WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Vivid Seats LLC v. Carolina Rodrigues, Fundacion Comercio Electronico Case No. D2019-1115 1. The Parties

The Complainant is Vivid Seats LLC, United States of America (the “United States”), represented by Norvell IP llc, United States.

The Respondent is Carolina Rodrigues, Fundacion Comercio Electronico, Panama. 2. The Domain Name and Registrar

The disputed domain name (the “Domain Name”) is registered with GoD, LLC (the “Registrar”). 3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 14, 2019. On May 15, 2019, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On May 16, 2019 the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details.

The Center verified that the 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 May 21, 2019. In accordance with the Rules, paragraph 5, the due date for Response was June 10, 2019. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 17, 2019.

The Center appointed Gareth Dickson as the sole panelist in this matter on July 1, 2019. 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 was founded in 2001 and sells tickets to events in the United States and Canada. It owns numerous federal trademark registrations and applications in the United States, Canada and other countries for VIVID SEATS, including United States registration numbers:

- 3,614,140, registered on April 28, 2009, and
- 5,193,840, registered on May 02, 2017,
(together, “the Marks”).

The Respondent registered the Domain Name on February 22, 2019. Currently, the Domain Name seems to have a dynamic redirection directing Internet users for example either: to a third party online ticket resale marketplace that competes with the Complainant, or to a website that is seemingly associated with malware. 5. Parties’ Contentions A. Complainant

The Complainant contends that the Domain Name is a common misspelling of the Marks and that the Respondent is typo-squatting. It alleges that the Domain Name has been used for websites associated with malware in the past and that it is currently being used to either compete with the Complainant or to redirect Internet users to another website associated with malware.

The Complainant provides evidence of the Respondent having been ordered to transfer domain names in at least 20 UDRP proceedings within the last 18 months, and of the Respondent’s many registrations of domain names featuring common misspellings of trade marks.

The Complainant states that the Respondent is not affiliated with or connected to the Complainant in any way and has not been given any permission to use the Marks, in the Domain Name or otherwise, nor is there any evidence that the Respondent has been commonly known by the Domain Name or that it has any rights or legitimate interests in respect of it. It argues that the Respondent must have been