Contrived Complaint or Unsuccessful Complaint? – vol. 5.37

Ankur RahejaUDRP Case Summaries Leave a Comment

Contrived Complaint or Unsuccessful Complaint?

When it comes to RDNH, I have consistently said that while Panelists are required to consider it when appropriate, RDNH is ultimately a matter of Panelist discretion having regard to the circumstances. Here, it appears that the Complainant apparently fumbled the case by failing to provide evidence of common law trademark rights, and as the Panelist noted should have known that the case could not succeed absent such evidence. That in and of itself could qualify as an abuse of the UDRP procedure because proceeding headlong with a Complaint that relies on unproven common law trademark rights is inexcusable after 25 years of the UDRP. As such, the Panelist should have considered RDNH, as the Panelist did. Continue reading commentary here. 

We hope you will enjoy this edition of the Digest (vol. 5.37) as we review these noteworthy recent decisions with expert commentary. (We invite guest commenters to contact us):

Contrived Complaint or Unsuccessful Complaint? (neubird .com *with commentary

Is the Domain Name “Similar” or “Confusingly Similar”? (nutanx .com *with commentary

Is TANGLY Confusingly Similar to Complainant’s TANGO Mark? (tangly .org *with commentary

Cumulative Requirement of Bad-Faith Registration and Use under the UDRP (onetile .com

Panel: Respondent Put to Trouble; Case Should Never Have Been Brought Under the Policy (magicmen .com *with commentary


Contrived Complaint or Unsuccessful Complaint?

NeuBird, Inc. v. Xiong Dao Hua, NAF Claim Number: FA2508002169241

<neubird .com>

Panelist: Mr. Eugene I. Low

Brief Facts: The Complainant develops and provides generative AI solutions for IT operations. The Complainant has used the NEUBIRD trademark since at least 2023 and has actively promoted its services under that mark. The Complainant also owns and operates the website <neubird .ai>, registered on April 15, 2023. The Complainant has a pending federal trademark application for NEUBIRD. The Complainant also asserts that, through significant marketing expenditures, it has developed consumer recognition and goodwill in the NEUBIRD mark in connection with its goods and services. The Complainant was also the prior owner of the disputed Domain Name, <neubird .com>, but its ownership accidentally lapsed. The Respondent purchased the disputed Domain Name on November 14, 2024, and used it for Respondent’s company official website to promote and sell its products.

The Complainant alleges that the disputed Domain Name was on offer for US $3195 in 2023. However, the Respondent offered to sell the domain for US $25,000 on November 4, 2024. When the Complainant indicated that it would not pay over US $3,000, the Respondent then threatened that the fee would likely go up to US$ 100,000 “in 6 months.” Furthermore, Respondent’s establishment of a sham adult products site after the Complainant first refused Respondent’s extortionate demands is further evidence of the bad faith. The Respondent contends that the Complainant negotiated the price of the disputed Domain Name with the domain name broker through email, which has nothing to do with the Respondent. The Respondent further contends that he registered the trademark NEUBIRD in China on March 12, 2025 under class 10.

Held: The Complainant provides evidence that it has a pending trademark application for NEUBIRD before the USPTO, for which a Notice of Allowance has been issued. Contrary to the Complainant’s contentions, it is the prevailing view in UDRP proceedings that a pending trademark application would not by itself establish trademark rights under the first element. Further, as regards the common law rights claim, the Panel would have expected evidence in the form of marketing materials, media publications, customer testimonials, etc. since 2023.

However, the Complainant has failed to provide any evidence to support those assertions, save for three hyperlinks to alleged media publications (two of those hyperlinks are directed to webpages which indicate that the original contents were no longer available; the remaining hyperlink is directed to an article dated July 10, 2025). The Complainant also claimed to be a prior registrant of the disputed Domain Name, but again failed to provide any supporting evidence. In the Panel’s view, clearly there is insufficient evidence for the Panel to find that the Complainant has established common law rights in the NEUBIRD trademark.

RDNH: The Panel makes a finding of RDNH against the Complainant. The Complainant, especially since it is legally represented, should have been aware that this Complaint could not have reasonably succeeded – not least because of the almost complete lack of supporting evidence. In addition, this case smells of the Plan B scenario where the Complainant is resorting to a contrived UDRP after unsuccessful attempts at purchasing the disputed Domain Name.

