ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Meadow Stream Distributing L.L.C. DBA Pro Trucking Products v. Ibragim Shakhzadov, Pro Trucking Products Case No. D2025-3946 1. The Parties The Complainant is Meadow Stream Distributing L.L.C. DBA Pro Trucking Products, United States of America (“United States”), represented by Goodhue, Coleman & Owens, P.C., United States. The Respondent is Ibragim Shakhzadov, Pro Trucking Products, United States. 2. The Domain Name and Registrar The disputed domain name
is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 26, 2025. On September 29, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On September 29, 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 (Registration Private, Domains By Proxy, LLC / Pro Trucking Products) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 30, 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 amended Complaints on October 2 and 7, 2025. The Center verified that the Complaint together with 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 October 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 28, 2025. The Respondent sent email communications to the
page 2 Center on October 12 and 29, 2025. Accordingly, the Center notified the Parties of commencement of panel appointment process on October 29, 2025. The Center appointed Evan D. Brown as the sole panelist in this matter on October 31, 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 selling parts and accessories for commercial trucks and trailers throughout the United States. It owns the trademark PTP PRO TRUCKING PRODUCTS (stylized), for which it enjoys the benefits of registration (United States Reg. No. 4,196,787, registered on August 28, 2012). The Complainant also claims common law rights in the mark PRO TRUCKING PRODUCTS, based on continuous commercial use since at least December 10, 2010. The Complainant also owns the domain name , registered on February 24, 2009, and used for the Complainant’s commercial website since at least January 22, 2011. According to the WhoIs records, the disputed domain name was registered on March 29, 2023. The Respondent has used the disputed domain name to operate a commercial website that offers truck and trailer parts identical or highly similar to those offered by the Complainant; uses the Complainant’s mark PRO TRUCKING PRODUCTS in its website header; mimics the Complainant’s visual presentation, including product categories and branding colors; and diverts Internet traffic away from the Complainant’s legitimate website, creating confusion as to affiliation. The Complainant has put forward evidence that the Registrar-confirmed disputed domain name registrant phone number is associated with the company ISN Transportation Inc. Moreover, the Complainant provided evidence that ISN Transportation Inc., using the same email as the Registrar-confirmed disputed domain name registrant email, submitted a trademark application in 2023 for the word mark “Pro Trucking Products”, which has been abandoned because the applicant failed to respond or filed a late response to an Office Action. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain name is identical or confusingly similar to the Complainant’s trademark; that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and that the disputed domain name was registered and is being used in bad faith. B. Respondent The Respondent did not substantively respond to the Complainant’s contentions but it did send two brief emails to the Center, first denying any confusing similarity on the ground that the disputed domain name differs from the Complainant’s mark by the omission of the letter “s”; and later, stating that it had changed its domain name. 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 name is 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
page 3 respect of the disputed domain name, and (iii) the disputed domain name has been registered and is being used in bad faith. The Panel finds that all three of these elements have been met in this case. A. Identical or Confusingly Similar This first element functions primarily as a standing requirement. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“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. This requires the Panel to consider two questions: first, whether the Complainant has rights in a relevant mark; and second, whether the disputed domain name is 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. However, the Panel notes that the Complainant expressly disclaimed exclusive rights in the phrase “PRO TRUCKING PRODUCTS” when it registered its mark with the United States Patent and Trademark Office. Under United States trademark practice, such a disclaimer indicates that the applicant does not claim exclusive rights in the disclaimed term standing alone. See Ideation Unlimited, Inc. v. Dan Myers, WIPO Case No. D2008-1441, citing J2 Global Communications, Inc. v. Ideas Plus, Inc., WIPO Case No. D2005-0792. Accordingly, to the extent the Complainant seeks to rely on the phrase “PRO TRUCKING PRODUCTS” as a mark in itself, the Panel does not rely on the federal registration as a basis for those rights. Instead, the Panel considers whether the Complainant has established common law rights in the PRO TRUCKING PRODUCTS mark. The Complainant asserts that it has used that mark continuously since at least December 10, 2010, in connection with its business of selling commercial truck and trailer parts. In support, the Complainant has submitted evidence showing use of the mark on its long-standing website; its social-media accounts on Facebook, Twitter/X, Instagram, and YouTube; and its Amazon brand page, which identifies “Pro Trucking Products” as an approved brand. This evidence demonstrates to the Panel’s satisfaction that the Complainant has used the PRO TRUCKING PRODUCTS mark prominently, consistently, and over a sustained period of time in commerce. The Panel is satisfied that the Complainant has established common law rights in the mark through acquired distinctiveness. See WIPO Overview 3.0, section 1.3. The disputed domain name essentially incorporates the PRO TRUCKING PRODUCTS mark in its entirety, differing only by the omission of the final “s.” This trivial variation does not avoid a finding of confusing similarity. The Complainant’s mark remains recognizable in the disputed domain name. For these reasons, the Panel finds that the Complainant has established this first element under the Policy. B. 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 name. 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 Complainant has not granted any authorization to the Respondent to register a domain name containing its trademark or otherwise make use of its mark, (2) the Respondent is not commonly known by the name “Pro Trucking Products,” but rather appears to be known as ISN Transportation Inc., and (3) the Respondent has used the disputed domain name to imitate the Complainant’s marks and product offerings in a manner that misleads consumers. The Panel also notes the misleading composition of the disputed domain name that is nearly identical to the Complainant’s prior registered trademark and domain name but missing a final “s” that is not missing in the
page 4 provided registrant organization or website resolving from the disputed domain name (noting also that the plural “products” is the more natural term from which to sell goods). In these circumstances, the composition suggests the disputed domain name was intended to play on the reputation of the Complainant’s trademark. Moreover, the Respondent (or its related entity) was unable to register a trademark for “Pro Trucking Products”, and there is nothing in the record to suggest the Respondent has any trademark rights in a mark corresponding to the disputed domain name. Lastly, upon receiving notice of the present dispute the Respondent did not put forward any claims of bona fide or fair use, but rather indicated that it had changed its domain name. Accordingly, the Panel infers that the Respondent no longer has an interest in the disputed domain name and is unable to put forward evidence of any rights or legitimate interests in it. Accordingly, the Panel finds that the Complainant has made the required prima facie showing. The Respondent has not presented any evidence or argument that overcomes this prima facie showing. And nothing in the record otherwise tilts the balance in the Respondent’s favor. Accordingly, the Panel finds that the Complainant has established this second element under the Policy. C. Registered and Used in Bad Faith Given the Complainant’s longstanding use of its registered and common law marks in the same area of activity as the Respondent, and also noting the composition of the disputed domain name, the Panel finds it more likely than not that the Respondent registered the disputed domain name with the Complainant and its marks in mind and did so to take advantage of the Complainant’s established reputation. The Respondent had not disputed the Complainant’s claims of such knowledge and targeting. The Respondent has used the disputed domain name to operate a website offering directly competing products, using the mark of the Complainant, namely, PRO TRUCKING PRODUCTS. The Respondent’s use appears to be designed to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the site. These facts demonstrate to the Panel, for purposes of the Policy, that the Respondent registered and is using the disputed domain name in bad faith. Accordingly, 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 name be transferred to the Complainant. /Evan D. Brown/ Evan D. Brown Sole Panelist Date: November 14, 2025
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