Sandals Resorts International 2000 Inc. filed a UDRP against the domain BeachesBusinessServices.com, owned by Rebecca Alldritt of Australia.
Complainant operates its well-known all-inclusive “Beaches Resorts” brand and holds multiple BEACHES and BEACHES RESORTS trademarks dating back to 1998. It argued that the domain incorporated its mark in full and would confuse users seeking corporate or group travel services offered by the company. Respondent filed no reply.
The WIPO Panel acknowledged the Complainant’s long-standing rights in BEACHES but emphasized that “beaches” is a common dictionary word with inherently low distinctiveness. The domain name added two descriptive terms—“business” and “services”—forming a phrase frequently used by unrelated companies. With no evidence that the domain was registered to exploit Sandals’ reputation or that it was ever used beyond a passive holding page, the Panel found no proof of bad faith registration or use.
It’s worth noting that the Complainant owns and operates the domain Beaches.com.
Final decision: the Complaint was denied and BeachesBusinessServices.com remains with the Respondent.
Copyright © 2025 DomainGang.com · All Rights Reserved.ARBITRATION AND MEDIATION CENTER
ADMINISTRATIVE PANEL DECISION
Sandals Resorts International 2000 Inc. v. Rebecca Alldritt, Beaches Business Services
Case No. D2025-29901. The Parties
The Complainant is Sandals Resorts International 2000 Inc., Panama, represented by Dechert LLP, United Kingdom.
The Respondent is Rebecca Alldritt, Beaches Business Services, Australia.
2. The Domain Name and Registrar
The disputed domain name beachesbusinessservices.com is registered with Squarespace Domains II LLC (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 28, 2025. On July 28, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 28, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent and contact information in the Complaint. The Center sent an email communication to the Complainant on July 29, 2025 providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on July 29, 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”).
In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on August 4, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 24, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Parties of the Respondent’s default on August 26, 2025.
The Center appointed Ingrīda Kariņa-Bērziņa as the sole panelist in this matter on September 5, 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 operates holiday resorts in various locations internationally under the “Beaches Resorts” brand. It is the proprietor of several trademark registration, including the following:
– United Kingdom Trade Mark No. UK00900169995 for BEACHES (device mark), registered on June 5, 1998 for goods and services in classed 16, 25, 28, and 42;
– European Union Trade Mark No. 009401357 for BEACHES (word mark), registered on March 22, 2012 for services in classes 35, 39, 41, 43, and 44;
– European Union Trade Mark No. 014605513 for BEACHES RESORTS BY SANDALS (device mark), registered on February 8, 2016 for goods and services in classes 16, 25, 35, 36, 39, 41, 43, 44, and 45.
The disputed domain name was registered on April 13, 2025. At the time of the Complaint and this Decision, it resolved to a holding page.
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 name.
Notably, the Complainant contends that it has operated a business offering international resort holidays under the BEACHES RESORTS marks since 1997 in locations including Turks & Caicos, Jamaica and the Bahamas. The Complainant markets its resorts worldwide and offers specific services for corporate and business clients, which comprise a meaningful part of the Complainant’s business. The disputed domain name reflects the Complainant’s BEACHES mark, in which it has developed goodwill and a reputation, along with the descriptive terms “business” and “services,” which are likely to confuse Internet users seeking information about the Complainant’s services for business clients.
The Respondent is not commonly known by the disputed domain name and is not affiliated with the Complainant, nor does it have any authorization to use the Complainant’s mark. The website at the disputed domain name lacks content, and there is no evidence to suggest that the Respondent registered the disputed domain name to pursue legitimate interests or to offer legitimate goods or services in good faith. The disputed domain name is being held for the purpose of likely future use that will tarnish and dilute the Complainant’s well-known marks and confuse Internet users. The Respondent has shielded its identity by using a privacy service.
B. Respondent
The Respondent did not reply to the Complainant’s contentions.
6. Discussion and Findings
Paragraph 4(a) of the UDRP requires the Complainant to make out all three of the following:
(i) the disputed domain name is identical or confusingly similar to a 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 Respondent has registered and is using the disputed domain name in bad faith.
Under paragraph 15(a) of the Rules, “[a] Panel shall 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”.
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 of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“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 entirety of the Complainant’s BEACHES mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.
Although the addition of other terms (here, “business services”) may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.
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 Respondent 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 proving 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 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 that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise.
The Panel notes the Respondent’s name provided by the Registrar does not resemble the disputed domain name, but that the Respondent Organization is listed as “Beaches Business Services.” There is no evidence indicating that the Respondent is commonly known by these terms. WIPO Overview 3.0, section 2.3.
The Panel further notes that the website linked to the disputed domain name is a holding page. The record therefore does not provide a basis to conclude that the Respondent is using or preparing to use the disputed domain name for any genuine offering of goods or services. WIPO Overview 3.0, section 2.2.
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.
However, the evidence in the case file as presented does not provide the Panel with a basis to conclude that the Respondent’s aim in registering the disputed domain name was to profit from or exploit the Complainant’s trademark. The Complainant’s BEACHES mark corresponds to an dictionary word in the English language, and, in that respect has low distinctiveness – the Panel recognizes however that as applied to the services provided, as shows in the record, the Complainant has acquired significant renown and therefore distinctiveness in the BEACHES mark.
The evidence available does not however indicate that the Complainant has used its mark in connection with the terms “business services”. The Panel also notes that a quick Google search shows a number of businesses using the terms “beach” or “beaches” together with “business services.” As the disputed domain name is not being used, there is insufficient evidence for the Panel to find bad faith registration of the disputed domain name. Under these circumstances, the Panel is unable to find that the Complainant has proved that the registration and passive holding of the disputed domain name is indicative of bad faith. WIPO Overview 3.0, section 3.3.
On this record, the Panel is also unable to conclude that the possible future use of the disputed domain name constitutes a basis to find tarnishment of the Complainant’s mark. WIPO Overview 3.0, section 3.12.
The Panel finds the third element of the Policy has not been established.
7. Decision
For the foregoing reasons, the Complaint is denied.
/Ingrīda Kariņa-Bērziņa /
Ingrīda Kariņa-Bērziņa
Sole Panelist
Date: September 18, 2025
