DECISION

 

JUUL Labs, Inc. v. web master / Expired domain caught by auction winner.***Maybe for sale on Dynadot Marketplace***

Claim Number: FA2606002227401

 

PARTIES

Complainant is JUUL Labs, Inc. ("Complainant"), represented by Hillary Schroeder of JUUL Labs, Inc., District of Colombia, USA. Respondent is web master / Expired domain caught by auction winner.***Maybe for sale on Dynadot Marketplace*** ("Respondent"), Hong Kong.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <myjuulrewards.com>, registered with 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.

 

Nick J. Gardner as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on June 15, 2026; Forum received payment on June 15, 2026.

 

On June 16, 2026, Dynadot Inc confirmed by e-mail to Forum that the <myjuulrewards.com> domain name is registered with Dynadot Inc and that Respondent is the current registrant of the name. Dynadot Inc has verified that Respondent is bound by the Dynadot Inc registration agreement 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 June 18, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 8, 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@myjuulrewards.com. Also on June 18, 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 July 9, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nick J. Gardner 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 name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant, JUUL Labs, Inc., contends as follows.

 

Complainant is a manufacturer and marketer of vaporizer devices and related accessories. Complainant has used its JUUL trademarks (the "JUUL Marks") in commerce since at least as early as 2015, and owns registered trademark rights in the JUUL Marks in the United States, Hong Kong, and other jurisdictions. Complainant contends that, as a result of substantial sales, advertising, and unsolicited media coverage, the JUUL Marks have become famous and are exclusively associated with Complainant.

 

Complainant further contends that it uses the mark MY JUUL REWARDS in connection with a customer loyalty program, that it owns an International Registration for the MY JUUL REWARDS mark through WIPO (IR 1912862, designating Canada, the European Union, and the United Kingdom) registered March 17, 2026, and that it has also filed and secured allowance of a U.S. trademark application for MY JUUL REWARDS (Serial No. 99430924).

 

Complainant contends that the domain name at issue was registered on October 12, 2025, only five days after Complainant filed its U.S. trademark application for MY JUUL REWARDS on October 7, 2025, and long after Complainant's rights in the JUUL Marks arose. Complainant contends that the domain name at issue wholly incorporates the JUUL mark, merely adding the terms "my" and "rewards," and is additionally confusingly similar to Complainant's MY JUUL REWARDS mark.

 

Complainant contends that Respondent has no rights or legitimate interests in the domain name at issue: Respondent is not commonly known by the domain name at issue, is not authorized or licensed to use Complainant's marks, and is not an authorized reseller of Complainant's goods. Complainant contends that the domain name at issue resolves to a page offering the Domain for sale for USD $1,999, which does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use, and that Respondent has never used the domain name at issue for any legitimate purpose.

 

Complainant contends that Respondent registered and is using the domain name at issue in bad faith. Complainant contends that the timing of registration - five days after Complainant's MY JUUL REWARDS trademark application - together with the fame of the JUUL Marks and the absence of any conceivable good-faith use, shows that Respondent registered the domain name at issue either with actual knowledge of Complainant's rights or opportunistically in response to Complainant's trademark application, with a view to selling the domain name at issue to Complainant at an inflated price.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

The Panel finds the following facts established by the evidence in the record:

1. Complainant owns registered trademark rights in the JUUL mark in the United States and other jurisdictions, and has used the JUUL mark continuously in commerce in connection with vaporizer devices and related accessories since at least 2015. See for example US registration no 4898257 registered February 9, 2016 for the word Juul.

2. Complainant owns International Registration No. 1912862 for the mark MY JUUL REWARDS, designating Canada, the European Union, and the United Kingdom, in connection with a customer loyalty program registered on March 17, 2026.

3. Complainant additionally holds an allowed, but not yet registered, U.S. trademark application (Serial No. 99430924) for the mark MY JUUL REWARDS, filed October 7, 2025.

4. Respondent registered the domain name at issue on October 12, 2025 — five days after Complainant filed its U.S. trademark application for MY JUUL REWARDS, and long after Complainant's rights in the JUUL mark arose.

5. The domain name at issue wholly incorporates Complainant's JUUL mark together with the terms "my" and "rewards," and closely mirrors Complainant's MY JUUL REWARDS mark.

6. The domain name at issue resolves to a webpage offering the domain name at issue for sale for USD $1,999.

7. Respondent has not been authorized, licensed, or otherwise permitted by Complainant to register or use any domain name incorporating Complainant's marks.

8. There is no evidence that Respondent is commonly known by the domain name at issue or has ever used, or made demonstrable preparations to use, the domain name at issue in connection with a bona fide offering of goods or services.