Complaint Denied (RDNH)

Complainant’s Counsel: Todd Marabella of Goodwin Procter LLP, USA
Respondent’s Counsel: Self-represented

Case Comment by ICA General Counsel, Zak Muscovitch: When it comes to RDNH, I have consistently said that while Panelists are required to consider it when appropriate, RDNH is ultimately a matter of Panelist discretion having regard to the circumstances. Here, it appears that the Complainant apparently fumbled the case by failing to provide evidence of common law trademark rights, and as the Panelist noted should have known that the case could not succeed absent such evidence. That in and of itself could qualify as an abuse of the UDRP procedure because proceeding headlong with a Complaint that relies on unproven common law trademark rights is inexcusable after 25 years of the UDRP. As such, the Panelist should have considered RDNH, as the Panelist did.

Nevertheless, at the admitted disadvantage of not having seen the pleadings unlike the Panelist, the Complainant’s allegations of “a sham adult products site” is compelling, having visited the website. It may very well have been that the Respondent’s conduct evidenced a scheme to register and sell the Domain Name back to the Complainant, rather than this being a “contrived Complaint” as concluded by the Panelist. It would however have been up to the Complainant to make this case and it apparently didn’t succeed in convincing the Panel. Perhaps greater investigation of the Respondent could have resulted in evidence demonstrating that the website was in fact a sham, for example, there is a nearly identical website located here: drimco .com. There is of course the matter of the Respondent’s registered trademark, but that too could have been part of the scheme.

The Complainant may have avoided a finding of RDNH by doing a little more research into the Respondent and presenting that research to the Panel.  The little bit of independent research that I conducted suggested that the Respondent’s hands may not be clean here.  Had the Panel been aware of the entirety of the circumstances, it may have determined that the Complaint did not warrant a finding of RDNH.


Is the Domain Name “Similar” or “Confusingly Similar”? 

Nutanix, Inc. v. Domain Admin / HugeDomains .com, NAF Claim Number: FA2507002167865

<nutanx .com>

Panelists: Mr. Alan L. Limbury, The Honorable Neil Anthony Brown KC and Mr. Fernando Triana (Chair)

Brief Facts: The Complainant is a publicly traded cloud computing company that sells software, cloud services and software-defined storage, all under the trademark NUTANIX. The Complainant has a worldwide presence with over 65 offices and hosts its website, at <nutanix .com> (registered on September 20, 2009). The Complainant owns rights in the trademark NUTANIX based on the international registration in class 9, dated November 16, 2011, in numerous jurisdictions. The disputed Domain Name was registered on July 6, 2025. The Complainant alleges that the disputed Domain Name consists of a misspelling of the Complainant’s trademark and that the Respondent is not using the disputed Domain Name in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, the disputed Domain Name is listed as for sale which shows neither a bona fide offering of goods nor services under the Policy.

The Respondent contends that the Complainant’s trademark NUTANIX is neither identical nor confusingly similar to the disputed Domain Name. The term “Nutan” has legitimate meaning and usage across diverse industries and regions. The Respondent is a bona fide domain reseller; the acquisition and holding of valuable domain names for resale constitutes a legitimate business. The disputed Domain Name was registered as part of a generalized business model targeting short, brandable names across the tech, health, financial, and consumer sectors. The Respondent did not initiate contact with the Complainant, did not attempt to sell the domain name to the Complainant, and has not used the domain name to redirect or harm the Complainant’s business. Accordingly, the domain name was simply listed for sale as part of the Respondent’s publicly available inventory, consistent with routine business operations.

Held: The Complainant proved its rights in the trademark NUTANIX in international class 9. The registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive. Therefore, the Panel concludes that the Complainant has demonstrated rights in the trademark NUTANIX for purposes of Paragraph 4(a)(i) of the Policy. Further, the Complainant alleges that the disputed Domain Name is confusingly similar to the trademark NUTANIX. The Panel by a majority considers that the reproduction of the trademark NUTANIX, with the exclusion of one letter, or intentional misspelling of  the disputed Domain Name <nutanx .com>, is sufficient ground to establish that the disputed Domain Name is confusingly similar to the trademark, see WIPO Overview, section 1.19. Especially since the Complainant’s trademark is clearly recognizable in the disputed Domain Name.

