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We hope you will enjoy this edition of the Digest (vol. 5.24) as we review these noteworthy recent decisions with expert commentary. (We invite guest commenters to contact us):
‣ Panel: Complainant Abused URS Proceeding (crane. legal *with commentary)
‣ Panel: “At least conceivable” that Respondent’s Choice of Domain Name Could be Coincidental (parkngofly .com *with commentary)
‣ Complainant Should Not Expect Panel to Conduct Independent Research to Support Its Case (pillsburylaw .biz *with commentary)
‣ Indian Bike-Sharing Firm Rapido’s UDRP Complaint Falls Flat, Somehow Escapes RDNH (rapido .com *with commentary)
‣ Does Alleged Identity Theft Justify Redacting Respondent Details in UDRP Proceedings? (casino-just .com and more)
‣ Panel: Complainant Ignored Established Policy and WIPO Overview Precedent (alumniventures .com)
Panel: Complainant Abused URS Proceeding
Krahn Chemie GmbH v. Zsolt Bikadi / Domain Science Ltd et al., NAF Claim Number: FA2505002156805
<crane. legal>
Panelist: Ms. Ivett Paulovics
Brief Facts: The Complainant is a German chemical distribution company operating under the name Krahn Chemie GmbH. The Complainant is the owner of various trademark registrations for the word CRANE, including EU wordmark CRANE (registered on June 12, 2012); International wordmark CRANE (November 11, 2011); UK wordmark CRANE, (June 12, 2012). The Complainant has submitted evidence showing that the CRANE trademark is currently in commercial use. The Respondent is Zsolt Bikadi / Domain Science Ltd, with a listed address in Hungary.
The domain name <crane .legal> was registered on 10 March 2025 and resolves to a parking page containing pay-per-click (PPC) advertising links (e.g., “Crane Lifting Machinery,” “Crane Lifting Equipment,” “Lifting Equipment”), along with a banner indicating that the domain name was for sale via GoDaddy at a listed price of USD $100. The Complainant relies on URS Procedure 1.2.6.3(a), which concerns domain names registered primarily for the purpose of selling them to the trademark owner or a competitor “for valuable consideration in excess of documented out-of-pocket costs directly related to the domain name.”
Held: The disputed Domain Name consists of the generic or descriptive word “crane” and there is no evidence before the Examiner that the domain name has been used to misleadingly divert consumers or to tarnish the Complainant’s trademark. Instead, the Complainant’s own evidence confirms that the Respondent is using the disputed Domain Name in connection with the dictionary meaning of the word “crane.” In such cases, use of a generic term in a descriptive sense, without targeting the complainant or its industry, may constitute fair use and confer legitimate interest. Additionally, a review of public trademark databases shows numerous third-party registrations for “CRANE” across different industries and jurisdictions, indicating that the word is not uniquely associated with the Complainant and weakens the inference that any use of “crane” is inherently connected to the Complainant’s mark.
Additionally, the evidence shows that the disputed Domain Name is being offered for sale at USD $100, which does not exceed typical domain registration and administrative costs in a manner suggesting bad-faith intent to profit. The URS Procedure under paragraphs 5.9.1 and 5.9.2 states that trading in domain names for profit and use of PPC parking pages do not, by themselves, constitute bad faith. These activities may be considered abusive only in context, taking into account: the nature of the domain name; the advertising links; and the overall conduct of the Registrant. The disputed Domain Name consists of a generic term, and the evidence submitted by the Complainant shows it was used in a manner consistent with its dictionary meaning. The PPC links on the parking page are directly related to that generic meaning, and there is no indication that the Respondent targeted the Complainant or its trademark.
Finding of Abuse: In this case, the Complainant failed to establish, by clear and convincing evidence, that the Respondent lacks rights or legitimate interests in the disputed Domain Name, or that the disputed Domain Name was registered and is being used in bad faith. The Complainant, assisted by a professional representative, should have known that it could not succeed under the strict and limited scope of the URS, particularly given the generic nature of the term “crane” and the existence of numerous third-party trademark registrations for that term across different industries. The Examiner finds that the Complainant filed this URS Complaint with knowledge that it was unfounded. Accordingly, the Complaint is deemed an abuse of the URS proceeding.
Complaint Denied (RDNH)
Complainant’s Counsel: VKK Patentanwälte PartG mbB Philipp Knoop of Hamburg, Germany
Respondent’s Counsel: Self-represented
Case Comment by ICA General Counsel, Zak Muscovitch: This case is particularly noteworthy because it is a case of an abusive Complaint, which is a relatively rare finding in URS. Kudos to the Panel for properly applying the URS test of “clear and convincing” and for making a finding of an abusive Complaint where appropriate.
