As Beauty Group, LLC v Jason Lee, Gale Florella, Datha Georgeta, Bari

WIPO Case No. D2025-2592

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

AS Beauty Group, LLC v. Jason Lee, Gale Florella, Datha Georgeta, Bari
Mariejeanne, Deni Melina, Kandy Sarita

Case No. D2025-2592

1. The Parties

The Complainant is AS Beauty Group, LLC, United States of America, represented by Dorsey & Whitney,

LLP, United States of America.

The Respondents are Jason Lee, China, Gale Florella, United States of America, Datha Georgeta, United

States of America, Bari Mariejeanne, Australia, Deni Melina, Canada and Kandy Sarita, Canada.

2. The Domain Names and Registrar

The Disputed Domain Names <lauragelleri.com>, <lauragellerpack.shop>, <laurergellerdeals.shop>, <laurragellerf lash.shop>, <laurragellerkit.shop>, <laurragellermagic.shop>, <laurragelleroutlet.shop>, <laurragellerplus.shop>, <laurragellervip.shop>, <laurragellerx.shop>, <laurrgellerbest.shop>,

<laurrgellerclear.shop>, <laurrgellerselect.shop>, <laurrgellershop.shop> and <laurrgellerzone.shop> (the

“Disputed Domain Names”) are registered with Dynadot Inc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 1, 2025. On July 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Names. On July 7, 2025, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the Disputed Domain Names which dif fered from the named Respondent (Super Privacy Service LTD c/o Dynadot) and contact information in the Complaint.

The Center sent an email communication to the Complainant on July 7, 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 Disputed Domain Names associated with dif ferent 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 July 10, 2025.

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The Center verif ied that the Complaint together with the amended Complaint satisf ied 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 notif ied the Respondents of the Complaint, and the proceedings commenced on July 11, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 31, 2025. The Respondents did not submit any response. Accordingly, the Center notif ied the Respondent’s default on August 6, 2025.

The Center appointed Gabriela Kennedy as the sole panelist in this matter on August 11, 2025. The Panel f inds 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 specializes in makeup, cosmetics and beauty care products, such as baked foundations, baked bronzers, and serum-based blushes.

The Complainant owns various word and figurative trademarks for the LAURA GELLER mark. The relevant trademark registrations include, inter alia, the United States Trademark Registration No. 3527188 for LAURA GELLER in Class 3 registered on November 4, 2008, the United States Trademark Registration No. 4787513 for in Class 3 registered on August 4, 2015, and the United States Trademark Registration No.

4787516 for in Class 3 registered on August 4, 2015 (the “Complainant’s Trademark”).

The Complainant also owns the domain names <laurageller.com> and <lauragellerbeauty.com> which fully incorporate the Complainant’s Trademark.

All of the Disputed Domain Names were registered on June 11, 2025, except one which was registered on June 12, 2025, many years after the Complainant registered the Complainant’s Trademark. According to the Complainant, at the time of f iling of the Complaint:

- the Disputed Domain Names <laurrgellerclear.shop>, <laurrgellerzone.shop>, <lauragelleri.com>,

<laurergellerdeals.shop>, and <laurragelleroutlet.shop> resolved to websites which purport to be the

<laurragellerplus.shop>, <laurragellerf lash.shop>, <laurragellervip.shop>, <laurrgellershop.shop>, various references to the LAURA GELLER mark and replicate the Complainant’s product photos, marketing text and overall layout of the Complainant’s website to pose as the Complainant’s retail storef ront;

- the Disputed Domain Names <laurragellerx.shop>, <laurrgellerselect.shop>, <lauragellerpack.shop>, <laurragellermagic.shop>, and <laurragellerkit.shop> resolved to websites which featured the Complainant’s Trademark, provided information about the Complainant and its brand, and included disclaimer language stating that the websites were “not af f iliated with Laura Geller Beauty Inc.” and that they '“do not sell any products” and “all content is for informational and educational purposes only”. These websites also directed users to the Complainant’s website at <laurageller.com> for of f icial purchases;

-

the Disputed Domain Name <laurrgellerbest.shop> resolved to a landing page with no discernable

information.

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At the time of the rendering of this Decision:

- the Disputed Domain Name <lauragelleri.com> resolved to an active website which displayed the Complainant's Trademark, offered to sell cosmetic and beauty products similar to that of the Complainant's, and referred to itself as a website named “Laurageller.com” that is owned by “AS Beauty LLC”.

- each of the Disputed Domain Names <lauragellerpack.shop>, <laurragellerf lash.shop>,
<laurragellerkit.shop>, <laurragellermagic.shop>, <laurragelleroutlet.shop>, <laurragellerplus.shop>,
<laurragellervip.shop>, <laurragellerx.shop>, <laurrgellerclear.shop>, <laurrgellerselect.shop>, and
<laurrgellershop.shop> resolved to an inactive website with a message “connection timed out” or “invalid

SSL certif icate”.

