ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Guangzhou Hete Technology Co., Ltd v. sen xiao Case No. D2025-4159 1. The Parties The Complainant is Guangzhou Hete Technology Co., Ltd, China, represented by Beijing TsingLaw Partners, China. The Respondent is sen xiao, China. 2. The Domain Name and Registrar The disputed domain name is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 10, 2025. On October 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 12, 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 (unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 15, 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 October 17, 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 the Respondent of the Complaint, and the proceedings commenced on October 27, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 16, 2025. The Respondent did not submit any formal response. The Center received email communications from the Respondent on October 28, October 29, October 30, November 1, November 5, November 6, and November 8, 2025. Accordingly, the Center
page 2 notified the commencement of panel appointment process on November 24, 2025. The Center received email communications from the Respondent on November 25, and November 27, 2025. 1 The Center appointed Hong Yang as the sole panelist in this matter on November 26, 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 Established in 2011 in Guangzhou, China, the Complainant markets women’s wig products under LUVME / LUVME HAIR brand, reaching consumers in China, the United States of America, Europe, and Africa through its independent official website (“www.luvmehair.com”) and social media. In 2021, the brand’s sales exceeded CNY one billion, and the sales volume of individual products exceeded 100,000 units in 2024. The brand was listed among the “Top 50 Chinese Brands Going Global” on Facebook / Google and was ranked third in the Instagram (“IG”) Influence Top 10 Chinese brands in 2023. The monthly visits to its independent official website have exceeded four million. The Complainant owns various trademarks containing the term LUVME / LUVME HAIR globally, including the following: China Trademark Registration No.14133418 for LUVME (word), registered on July 14, 2015; United States Registration No. 4982545 for LUVME HAIR (word), registered on June 21, 2016; and South Africa Trademark Registration No. 2015/30933 for LUVME HAIR (word), registered on December 19, 2017. The Complainant operates its official website located at the domain name , registered on March 8, 2014. The disputed domain name was registered on February 27, 2025, and the Respondent is reportedly resides in China. At the time of filling of the Complaint, the disputed domain name resolved to a website offering for sale women’s wigs, and the product prices were at extremely low discounts amounting to 95% off. Previously, the website under the disputed domain name prominently displayed the Complainant’s trademark, offered the Complainant’s purported products for sale, and showed without authorization a photograph almost identical to a designed photograph from the Complainant’s official website. Numerous consumers reportedly visited the Respondent’s website, misled into believing that they were buying products of the Complainant, and made complaints to the Complainant upon failure to receive the delivery. 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. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. The Center received numerous emails from what appeared to be automated customer service chatbot messages requesting order information and offering product assistance, without addressing the domain name dispute. 1 The email communications were sent from an email address which was displayed on the website to which the disputed domain name resolved. The Panel finds that it is appropriate to treat these email communications as the Respondent’s email communications under the circumstances of this case.
page 3 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. 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 Panel finds 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. Although the addition of other terms here, “s”, “shop” and the hyphen “-”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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. The Panel notes that the composition of the disputed domain name itself affirms the Respondent’s intention of taking unfair advantage of the likelihood of confusion between the disputed domain name and the Complainant as to the origin or affiliation, incorporating the Complainant’s mark in full and merely adding a letter of “s”, a hyphen and a term of “shop”, which closely relates to the Complainant’s field of business. Further, the available record shows that the Respondent is not affiliated or otherwise authorized by the Complainant or held any registration of the LUVME HAIR mark anywhere. There is no evidence indicating that the Respondent is commonly known by the disputed domain name. The disputed domain name resolved to a website offering for sale women’s wigs, which are the same as or similar to the products from the Complainant. Previously, the website under the disputed domain name, prominently displayed the Complainant’s trademark, claimed to be “Official” in the browser tab, offered the
page 4 Complainant’s purported products for sale, and used without authorization a copyrightable photograph from the Complainant. Reportedly, consumers were misled into believing they were buying products from the Complainant. The overall circumstances indicate the Respondent’s attempt to impersonate the Complainant. The Panel is convinced that the Respondent has attempted to gain unfair revenues from targeting the Complainant and creating a likelihood of confusion. Such use cannot constitute any bona fide offering of goods or services nor a legitimate noncommercial or fair use of the disputed domain name. Furthermore, panels have held that the use of a domain name for illegal activity, here claimed impersonation, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. 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. In the present case, the Panel notes that the Respondent has used without any license or authorization the Complainant’s trademark in full in the disputed domain name plus a related term with a hyphen and a letter with no special meaning. The Complainant’s trademark LUVME HAIR is widely used in multiple jurisdictions, including the location where the Respondent resides, and the Complainant’s registration and use of its marks predate the Respondent’s registration of the disputed domain name. Moreover, the disputed domain name is confusingly similar to the Complainant’s domain name . This signals the Respondent’s intention to target the Complainant and trade off its distinctive mark. Thus, the Panel considers that the Respondent knew or should have known the Complainant’s mark at the time of registering the disputed domain name. Further, the Complainant has provided several different uses of the disputed domain name analyzed in Section 6.B above, in particular, the impersonation of the Complainant, the Panel finds that the Respondent intentionally attempted to attract, for commercial gain, Internet users to its websites, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s websites. The disputed domain name was thus registered and used in bad faith, according to paragraph 4(b)(iv) of the Policy. The Panel finds that the 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 the Complainant. /Hong Yang/ Hong Yang Sole Panelist Date: December 5, 2025
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