Sanrio Company Ltd. v Song Chen and Chowbus Chowbus

WIPO Case No. D2025-2292

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Sanrio Company Ltd. v. Song Chen and Chowbus Chowbus

Case No. D2025-2292

1. The Parties

The Complainant is Sanrio Company Ltd., Japan, represented by Gamma Law, United States of America

(“USA”).

The Respondents are Song Chen, USA, and Chowbus Chowbus, USA.

2. The Domain Names and Registrars

The disputed domain name <hellokittyktv.com> is registered in the name of Song Chen with GoDaddy.com, LLC. The disputed domain name <hellokittyktvla.com> is registered in the name of Chowbus Chowbus with Wix.com Ltd. (GoDaddy.com and Wix.com Ltd hereinafter the “Registrars”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 12, 2025.
On June 12, 2025, the Center transmitted by email to the Registrars a request for registrar verification in
connection with the disputed domain names. On June 12 and 17, 2025, the Registrars transmitted by email
to the Center their verification responses disclosing registrant and contact information for the disputed
domain names which differed from the named Respondents (Domains By Proxy, LLC, and Tucows Domains)
and contact information in the Complaint.

The Center sent an email communication to the Complainant on June 24, 2025, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different 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 June 30, 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”).

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In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondents of the Complaint, and the proceedings commenced on July 10, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 30, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on August 12, 2025.

The Center appointed Andrea Mondini as the sole panelist in this matter on August 18, 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 licensing company that designs, manufactures, and licenses products, including
karaoke machines, music players, greeting cards, books and videos on an international basis. The

Complainant has offered goods and services under the HELLO KITTY mark since 1976.

The Complainant owns several trademark registrations, including:

TRADEMARK	JURISDICTION	REGISTRATION	REGISTRATION
NUMBER	DATE
HELLO KITTY	USA	1,279,486	May 29, 1984
HELLO KITTY	USA	4,620,151	October 14, 2014
USA	1,200,083	July 6, 1982

The Complainant holds the domain name <hellokitty.com> which was registered in 1996 and directs users to

“ where its main website is hosted.

The Respondents did not file a Response.

The disputed domain name <hellokittyktv.com> was registered on May 20, 2017. The disputed domain name <hellokittyktvla.com> was registered on January 3, 2024.

According to the evidence submitted with the Complaint, the disputed domain names resolved to websites
for a karaoke lounge and restaurant named “Long Time Ago KTV” prominently displaying the Complainant’s

USA design trademark no. 1,200,083 which is an image of the licensing character known as “Hello Kitty”.

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 as follows:

The disputed domain names are confusingly similar to the HELLO KITTY trademark in which the
Complainant has rights, because they incorporate this trademark in its entirety, and the addition of the letters
“ktv” and “ktvla”, respectively, is not sufficient to prevent a finding of confusing similarity. The letters “ktv”
stand for a karaoke facility featuring private individual rooms, and “la” is an abbreviation for Los Angeles,
USA.

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The Respondents have no rights or legitimate interests in respect of the disputed domain names. The trademark HELLO KITTY has been extensively used for decades to identify the Complainant’s products and services. The previous owner of the karaoke and restaurant establishment featured in the websites to which the disputed domain names resolve, had signed a license agreement with the Complainant for the display of certain artwork at that location, but that license agreement expressly prohibited the registration of any domain names containing the HELLO KITTY mark, was non-transferable and expired on December 31, 2019. The Respondents have not been authorized by the Complainant to register the disputed domain names, are not commonly known by the disputed domain names, and there is no evidence of the Respondents’ use, or demonstrable preparation to use, the disputed domain names in connection with a bona fide offering of goods and services.

The disputed domain names were registered in bad faith because it is obvious that the Respondents had knowledge of both the Complainant and its well-known trademark HELLO KITTY at the time they registered the disputed domain names.

The Respondents are using the disputed domain names in bad faith, by intentionally attempted to attract, for
commercial gain, Internet users to their web sites, by creating a likelihood of confusion with the

Complainant's mark as to the source, sponsorship, affiliation, or endorsement of their web sites.

B. Respondents

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

6. Discussion and Findings

According to paragraph 4(a) of the Policy, in order to succeed, a complainant must establish each of the following elements:

(i) the disputed domain name is identical or confusingly similar to the 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.

