Fear of God, LLC v Alwadi ALK, Ahmad Abed

WIPO Case No. D2025-1554

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Fear of God, LLC v. ALWADI ALK, AHMAD ABED

Case No. D2025-1554

1. The Parties

The Complainant is Fear of God, LLC, United States of America (“United States), represented by Sheppard,

Mullin, Richter & Hampton, LLP, United States.

The Respondent is ALWADI ALK, AHMAD ABED, United States.

2. The Domain Name and Registrar

The disputed domain name <fearofqod.com> is registered with NameSilo, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 16, 2025.
On April 17, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On April 17, 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 Administrator / See PrivacyGuardian.org) and contact
information in the Complaint. The Center sent an email communication to the Complainant on April 22,
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 April 22, 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 April 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was May 20, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 21, 2025.

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The Center appointed W. Scott Blackmer as the sole panelist in this matter on May 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 is a limited liability company established in 2011 under California law and based in Los
Angeles, California, United States. The Complainant designs and sells “luxury streetwear and accessories”
through its website at “ (operating for more than ten years), a linked @fearofgod
Instagram account with over 2.1 million followers, and retail stores including Nordstrom, Saks Fifth Avenue,
Selfridges, Neiman Marcus, Mr. Porter, Matches Fashion, Pacsun, and SSENSE. The Complainant has also
marketed co-branded FEAR OF GOD products with well-known brands including NIKE, ADIDAS, VANS.
CONVERSE, ERMENEGILDO, ZEGNA, BIRKENSTOCK, and BARTON PERREIRA. The Complaint
attaches examples of media recognition of its brand in GQ, Vogue, Esquire, Woman’s Wear Daily, Harper’s

Bazaar, The Wall Street Journal, The New York Times, and The Los Angeles Times.

The Complainant holds numerous trademark registrations, including the following:

Mark	Jurisdiction	Registration	Registration Date	Goods or Services
Number
FEAR OF GOD	European Union	17806175	June 20, 2018	International Classes
(word)	18, 25, 35
FEAR OF GOD	United States	5696924	March 12, 2019	International Class 25
(word)
FEAR OF GOD	United States	6380625	January 8, 2021	International Class 25
ESSENTIALS (word)

The disputed domain name was created on March 25, 2025, and registered in the name of a domain privacy service. The Registrar identified the underlying registrant as the Respondents “ALWADI ALK AHMAD ABED”, listing a postal address in the State of Texas, United States, with a Gmail contact email address. These appear to be the names of two individuals giving a single address (which maps to a residential address in a Texas city). Lacking further information, the Panel refers to these individuals collectively hereafter as the “Respondent”.

As demonstrated by screenshots attached to the Complaint, the disputed domain name has resolved to a landing page displaying a message that the disputed domain name is registered by the Registrar and linking to pages advertising the Registrar’s services, at times also displaying pay-per-click (“PPC”) advertising links to a variety of third parties.

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 contends that the disputed domain name is confusingly similar to its registered name. The Complainant cites the “passive holding” doctrine to assert bad faith, as well as the Respondent’s

FEAR OF GOD and FEAR OF GOD ESSENTIALS marks, “typosquatting” the marks by substituting the letter
“q” for “g” in the word “god”. The Complainant asserts that this error is intentional and meant to mislead

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registration using a domain privacy service. Because the disputed domain name is “nearly identical” to the Complainant’s registered and well-known mark, the Complainant infers the Respondent’s actual knowledge of the mark and intent to misdirect Internet users in bad faith.

B. Respondent

The Respondent did not reply 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 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 (here, the registered FEAR OF GOD and FEAR OF GOD ESSENTIALS marks) for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.

The Panel finds the marks are recognizable within the disputed domain name. The disputed domain name differs from FEAR OF GOD only by substituting the visually similar letter “q” for the letter “g”, in an apparent instance of typosquatting. Accordingly, the disputed domain name is confusingly similar to the marks for the purposes of the Policy. WIPO Overview 3.0, sections 1.7, 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 disputed domain name, substituting a letter to make a nonsense string, does not
reflect a meaningful word or phrase, and its use for irrelevant PPC advertising does not represent a use in
connection with a bona fide offering of goods or services under the Policy, paragraph 4(c)(i). See

WIPO Overview 3.0, section 2.9.

The Panel finds 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.

In the present case, the Panel finds that the Respondent was more likely than not aware of the Complainant and its FEAR OF GOD marks, given that they have been long established online and especially given the composition of the disputed domain name. This does not comprise a meaningful phrase but rather a one- letter variation on the Complainant’s mark – a letter, moreover, which is easily mistaken for the original version, especially in a small font or on a small screen. The Respondent has not come forward to offer an alternative explanation for this apparently intentional confusion. The Respondent has allowed the disputed domain name to be used for PPC advertising and advertising the Registrar’s services for more than a de minimis period immediately following registration. This is consistent with the example of bad faith given in the Policy, paragraph 4(b)(iv), intentionally attempting to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s mark.

Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances also may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1.

Panels have found that the non-use of a domain name (including parking it for the Registrar’s default landing page, as appears to be the case here at times) would not prevent a finding 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 distinctiveness or reputation of the Complainant’s trademark and the composition of the disputed domain
name, finding that in the circumstances of this case the passive holding of the disputed domain name does

not prevent a finding of bad faith under 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 <fearofqod.com> be transferred to the Complainant.

/W. Scott Blackmer/
W. Scott Blackmer
Sole Panelist
Date: June 2, 2025