The Complainant also failed to prove the Respondent’s lack of rights or legitimate interests. Moreover, the Panel notes that, while the Respondent does not deny that the disputed Domain Name is currently inactive, it has shown that its business is operating as a domain name reseller and it has been held on many prior occasions that a registrant in that position may well have a right or legitimate interest in the domain name. The Panel finds that Respondent’s evidence is persuasive on the issue of rights and legitimate interests. Although it is unnecessary to proceed further in analyzing the registration and use in bad faith, as the Complainant failed to establish the lack of rights or legitimate interest, it is important to point out that the Complainant did not provide any evidence to support its submission that the domain name was registered and used in bad faith.

RDNH: The Panel has not found it easy to reach a conclusion on this issue. On the one hand, the majority of the Panel has found that the domain name is confusingly similar to the trademark. On the other hand, the panel has unanimously found that the Respondent has rights and legitimate interests in the disputed Domain Name. The Panel has also found unanimously that there was no evidence offered by the Complainant that the domain name was registered and used in bad faith and its submissions to that effect were largely based on conjecture. On balance, the Panel finds that although it transpired that the Complainant’s case was weak, it was not harassment or bad faith to initiate the proceeding. The Panel therefore declines to make a finding of Reverse Domain Name Hijacking. On balance, the Panel finds that the Complaint was not brought in bad faith, in an instance of reverse domain name hijacking.

Dissenting Opinion: Panelist Brown does not agree with that conclusion under the first clause and would find that the disputed Domain Name is not confusingly similar to the trademark. It is similar, but it is not confusingly so, as it cannot be said on the balance of probabilities that internet users would see the domain name as confusingly similar to the trademark and that they would therefore be confused.

The disputed Domain Name does not entirely reproduce the trademark. Moreover, if the difference were simply that there was a minor difference in spelling with, for example, a singular in the trademark but a plural in the domain name, or vice versa, the domain name would probably be confusingly similar to the trademark, but in the present case the domain name seems to be essentially different to and distinctive from the trademark.

In that regard, the domain name seems to invoke a specific brand, the dominant feature of which is known as “NUTAN”, a word that stands easily on its own both visually and phonetically. Moreover, the presence of “x” in the domain name may well connote to internet users that it is new and thus different from the trademark, as it adopts the new practice of branding by adding to the name of enterprises.

Complaint Denied

Complainant’s Counsel: Allen J. Baden, USA
Respondent’s Counsel: Megan Long, USA

Case Comment by ICA General Counsel, Zak Muscovitch: The issue of “confusing similarity” is often given less attention than it deserves. Often, we see that despite the clear wording of the Policy which requires not mere similarity, but confusing similarity, Panelists will not fully examine this issue. It is therefore good to see that this issue is being considered in this case, despite the majority and minority reaching different conclusions on this issue.  Although the first part of the test can be considered preliminary in the sense that only an identical or confusingly similar trademark qualifies for a UDRP and thereby confers “standing” so that the Complainant can proceed onto the second and third parts of the test, it is no more nor less important than the other parts of the test. Panelists should apply an appropriate amount of focus on this part of the test as they do the other parts of the test.

As noted in UDRP Perspectives at 1.8, confusing similarity is a higher threshold than mere similarity but in most cases it is not a difficult test to meet. Where a domain name merely adds on a descriptive term such as “shop” or “store” to a distinctive trademark or where the domain name is a typo of a distinctive mark, Panels will generally find that a domain name is confusingly similar. Where however, the inclusion of additional characters or words results in a new term, a sufficiently different term, conveys a different meaning, or otherwise sufficiently differentiates or distances itself from the trademark, the domain name may not be confusingly similar. It was this subjective analysis that resulted in some disagreement amongst the Panelists.

Interestingly, the minority Panelist acknowledged that having undertaken an analysis to determine whether the Domain Name was similar or confusingly similar, that “the issue is not entirely free from doubt”, and ultimately found that on a balance of probabilities he could not make the determination of confusing similarity.


Is TANGLY Confusingly Similar to Complainant’s TANGO Mark?

