The Elizabeth Taylor Trust, along with related entities, filed a complaint over the domain ElizabethTaylor.ai, registered in September 2024 by a Florida resident. The domain pointed to a GoDaddy pay-per-click page with ads for perfumes, gowns, and jewelry—categories tied closely to the Elizabeth Taylor brand.
The panel found the domain identical to the ELIZABETH TAYLOR mark, with no rights or legitimate interests shown by the respondent. Given Elizabeth Taylor’s global fame and longstanding trademark rights, it was deemed implausible that the registrant was unaware of the name’s significance. The panel held that the domain was registered and used in bad faith to divert traffic for commercial gain.
Ultimately, the panel granted the transfer of the domain ElizabethTaylor.ai to the Complainant. The decision matches that of a recent UDRP won by the Trust, for the domain HouseOfTaylor.info.
Copyright © 2025 DomainGang.com · All Rights Reserved.The Elizabeth Taylor Trust, Interplanet Productions Limited and The Elizabeth Taylor Cosmetics Company v. Shawn Rucks
Claim Number: FA2507002166852
PARTIES
Complainants are The Elizabeth Taylor Trust, Interplanet Productions Limited and The Elizabeth Taylor Cosmetics Company (“Complainant”), represented by Stephen J. Strauss of BUCHALTER, California, USA. Respondent is Shawn Rucks (“Respondent”), Florida, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is elizabethtaylor.ai, registered with GoDaddy.com, LLC.
PANEL
The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.
James Bridgeman SC as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on July 21, 2025; Forum received payment on July 21, 2025.
On July 22, 2025, GoDaddy.com, LLC confirmed by e-mail to Forum that the elizabethtaylor.ai domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, LLC 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 July 24, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 13, 2025 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@elizabethtaylor.ai.
Also on July 24, 2025, 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 August 14, 2025, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, Forum appointed James Bridgeman SC 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 Complainants but has not identified any Complainant to receive the transfer. In these circumstances the Panel directs that the disputed domain name be transferred to the first named Complainant: The Elizabeth Taylor Trust.
PRELIMINARY ISSUE: MULTIPLE COMPLAINANTS
Rules 10(e) permits the panel to decide a request by a party to “consolidate multiple domain name disputes in accordance with the Policy and these Rules”.
The first named Complainant is the owner, in trust, of the personality name of the late Elizabeth Taylor as evidence by the registration of a claim as successor-in-interest filed with the Secretary of State, State of California on April 1, 2011. The second and third named Complainants are registered owners of registrations for the ELIZABETH TAYLOR mark in the United States of America.
Consolidating the complaints presents no prejudice to Respondent and is an efficient manner of dealing with the claims made by the three Complainants.
At the request of the Parties, and in the absence of any objection from Respondent, this Panel accepts and admits the Complaint and consolidates the claims brought by the three Complainants in accordance with Rule 10(e).
Furthermore, as Complainants have not identified the entity to which they wish the disputed domain name to be transferred, this Panel directs that that it should be transferred to the lead Complainant.
PARTIES’ CONTENTIONS
A. Complainant
Complainants claim rights in the ELIZABETH TAYLOR trademark established by their ownership of the trademark registrations described below and extensive use of the mark through licensing of the mark and the manufacture and of cosmetics, perfumes, and skin care products under the ELIZABETH TAYLOR trademark.
Complainants submit that they have an established Internet presence and operate websites and domain names associated with the ELIZABETH TAYLOR brand, including those used for commercial and promotional purposes.
Complainants assert that their brand is associated with the legacy of the late actor Ms Elizabeth Taylor, one of the most recognized personalities worldwide who died in March 23, 2011; and further submit that they and their predecessors in title have used the ELIZABETH TAYLOR mark extensively in commerce since the 1980s. The mark has been featured in globally distributed product lines, including a successful range of perfumes and colognes.
Complainants submit that they include entities that manage Ms Taylor’s estate and commercial rights, and they maintain a global presence through licensing and promotional activities. While specific figures such as annual revenue, marketing spend, or number of employees are not provided in the Complaint, the brand’s reputation is supported by widespread media coverage and longstanding commercial use.
In this regard in an annex to the Complaint, Complainants exhibit a copy of an article available on the Internet describing the jewelry collection of the famous actor the late Ms Elizabeth Taylor
Complainants firstly allege that the disputed domain name is identical to the ELIZABETH TAYLOR mark as it consists of the mark in its entirety with no additional textual elements, together with the generic Top-Level Domain (“gTLD”) extension .ai.
Complainants secondly allege that Respondent has no rights or legitimate interests in the disputed domain name because:
· Respondent is not affiliated with Complainants and has not been authorized to use the ELIZABETH TAYLOR mark;
· Respondent has not been commonly known by the disputed domain name;
· Respondent was aware of Complainants’ mark prior to the registration of the disputed domain name;
· Respondent has made no demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services;
· the disputed domain name resolves to a GoDaddy pay-per-click landing page with links to third-party websites selling men’s colognes, evening gowns, and jewelry, which are unrelated to Complainants’ products as shown in a screen capture exhibited in an annex to the Complaint;
· Respondent’s use of the disputed domain name is neither a legitimate noncommercial nor fair use under Policy ¶ 4(c)(iii).
Complainants thirdly alleges that the disputed domain name was registered and is being used in bad faith, arguing that Respondent had actual knowledge of Complainants’ rights in the ELIZABETH TAYLOR mark at the time of registration of the disputed domain name.
Complainants assert that Respondent registered the disputed domain name to attract internet users seeking Complainants’ products, deriving commercial benefit from click-through fees.