Panel: “At least conceivable” that Respondent’s Choice of Domain Name Could be Coincidental
Park ’N Fly Service LLC v. Jon Jones, Onex Protection, WIPO Case No. D2025-1729
<parkngofly .com>
Panelist: Dr. Kaya Köklü
Brief Facts: The Complainant and its group of affiliates operate airport parking and shuttle services in the United States since 1967. The Complainant is the owner of some PARK ‘N FLY trademark registrations, mainly in the United States, but also in the European Union and the United Kingdom. Among others, the Complainant is the registered owner of the United States Trademark, registered on January 23, 1979, for the PARK ‘N FLY word mark, and registered on December 24, 2002, for the figurative mark PARK ‘N FLY. The Complainant further owns the domain name <parknfly .com> since at least February 27, 2000, which redirects users to another website with a different domain name of the Complainant’s parent company. The disputed Domain Name was registered on May 4, 2024 by the Canadian Respondent. The Complainant points out that the disputed Domain Name resolves to a parked page displaying PPC links related to various parking services at airports worldwide and that various web browsers indicate the parked page as “not secure”. On February 26, 2025, the Complainant’s lawyers sent a request letter to the Respondent, but no response was received.
Held: The Panel acknowledges that the disputed Domain Name consists of several dictionary words and that it is conceivable that such word combination might form a commonly used phrase. While the Complainant’s PARK ‘N FLY mark is widely known in the United States, it has also a descriptive nature. The Panel notes that its Internet search in respect of “Park ‘n fly” reveals that this combination of terms is also used in connection with airport parking services by other operators in other jurisdictions, such as in India, the Philippines, but also in Canada, where the Respondent is reportedly located. Given these facts, it is at least conceivable that the Respondent’s choice of the disputed Domain Name, which only partly matches with the Complainant’s PARK ‘N FLY trademark due to the inserted term “go”, could be coincidental.
The Panel also notes that, even though the disputed Domain Name was registered almost a year ago, the Complainant has not been able to produce any evidence demonstrating the opposite. Despite the potentially descriptive use by the Respondent, the Complaint does not contain any direct evidence of bad faith targeting presented by the Complainant, like phishing or other uses for malicious purposes. In this regard, the Panel further finds that a missing SSL certificate, as in the present case, does not necessarily constitute any such evidence, since websites that are only parked or under construction often do not have such an SSL certificate yet. Also, the fact that the Respondent preferred to keep silent to the request letter of the Complainant and to the Complaint is not sufficient evidence in the present case to accept bad faith registration and use.
In light of the above, the Panel cannot conclude that there is bad faith registration and use for the purposes of the Policy merely on the bases of the PPC links as used on the landing page associated to the disputed Domain Name, while the further case record lacks of sufficiently strong indications of malicious intent to trade off the Complainant’s trademark rights. Particularly the Panel notes that the disputed Domain Name consists of a variation of the Complainant’s mark including the term “go”, and there are conceivable other uses of the disputed Domain Name which do not target and relate to the Complainant and its business. The Panel notes that the general business of monetizing domain names consisting of dictionary terms (including by way of PPC links) can be legitimate and is not per se a convincing indication of cybersquatting and bad faith.
Complaint Denied
Complainant’s Counsel: Neal, Gerber & Eisenberg LLP, United States
Respondent’s Counsel: No Response
Case Comment by ICA General Counsel, Zak Muscovitch: Notably, the Panel found that it was “conceivable that such word combination might form a commonly used phrase” and also found that “the Complaint does not contain any direct evidence of bad faith targeting presented by the Complainant”. Where “it is at least conceivable” that the Respondent’s choice of the disputed Domain Name…. could be coincidental”, combined with a lack of direct evidence, a Panel may properly dismiss a Complaint rather than take a guess. This is a good example of appropriate Panelist restraint.