- each of the Disputed Domain Names <laurergellerdeals.shop>, <laurrgellerbest.shop>, and

<laurrgellerzone.shop> resolved to an inactive website displaying the message “website not found”.

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 Names.

Notably, the Complainant contends that:

(a) The Disputed Domain Names are confusingly similar to the Complainant’s Trademark. The Disputed Domain Names incorporate the Complainant’s Trademark in its entirety. Each of the Disputed Domain Names is merely misspellings of the Complainant’s Trademark or contains additional descriptive words such as “vip” or “outlet” etc. Such misspellings do not negate a finding of confusing similarity. The addition of the generic top-level domain (“gTLD”), such as “.com” and “.shop”, should be disregarded when determining whether a Disputed Domain Name is confusingly similar to the Complainant’s Trademark.

(b) The Respondents have no rights or legitimate interests in the Disputed Domain Names. The

Respondents are unaf f iliated with the Complainant, and they are not a licensee or subsidiary of the Complainant. The Respondents have never been authorized to use the Complainant’s Trademark. The Respondents have no reason to use the Complainant’s Trademark in its domain name except to create the impression of an association with, or to trade off the goodwill of, the Complainant for its own gain. Some of the Disputed Domain Names resolve to websites that impersonate the Complainant and of fer the Complainant’s products for sale at highly discounted prices. It is likely that the Respondents are either selling counterfeit goods, or collecting payment without delivering the actual products, all while f raudulently presenting themselves as the Complainant. Some other Disputed Domain Names resolve to websites which feature the Complainant’s Trademark and provide information about the Complainant and its brand, with a disclaimer language at the top of the webpage indicating that the websites are “not af f iliated with Laura Geller Beauty Inc.” and direct users to go to the Complainant’s website for purchase of legitimate products. Such use of the Disputed Domain Names should not be regarded as evidence of rights or legitimate interests of the Respondents and should not constitute legitimate use of the Disputed Domain Names.

(c) The Respondents have registered the Disputed Domain Names and are using them in bad faith. Given the well-known nature of the Complainant’s Trademark, the Respondents must have been fully aware of the existence of the Complainant’s Trademark when the Respondents registered and used the Disputed Domain Names. The websites to which twelve of the Disputed Domain Names resolve feature the

Complainant’s Trademark repeatedly, suggesting that the Respondents likely had actual knowledge of the the public. It is inconceivable that the Respondents registered f if teen domain names containing the
Complainant’s rights. The Respondents use the Disputed Domain Names to falsely impersonate the

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Complainant’s Trademark without the intent of capitalizing on the Complainant's goodwill in the

Complainant’s Trademark.

B. Respondent

The Respondents did not reply to the Complainant’s contentions.

6. Discussion and Findings

Consolidation: Multiple Respondents

The amended Complaint was f iled in relation to nominally dif ferent 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 Complainant requests the consolidation of the Complaint against the multiple

Disputed Domain Name registrants pursuant to paragraph 10(e) of the Rules.

The Disputed Domain Name registrants did not comment on the Complainant’s request.

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 Disputed Domain Names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2.

As regards common control, the Panel notes that:

(i)        The Disputed Domain Names were registered around the same time with the same Registrar.

<laurragellerx.shop>, <laurrgellerselect.shop>, <lauragellerpack.shop>, <laurragellermagic.shop>,
<laurragellerkit.shop>, <laurrgellerclear.shop>, <laurrgellerzone.shop>, <laurragellerplus.shop>,
<laurragellerf lash.shop>, <laurragellervip.shop>, <laurragelleroutlet.shop>, <laurrgellershop.shop>,
<laurrgellerbest.shop>, <laurergellerdeals.shop> were registered on June 11, 2025 while <lauragelleri.com>
was registered on June 12, 2025.

(ii) The Panel notes the interrelated use and the overlapping or coordinated registration patterns among these Disputed Domain Names. Based on the screenshots provided by the Complainant, groups of the Disputed Domain Names, despite being registered to different individuals according to the WhoIs records, resolved to identical or nearly identical webpages which displayed highly similar content and layouts. For example, the Disputed Domain Names <laurrgellerclear.shop>, <laurrgellerzone.shop>, <lauragelleri.com>, <laurragellerplus.shop>, <laurragellerf lash.shop>, <laurragellervip.shop>, <laurrgellershop.shop>,

<laurergellerdeals.shop>, and <laurragelleroutlet.shop> were registered to four different named individuals, nonetheless all resolved to webpages that are either identical or substantially similar. Likewise, the Disputed Domain Names <laurragellerx.shop>, <laurrgellerselect.shop>, <lauragellerpack.shop>,
<laurragellermagic.shop>, and <laurragellerkit.shop> were registered to three different named individuals but
also resolve to identical or substantially similar webpages. Furthermore, the remaining
<laurrgellerbest.shop> (which resolved to an inactive page with no discernable information) was registered
by “Deni Melina” who also owns other two Disputed Domain Names discussed above.