LinkedIn Corporation v. Ludjon Roshi, WIPO Case No. D2025-3024

<tangly .org>

Panelist: Mr. Andrew D. S. Lothian

Brief Facts: The Complainant, founded in 2003, operates the world’s largest professional network on the Internet, with more than 1 billion members. On April 30, 2024, the Complainant announced that it would offer a number of games on its website. On October 8, 2024, the Complainant announced a logic game called “Tango.” The Complainant is the owner of UK Trademark for the word mark TANGO, dated March 21, 2025. The disputed Domain Name was registered on March 28, 2025. A screenshot submitted by the Complainant shows a webpage titled “Tango Game – Play Unlimited,” displaying a grid-formatted game. Directly beneath the game appears a message that refers to the Complainant.

The Complainant shows the Respondent was the respondent in a Policy case concerning <tangogame .org>, registered October 9, 2024. The Center disclosed the Respondent’s identity to the Complainant on March 27, 2025. The disputed domain here was registered the next day, one week after the Complainant’s TANGO mark was registered. The Complainant alleges that the disputed Domain Name constitutes an intentional misspelling of its said trademark, and thus is confusingly similar thereto, adding that the website at the disputed domain clearly targets the Complainant (and TANGO mark), and that two security vendors have flagged the website as “malicious,” and “malware” respectively.

The Respondent contends that “tangly” is an ordinary dictionary word meaning, and is unrelated to the Complainant’s brand name, adding that the overall look, sound and commercial impression of Tangly is distinct from TANGO. The Respondent further contends that players understand that the Respondent’s game has its own identity, and that they do not confuse it with the Complainant’s TANGO mark. With regard to the allegation that it is a cybersquatter, the Respondent submits that the settlement in the said previous case regarding <tangogame .org> was resolved amicably and without admission of liability, arguing that this is unrelated to the instant case, and noting that each case must be judged on its own facts.

Held: The Panel finds the mark is recognizable 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. The disputed Domain Name and the mark are phonetically similar, and are also alphanumerically identical in their first four letters, being four out of five letters in total in the case of the mark and four out of six letters in total in the case of the Second-Level Domain of the disputed Domain Name. The Panel is satisfied that at least a dominant feature of the relevant mark is recognizable in the domain name that is the subject of the comparison, such domain name will normally be considered confusingly similar to that mark for purposes of UDRP standing. WIPO Overview 3.0, section 1.7.

Further, the problem with the Respondent’s case is that the wording of paragraph 4(c)(i) of the Policy requires that it use the disputed Domain Name in connection with a bona fide offering of services, “before any notice to you of the dispute”. That could hardly be said in the present case, where the Respondent registered the disputed Domain Name the day after its identity was disclosed to the Complainant in connection with its registration of <tangogame .com>, following upon an earlier complaint under the Policy. Additionally, it cannot be overlooked that the Respondent named the site “Tango Game,” directly referencing the Complainant’s TANGO mark and showing the site was linked to that mark.

Finally, in all of the circumstances, the Panel considers that the Respondent’s actions in this case could not be considered registration and use of the disputed Domain Name in good faith, notably because, by using the disputed Domain Name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of such website, conform to paragraph 4(b)(iv) of the Policy. Panels have also held that the use of a domain name for illegitimate activity, here, claimed distribution of malware, can never confer rights or legitimate interests on a respondent and constitutes bad faith.

Transfer

Complainant’s Counsel: The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States
Respondent’s Counsel: Self-represented

Case Comment by ICA General Counsel, Zak Muscovitch: When considered in a vacuum (i.e. absent the circumstances of this case), one could reasonably conclude that TANGO and TANGLY are similar but not confusingly similar. One cannot, for example, identify TANGO within TANGLY, and TANGLY could easily form the basis for a distinctive brand unrelated to the Complainant’s TANGO brand for online games.

But alas, in the particular circumstances of the case, one must conclude that the Respondent’s selection of the Domain Name was an intentional effort to trade off of the Complainant’s TANGO goodwill by using TANGLY in connection with a similar game. Moreover, as the Panelist pointed out, “the Respondent registered the disputed Domain Name the day after its identity was disclosed to the Complainant in connection with its registration of <tangogame .com>”, and “it cannot be overlooked that the Respondent named the site “Tango Game,” directly referencing the Complainant’s TANGO mark and showing the site was linked to that mark”. So as far as the Respondent was concerned, the disputed Domain Name was confusingly similar, or it would not have been selected and not fit the Respondent’s purpose which was apparently to infringe upon the Complainant’s brand and to pass itself off as the Complainant.

