Netflix Studios, LLC v Saratovskaya Oblast

WIPO Case No. D2025-0991

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Netflix Studios, LLC v. Saratovskaya Oblast

Case No. D2025-0991

1. The Parties

The Complainant is Netflix Studios, LLC, United States of America (“United States”), represented by Coates

IP LLP, United States.

The Respondent is Saratovskaya Oblast, Russian Federation.

2. The Domain Name and Registrar

The disputed domain name <bridgerton.store> is registered with NameCheap, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 11, 2025. connection with the disputed domain name. On March 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 Respondent) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 13, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Center sent a reminder to the notice of registrant information on March 21, 2025. The Complainant filed an amended Complaint on March 26, 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 March 31, 2025. In accordance with the Rules, paragraph
5, the due date for Response was April 20, 2025. The Respondent did not submit any response.
Accordingly, the Center notified the Respondent’s default on April 22, 2025.

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The Center appointed Zoltán Takács as the sole panelist in this matter on May 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, founded in 1997 is one of the world’s leading streaming entertainment services featuring

TV series, films and games in multiple genres and languages.

The Complainant has over 300 million paid memberships in over 190 countries.

On December 25, 2020, the Complainant released a televised series named “Bridgerton”, an American alternative history regency romance based on the book series by Julia Quinn. Season 1 of the series, which was released on December 25, 2020, ranks 5th of the Complainant’s Global All Time Top 10 Most Popular Shows list with 113,300,000 total views and 929,300,000 hours viewed.

The Complainant is among others owner of the United States Trademark Registration No. 6296166
BRIDGERTON registered since March 16, 2021.

According to the screenshots available on the Internet Archive (“ since at least as of May 12, 2022, the Complainant has been offering a variety of Bridgerton themed merchandise and clothing at its “ website.

The disputed domain name was registered on June 6, 2024, and redirected to a website that claimed that “Bridgerton Merchandise Store is the OFFICIAL Merchandise Store for Bridgerton fans”. The website featured the BRIDGERTON logos and characters on merchandise that was identical or highly similar to those of the Complainant.

Currently the disputed domain name is inactive.

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 identical to its BRIDGERTON trademark;

- the Respondent has no rights or legitimate interests in respect of the disputed domain name since it is

unable to rely on any of the circumstances set out in paragraphs 4(c)(i), (ii), or (iii) of the Policy;

- the use of the disputed domain name for a website that offered unofficial and unauthorized and in view of
the Complainant in fact counterfeit merchandise related to its Bridgerton show and depicted its NETFLIX and

BRIDGERTON trademarks is evidence of bad faith registration and use of the disputed domain name; and

- the Respondent has repeatedly been found to have engaged in abusive domain name registrations and

use which is further evidence of a pattern of bad faith conduct prescribed by the Policy.

The Complainant requests that the disputed domain name be transferred from the Respondent to the
Complainant.

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B. Respondent

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

6. Discussion and Findings

A complainant must evidence each of the three elements required by paragraph 4(a) of the Policy in order to succeed on the complaint, namely that:

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

(ii)       the respondent has no rights or legitimate interests in respect of the domain name; and

(iii)      the domain name has been registered and is being used in bad faith.

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 entirety of the Complainant’s trademark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

The Panel finds that 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.

According to the documentary evidence submitted by the Complainant, the Respondent has used the disputed domain name to deceive Internet users looking for the Complainant through redirecting them to its own website at which the Respondent allegedly offered for sale “official” BRIDGERTON merchandise, prominently featuring the BRIDGERTON trademark, logos, and characters on the merchandise in a way which is identical or highly similar to the Complainant’s products.

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There is no indication of any relationship of the Respondent with the Complainant as to the source of the products at issue and the website at the disputed domain name implied that the merchandise offered for sale on the Respondent’s website originated with the Respondent and not the Complainant.

The Panel notes that there is no evidence as to whether the goods offered on the Respondent’s website at the disputed domain name were counterfeit or “genuine”, or whether any of those goods ultimately existed.

The Panel also notes that it is evident that the Complainant has not authorized, licensed, or allowed the would confer validity or legitimacy upon such use.

Despite the lack of authorization or relationship, the Respondent identifies its website as an “official” store for
the Complainant’s merchandise products. Consequently, even if the merchandise that appeared on the
Respondent’s website under the disputed domain name would have existed or were genuine, the
Respondent’s website would still not qualify as fair use. WIPO Overview 3.0, sections 2.13.2 and 2.8.1, and
Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903.

The Panel considers that the composition of the disputed domain name when considered together with its use creates a high risk of implied affiliation with the Complainant.

The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name and 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.

Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy.

In the present case, the Panel notes that the Complainant’s BRIDGERTON trademark is inherently distinctive and that its priority predate the date of registration of the disputed domain name.

The website at the disputed domain name which claimed that the “Bridgerton Merchandise Store is the OFFICIAL Merchandise Store for Bridgerton fans” featured BRIDGERTON logos and characters on merchandise that was identical or highly similar to those of the Complainant. Thus, in view of the Panel it is clear that the Respondent had actual knowledge of the Complainant and its trademark and registered the disputed domain name to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trademark. Paragraph 4(b)(iv) of the Policy.

The Respondent’s intent to target the Complainant and its trademark can be readily inferred from the contents of the Respondent’s website that was seeking to impersonate the Complainant by directing Internet traffic to its website in order to gain illegitimate profit through impersonation or false association. Visitors of the Respondent’s website might have reasonably believed that it was connected to or approved by the Complainant as it appeared to offer merchandise under the Complainant’s trademark, logos and imagery and gave the impression that the site attached to the disputed domain name was official, while that was clearly not the case.

Moreover, the Respondent has engaged in a pattern of abusive domain name registrations, being respondent in previous UDRP decisions found against the Respondent (see NSN Apparel Co, LLC v. Saratovskaya Oblast, WIPO Case No. D2023-3758 and Kendrick Lamar Duckworth and Nomo Hashimoto, LLC v. Tomas Lain, Saratovskaya Oblast, Chung Do, Abid Ali, proin SEO, ijaz amin, Bhavya Popli, sajid mahe, itnas, WIPO Case No. D2024-1805. Taking this into account, the Panel also finds bad faith registration and use under paragraph 4(b)(ii) of the Policy.

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The disputed domain name is currently inactive.

However, panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. In this context, the Panel notes the reputation of the Complainants’ trademark, the composition of the disputed domain name, and the previous use of the disputed domain name, and finds that in the

circumstances of this case the current 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 <bridgerton.store> be transferred to the Complainant.

/Zoltán Takács/
Zoltán Takács
Sole Panelist
Date: May 15, 2025