Eli Lilly and Company v Quan Zhongjun, Juanita Co

WIPO Case No. D2025-3359

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Eli Lilly and Company v. Quan Zhongjun, Juanita Co.

Case No. D2025-3359

1. The Parties

The Complainant is Eli Lilly and Company, United States of America (“United States”), represented by

Faegre Drinker Biddle & Reath LLP, United States.

The Respondent is Quan Zhongjun, Juanita Co., China.

2. The Domain Names and Registrar

The disputed domain names <sepbound.com>, <xepbound.com>, <zelbound.com>, <zepblund.com>,
<zepboound.com>, <zephound.com>, <zepnound.com>, <zopbound.com>, <zpebound.com>, and

<zwpbound.com> are all registered with Cosmotown, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 21, 2025. On August 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On August 21, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Private Whois) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 24, 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 amendment to the Complaint on August 27, 2025.

The Center verified that the Complaint together with the amendment to the 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 September 1, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 21, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 26, 2025.

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The Center appointed Tobias Zuberbühler as the sole panelist in this matter on October 1, 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 pharmaceutical company that launched injectable products for the treatment of obesity under the brand name ZEPBOUND in December 2023. Worldwide sales of the product reached a revenue of almost USD 5 billion in 2024.

The Complainant owns various ZEPBOUND trademarks, including United States Trademark No. 7,288,373, which was filed for registration on April 14, 2022, and registered on January 23, 2024.

The Complainant also has an Internet presence for its ZEPBOUND products available at
“ which redirects to the website at “

The disputed domain names were registered with the same registrar on either March 16, 2025, or March 29, 2025. At the time of the filing of the Complaint, the disputed domain names all redirected to the same third- party website that displays the Complainant’s mark and purports to offer Tirzepatide (Zepbound) products for sale for 80% less.

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.

B. Respondent

The Respondent has not submitted any response to the Complainant’s contentions.

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 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.

Each of the disputed domain names misspells the Complainant’s trademark ZEPBOUND by adding a letter in <zepboound.com>, reversing two letters in <zpebound.com> and replacing a letter in the remaining disputed domain names. Accordingly, the disputed domain names are confusingly similar to the trademark for the purposes of the Policy. WIPO Overview 3.0, sections 1.7 and 1.9.

The Panel finds that the first element of the Policy has been established.

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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 that the Complainant has established a prima facie products sold on the third-party website appear to be gray market or counterfeit goods.

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 finds that the composition of the disputed domain names
(misspelling the Complainant’s trademark), coupled with the redirection to a third-party website displaying the
Complainant’s mark and purportedly offering Tirzepatide (Zepbound) products for sale for 80% less without
any prominent and accurate disclaimer regarding the lack of relationship between the Complainant and the
Respondnet, does not amount to a bona fide offering of goods or services. The Panel further notes that

The Panel finds that 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.

Under the circumstances of this case particularly the use of the websites at the disputed domain names, it can be inferred that the Respondent was aware of the Complainant’s prior registered trademark when registering the disputed domain names.

The evidence and allegations submitted by the Complainant support a finding that the Respondent has engaged in an attempt to attract Internet users to its website for its own commercial gain. The Respondent therefore has registered and used the disputed domain names in bad faith (see paragraph 4(b)(iv) of the Policy).

Further, the Complainant’s evidence shows that the Respondent has previously been subject to a large
number of different UDRP decisions awarding transfer of domain names. See, for example, PN II, Inc. v.
Quan Zhongjun, Juanita Co., WIPO Case No. D2025-0224, Asurion, LLC v. Quan Zhongjun, Juanita Co.,
WIPO Case No. D2024-4299, Dynatrace LLC v. Quan Zhongjun, Juanita Co., WIPO Case No. D2023-4533.
The Panel therefore finds that the Respondent has engaged in a pattern of bad faith conduct (see paragraph

4(b)(ii) of the Policy).

The Panel finds that the Complainant has also 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 <sepbound.com>, <xepbound.com>, <zelbound.com>,
<zepblund.com>, <zepboound.com>, <zephound.com>, <zepnound.com>, <zopbound.com>,

<zpebound.com>, and <zwpbound.com> be transferred to the Complainant.

/Tobias Zuberbühler/
Tobias Zuberbühler
Sole Panelist
Date: October 15, 2025