Taking such evidence into account does, however, exceed the traditional “side-by-side comparison of the domain name and the trademark” alone. One could however, reasonably conclude, on the basis of a side-by-side comparison alone, that the two respective terms were “confusingly similar” in the sense that they shared a good portion if not the dominant aspect of the term. I think that in some cases, evidence beyond the side-by-side comparison can be useful, and indeed crucial in determining whether a domain name is confusingly similar.


Cumulative Requirement of Bad-Faith Registration and Use under the UDRP

One Click Tiles Srl v. GM Marble, WIPO Case No. D2025-2740

<onetile .com>

Panelist: Mr. Assen Alexiev

 Brief Facts: Founded in 2017, the Complainant claims to be a leading online distributor of floor and wall tiles, offering a wide range of products from porcelain to parquet. It has an online presence at <onetile .it>, registered on August 10, 2017. The Complainant also operates localized versions of its official website at the domain names <onetile .fr>, <onetile .com .au>, and <onetile .us>, which were registered at later points in time. The Complainant is also the owner of several trademark registrations for ONETILE, including the EU trademark ONETILE .IT, registered on April 12, 2023, which is the earliest registration of this trademark. The disputed Domain Name was registered on November 5, 2004 and currently resolves to a parking webpage of the Registrar featuring pay-per-click links.

The Complainant alleges that the content of the website at the disputed Domain Name is likely to mislead consumers into believing that it is connected to the Complainant, because the Complainant’s website and the website at the disputed Domain Name feature the same categories of products, thus reinforcing the likelihood of confusion. The Complainant further alleges that the disputed Domain Name remained parked for years, only later being exploited in bad faith to capitalize on the established reputation of the ONETILE trademark. When the Complainant began using the ONETILE trademark extensively and achieved market recognition, the Respondent started to exploit the disputed Domain Name, redirecting traffic to third-party websites, including the Complainant’s direct competitors. The Respondent did not submit a Response.

Held: The disputed Domain Name was registered in 2004, while the Complainant was established in 2017. The Complainant has not shown that its ONETILE brand had become a distinctive identifier which consumers associate with its goods or services prior to its formal registration as a trademark on April 12, 2023, and has not established having any unregistered trademark rights in ONETILE at any earlier point in time. According to the Complainant, in 2016 – 2017 the associated website underwent significant alterations, and also a transfer of ownership, which has been anonymized, and this period coincides with the promotion by the Complainant of its own website and social media on a broader scale. The Panel made an attempt to view the archived versions of this website for 2017 and 2018, but the respective records displayed only error messages. In any case, there is nothing extraordinary in the fact that the website has been archived nine times in two years, and this fact does not necessarily mean that the disputed Domain Name has been transferred to a different owner.

It is also important to note that the Complainant provided no historical WhoIs records for the Domain Name, and the Panel finds no evidence of any ownership change or that the Respondent acquired the Domain Name after 2017, when the Complainant went online. In the absence of any evidence pointing to a different conclusion, the Panel also finds that it is more likely than not that the Respondent has been the registrant of the disputed Domain Name since 2004, when it was originally registered. Therefore, since the Complainant started in 2017, the Respondent could not have known of the Complainant when it registered the disputed Domain Name 13 years earlier, and could not have targeted it with the registration of the disputed Domain Name. Furthermore, since the Policy contains a cumulative requirement for the Complainant to establish both registration and use in bad faith, the Complainant cannot prevail if it has not established registration of the disputed Domain Name in bad faith, even if there may arguably be evidence of present use in bad faith.

Complaint Denied

Complainant’s Counsel: Studio legale Carantani Bottoli, Italy
Respondent’s Counsel: No Response


Panel: Respondent Put to Trouble; Case Should Never Have Been Brought Under the Policy

Magic Men Holdings Pty Ltd v. Wayne R. Ball, Wayne R. Ball, WIPO Case No. D2025-3125

<magicmen .com>

Panelist: Mr. Andrew D. S. Lothian

Brief Facts: The Australian Complainant, registered on May 5, 2014, owns the MAGIC MEN trademark; otherwise, nothing is known about the nature of its business. The Complainant is the owner of an Australian trademark, registered on January 7, 2014, filed on May 17, 2013. Around July 24, 2025, the Complainant asked a domain broker to reach out to the Respondent about purchasing the contested domain. On August 6, 2025, the broker said the Respondent had not replied but they would continue attempting contact. The disputed Domain Name was registered on April 6, 2002 and does not resolve to a website. The Complainant alleges that the disputed Domain Name was registered after the Complainant’s trademark was registered, that the disputed Domain Name is not being used and is being passively held, that the Respondent has not responded to contact attempts or has offered to sell the disputed Domain Name for an excessive price.

