DECISION

 

Target Brands, Inc. v. pro sohaib / Mondo Llama / Rizwan Shad

Claim Number: FA2601002199686

 

PARTIES

Complainant is Target Brands, Inc. ("Complainant"), represented by Jeanette Eriksson of FairWinds Partners LLC, District of Columbia, USA. Respondent is pro sohaib / Mondo Llama / Rizwan Shad ("Respondent"), Pakistan.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <mondollamaco.com> and <mondollamabrand.com>, registered with Name.com, Inc. and Dynadot Inc.

 

PANEL

The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding.

 

Sandra J. Franklin as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 14, 2026; Forum received payment on January 14, 2026.

 

On January 14 and 15, 2026, Name.com, Inc. and Dynadot Inc confirmed by e-mail to Forum that the <mondollamaco.com> and <mondollamabrand.com> domain names are registered with Name.com, Inc. and Dynadot Inc and that Respondent is the current registrant of the names. Name.com, Inc. and Dynadot Inc have verified that Respondent is bound by the Name.com, Inc. and Dynadot Inc registration agreements and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").

 

On January 19, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 9, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@mondollamaco.com, postmaster@mondollamabrand.com. Also on January 19, 2026, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.

 

Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.

 

On February 10, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Sandra J. Franklin as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.

 

RELIEF SOUGHT

Complainant requests that the domain names be transferred from Respondent to Complainant.

 

PRELIMINARY ISSUE: MULTIPLE RESPONDENTS

Paragraph 3(c) of the Rules provides that "[t]he complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder."  Here, the Panel notes that the disputed domain names resolve to similar content and have some similar contact/registration information. The disputed domain names were registered within 3 days of each other with similar naming conventions. The Panel also notes that the named Respondents did not object to consolidating the UDRP cases on the disputed domain names. The Panel thus determines that the listed registrant names are aliases for the same person or entity and will refer to them jointly as "Respondent". See Eli Lilly and Company v. Private Registration, WhoisGuardService.com, D2016-1737 (WIPO Oct. 11, 2016) (consolidation found to be fair and equitable where "the respondent has the opportunity to make its submissions on the validity of the consolidation together with its substantive arguments. … The Respondent had the opportunity but did not respond to the Complaint"); see also Target Brands, Inc. v. Nosheen Rizwan / Sohaib Amin, FA2181734 (Forum, Nov 6, 2025) ("The WHOIS printouts included in Complaint Exhibit B show that the domain names were registered within eight days of each other with the same registrar and using the same hosting provider. The domain names have the same naming convention, i.e., adding a simple generic term to the MONDO LLAMA mark, and the websites resolving from them are very similar in layout, structure, general appearance and content, both of them claiming to be an "official" website of Complainant. On this evidence the Panel finds that both domain names are registered to the same person or entity or are under common control and will proceed as to both of them.")

 

PARTIES' CONTENTIONS

A. Complainant

1.       Respondent's <mondollamaco.com> and <mondollamabrand.com> domain names are confusingly similar to Complainant's MONDO LLAMA mark.

 

2.       Respondent does not have any rights or legitimate interests in the <mondollamaco.com> and <mondollamabrand.com> domain names.

 

3.       Respondent registered and uses the <mondollamaco.com> and <mondollamabrand.com> domain names in bad faith.

 

B. Respondent did not file a Response.

 

FINDINGS

Complainant provides art and crafts products and holds a registration for the MONDO LLAMA mark with the European Union Intellectual Property Office ("EUIPO") (registered July 22, 2021).

 

Respondent registered the <mondollamabrand.com> and <mondollamaco.com> domain names on October 14 and 17, 2025, respectively, and uses them primarily to offer pay-per-click links.

 

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."

 

Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

(1)       the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

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

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

 

In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules.  The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint").

 

Identical and/or Confusingly Similar

The Panel finds that Complainant has rights in the MONDO LLAMA mark through registration with the EUIPO. See Zebra A/Sj v. Slavko Malevic, FA 1922006 (Forum Dec. 7, 2020) ("Since Complainant evidences its registration of the trademark FLYING TIGER with the EUIPO the Panel finds that it has shown trademark rights.")