6.1 Consolidation: Multiple Respondents

The amended Complaint was filed in relation to nominally different domain name registrants. The or under common control. In particular, the Complainant contends that the Respondent Song Chen is the Manager of Xin Mei International LLC, which uses the business name “Long Time Ago”. Although the Complainant did have a license agreement with K Music, the previous operator of a karaoke lounge at the same location, that license was non-transferable, expressly prohibited the registration of any domain name that uses the Complainant’s trademarks and was terminated entirely on December 31, 2019.

The Complainant further contends that the Respondent “chowbus chowbus” is actually Chowbus, Inc. (“Chowbus”), and that Chowbus offers website creation services to restaurants, including domain registration, and thus was likely acting as an agent for the Respondent Song Chen when it registered the disputed domain name <hellokittyktvla.com>.

Both disputed domain names contain a similar structure consisting of “hellokitty”, then “ktv” with the addition of the geographic indicator “la” on the disputed domain name <hellokittyktvla.com>, and they both resolve to websites that (1) promote the business Long Time Ago KTV; (2) provide the same physical address in Los

Angeles, USA; (3) use the same or similar images and content; and (4) offer the same karaoke entertainment services. Thus, according to the Complainant, it stands to reason that both disputed domain names are under common control.

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The Complainant therefore 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.

As regards common control, the Panel notes that the above circumstances described by the Complainant indicate that the disputed domain names are subject to 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 herein as “the Respondents”) in a single proceeding.

6.2 Substantive issues

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 entirety of the mark is reproduced within the disputed domain names.

Although the addition of other elements such as here “ktv” and “la” may bear on assessment of the second and third elements, the Panel finds that in the present case 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 addition of the generic Top-Level Domain (“gTLD”) “.com” in the disputed domain names is a standard registration requirement and as such may be disregarded under the confusing similarity test under the Policy, paragraph 4(a)(i). WIPO Overview 3.0, section 1.11.1.

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 Respondents 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 for a complainant to prove that 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

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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 domain name prior to the license agreement and were then clearly prohibited from registering any domain name by the license agreement. Furthermore, the disputed domain name <hellokittyktvla.com> was registered on January 3, 2024, after the expiration of license agreement. In summary, the Panel finds that the Respondents cannot claim any rights or legitimate interests pursuant to the license agreement.

that the Respondents lack rights or legitimate interests in the disputed domain names. The Complainant
credibly contends that the previous owner of the karaoke and restaurant establishment featured in the
websites to which the disputed domain names resolve, had signed a license agreement with the
Complainant for the display of certain artwork at that location, but that license agreement expressly
prohibited the registration of any domain names containing the HELLO KITTY mark, was non-transferrable,
started from September 1, 2017, and expired on December 31, 2019. The Panel notes that the disputed
domain name <hellokittyktv.com> was registered on May 20, 2017, before the term of the license agreement.

The Respondents have not rebutted the Complainant’s prima facie showing and have 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 composition of the disputed domain names themselves suggest a connection or affiliation between the Complainant and the Respondents which in fact does not exist.

Based on the available record, the Panel finds 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.

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.

In the view of the Panel, noting that the Complainant’s trademark predates the registration of the disputed domain names and considering that the Complainant’s trademark is well known and that the disputed domain names resolve to websites featuring the Complainant’s HELLO KITTY logo, it is inconceivable that the Respondents could have registered the disputed domain names without knowledge of the Complainant’s well known trademark. In the circumstances of this case, and particularly the Panel’s findings under section 6.B. of the Decision, this is evidence of registration in bad faith.

The disputed domain names and the impression given by these websites would cause Internet users to believe that the Respondents are somehow associated with or licensed by the Complainant when, in fact, they are not. The Panel holds that by using the disputed domain names, the Respondents have intentionally attempted to attract, for commercial gain, Internet users to their web sites, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of their web sites in the sense of Policy, paragraph 4(b)(iv).

The Panel finds the third element of the Policy has been established.

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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 <hellokittyktv.com> and <hellokittyktvla.com> be transferred to the Complainant.

/Andrea Mondini/
Andrea Mondini
Sole Panelist
Date: August 21, 2025