The Complainant further alleges that the Respondent appears to have registered the disputed Domain Name primarily for the purpose of selling, renting, or otherwise transferring it to the trademark owner or a competitor for valuable consideration. The Respondent’s contends that it has been personally involved in the magic hobby predating the Complainant’s existence for decades, and that it registered the disputed Domain Name on its original registration date with a plan to use it for a website promoting a small amateur magic act which it shared with a friend, which business never materialized. The Respondent produces a range of evidence to support its submissions regarding its longstanding magic hobby. The Respondent also points out that it is not possible for it to have registered the disputed Domain Name to target a mark or business that did not then exist.

Held: Despite the Complainant’s various objections, the Respondent’s evidence is more than plausible regarding its contention that it had an interest in magic and that the disputed Domain Name was registered in furtherance of the same. It is not necessary, in the circumstances of this particular case, for the Respondent to establish that it has actually used the disputed Domain Name in connection with its hobby, as contended by the Complainant when it calls for the provision of specific evidence of the Respondent’s use of the name “magicmen” or “Magic Men” in connection with its proposed magic act. The Panel is satisfied, on the evidence before it, that it is reasonable to infer that the disputed Domain Name was registered by the Respondent in 2002 and the Complainant has produced nothing to displace that inference. The Complainant was not incorporated until 2014, and its trademark, even if taken from the effective date, dates from 2013.

The Panel further notes that it does not consider that the Complainant could have made out a case of bad faith arising from passive holding in the circumstances of this case, see WIPO Overview 3.0, section 3.3. Taking these factors in turn, the Complainant has produced no evidence regarding the degree of distinctiveness or reputation of its mark, despite making conclusory allegations to this effect. The Respondent has submitted a Response in this case and has provided evidence of actual or contemplated good faith use which the Panel accepts. Although the Respondent used a privacy service for its registration data, it did not actively attempt to conceal its identity. Finally, the Respondent’s contemplated good faith use is entirely plausible as far as the Panel is concerned. The Panel, therefore, finds that the Complainant has failed to establish that the disputed Domain Name was registered in bad faith, and the Complaint fails.

RDNH: The disputed domain was registered long before the Complainant (and its rights) existed, and there is no evidence the Respondent acquired it after the Complainant’s rights accrued. The Complainant, therefore, knew or should have known that it could not succeed in demonstrating that the disputed Domain Name was registered in bad faith, given that the Respondent could have had no knowledge of it or its rights at the material date. The Complainant put forward no facts or circumstances suggesting that any recognized exception to the general rule regarding predating domain names should apply (see WIPO Overview 3.0, section 3.8.2).

In these circumstances, the Panel finds that the Complainant ignored established Policy precedent, for example, as set out on this topic in section 3.8 of the WIPO Overview 3.0. The Respondent has been put to the time and trouble of preparing a full Response under the Policy together with having to gather together what amounts to a remarkable collection of evidence dating from the late 1990s, in a case that should never have been brought under the Policy. The Panel therefore finds that the Complaint has been brought in bad faith and constitutes an attempt at Reverse Domain Name Hijacking.

Complaint Denied (RDNH)

Complainant’s Counsel: Self-represented
Respondent’s Counsel: Self-represented

Case Comment by ICA General Counsel, Zak Muscovitch: For more on this case, see “Male Strippers Try to Reverse Hijack Domain Name” in DNW .COM.


About the Editor: 

Ankur Raheja is the Editor-in-Chief of the ICA’s new weekly UDRP Case Summary service. Ankur has practiced law in India since 2005 and has been practicing domain name law for over ten years, representing clients from all over the world in UDRP proceedings. He is the founder of Cylaw Solutions

He is an accredited panelist with ADNDRC (Hong Kong) and MFSD (Italy). Previously, Ankur worked as an Arbitrator/Panelist with .IN Registry for six years. In a advisory capacity, he has worked with NIXI/.IN Registry and Net4 India’s resolution professional. 

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