 

Respondent's <mondollamabrand.com> and <mondollamaco.com> domain names use Complainant's MONDO LLAMA mark and simply add the generic element "brand" or "co", and ".com". These changes do not distinguish a disputed domain name from a mark under Policy ¶ 4(a)(i). See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognizable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element."); see also Vanguard Group Inc. v. Proven Fin. Solutions, FA 572937 (Forum Nov. 18, 2005) (holding that the addition of both the word "advisors" and the gTLD ".com" did not sufficiently alter the disputed domain name to negate a finding of confusing similarity under Policy ¶ 4(a)(i)). The Panel therefore finds that Respondent's <mondollamabrand.com> and <mondollamaco.com> domain names are confusingly similar to Complainant's MONDO LLAMA mark.

 

The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Once Complainant makes a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), the burden shifts to Respondent to show it does have rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests").

 

Complainant contends that Respondent has no rights or legitimate interests in the <mondollamabrand.com> and <mondollamaco.com> domain names as Respondent is not commonly known by the domain names. Complainant has not given Respondent permission to use its MONDO LLAMA mark in the disputed domain names. The WHOIS identifies "pro sohaib / Mondo Llama / Rizwan Shad" as the registrant of the disputed domain names.  Despite the gratuitous listing of "Mondo Llama" in the registrant information, the Panel finds that Respondent is not commonly known by the disputed domain names, and thus has no rights under Policy ¶ 4(c)(ii). See Amazon Technologies, Inc. v. Suzen Khan / Nancy Jain / Andrew Stanzy, FA 1741129 (Forum Aug. 16, 2017) (finding that respondent had no rights or legitimate interests in the disputed domain names when the identifying information provided by WHOIS was unrelated to the domain names or respondent's use of the same); see also Navistar International Corporation v. N Rahmany, FA 1620789 (Forum June 8, 2015) (finding that the respondent was not commonly known by the disputed domain name where the complainant had never authorized the respondent to incorporate its NAVISTAR mark in any domain name registration). 

 

Complainant demonstrates that Respondent fails to use the <mondollamabrand.com> and <mondollamaco.com> domain names for a bona fide offering of goods or services or a legitimate noncommercial or fair use as the domain names resolve to pay-per-click links, some of which offer arts and craft products in competition with Complainant. The Panel finds that this is not a bona fide offering of goods or services or a legitimate noncommercial or fair use, and constitutes further evidence that Respondent has no rights under Policy ¶¶ 4(c)(i) or (iii). See Vance Int'l, Inc. v. Abend, FA 970871 (Forum June 8, 2007) (concluding that the operation of a pay-per-click website at a confusingly similar domain name does not represent a bona fide offering of goods or services or a legitimate noncommercial or fair use, regardless of whether or not the links resolve to competing or unrelated websites or if the respondent is itself commercially profiting from the click-through fees); see also Vapor Blast Mfg. Co. v. R & S Tech., Inc., FA 96577 (Forum Feb. 27, 2001) (finding that Respondent's commercial use of the domain name to confuse and divert internet traffic is not a legitimate use of the domain name).

 

The Panel finds that Complainant has satisfied Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

Complainant argues that Respondent registered and uses the <mondollamabrand.com> and <mondollamaco.com>  domain names in bad faith to divert users to its websites, which feature pay-per-click links. The Panel agrees and finds bad faith attraction for commercial gain under Policy ¶ 4(b)(iv).  See Office Depot, LLC and The Office Club, Inc. v. Milen Radumilo, FA 978700 (Forum February 10, 2022) ("Use of a confusingly similar domain name to display third-party hyperlinks and collect click-through fees is evidence of bad faith")

 

The Panel notes Respondent's claim to be the official MONDO LLAMA website using Complainant's mark and logo, and its use of the MONDO LLAMA mark to offer competing products via links, and therefore finds that Respondent had knowledge of Complainant's rights in the MONDO LLAMA mark, evincing bad faith under Policy ¶ 4(a)(iii). See Charter Commc'ns Holding Co. v. MIZHAR salem, FA 1774836 (Forum April 4, 2018) (finding bad faith registration of the domain name <charterspectrumonline.com> because "[a]ctual knowledge of a complainant's mark prior to registering a confusingly similar domain name can evidence bad faith under Policy ¶ 4(a)(iii).") see also iFinex Inc. v. xu shuaiwei, FA 1760249 (Forum Jan. 1, 2018) ("Respondent's prior knowledge is evident from the notoriety of Complainant's BITFINEX trademark as well as from Respondent's use of its trademark laden domain name to direct internet traffic to a website which is a direct competitor of Complainant").

 

The Panel finds that Complainant has satisfied Policy ¶ 4(a)(iii).

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <mondollamaco.com> and <mondollamabrand.com> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Sandra J. Franklin, Panelist

Dated: February 11, 2026