Bausch & Lomb Incorporated successfully secured the transfer of the disputed domain <preservisions.site> from Respondent 柳传榜 (liu chuan bang). The Respondent registered the domain to build a clone website that mimicked Bausch & Lomb’s brand assets to sell eye vitamins. Panelist Karen Fong ruled in favor of the Complainant, ordering a full transfer of the domain.
Case Snapshot
| Case Number | D2025-4468 |
|---|---|
| Complainant | Bausch & Lomb Incorporated |
| Respondent | 柳传榜 (liu chuan bang) |
| Disputed Domain | preservisions.site |
| Threat Tactic | Fake Stores |
| Decision Date | 2026-01-06 |
| Panelist | Karen Fong |
| Outcome | Transfer |
| Official Source | https://www.wipo.int/amc/en/domains/search/text.jsp?case=D2025-4468 |
E-Commerce Impersonation and Typosquatting Risks in the Healthcare Sector
The registration of the typosquatted domain <preservisions.site> by a China-based respondent highlights the severe commercial threat posed by lookalike e-commerce storefronts targeting established healthcare brands. By adding a minor plural ‘s’ to the PRESERVISION mark, which Bausch & Lomb has used since 2001 and registered as a US trademark in 2003, the respondent capitalized on common user typographical errors. The resulting website prominently displayed the authentic trademark, mimicked the brand’s layout, and used genuine product imagery to pretend to sell authorized eye vitamins. This highly targeted impersonation tactic creates immediate customer-trust risks, potentially diverting consumers looking for genuine healthcare products to unauthorized, unverified online storefronts.
For brand owners, the unauthorized replication of digital assets and product catalogs erodes brand equity and threatens client relationships. While there is no direct evidence in the case record of consumers purchasing counterfeit vitamins, suffering physical harm, or falling victim to email phishing schemes, the structural layout of the clone shop was designed specifically to exploit consumer confusion for commercial gain. This form of brand dilution and traffic diversion forces corporate IP departments to bear substantial administrative and legal burdens. Brands must continuously monitor registrar databases to identify infringing domains before they can capture significant traffic or cause unquantified financial damage.
To counter the fake store threat, the Complainant deployed a multi-stage defense strategy that combines immediate host-level intervention with formal administrative litigation. Before the final WIPO UDRP decision was rendered by panelist Karen Fong, Bausch & Lomb successfully notified the third-party web host to take down the unauthorized content. However, while host-level takedowns provide rapid temporary relief by disabling the active website, brand owners must still pursue a full domain transfer through the UDRP process. Securing the transfer of <preservisions.site> prevents the respondent from simply pointing the typosquatted domain to an alternative hosting provider, permanently neutralizing the specific threat vector.
Panelist Analysis of Confusing Similarity, Legitimate Interests, and Bad Faith Registration
In analyzing the first element of the Policy, Panelist Karen Fong determined that the disputed domain name <preservisions.site> is confusingly similar to Bausch & Lomb’s registered PRESERVISION trademark. The addition of the single letter ‘s’ to pluralize the mark and the use of the generic top-level domain ‘.site’ do not alter the overall commercial impression of the domain name. The core of the trademark remains fully recognizable within the string, which is insufficient to avoid a finding of confusing similarity.
Under the second element, the Panel found that the Respondent, 柳传榜 (liu chuan bang), held no rights or legitimate interests in the domain name. Bausch & Lomb established that it had not authorized or licensed the Respondent to use its PRESERVISION mark, which was registered in the United States under Registration No. 2696725 in 2003. Furthermore, the Respondent was not commonly known by the name and instead used the domain to host an unauthorized storefront that cloned the Complainant’s visual assets and product imagery to falsely purport to sell eye vitamins.
The assessment of registration and use in bad faith relied heavily on the evidence of active brand impersonation. By deploying a website that prominently displayed the PRESERVISION trademark and copied Bausch & Lomb’s proprietary images and content, the Respondent intentionally attempted to attract internet users for commercial gain by creating confusion. Although the Complainant initiated a successful web-host takedown of the site prior to the panel’s decision, the historical operation of this fake shop established clear bad faith registration and use.