Complainant Should Not Expect Panel to Conduct Independent Research to Support Its Case
Pillsbury Winthrop Shaw Pittman LLP v. PILLSBURY PILLSBURY, PILLSBURY, WIPO Case No. D2025-0934
<pillsburylaw .biz>
Panelist: Mr. Phillip V. Marano
Brief Facts: The Complainant is a full-service law firm which is headquartered in New York, operates twenty offices worldwide with over seven hundred lawyers, and specializes “in multiple fields such as energy, real estate and financial services.” The Complainant offers information about its services through its official domain name <pillsburylaw .com> and website. The Complainant owns a valid and subsisting registration for the PILLSBURY trademark dated December 23, 1997, with the earliest priority dating back to 1874. The Respondent registered the disputed Domain Name on February 14, 2024, which does not resolve any website content. The Registrar revealed registration data for the Respondent that corresponds to the Complainant’s name and physical address.
The Complainant, through its external cybersecurity vendor, has filed a 465-word Complaint, with limited supporting annexed evidence, and devoid of citations to applicable authority, such as the WIPO Overview 3.0. The Complainant essentially argues that the Respondent registered and used the disputed Domain Name in bad faith because: (i) the disputed Domain Name wholly incorporates Complainant’s PILLSBURY trademark; (ii) the Respondent has “passively held” the disputed Domain Name; and (iii) Respondent has obfuscated their domain name registration data; and “Respondent has demonstrated through the WhoIs information that they are aware of the Complainant and are attempting to imply an affiliation or relationship with them that has not been authorized.”
Held: In this Complaint, the record is devoid of any evidence that the disputed Domain Name has ever been used by the Respondent, for legitimate purposes or otherwise. The Panel conducted a limited investigation, checking Internet Archive records, registration data, and name server configurations, but found no sign of legitimate use either. Therefore, based primarily on Respondent’s default, the Complainant’s assertions that it “has not authorized, licensed or otherwise permitted the Respondent to use its trademark or to imply any connection between the two parties”, and the Complainant’s additional assertion that, “Complainant is not aware of nor can they find any other organization known as ‘Pillsbury Law’, especially one that is also from New York”, the Panel finds the second element of the Policy has been established. Contrary to the Complainant’s conclusory argument, wholesale incorporation of a trademark, particularly a surname that has acquired distinctiveness in relation to Complainant’s services over time, would not be conclusive evidence of bad faith under the third element of the Policy. To that end, the Panel’s limited web search found thousands worldwide who share the “Pillsbury” surname. While the term “law” in the disputed domain may suggest bad faith targeting of the Complainant, another search showed dozens of US attorneys, including in New York, using the same “Pillsbury” name to provide legal services.
While the Panel does recognize the failure of the Respondent to submit a Response, plus Respondent’s use of a proxy service, or selection of a Registrar that applies proxy services by default, as limited indicia of bad faith, these two individual factors are not determinative in a totality of circumstances analysis. Further, even after the Panel’s direct request in its initial Procedural Order, the Complainant has provided no evidence or argument about the distinctiveness or reputation of its PILLSBURY trademark beyond broad conclusions. The Panel briefly checked Complainant’s website and press releases but found no clear evidence of the trademark’s distinctiveness, reputation, or fame and did not conduct an exhaustive search. Ultimately, taking all the foregoing circumstances into account, including all facts and circumstances identified through the Panel’s own limited research, it appears more likely than not that the Respondent has registered and passively held the disputed Domain Name in bad faith. It is worth noting that it is for the Complainant to submit a complete Complaint with sufficient supporting evidence and citations, and the Complainant should not rely on a panelist performing additional research in order to assess the merits, noting that a complaint without sufficient supporting evidence and relevant citations could easily result in a denial.
Transfer
Complainant’s Counsel: ZeroFox, US
Respondent’s Counsel: No Response
Case Comment by ICA General Counsel, Zak Muscovitch: An excellently analyzed case and excellent decision by the Panelist. Amongst many notable aspects, the Panel in particular articulated an important principle: “A respondent’s default would not by itself mean that the complainant is deemed to have prevailed; a respondent’s default is not necessarily an admission that the complainant’s claims are true.”
Also, the Panel to its credit noted that “contrary to Complainant’s conclusory argument, wholesale incorporation of a trademark, particularly a surname that has acquired distinctiveness in relation to Complainant’s services over time, would not be conclusive evidence of bad faith under the third element of the Policy.” Well said.
I want to credit the Panel for its analysis of passive holding under the Telstra test where it noted in particular; “The first and fourth Telstra factors are often viewed as paramount, and are viewed together by panels along a continuum of inverse relation, meaning that the more distinctive a Complainant’s trademark, the less plausible a claimed non-infringing good faith use by Respondent” while also noting the importance of “the totality of the circumstances in each case”.
