Paris Hilton v tu he, tyhn dg

WIPO Case No. D2025-2891

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Paris Hilton v. tu he, tyhn dg

Case No. D2025-2891

1. The Parties

The Complainant is Paris Hilton, United States of America (“United States”), represented by Tucker & Latifi,

LLP, United States.

The Respondents are tu he, Algeria, and tyhn dg, Timor-Leste.

2. The Domain Names and Registrar

The disputed domain names <parishiltonsalebst.shop>, <parishiltonsale.shop>, and <parishiltonusa.shop> are registered with Spaceship, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 21, 2025. On connection with the disputed domain names. On July 23, 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 (Spaceship, Inc.) and contact information in the Complaint.

The Center sent an email communication to the Complainant on July 23, 2025 with the registrant and contact 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 24, 2025.

information of nominally multiple underlying registrants revealed by the Registrar, requesting the
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 July 25, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was August 14, 2025. The Respondents did not submit any response.
Accordingly, the Center notified the Respondents’ default on August 19, 2025.

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The Center appointed Fabrizio Bedarida as the sole panelist in this matter on August 22, 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 well-known and widely recognized celebrity, entrepreneur, and business executive.

The Complainant has numerous registrations for the PARIS HILTON trademark around the world. The
Complainant is, inter alia, the owner of the following:

United States Trademark registration number 3059587 for the PARIS HILTON (word) trademark registered on February 14, 2006, covering goods in class 3;

United States Trademark registration number 3309679 for the PARIS HILTON (word) trademark registered on October 9, 2007, covering goods in class 25; and

European Union Trademark registration number 4059631 for the PARIS HILTON (word) trademark registered on July 14, 2006, covering goods in classes 3, 14 and 25.

In addition, the Complainant operates the website at “ as her primary online retail platform.

All the disputed domain names were registered in June 2025 and resolve to similar websites. On the home pages of these websites, the Complainant’s PARIS HILTON trademark is prominently displayed, and purported PARIS HILTON-branded goods are offered for sale alongside competing products.

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 the disputed domain names are confusingly similar to the PARIS HILTON trademark, that the Respondents have no rights or legitimate interests in respect of the disputed domain names, and particularly that it is implausible that the Respondents were unaware of the

Complainant’s renowned trademark when they registered the disputed domain names. The disputed domain names were registered and are being used in bad faith.

Regarding the Respondents’ identity, the Complainant has requested a consolidation of multiple disputed domain names and the Respondents.

B. Respondents

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

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6. Discussion and Findings

6.1. Consolidation: Multiple Respondents

The amended Complaint was filed in relation to nominally different 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.

With respect to the issue of common control, the Panel finds, on the balance of probabilities, that the disputed domain names identified in the Complaint are registered by the same domain name holder or are at least under common control. This conclusion is based on the following factors:

The registrants of the disputed domain names provided incorrect, if not outright false, addresses with similar structure. Specifically, the Respondents’ addresses list major United States cities (New York and Austin) but include country codes of Algeria and Timor-Leste—countries in which such cities do not exist—indicating that the addresses are fictitious.

The websites associated with the disputed domain names prominently feature the Complainant’s PARIS coordination or common intent among the Respondents.

All disputed domain names were registered in June 2025.

All disputed domain names were registered through the same Registrar.

The registrants’ email addresses originate from the same domain name or service provider, namely

“@angegg.com”.

The overall composition of the disputed domain names is highly similar. Each incorporates the
Complainant’s PARIS HILTON mark in its entirety, with only minor variations by adding “sale”, “salebst”, or
“usa”, and all are registered in the generic Top-Level Domain “.shop”.

Based on these cumulative factors, the Panel concludes that the disputed domain names are more likely than not under common control.

As regards fairness and equity, the Panel 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 different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding.

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6.2. Substantive Issues

In order for the Complainant to obtain a transfer of the disputed domain names, paragraph 4(a) of the Policy requires that the Complainant must demonstrate to the Panel that:

(i) the disputed domain names are 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 names; and

(iii) the disputed domain names have been registered and are 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 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.

The Panel finds the mark is incorporated entirely and recognizable within the disputed domain names.
Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.7.

Although the addition of the other terms here, “sale”, “bst” and “usa”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.

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 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. Furthermore, the Panel considers that the use of the disputed domain names (as described under Section 4 of the Decision) cannot fulfill the requirements in the Oki Data test. See Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903, and WIPO Overview 3.0, section 2.8.

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 notes that the Respondent was aware of the Complainant’s trademark registrations and rights to the PARIS HILTON trademark when it registered the disputed domain names.

The term “Paris Hilton” is neither generic nor descriptive, but a distinctive and well-known trademark as well as a patronymic associated exclusively with the Complainant. The disputed domain names contain in its entirety, without any authorization or approval, the Complainant’s registered PARIS HILTON trademark, and this is the only distinctive component of the disputed domain names.

The disputed domain names were registered many years after the Complainant’s renowned trademark was registered. In addition, owing to the substantial presence established worldwide and on the Internet by the Complainant, and the use of the disputed domain names to sell purported PARIS HILTON-branded goods, it

is at the least very unlikely that the Respondent was not aware of the existence of the Complainant’s
trademark when registering the disputed domain names.

Therefore, it is more likely than not that the Respondent, when registering the disputed domain names, had knowledge of the Complainant’s earlier rights to the PARIS HILTON trademark and name and targeted those.

It thus appears that the Respondent registered the disputed domain names to misleadingly attract, for commercial gain, Internet users to its websites by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation or endorsement of the Respondent’s websites and products, and this shows bad faith registration and use of the disputed domain names.

In addition, panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4.

The bad faith registration and use of the disputed domain names are further supported by the Respondent’s failure to deny the Complainant’s allegations of bad faith in this proceeding.

Based on the available record, 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 names <parishiltonsalebst.shop>, <parishiltonsale.shop>, and

<parishiltonusa.shop> be transferred to the Complainant.

/Fabrizio Bedarida/
Fabrizio Bedarida
Sole Panelist
Date: September 1, 2025