Procedurally, the case highlights how panels handle administrative language barriers. While the registration agreement with Alibaba Cloud Computing Ltd was in Chinese, the Complainant’s request to proceed in English was accepted. Because the Respondent failed to object or reply to any communications, and because WIPO issued notifications in both languages, conducting the proceeding in English maintained administrative efficiency without prejudice to either party.
Proactive Hosting Takedowns and Strategic Procedural Choices
Bausch & Lomb Incorporated executed a highly effective two-tiered enforcement strategy that combined an immediate hosting-level intervention with a structured UDRP filing. Upon discovering that the disputed domain name <preservisions.site> resolved to an unauthorized lookalike store mimicking the authentic PRESERVISION eye vitamin brand, the complainant quickly notified the third-party web host. This swift notification resulted in the site being taken down prior to the panel’s final decision, mitigating immediate business risks such as consumer diversion and trademark erosion. However, rather than relying solely on the temporary relief of a host-level takedown, the brand owner pursued a UDRP action to permanently secure the transfer of the domain, neutralizing the threat of the respondent, 柳传榜 (liu chuan bang), simply point-redirecting the domain to a new host in the future.
The persuasiveness of the complainant’s case rested on robust evidentiary submissions and decisive procedural management. Bausch & Lomb established its long-standing trademark rights by citing its PRESERVISION marks registered as early as March 11, 2003, and documented the respondent’s bad faith by capturing evidence of the clone store’s unauthorized use of authentic product imagery and trademarked branding. Furthermore, the complainant successfully navigated a potential procedural hurdle regarding the language of the proceeding. Despite the registrar, Alibaba Cloud Computing Ltd, utilizing a Chinese registration agreement, the complainant preemptively requested English as the language of the proceeding. This procedural request went unopposed by the defaulting respondent, allowing the case to proceed efficiently in English and securing a favorable transfer order from panelist Karen Fong without administrative delays.
Practical Recommendations
- Deploy immediate hosting-level takedown notices as a rapid first-line defense to dismantle clone web stores (such as <preservisions.site>) while concurrently preparing a formal UDRP complaint.
- Archive comprehensive, time-stamped screenshots and source code copies of the infringing website prior to executing hosting takedowns, ensuring robust evidence of bad faith use is preserved for the UDRP panel even if the site goes offline.
- Proactively request English as the language of the UDRP proceeding when dealing with foreign registrars (such as Alibaba Cloud Computing Ltd) by demonstrating that the disputed domain specifically targets English-speaking consumers and utilizes English-language brand assets.
- Expand defensive brand monitoring portfolios and domain surveillance to include pluralized variations (adding ‘s’) and cost-effective gTLDs (like ‘.site’) of primary product-level trademarks to pre-empt typosquatting and fake shop registrations.
Frequently Asked Questions (FAQ)
Why was the domain ‘preservisions.site’ considered confusingly similar to the PRESERVISION trademark?
The panel determined that the addition of the letter ‘s’ to the trademark and the use of the generic top-level domain ‘.site’ were insufficient to distinguish the domain from Bausch & Lomb’s registered PRESERVISION mark, creating a high likelihood of confusion for consumers.
What evidence established the Respondent’s bad faith in this case?
Bad faith was proven by the Respondent’s creation of a clone website that prominently displayed Bausch & Lomb’s trademark, utilized the company’s proprietary product imagery and content, and falsely purported to sell authentic PRESERVISION eye vitamins for commercial gain.
How did the Complainant effectively counter the fake shop before the UDRP decision was finalized?
Bausch & Lomb took proactive steps by identifying the third-party web host hosting the infringing content and issuing a takedown notice. This immediate administrative action successfully disabled the fraudulent website while the formal legal UDRP proceedings to secure the domain transfer were still ongoing.
How were potential linguistic barriers managed during the UDRP process?
Although the domain’s registration agreement was in Chinese, the Complainant requested that the proceedings be conducted in English. The respondent failed to object or participate, allowing the panel to proceed in English to ensure an efficient resolution of the case.
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This case note is for informational purposes only and is not legal advice.
