WIPO D2024-0481 · decided 20 March 2024
Fat Face Holdings Limited v. 方智强 (fang zhi qiang)
The parties
- Complainant
- Fat Face Holdings Limited
- Respondent
- 方智强 (fang zhi qiang)
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel disregarded ".shop" as a standard registration requirement and found fatface-uk.shop confusingly similar to FATFACE, since the added hyphen and "uk" do not prevent confusing similarity. |
| 4(a)(ii) No rights or legitimate interests | The panel found no rights or legitimate interests, because the inactive domain name is not a bona fide offering of goods or services, and neither was its earlier redirect to a competing store. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith because the redirect to a store selling competing goods was an attempt to confuse users about their source, and the later passive holding did not prevent that finding. |
Why does Fat Face matter for a complaint today?
The panel in Fat Face Holdings Limited v. 方智强 (fang zhi qiang), D2024-0481, ordered the transfer of fatface-uk.shop on March 20, 2024. The Respondent registered the domain name on September 2, 2023. It first sent visitors to www.young-lauk.shop, a clothing store selling products that compete with Fat Face. By the time of the Complaint it resolved to no content. The panel ignored the ".shop" ending when comparing the domain name with the FATFACE trademark. Section 1.11.2 of the WIPO Overview 3.1 says panels disregard the Top Level Domain whichever one it is, including new gTLDs. So a registrant cannot argue that ".shop" makes the domain name different from your trademark. The meaning of the ending can still count against the registrant under the second and third elements, for example where it matches your area of trade. The registration agreement was in Chinese, and the panel let the case run in English after accepting Fat Face's reasons, including that the website was in English and advertised sales in GBP. Fat Face had also sent a cease and desist letter through the Registrar on September 22, 2023. The Respondent never replied, and the panel said this reinforced its bad faith finding.
What does the WIPO Overview 3.1 say?
The WIPO Overview 3.1 summarises how WIPO panels decide each issue. These sections cover the same point of law.
- Section 1.11.1: Is the Top Level Domain relevant in determining identity or confusing similarity? The Overview cites this decision here.
- Section 1.11.2: Is the Top Level Domain relevant in determining identity or confusing similarity?
- Section 3.3: Can the "passive holding" of a domain name support a finding of bad faith?
Who decided the case?
A single panelist, Andrew Sim, decided the case on 20 March 2024.
Read the decision
The full text is published by the WIPO Arbitration and Mediation Center. We summarise it here; the decision itself is the authority.
Summarised by Gergana Dimitrova, who worked at the WIPO Arbitration and Mediation Center from 2018 to 2021 and sits as a domain name panelist at the Czech Arbitration Court. Checked against the published decision on 23 October 2026. Full background.
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