9. Respondent's registrant name of record - "web master / Expired domain caught by auction winner.***Maybe for sale on Dyandot Marketplace***" - is consistent with Complainant's contention that the domain name at issue was acquired for speculative resale rather than for any independent legitimate purpose.

10. Respondent failed to respond to the Complaint, offering no explanation for its registration or use of a domain name incorporating Complainant's mark.

 

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 3.1 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

Complainant has established rights in the JUUL mark through its registered trademarks and its extensive, continuous use of the mark in commerce since at least 2015. Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of Policy ¶ 4(a)(i). See Farmlane Brands, LLC v. Helene Isbell Biggane, FA 1996757 (Forum July 12, 2022).

Complainant also owns International Registration No. 1912862 for the mark MY JUUL REWARDS. Complainant's allowed but not-yet-registered U.S. trademark application (Serial No. 99430924) for MY JUUL REWARDS is noted for background purposes only and is not relied upon in establishing Complainant's rights under this element.

 

The domain name at issue wholly incorporates Complainant's JUUL mark, adding only the terms "my" and "rewards" and the ".com" generic top-level domain ("gTLD"). The addition of common terms to a complainant's mark does not avoid a finding of confusing similarity. See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognisable 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."). The domain name at issue is, in addition, effectively identical to Complainant's MY JUUL REWARDS mark, differing only by the omission of spacing between words and the addition of the ".com" gTLD. The gTLD is a technical requirement of domain name registration and is disregarded under a Policy ¶ 4(a)(i) analysis. See Blue Cross and Blue Shield Association v. Shi Lei aka Shilei, FA 1784643 (Forum June 18, 2018). Similarly spaces cannot appear within a domain name for technical reasons.

 

Accordingly, the Panel finds that Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Under Policy ¶ 4(a)(ii), Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the domain name at issue; the burden then shifts to Respondent to demonstrate that it does have such rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011).

Complainant has demonstrated that Respondent is not authorized to use Complainant's marks and has no relationship with Complainant. The WHOIS record identifies Respondent as "web master / Expired domain caught by auction winner.***Maybe for sale on Dyandot Marketplace***," which bears no resemblance to the Domain and is not indicative that Respondent is commonly known by it. Accordingly, Complainant has established a prima facie case, and the burden shifts to Respondent.

 

Respondent's only demonstrated use of the domain name at issue is to offer it for sale to the public for USD $1,999, a sum for which there is no evidence of any corresponding out-of-pocket investment by Respondent. Such use does not constitute a bona fide offering of goods or services under Policy ¶ 4(c)(i), nor a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii).

 

Respondent has failed to file a Response or otherwise rebut Complainant's prima facie case. The Panel may draw such adverse inferences from Respondent's default as it considers appropriate.  

Respondent has failed to rebut Complainant's prima facie case or to demonstrate any rights or legitimate interests in the disputed domain name.

 

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

 

Registration and Use in Bad Faith

Policy ¶ 4(b) sets forth four non-exclusive circumstances evidencing registration and use in bad faith, including where a respondent has "registered or [] acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of [Respondent's] documented out-of-pocket costs directly related to the domain name." Policy ¶ 4(b)(i).

 

The domain name at issue resolves to a webpage offering it for sale for USD $1,999, a price which, on the record before the Panel, is unrelated to and well in excess of any documented registration costs. The domain name at issue was registered on October 12, 2025 — just five days after Complainant filed its U.S. trademark application for MY JUUL REWARDS — a temporal proximity which, combined with the fame of Complainant's JUUL mark and the composition of the domain name at issue, renders it entirely implausible that Respondent selected the domain name at issue independently of Complainant's marks.

 

The registration of a domain name obviously connected with a well-known trademark by someone with no connection to the trademark owner suggests bad faith. See Household Int'l, Inc. v. Cyntom Enters., FA 096784 (Forum Nov. 7, 2000) (inferring that respondent registered a well-known business name with hopes of attracting complainant's customers). The JUUL marks are so obviously connected with Complainant that Respondent's registration and use of the confusingly similar domain name at issue strongly supports a finding of bad faith.

 

Given the factual background (above) Respondent must have had actual knowledge of Complainant's rights at the time of registration and this further evidences bad faith. The Panel further notes that Respondent's own registrant name of record — describing the domain name at issue as an "Expired domain caught by auction winner" that is "Maybe for sale on Dyandot Marketplace" — is itself consistent with a pattern of registering domain names for speculative resale rather than for any bona fide purpose, and reinforces the Panel's finding that the domain name at issue was registered and is being used in bad faith.

 

The Panel therefore 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 <myjuulrewards.com> domain name be TRANSFERRED from Respondent to Complainant. 

 

 

 

Nick J. Gardner, Panelist

Dated: July 23, 2026