are met. At the outset, the Panel notes that the applicable standard of proof in UDRP cases is the “balance of probabilities” or “preponderance of the evidence”. See section 4.2 of the WIPO Overview 3.0. A. Identical or Confusingly Similar Under the first element, the Complainant must establish that the Domain Names are identical or confusingly similar to the trademark in which the Complainant has rights. The Complainant holds valid registrations for the LPL trademark. The Domain Names incorporate this trademark in its entirety. As numerous UDRP panels have held, incorporating a trademark in its entirety is sufficient to establish that a domain name is identical or confusingly similar to that trademark (see PepsiCo, Inc. v. PEPSI, SRL (a/k/a P.E.P.S.I.) and EMS COMPUTER INDUSTRY (a/k/a EMS), WIPO Case No. D2003-0696). The addition of the terms “finadvisor”, “-finex”, “-finex”, and “fintech” in the Domain Names does not prevent a finding of confusing similarity between the Domain Names and the LPL trademark. Panels have consistently held that where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. See section 1.8 of the WIPO Overview 3.0. The gTLDs “.com” and “.net” in the Domain Names are viewed as a standard registration requirement and as such are typically disregarded under the first element test. See section 1.11.1 of the WIPO Overview 3.0. Given the above, the Panel finds that the Domain Names are confusingly similar to the Complainant’s LPL trademark for purposes of the Policy. In sum, the Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Under the second element, the Complainant must prove that the Respondent has no rights or legitimate interests in the Domain Names. A right or legitimate interest in the Domain Names may be established, in accordance with paragraph 4(c) of the Policy, if the Panel finds any of the following circumstances: (i) that the Respondent has used or made preparations to use the Domain Names or a name corresponding to the Domain Names in connection with a bona fide offering of goods or services prior to the dispute; or
page 5 (ii) that the Respondent is commonly known by the Domain Names, even if the Respondent has not acquired any trademark rights; or (iii) that the Respondent is making a legitimate noncommercial or fair use of the Domain Names without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark. In the present case, the Complainant’s LPL trademark registrations predate the Respondent’s registration of the Domain Names. There is no evidence in the case record that the Complainant has licensed or otherwise permitted the Respondent to use the LPL trademark or to register the Domain Names incorporating this trademark. Moreover, it results from the evidence on record that the Respondent does not make use of the Domain Names in connection with a bona fide offering of goods or services, nor does it make a legitimate noncommercial or fair use of the Domain Names. Both at the time the Complaint was filed and as of the date of this Decision, the disputed domain names and did not resolve to any active websites. In contrast, the disputed domain name resolved to a website branded “LPL Finance,” which presented itself as an online trading platform and featured a “Start Trading” button that redirected users to a login page. The disputed domain name likewise resolved to a webpage displaying a login window labeled “LPL Finance”. The Panel considers that, based on the overall evidence in the case, the Respondent’s use of the Domain Names appears to form part of a fraudulent trading scheme designed to mislead Internet users into transferring funds under the pretense of a fictitious trading platform. Such use of the Domain Names cannot confer rights or legitimate interests on the Respondent. Given the above, there are no circumstances in evidence which could demonstrate, pursuant to paragraph 4(c) of the Policy, any rights or legitimate interests of the Respondent in respect of the Domain Names. Thus, there is no evidence in the case record that refutes the Complainant’s prima facie case. In sum, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Under the third element, the Complainant must prove that the Domain Names have been registered and are being used in bad faith. Bad faith under the UDRP is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark. See section 3.1 of the WIPO Overview 3.0. Under paragraph 4(b) of the Policy, evidence of bad faith registration and use includes, without limitation: (i) circumstances indicating the domain name was registered or acquired primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the owner of a trademark or to a competitor of the trademark owner, for valuable consideration in excess of the documented out-of-pocket costs directly related to the domain name; or (ii) circumstances indicating that the domain name was registered in order to prevent the owner of a trademark from reflecting the mark in a corresponding domain name, provided it is a pattern of such conduct; or (iii) circumstances indicating that the domain name was registered primarily for the purpose of disrupting the business of a competitor; or
page 6 (iv) circumstances indicating that the domain name has intentionally been used in an attempt to attract, for commercial gain, Internet users to a website or other online location, by creating a likelihood of confusion with a trademark as to the source, sponsorship, affiliation, or endorsement of the website or location or of a product or service on a website or location. As indicated above, the Complainant’s rights in the LPL trademark predate the registration of the Domain Names. This Panel finds that the Respondent was or should have been aware of the Complainant’s trademark at the time of registration. This finding is supported by the inclusion of the LPL trademark in the Domain Names, as well as their subsequent use for the websites displaying branding and functionality that mimic or reference the Complainant’s services. Moreover, it has been proven to the Panel’s satisfaction that the Complainant’s LPL trademark is well known and unique to the Complainant, at least within the financial services sector. Thus, the Respondent could not reasonably ignore the reputation of services under this trademark. In sum, the Respondent registered the Domain Names with the expectation of taking advantage of the reputation of the Complainant’s LPL trademark. Next, the Domain Names have been used by the Respondent in bad faith. As noted above, at the time of submitting the Complaint and as of the date of this Decision, the disputed domain names and were used by the Respondent to attract Internet users to the “LPL Finance”-branded websites purporting to offer online trading services and directing users to login pages requesting email and password information. There is thus little doubt that the Respondent intended to earn profit from the confusion created with Internet users. Consequently, the Panel finds that the Respondent registered and used these Domain Names deliberately in order to take advantage of the Complainant’s reputation and to give credibility to its operations. Moreover, as of the date of this Decision, as well as at the time of submitting the Complaint, two of the remaining Domain Names did not resolve to any active websites. Considering the overall circumstances of this case, the Panel finds that the Respondent’s passive holding of these Domain Names does not prevent a finding of bad faith. As numerous UDRP panels have held, passive holding, under the totality of circumstances of the case, would not prevent a finding of bad faith under the Policy. See section 3.3 of the WIPO Overview 3.0. In this case, given the well-known nature of the Complainant’s LPL trademark, the Respondent’s failure to submit a response, and the use to which the other Domain Names have been put (namely, to capitalize on the Complainant’s trademark), the Panel deems a bad-faith finding appropriate. Finally, the Respondent’s use of privacy services that concealed registrant information for the Domain Names further supports a finding of bad faith. For the reasons discussed above, 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 Domain Names , , , be transferred to the Complainant. /Piotr Nowaczyk/ Piotr Nowaczyk Sole Panelist Date: November 20, 2025
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