Lastly, the Panel rightly criticized the Complaint for what appears to have been an incredibly skeletal Complaint comprising “a 465-word Complaint, with limited supporting annexed evidence, and devoid of citations to applicable authority”. As noted by the Panel, “even after the Panel’s direct request in its initial Procedural Order, Complainant has not provided any evidence or argumentation whatsoever regarding the degree of distinctiveness or reputation of its PILLSBURY trademark apart from the high-level conclusions”. This was insufficient and the Panel noted that “Complainant is still required to prove its case, and the Panel declines to research any additional information concerning the degree of distinctiveness or reputation of the PILLSBURY trademark”. It is not up to the Panel to research and assist a Complainant as the Panel noted: “It is for the Complainant to submit a complete Complaint with sufficient supporting evidence and citations, and the Complainant should not rely on a panelist performing additional research in order to assess the merits, noting that a complaint without sufficient supporting evidence and relevant citations could easily result in a denial”.
Indian Bike-Sharing Firm Rapido’s UDRP Complaint Falls Flat, Somehow Escapes RDNH
<rapido .com>
Panelist: Mr. John Swinson
Brief Facts: The Complainant, a company incorporated in India on January 5, 2015, is a leading ridesharing platform in the country and has online presence at <rapido .bike> (registered since September 23, 2015). The Complainant owns Indian trademark applications for RAPIDO in various classes and for a range of logos. An example is Indian Registration Number 5926068 for RAPIDO in class 39, filed on May 7, 2023, claiming usage since September 30, 2015. The Respondent acquired the disputed Domain Name in November 2014 from RapidoInternet of Florida, intending to use it for a new storefront under the RAPIDO brand for gift cards, mobile top-ups, and payment cards. Preparations for this online storefront were made, and the website was launched in early 2019. On March 5, 2021, the Respondent changed its name to Recharge.com Capital B.V. In 2022, the Respondent phased out the RAPIDO brand and shifted focus to RECHARGE .COM, redirecting the disputed domain to <recharge .com>, which it claims to own.
The Complainant alleges that it is evident that while the disputed Domain Name may have been initially used for legitimate purposes, it was later parked and now only redirects to another website, demonstrating that the Respondent has no legitimate use of the disputed Domain Name and that the Respondent undoubtedly had active knowledge of the Complainant’s rights in the trademark RAPIDO, as is evident from the communication outreach made to the Complainant’s representative to sell the disputed Domain Name for an extortionist amount of USD $1 million. The Respondent contends that “rapido” means “rapid, fast, or quick” in Italian and acquired the domain name to launch a RAPIDO storefront offering gift cards, mobile top-ups, and payment cards (used from 2019 to 2022). The Complainant offers taxi services, which differ from the Respondent’s offerings. Further, selling a domain name is not inherently in bad faith if the Respondent did not know of the Complainant’s trademark rights and did not intend to benefit unfairly from their goodwill.
Held: The Respondent acquired the disputed Domain Name in November 2014, while the Complainant was established on January 5, 2015 and claims first use of its RAPIDO trademark in September 2015. The Complainant does not make any submission as to whether the Respondent registered or acquired the disputed Domain Name in anticipation of the Complainant’s trademark rights. Therefore, in the Procedural Order, the Complainant was given the opportunity to provide further evidence as to the Complainant’s reputation on or before the date the Respondent acquired the disputed Domain Name. The Panel noted that the Respondent had submitted that the Complainant was not incorporated when the Respondent acquired the disputed Domain Name. The Complainant provided no such evidence in response to the Procedural Order.
The Panel finds that the Respondent did not register the disputed Domain Name in bad faith targeting of the Complainant or its trademark rights because the Complainant had no trademark rights or nascent trademark rights at the time that the Respondent registered the disputed Domain Name. WIPO Overview 3.0, sections 3.8.1 and 3.8.2. In short, the Complainant must prove both bad faith registration and bad faith use. For example, if the Respondent registered a domain name without any bad faith, and later learned of the Complainant’s trademark, and then offered to sell the domain name to the Complainant at a profit, the consensus view of panelists is that this does not satisfy the third element of the Policy. Xbridge Limited v. Marchex Sales, Inc., WIPO Case No. D2010-2069.