(iii) Apart f rom <lauragelleri.com>, all other Disputed Domain Names were registered with registrant's email addresses that follow similar naming conventions, each comprising the purported registrant’s last name followed by a sequence of random letters and numbers, and each utilizes the “@gmail.com” domain.

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As regards fairness and equity, the Panel notes that the consolidation will serve the interests of procedural ef f iciency and consistency, and sees no reason why consolidation of the disputes would be unfair or inequitable to any Party.

Accordingly, the Panel decides to consolidate the disputes regarding the nominally dif ferent Disputed

Domain Name registrants (referred to below as “the Respondent”) in a single proceeding.

A. Identical or Confusingly Similar

It is well accepted that the f irst 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.

For each of the following Disputed Domain Names: <laurergellerdeals.shop>, <laurragellerf lash.shop>,
<laurragellerkit.shop>, <laurragellermagic.shop>, <laurragelleroutlet.shop>, <laurragellerplus.shop>,
<laurragellervip.shop>, <laurragellerx.shop>, <laurrgellerbest.shop>, <laurrgellerclear.shop>,
<laurrgellerselect.shop>, <laurrgellershop.shop> and <laurrgellerzone.shop>, the Panel f inds the
Complainant's Trademark is recognizable within each of the Disputed Domain Names. Each of these
Disputed Domain Names incorporates the Complainant’s Trademark, save for the substitution of the term
“laura” with “laurer”, “laurra” or “laurr”. The intentional misspelling of the Complainant’s Trademark does not
alter the f inding of confusing similarity. WIPO Overview 3.0, section 1.9. Furthermore, it is well established
that the gTLD, “.shop” in this case, may be disregarded for the purposes of assessing confusing similarity
under the f irst element. See section 1.11.1 of the WIPO Overview 3.0. Accordingly, these Disputed Domain
Names are confusingly similar to the Complainant's Trademark for the purposes of the Policy. WIPO

Overview 3.0, section 1.7.

For each of <lauragelleri.com> and <lauragellerpack.shop>, the Panel notes that the Complainant’s case “.com” and “.shop” may be disregarded for the purposes of assessing confusing similarity under the first element. Accordingly, each of the above Disputed Domain Names is confusingly similar to the Complainant’s Trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

Although the addition of other terms, such as “i”, “pack”, “deals”, “flash”, “kit”, “magic”, “outlet”, “plus”, “vip”, “x”, “best”, “clear”, “select”, “shop” and “zone” in the present case, may bear on assessment of the second and third elements, in each case the Panel finds the addition of such terms does not prevent a f inding of confusing similarity between the Disputed Domain Names and the Complainant’s Trademark for the

purposes of the Policy. WIPO Overview 3.0, section 1.8.

The Panel f inds the f irst 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 of ten 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

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evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section
2.1.

The Panel notes that there is no evidence to show that the Respondent has trademark rights corresponding to the Disputed Domain Names, or that the Respondent has become commonly known by the Disputed Domain Names. The Panel further notes that the Complainant has provided no license or authorization of any kind to the Respondent to use the Complainant’s Trademark or to apply for or use any domain name incorporating the Complainant’s Trademark.

The Respondent used some of the websites (namely, <laurrgellerclear.shop>, <laurrgellerzone.shop>, <lauragelleri.com>, <laurragellerplus.shop>, <laurragellerf lash.shop>, <laurragellervip.shop>, <laurrgellershop.shop>, <laurergellerdeals.shop>, and <laurragelleroutlet.shop>) to impersonate or pass itself off as the Complainant by purportedly featuring the Complainant’s Trademark, using the Complainant's product photos and offering to sell cosmetic and beauty products similar to that of the Complainant, without the Complainant's authorization. The Respondent would likely not have adopted the Complainant’s Trademark if not for the purpose of creating an impression that these Disputed Domain Names are associated with, or originate f rom the Complainant. There is also no evidence to suggest that the Respondent’s use of the Disputed Domain Names is in connection with a bona f ide of fering of goods or services or be regarded as legitimate noncommercial or fair use. These websites attempt to divert business away f rom the Complainant while capitalizing on the goodwill associated with the Complainant’s Trademark. Panels have held that the use of a domain name for illegitimate activity, in this case claimed impersonation or passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1.

