The Original Roof Store —
Florida's First Since 1994

The Roof Store is aware of at least two business entities that have adopted names or domain registrations confusingly similar to "The Roof Store" and that actively market roofing products or services into the State of Florida — the same primary geographic market in which The Roof Store has operated continuously since our domain registration on July 29, 2002.

Both registrations were made after theroofstore.net had already established over 20 years of unbroken commercial use and digital footprint. Any standard domain availability check, WHOIS query, or registrar search system conducted at or before the time of registration would have revealed the existence of theroofstore.net and its long-established commercial use.

Under the willful blindness doctrine — recognized by UDRP panels and U.S. federal courts — deliberate avoidance of a readily available search, or failure to conduct one, does not constitute good faith and may itself constitute evidence of bad faith registration. A registrant cannot claim ignorance of a prior mark when basic due diligence would have revealed its existence. This is sometimes referred to as the "ostrich approach" and has been consistently rejected by WIPO and Forum arbitrators in UDRP proceedings.

The geographic overlap — both parties selling into Florida, our established and primary market — provides additional grounds supporting a finding of intentional bad faith targeting and likely consumer confusion as to source, sponsorship, or affiliation, consistent with UDRP Policy ¶4(b)(iii) and ¶4(b)(iv).