Complaint Denied
Complainant’s Counsel: Ira Law Firm, India
Respondent’s Counsel: Chiever B.V., Netherlands (Kingdom of the)
Case Comment by Digest Editor, Ankur Raheja:
The Complainant in this matter is an Indian ridesharing platform that competes with companies like Uber and Ola and is a well-known brand in India. However, regarding domain names, it is well-established that domain names are available for registration on a first-come, first-served basis, and even more so when the domain name consists of a dictionary word. The Respondent argues and also online dictionaries clearly provide that ‘Rapido’ is an Italian word to mean ‘rapid, swift, quick.’ Furthermore, it has been held that where Respondent registers a domain name consisting of dictionary term because he has a good faith belief that domain name’s value derives from its common/descriptive qualities rather than its specific trademark value, the use of domain name consistent with such good faith establishes a legitimate interest. (see National Trust for Historic-Preservation v. Barry Preston, WIPO-D2005-0424; Private Media Group v. DHL Virtual Networks, WIPO-D2004-0843; Zero Int’l Holding v. Beyonet Servs. [WIPO-D2000-0161; Zero.com).
In addition, the Complainant was established in 2015, whereas the Respondent acquired the disputed domain name in 2014 for use in a legitimate business offering gift cards, mobile top-ups, and payment cards. This timeline makes it clear that the Complaint should not have been filed, as the Respondent’s registration predated the Complainant’s existence and was for a legitimate business purpose. Despite this, it appears the Respondent did not seek a finding of Reverse Domain Name Hijacking (RDNH) under Rule 15(e) of the UDRP Rules. Panelist Mr. Gerald M. Levine recently observed in the <nolaelectric.com> matter:
Even though the Respondent has not requested a finding of reverse domain name hijacking, the Panel finds that the Complainant has attempted to wrest the disputed domain name from the Respondent on the false contention that the Respondent was a cybersquatter when in fact the violator of the UDRP was the Complainant. See Tecme S.A. v. Stephen Bougourd, WIPO Claim No. D2020-2597 (“Although the Respondent did not request a finding of Reverse Domain Name Hijacking, the Panel considers this an appropriate case to enter such a finding.”)
Furthermore, since another leading Indian ridesharing platform is OLA, it is not surprising that they are also pursuing an UDRP action. OLA’s parent company, ANI Technologies Pvt. Ltd., filed a domain dispute with WIPO in May 2025, vide WIPO Case No: D2025-1989 (proceedings commenced on May 26, 2025 and should see a 3-member Panel appointment). Therefore, the article “The Case of Ekart .com and UDRP Disputes by Indian Companies” remains relevant.
The Complainant in this matter is an Indian ridesharing platform that competes with companies like Uber and Ola and is a well-known brand in India. However, regarding domain names, it is well-established that domain names are available for registration on a first-come, first-served basis, and even more so when the domain name consists of a dictionary word. The Respondent argues and also online dictionaries clearly provide that ‘Rapido’ is an Italian word to mean ‘rapid, swift, quick.’ Furthermore, it has been held that where Respondent registers a domain name consisting of dictionary term because he has a good faith belief that domain name’s value derives from its common/descriptive qualities rather than its specific trademark value, the use of domain name consistent with such good faith establishes a legitimate interest. (see Does Alleged Identity Theft Justify Redacting Respondent Details in UDRP Proceedings?
<casino-just .com>, <justcasinos .org>, <just-casinos .com>, <casino-just .net>, <casinojust .net>, <justcasinos1 .com>, <justcasino .co .com>, <casinojust-au .com>, <justcasinobonuses .net>, <justcasino .pro>, <just-casino-at .com>, <just-casinos .org>, and <just-casinos .net>
Panelist: Mr. Richard Hill
Brief Facts: The Complainant states that, in March 2023, it, together with Dama N.V., released its online casino platform under the JUSTCASINO brand operating on the domain name <justcasino .com>. The Complainant’s website provides players from the EU with a wide diversity of online entertainment experience, including numerous slot games from world top providers and live casino games. In mid-2023, following the increased popularity of the JUSTCASINO brand among EU players, the Complainant decided to protect its brand name and logo by registering them as an EU trademark, which was finally registered on May 3, 2024. The domain names <casino-just .com> and <justcasinos .org> were registered on, respectively, March 6, 2023; and April 5, 2023. The other registrations postdate the date on which the Complainant established rights in its trademark. The resolving websites purport to offer services that compete with those of the Complainant; they display Complainant’s mark and mimic Complainant’s legitimate website. The WHOIS information for one of the disputed Domain Names is false.
