WIPO D2024-3322 · decided 14 October 2024
Lennar Pacific Properties Management, LLC and Lennar Corporation v. George Oatman
The parties
- Complainant
- Lennar Pacific Properties Management, LLC and Lennar Corporation
- Respondent
- George Oatman
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found lennarcorps.com confusingly similar to the LENNAR trademark, because LENNAR is recognisable in the domain name and the added term "corps" does not prevent a finding of confusing similarity. |
| 4(a)(ii) No rights or legitimate interests | The panel found George Oatman had no rights or legitimate interests, because sending fraudulent emails and fabricated invoices in the names of real Lennar employees is not a bona fide offering of goods or services. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith registration and use, because the Respondent used email on lennarcorps.com to ask Lennar's vendors to pay fabricated invoices into bank accounts the Respondent controlled. |
Why does Lennar matter for a complaint today?
The panel in Lennar Pacific Properties Management, LLC and Lennar Corporation v. George Oatman, D2024-3322, ordered the transfer of lennarcorps.com on October 14, 2024. The domain name was registered on May 13, 2024. The Respondent set it up for email and wrote to Lennar's vendors in the names of real Lennar employees. The emails carried fabricated invoices and told the vendors to pay into the Respondent's bank account. The website at lennarcorps.com only redirected to lennar.com. The panel decided the case on the emails, which Lennar filed as screenshots in an annex to the Complaint. Lennar filed the Complaint on August 13, 2024, and had a decision two months later. Section 3.4 of the WIPO Overview 3.1 says that sending deceptive emails to solicit payment of fraudulent invoices can be bad faith even where the domain name hosts no website of its own. The limit is evidence. Section 2.13.2 of the Overview says panels will not accept wholly unsupported allegations of illegal activity, even when the respondent is in default. If your customers or suppliers receive fake invoices, keep the emails and the invoices before you file.
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 2.13: How do panels treat complainant claims of illegal activity in relation to potential respondent rights or legitimate interests?
- Section 3.4: Can the use of a domain name for purposes other than hosting trademark-abusive content constitute bad faith?
- Section 3.1.4: How does a complainant prove that a 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?
Who decided the case?
A single panelist, Lynda M. Braun, decided the case on 14 October 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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