Alternatively, Complainants argue that the passive holding of the disputed domain name constitutes bad faith, citing the panel decision in Volvo Trademark Holding AB v. Nicklas Uvelov, WIPO Case D2002-0521 (“[I]t is becoming an established principal of this procedure under UDRP that merely holding an infringing domain name without use, can constitute use in bad faith.”).
Moreover, Complainants argue that there is no conceivable active use of the disputed domain name that would not infringe Complainants’ rights.
Complainants add that Respondent’s unauthorized elizabethtaylor.ai domain usurps Complainants’ rights in their ELIZABETH TAYLOR mark, and blocks their ability to control use of the mark as a domain name.
In conclusion Complainants submit that Respondent benefits commercially from confusion caused by the disputed domain name, which is confusingly similar to Complainants’ ELIZABETH TAYLOR mark.
B. Respondent
Respondent failed to submit a Response in this proceeding.
FINDINGS
Complainants are engaged in the manufacture and licensing of cosmetics, perfumes, and skin care products under the ELIZABETH TAYLOR trademark.
The first named Complainant is the owner, in trust, of the personality name of the late Elizabeth Taylor as evidence by the registration of a claim as successor-in-interest filed with the Secretary of State, State of California on April 1, 2011.
The Second Named Respondent is the registered owner of:
· United States trademark registration ELIZABETH TAYLOR, registration number 4,579,717, registered on the Principal Register, on August 5, 2014 for goods in international class 9;
· United States trademark registration ELIZABETH TAYLOR, registration number 6,591,384, registered on the Principal Register, on December 14, 2021 for goods in international class 16.
The third named Complainant is the registered owner of:
· United States trademark registration ELIZABETH TAYLOR, registration number 1,827,152, registered on the Principal Register, on March 22, 1994 for goods in international class 3;
· United States trademark registration ELIZABETH TAYLOR, registration number 2,162,334, registered on the Principal Register, on June 2, 1998, for goods in international class 3.
Complainants have an established Internet presence and operate websites and domain names associated with the ELIZABETH TAYLOR brand, including those used for commercial and promotional purposes.
The disputed domain name elizabethtaylor.ai was registered on September 15, 2024, and resolves to a GoDaddy pay-per-click landing page featuring links to third-party websites selling men’s colognes, evening gowns, and jewelry unrelated to Complainants’ products.
There is no information available about Respondent, except for that provided in the Complaint, the Registrar’s WhoIs for the disputed domain name, and the Registrar’s response to the request by Forum for details of the registration of the disputed domain name for the purpose of this proceeding.
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
Complainants have provided uncontested convincing evidence of their concurrent rights in the ELIZABETH TAYLOR trademark established by their ownership of the abovementioned trademark registrations and extensive use of the mark in their businesses of licensing the mark and the manufacture of cosmetics, perfumes, and skin care products.
The disputed domain name elizabethtaylor.ai is identical to the ELIZABETH TAYLOR trademark; and in the circumstances of this Complaint the gTLD extension .ai within the disputed domain name may be ignored for the purposes of comparing the mark and the disputed domain name, because it would be considered by Internet users to be a necessary technical element for a domain name.
This Panel finds therefore that the disputed domain name is identical to the ELIZABETH TAYLOR mark in which Complainants have rights and Complainants have therefore succeeded in the first element of the test in Policy ¶ 4(a)(i).
Rights or Legitimate Interests
In its Complaint, Complainant has made out a prima facie case that Respondent has no rights legitimate interests in the disputed domain name as set out in Complainant’s detailed submissions above.
The trademark and personality rights in ELIZABETH TAYLOR mark are long established; Respondent has no rights in the mark and is using the mark only to attract Internet traffic to the Registrar’s parking page from which Respondent is on the balance of probabilities receiving unauthorized revenue.
It is well established that once a complainant makes out a prima facie case that a respondent has no rights or legitimate interests in the domain name at issue, the burden of production shifts to the respondent to prove its rights or legitimate interests.
Respondent has failed to discharge that burden and therefore this Panel must find that Respondent has no rights or legitimate interests in the disputed domain name.
Complainant has therefore succeeded in the second element of the test in Policy ¶ 4(a)(ii).
Registration and Use in Bad Faith
The late actor Elizabeth Taylor achieved global fame in her career. Her name is distinctive and the successors in title to her personality rights and trademark rights acquired for merchandizing, jeweler in the present case, have been maintained and actively promoted by Complainants.
It is improbable that the registrant of the disputed domain name was unaware of Complainants’ mark when the disputed domain name was chosen and registered on September 15, 2024.
There appears to be therefore no plausible reason for registering the disputed domain name other than to create an association with Complainants and their ELIZABETH TAYLOR mark. Respondent’s use of the disputed domain name to resolve to the Registrar’s parking page is consistent with this finding.
On the balance of probabilities, therefore, this Panel finds that the disputed domain name was chosen and registered with Complainants mark in mind with the intention of taking predatory advantage of Complainants’ rights and goodwill in the ELIZABETH TAYLOR mark.
The uncontested evidence in the form of the screen capture of the webpage to which the disputed domain name resolves shows that Respondent has caused, permitted or allowed the disputed domain name to resolve to the Registrar’s parking page which contains unauthorized links to third party websites.
On the balance of probabilities Respondent is receiving pay-per-click revenue from the traffic that is being diverted to Respondent’s parking page.
This Panel finds therefore that Respondent is using the disputed domain name intentionally to attract and confuse Internet users and cause them to divert their Internet traffic intended for Complainant and misdirect it to Respondent’s website by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s web site which constitutes bad faith for the purposes of the Policy.
As this Panel has found that the disputed domain name was registered and is being used in bad faith, Complainant has succeeded in the third element of the test in 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 elizabethtaylor.ai domain name be TRANSFERRED from Respondent to Complainant: The Elizabeth Taylor Trust.
James Bridgeman SC
Panelist
Dated: August 15, 2025
