Safariland, LLC v d's'da's'da's'd dasd

WIPO Case No. D2025-2479

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Safariland, LLC v. d's'da's'da's'd dasd

Case No. D2025-2479

1. The Parties

1.1 The Complainant is Safariland, LLC, United States of America, represented by Kane Kessler, PC, United

States of America (the “Complainant”).

1.2 The Respondent is d's'da's'da's'd dasd, Armenia (the “Respondent”).

2. The Domain Name and Registrar

2.1 The disputed domain name <safarilands.shop> (the “Disputed Domain Name”) is registered with

Spaceship, Inc. (the “Registrar”).

3. Procedural History

3.1 The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 23,
2025. On June 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification
in connection with the Disputed Domain Name. On June 25,2025 , 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 (Redacted) and contact information in the Complaint. The
Center sent an email communication to the Complainant on June 26, 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 amended Complaint on July 1, 2025.

3.2 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”).

3.3 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the the due date for Response was July 23, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 25, 2025.

3.4 The Center appointed Ike Ehiribe as the sole panelist in this matter on July 31, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of

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Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.

4. Factual Background

4.1 The Complainant is a direct wholly-owned subsidiary of Cadre Holdings, Inc. operating from Jacksonville
in Florida, United States of America. The Complainant is the owner of all rights in the SAFARILAND
trademarks, including United States of America trademark number 3995719, registered on July 19, 2011, in
respect of bulletproof and bullet resistant body armour and other related goods and services. The
Complainant has expended significant time, resources and effort in promoting the trademark. The
Complainant conducts business on the Internet through its <safariland.com> domain name among other
URLs.

4.2 The Respondent is said to be based in Armenia. The Respondent created the Disputed Domain Name on February 23, 2025 according to the attached WhoIs data base. The Disputed Domain Name resolves to a website displaying the Complainant’s trademark and logo, and purportedly offering the Complainant’s

products for sale.

5. Parties’ Contentions

A. Complainant

5.1 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 it owns several trademark
registrations for the SAFARILAND trademark. In particular, since the Disputed Domain Name reproduces
the entire trademark, the only difference being the addition of the letter “s” to the Disputed Domain Name. It
is stated further that the Respondent is offering for sale counterfeit goods falsely labelled as SAFARILAND
goods through the website and is also holding itself out as the Complainant and or affiliated with and or an
authorised distributor of the Complainant. It is therefore submitted that the Respondent’s actions have
willfully deceived consumers and have caused serious economic and brand harm to the Complainant.

5.2 The Complainant further contends that the Respondent lacks rights or legitimate interests in the Disputed Domain Name considering there is no evidence of the Respondent’s use of, or demonstrable preparations to use the Disputed Domain Name or a name corresponding to the Disputed Domain Name in connection with a bona fide offering of goods or services. It is also submitted that the Respondent has never been

commonly known by the Disputed Domain Name nor is there any evidence that the Respondent has
acquired any trademark or service mark rights in connection with the SAFARILAND trademark. Finally, it is
contended that the Respondent is not making a legitimate noncommercial or fair use of the Disputed Domain
Name but is intentionally and misleadingly diverting consumers to its website and tarnishing the
SAFARILAND trademark in issue.

5.3 In support of the contention, that the Disputed Domain Name was registered and being used in bad faith the Complainant asserts that the Respondent intentionally attempted to attract for commercial gain Internet users to the Respondent’s website by creating a likelihood of confusion with the Complainant’s trademark as

to the source, sponsorship, affiliation, or endorsement of the Respondent’s website and of a product or

services on the Respondent’s website or location.

B. Respondent

5.4 The Respondent did not reply to the Complainant’s contentions and therefore the Panel shall draw such
adverse inferences from the Respondent’s failure to respond as may be deemed appropriate.

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6. Discussion and Findings

A. Identical or Confusingly Similar

6.1 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.

6.2 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.

6.3 The entirety of the mark SAFARILAND is reproduced within the Disputed Domain Name. Accordingly,
the Disputed Domain Name is confusingly similar to the mark for the purposes of the Policy. WIPO

Overview 3.0, section 1.7.

6.4 Although the addition of other terms such as the letter “s” may bear on assessment of the second and
third elements, the Panel finds the addition of such a letter does not prevent a finding of confusing similarity
between the Disputed Domain Name and the mark for the purposes of the Policy. WIPO Overview 3.0,
section 1.8. The generic Top-Level Domain (“gTLD”) “.shop” is typically disregarded under the first element.

WIPO Overview 3.0, section 1.11.1.

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

B. Rights or Legitimate Interests

6.6 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.

6.7 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.

6.8 Having reviewed the available record, the Panel finds the Complainant has established a prima facie relevant evidence demonstrating rights or legitimate interests in the Disputed Domain Name such as those enumerated in the Policy or otherwise.

case that the Respondent lacks rights or legitimate interests in the Disputed Domain Name. The

6.9 The Panel finds the second element of the Policy has been established.

C. Registered and Used in Bad Faith

6.10 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.

6.11 In the present case, the Panel notes that the Respondent created the Disputed Domain Name on
February 23, 2025, a date which post-dates the registration of the Complainant’s numerous trademarks in

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different International classes. Accordingly, the Panel finds that the Respondent intentionally set out to

exploit the reputation of the Complainant’s SAFARILAND trademarks.

6.12 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 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.

6.13 The Panel finds the Respondent has intentionally attempted to attract, for commercial gain, Internet
users to its website, by creating a likelihood of confusion with the Complainant’s mark as to the source,
sponsorship, affiliation, or endorsement of its website. Such use constitutes bad faith under paragraph

4(b)(iv) of the Policy.

6.14 The Panel finds that the Complainant has established the third element of the Policy.

7. Decision

7.1 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 <safarilands.shop> be transferred to the Complainant.

/Ike Ehiribe/
Ike Ehiribe
Sole Panelist
Date: August 14, 2025