Royal Adhesives and Sealants, LLC v Valentina

WIPO Case No. D2025-3100

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Royal Adhesives and Sealants, LLC v. Valentina

Case No. D2025-3100

1. The Parties

The Complainant is Royal Adhesives and Sealants, LLC, United States of America (“US”), represented by

Faegre Drinker Biddle & Reath, LLP, US.

The Respondent is Valentina, Germany.

2. The Domain Name and Registrar

The disputed domain name <myeternabond.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 4, 2025.
On August 5, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On August 6, 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 (GDPR Masked) and contact information in the Complaint. The
Center sent an email communication to the Complainant on August 7, 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 12, 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 August 13, 2025. In accordance with the Rules, paragraph
5, the due date for Response was September 2, 2025. The Respondent did not submit any response.
Accordingly, the Center notified the Respondent’s default on September 7, 2025.

page 2

The Center appointed Erica Aoki as the sole panelist in this matter on September 11, 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, Royal Adhesives and Sealants, LLC, is part of the H.B. Fuller group, a global manufacturer of high-performance adhesives and sealants.

The Complainant’s ETERNABOND brand is well known in the US for its roof repair and sealing tapes, widely used in industrial, commercial, and residential applications. The products are distributed through hundreds of retail outlets and major online platforms such as Amazon and are recognized in the construction and repair sectors for their quality and reliability.

The Complainant owns longstanding trademark rights in ETERNABOND. These include US Registration No.
4,587,432 (stylized), registered on August 19, 2014, with first use dating back to August 5, 1999, covering
inter alia adhesive tape for industrial and commercial use in Classes 16 and 17.

In addition to its trademark rights, the Complainant registered and has continuously used the domain name <eternabond.com> since April 20, 1999. That domain name has served as the Complainant’s primary online platform for corporate communications, product information, and customer interaction. More recently, it started redirecting to the Complainant’s parent company website at the domain name <hbfuller.com>, which includes dedicated pages for the ETERNABOND product line.

The disputed domain name was registered on March 11, 2024. Evidence in the record shows that it resolved to webpages prominently displaying the Complainant’s ETERNABOND stylized trademark, purporting to be the “official website of Eternabond Tape,” and with links redirecting Internet users to the Complainant’s Amazon store.

5. Parties’ Contentions

A. Complainant

The Complainant contends that it has satisfied all three elements required under the Policy for a transfer of the disputed domain name.

First, the Complainant argues that the disputed domain name is confusingly similar to its ETERNABOND trademark. The disputed domain name wholly incorporates the ETERNABOND mark, with only the addition of the term “my” and the generic Top-Level Domain (“gTLD”) “.com”. The Complainant submits that such additions do not prevent a finding of confusing similarity.

Second, the Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not affiliated with the Complainant, has never been authorized to use its marks, and is not commonly known by “myeternabond”. The Complainant further submits that the disputed domain name resolved to a page prominently displaying the Complainant’s ETERNABOND design mark and presenting itself as the “official website of Eternabond Tape”, while redirecting users to the Complainant’s Amazon store. Such use cannot constitute a bona fide offering of goods or services, nor a legitimate noncommercial or fair use.

Third, the Complainant argues that the disputed domain name was registered and is being used in bad faith.
The Respondent registered the domain name in 2024, long after the Complainant had established strong
rights in the ETERNABOND mark through its trademark registrations and use of <eternabond.com> since
1999. By using the disputed domain name to impersonate the Complainant’s official website and create a

page 3

likelihood of confusion as to source, sponsorship, affiliation, or endorsement, the Respondent has

intentionally attempted to attract Internet users for commercial gain.

The Complainant requests that the disputed domain name be transferred.

B. Respondent

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

6. Discussion and Findings

Under paragraph 4(a) of the Policy, the Complainant must prove that: (i) the disputed 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 disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith.

A. Identical or Confusingly Similar

It is well established that the first element functions primarily as a standing requirement. WIPO Overview of
WIPO Panel Views on Selected UDRP Questions, Third Edition (WIPO Overview 3.0), section 1.7.

The Complainant has demonstrated rights in the ETERNABOND trademark through longstanding use and registration, including US Registration No. 4,587,432.

The disputed domain name incorporates the ETERNABOND mark in its entirety, with only the addition of the term “my” and the gTLD “.com”.

Panels have consistently found that such additions do not prevent a finding of confusing similarity where the complainant’s mark remains clearly recognizable (WIPO Overview 3.0, section 1.8). Accordingly, the Panel finds that the disputed domain name is confusingly similar to the Complainant’s registered trademark.

The first element of the Policy is satisfied.

B. Rights or Legitimate Interests

Under paragraph 4(c) of the Policy, a respondent may demonstrate rights or legitimate interests by showing bona fide use, being commonly known by the domain name, or legitimate noncommercial or fair use. Although the overall burden of proof remains with the Complainant, once a complainant makes a prima facie showing that the respondent lacks rights or legitimate interests, the burden of production shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests (WIPO Overview 3.0, section 2.1).

The Complainant has made a prima facie case: the Respondent is not affiliated with the Complainant, has not been authorized to use the ETERNABOND mark, and is not commonly known by “myeternabond.”

The disputed domain name resolves to a webpage prominently displaying the Complainant’s stylized mark, presenting itself as the “official website of Eternabond Tape” and containing a link redirecting users to the Complainant’s Amazon store. Such use creates a false impression of association and cannot constitute a bona fide offering of goods or services or a legitimate noncommercial use.

The Respondent has not submitted any Response to rebut the Complainant’s assertions. The Panel therefore finds that the Respondent has no rights or legitimate interests in respect of the disputed domain name.

page 4

The second element of the Policy is satisfied.

C. Registered and Used in Bad Faith

To satisfy the third element under the Policy, the Complainant must demonstrate that the disputed domain name was both registered and is being used in bad faith (Policy, paragraph 4(a)(iii)).

The Complainant contends that the Respondent registered the disputed domain name with knowledge of its well-known ETERNABOND brand and has used the domain name to impersonate the Complainant. The disputed domain name incorporates the entirety of the Complainant’s mark with only the addition of the non- distinctive term “my” and resolves to a webpage displaying the Complainant’s stylized trademark, describing itself as the “official website of Eternabond Tape,” and containing a link redirecting users to the Complainant’s Amazon store.

The Complainant submits that such conduct constitutes an intentional attempt to attract, for commercial gain, within the meaning of paragraph 4(b)(iv) of the Policy.

The Respondent has not filed a Response and has therefore not contested the Complainant’s assertions or provided any alternative explanation for its registration or use of the disputed domain name.

The Panel notes that the Complainant’s first use of the ETERNABOND trademark dates back to 1999 and that its US federal registration issued in 2014, long before the Respondent registered the disputed domain name in March 2024.

Given the fame of the trademark in the Complainant’s industry, the close similarity between the disputed domain name and the Complainant’s own domain name <eternabond.com>, and the nature of the use made of the disputed domain name, the Panel finds it more likely than not that the Respondent was aware of the Complainant’s trademark at the time of registration.

The Panel further finds that the Respondent’s use of the disputed domain name to present itself as an
“official” source for the Complainant’s products, and include a link that redirects users to the Complainant’s
Amazon store, constitutes bad faith use under paragraph 4(b)(iv) of the Policy.

Accordingly, the Panel concludes that the disputed domain name was registered and is being used in bad faith.

The third element of the Policy is satisfied.

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 <myeternabond.com> be transferred to the Complainant.

/Erica Aoki/
Erica Aoki
Sole Panelist
Date: September 25, 2025