With regard to the other Disputed Domain Names (namely, <laurragellerx.shop>, <laurrgellerselect.shop>, <lauragellerpack.shop>, <laurragellermagic.shop>, and <laurragellerkit.shop>), the Panel observes that, based on the screenshots submitted by the Complainant, these websites may previously have featured genuine commentary on the Complainant’s products, including expert tips and product reviews, and

displayed a clear disclaimer of af f iliation. While such factors could, in principle, support a f inding of legitimate noncommercial or fair use, the near-identical layout and content across the webpages of these five Disputed Domain Names raises the possibility that the Respondent’s activities were a pretext for

cybersquatting or commercial gain. At the time of this Decision, however, all of these Disputed Domain ongoing bona fide use of the Disputed Domain Names, nor any demonstrable preparations to use them in connection with a bona fide offering of goods or services. Accordingly, the current passive holding of these Disputed Domain Names weighs against a f inding of rights or legitimate interests.

With regard to the Disputed Domain Name <laurrgellerbest.shop>, the Panel notes that it resolved to an inactive website both at the time of the filing of the Complaint and at the time of rendering of this Decision. There is also no evidence to show that any use of , or demonstrable preparations to use, this Disputed Domain Name in connection with a bona fide offering of goods or services, or that the Respondent is making a legitimate noncommercial or fair use of this Disputed Domain Name without intent for commercial gain, or that the Respondent has been commonly known by this Disputed Domain Name.

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 Names. 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 Names such as those

enumerated in the Policy or otherwise.

The Panel f inds the second element of the Policy has been established.

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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.

Panels have previously held that a finding of bad faith can be established where a complainant’s trademark is shown to be well known or in wide use at the time of registration of the disputed domain name (see LEGO Juris A/S v. store24hour, WIPO Case No. D2013-0091). The Respondent must have been aware of the Complainant and the Complainant’s Trademark when registering and using the Disputed Domain Names given the well-known nature of the Complainant’s Trademark in its industry and the fact that it was put into use well before the Respondent registered the Disputed Domain Names.

The Panel f inds the Respondent registered the Disputed Domain Names to attract Internet users to its website, for commercial gain, by creating a likelihood of confusion with the Complainant’s Trademark.

The Panel also notes that, at the time of rendering of this Decision, one of the Disputed Domain Names, <lauragelleri.com> resolved to an active website which displayed the Complainant's Trademark, of fered to sell cosmetic and beauty products similar to those of the Complainant, and referred to itself as a website named “laurageller.com” that is owned by “AS Beauty LLC”, a name that is very similar to the name of the Complainant “AS Beauty Group, LLC”. In the present case, the Panel notes that it is difficult to conceive of any plausible use of the Disputed Domain Name by the unaffiliated Respondent that would amount to good faith use, given that the Disputed Domain Name incorporates the Complainant’s Trademark in its entirety together with a letter “i”, and the website displays the Complainant’s Trademark, of fers to sell similar

cosmetic and beauty products, and referred to itself as an entity with a name very similar to that of the Complainant. The Respondent has registered and has been using this Disputed Domain Name to mislead and divert Internet users to its website for commercial gain by creating a likelihood of confusion with the Complainant’s Trademark as to the source, sponsorship, affiliation, or endorsement of its website. Panels have held that the use of a domain name for illegitimate activity, in this case claimed impersonation or passing of f , constitutes bad faith. WIPO Overview 3.0, section 3.4.

With respect to the other fourteen Disputed Domain Names (namely, <lauragellerpack.shop>,
<laurergellerdeals.shop>, <laurragellerf lash.shop>, <laurragellerkit.shop>, <laurragellermagic.shop>,
<laurragelleroutlet.shop>, <laurragellerplus.shop>, <laurragellervip.shop>, <laurragellerx.shop>,
<laurrgellerbest.shop>, <laurrgellerclear.shop>, <laurrgellerselect.shop>, <laurrgellershop.shop> and
<laurrgellerzone.shop>), the Panel notes that these Disputed Domain Names now resolve to inactive
websites. Panels have found that the non-use of a domain name would not prevent a f inding of bad faith
under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available
record, the Panel notes the reputation of the Complainant’s Trademark, the composition of the Disputed
Domain Names, and the Respondent’s failure to file a response, and finds that in the circumstances of this
case the passive holding of the Disputed Domain Names does not prevent a f inding of bad faith under the

Policy.

The Panel f inds that the Complainant has established the third element of the Policy.

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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 Names <lauragelleri.com>, <lauragellerpack.shop>,
<laurergellerdeals.shop>, <laurragellerf lash.shop>, <laurragellerkit.shop>, <laurragellermagic.shop>,
<laurragelleroutlet.shop>, <laurragellerplus.shop>, <laurragellervip.shop>, <laurragellerx.shop>,
<laurrgellerbest.shop>, <laurrgellerclear.shop>, <laurrgellerselect.shop>, <laurrgellershop.shop> and

<laurrgellerzone.shop> be transferred to the Complainant.

/Gabriela Kennedy/
Gabriela Kennedy
Sole Panelist
Date: August 26, 2025