CWI, LLC v Domain Admin, TotalDomain Privacy Ltd

WIPO Case No. D2025-3328

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

CWI, LLC v. Domain Admin, TotalDomain Privacy Ltd

Case No. D2025-3328

1. The Parties

The Complainant is CWI, LLC, United States of America (“United States”), represented by Neal & McDevitt,

United States.

The Respondent is Domain Admin, TotalDomain Privacy Ltd, Panama.

2. The Domain Name and Registrar

The disputed domain name <campinworld.com> is registered with PDR Ltd. d/b/a

PublicDomainRegistry.com (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 19, 2025.
On August 19, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On August 20, 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 (Domain Admin, Privacy Protect LLC (PrivacyProtect.org)) and
contact information in the Complaint. The Center sent an email communication to the Complainant on
August 20, 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

August 25, 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 August 28, 2025. In accordance with the Rules, paragraph
5, the due date for Response was September 17, 2025. The Respondent did not submit any response.
Accordingly, the Center notified the Respondent’s default on September 18, 2025.

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The Center appointed Wilson Pinheiro Jabur as the sole panelist in this matter on September 23, 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 offers specialized products and accessories, expert advice and professional services to recreational vehicle owners and campers since 1966 under the Complainant’s CAMPING WORLD trademark, presently serving more than 4 million customers.

The Complainant is the owner of the domain name <campingworld.com>, where it operates its official website as well as of the following, amongst other, trademark registrations:

- United States Trademark Registration No. 930,179, for the word mark CAMPING WORLD, registered on February 29, 1972, subsequently renewed, in class 42;

- United States Trademark Registration No. 4,532,411, for the word and device mark CAMPING

WORLD, registered on May 20, 2014, subsequently renewed, in classes 35, 37, and 39;

- United States Trademark Registration No. 4,536,313, for the word mark CAMPING WORLD,

registered on May 27, 2014, subsequently renewed, in classes 35, 37, and 39; and

- United States Trademark Registration No. 4,536,315, for the word and device mark CAMPING

WORLD, registered on May 27, 2014, subsequently renewed, in classes 35, 37, and 39.

The disputed domain name was registered on April 24, 2001, and presently redirects Internet users to suspicious webpages. At the time of the filing of the procedure, the disputed domain name was used to host a parked webpage displaying “pay-per-click” (“PPC”) advertisements.

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.

Notably, the Complainant asserts to have been using the CAMPING WORLD trademark in the United States since at least 1968, which later become a renowned well-known and famous in connection with its goods and services.

Also, according to the Complainant, the disputed domain name is confusingly similar to the Complainant’s trademark, differing only by the exclusion of the letter “g” in the word “camping”, a minor variation that increases the likelihood of consumer confusion.

Furthermore, the Complainant asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name given that:

(i) there has never been any relationship between the Complainant and the Respondent that would give

rise to any license, sponsorship, permission or authorization for the Respondent to use or register the
disputed domain name;

(ii) the Complainant has not authorized the Respondent to use the CAMPING WORLD trademark or any confusingly similar marks, in a domain name, at any website, or for any other purpose;

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(iii)      the Respondent is not able to provide any evidence of legitimate noncommercial or fair use of the

disputed domain name;

(iv)      the Respondent is not able to provide any evidence of demonstrable preparation to use the disputed

domain name in connection with a bona fide offering of goods or services, being the Respondent’s use of the disputed domain name to display competitive ads, and to collect information or install malware in furtherance of fraudulent activity, not a bona fide offering of goods or services;

(v)       the Respondent’s registration of a confusingly similar domain to suggest a false affiliation with the

Complainant cannot be considered fair use of the disputed domain name; and

(vi)      the Respondent is not commonly known by the disputed domain name.

Moreover, the Complainant points out that the disputed domain name incorporates Complainant’s the CAMPING WORLD well-known trademark, which is uniquely associated with the Complainant, and its recreational vehicles and outdoor recreational goods and services, what per se constitutes bad faith under

for goods and services that directly compete with the Complainant’s offerings demonstrates an intentional
attempt to attract, for commercial gain, Internet users to the Respondent's website by creating a likelihood of
confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of the

the UDRP. Furthermore, the Respondent’s use of the disputed domain name to display PPC advertisements service so as to conceal the Respondent’s identity.

B. Respondent

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

6. Discussion and Findings

Paragraph 4(a) of the Policy sets forth the following three requirements which have to be met for this Panel to order the transfer of the disputed domain name to the Complainant:

(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and

(ii)	the Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii)	the disputed domain name has been registered and is being used in bad faith.

The Complainant must prove in this administrative proceeding that each of the aforesaid three elements is present in order to obtain the transfer of the disputed domain name.

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.

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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

1.9.

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 Respondent, in not formally responding to the Complaint, has failed to invoke any of the circumstances, which could demonstrate, pursuant to paragraph 4(c) of the Policy, any rights to or legitimate interests in the disputed domain name. This entitles the Panel to draw any such inferences from such default as it considers appropriate pursuant to paragraph 14(b) of the Rules. Nevertheless, the burden of proof is still on the

Complainant to make a prima facie case against the Respondent.

In that sense, and according to the evidence submitted, the Complainant has made a prima facie case against the Respondent that the Respondent has not been commonly known by the disputed domain name, and neither there is any relationship between the Complainant and the Respondent.

Also, the absence of any indication that the Respondent has rights in a term corresponding to the disputed domain name, or any possible link between the Respondent and the Complainant that could be inferred from the details known of the Respondent or the webpage relating to the disputed domain name, corroborate with the Panel’s finding of the absence of rights or legitimate interests.

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.

The registration and use of the disputed domain name in bad faith are further corroborated in the present case in view of the following circumstances:

i) the composition of the disputed domain name consisting of a clear typo of the Complainant’s well-known
trademark (as well as the Complainant’s primary domain name <campingworld.com>);

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ii) the Respondent has provided no evidence whatsoever of any actual or contemplated good faith use by it

of the disputed domain name;

iii) the past use of the disputed domain name in connection with PPC links and the present use of the

disputed domain name in connection with suspicious websites; and,

iv) the selection of a privacy protection service within a privacy protection service so as to conceal the

Respondent’s identity (WIPO Overview 3.0, section 4.4.6).

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 <campinworld.com> be transferred to the Complainant.

/Wilson Pinheiro Jabur/
Wilson Pinheiro Jabur
Sole Panelist
Date: October 7, 2025