Preliminary Issue – Multiple Respondents: The Complainant alleges that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. In support of this allegation it states each domain incorporates the JUSTCASINO trademark, mimics the Complainant’s website, uses unreliable WHOIS data, shares IP addresses and name servers (often Cloudflare), were registered in close succession, and are linked by common registrars. However, the Panel found that the evidence does not conclusively show common control over all domains: not all websites mimic the Complainant’s site, and similarities in registration details are insufficient. As required by the Rules and Forum’s Supplemental Rule 4(c), the Panel will proceed only with those domains it finds are commonly owned (<casino-just .com>, <justcasinos .org>, <just-casinos .com>, <casino-just .net>, <casinojust .net>, <justcasinos1 .com>, <just-casino-at .com>, <just-casinos .org>, <just-casinos .net>), dismissing without prejudice the complaint regarding the others – <justcasino .co .com>, <casinojust-au .com>, <justcasinobonuses .net>, and <justcasino .pro>.
Identity Theft: The Complainant presents evidence showing that one of the Respondents, Evgeniya Tolstova, has been the victim of identity theft. As Forum had not received any further response from the named Respondents, it proceeded with the Panel appointment. The Panel notes precedent which holds the registrar-confirmed registrant of a disputed domain the proper respondent, notwithstanding the possibility that said respondent’s identity was stolen. See, e.g., Banco Bradesco S/A v. Gisele Moura Leite, D2014-0414 (WIPO Apr. 30, 2014). In the instant case, there has been no request in the Complaint to redact any portion of the decision in terms of the Policy 4(j) read with Forum Supplemental Rule, nor has there been a Response or an Additional Submission from the Respondent in question. Consequently, the Panel finds that it is not warranted to redact Respondent’s name and location from the Panel’s decision.
Held: Here, the Complainant fails to provide evidence showing that the disputed Domain Names <casino-just .com> and <justcasinos .org> were registered further to significant media attention in connection with the launch of the Complainant’s JustCasino services. Indeed, the Complainant’s services were launched in March 2023, and the disputed Domain Names in question were registered in March and April 2023. Thus the Panel finds that the Complainant has failed to satisfy its burden of proof of bad faith registration for the domain names <casino-just .com> and <justcasinos .org>. However, the Complainant has provided sufficient evidence to show that the other disputed Domain Names were registered further to significant media attention in connection with the launch of the Complainant’s JustCasino services.
The resolving websites purport to offer services that compete with those of the Complainant. Previous Panels have found that use of a disputed Domain Name to offer goods or services in competition with those of a complainant does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. Thus the Panel finds that the Respondent fails to use the disputed Domain Name to make a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) or (iii). Further, Panels have held that registration and use of a disputed Domain Name to divert Internet traffic to a competing website offering the same or similar goods or services demonstrates bad faith registration and use under Policy ¶¶ 4(b)(iii) and/or (iv).
Furthermore, the Respondent registered the disputed Domain Names with actual knowledge of the Complainant’s mark: the resolving websites display Complainant’s mark and mimic Complainant’s legitimate website. While constructive notice is insufficient to demonstrate bad faith, actual knowledge of a complainant’s rights in a mark prior to registration may be evidence of bad faith per Policy 4(a)(iii). In addition, the Respondent displays a pattern of bad faith registration of disputed Domain Names containing Complainant’s JUSTCASINO mark. Finally, on the balance of the evidence before it, the Panel finds that the Respondent registered the disputed Domain Names (again, apart from <casino-just .com> and <justcasinos .org>) opportunistically, because it registered them shortly after the public announcement of Complainant’s JustCasino services. This constitutes bad faith registration and use.
Transfer (Partly Denied / Dismissed)
Complainant’s Counsel: Kamal Tserakhau of REVERA Polska sp. z o.o., Poland
Respondent’s Counsel: No Response
Panel: Complainant Ignored Established Policy and WIPO Overview Precedent
Alumni Ventures LLC v. SocialNicheGuru .com, WIPO Case No. D2025-1624
<alumniventures .com>
Panelist: Mr. Evan D. Brown
Brief Facts: The Complainant is in the business of providing venture capital advisory and related services. It owns the trademark ALUMNI VENTURES, for which it owns registrations in the United States (e.g., Reg. No. 7678914, registered on February 4, 2025, with a date of first use in commerce of April 2018; Reg. No. 6958785, registered on January 17, 2023, with a date of first use in commerce of November 10, 2021). The disputed Domain Name was registered on February 1, 2011 and resolves to a parked page showing pay-per-click (PPC) links.
The Complainant asserts it has satisfied requirements of the Policy. The Respondent disputes the Complainant’s allegations regarding the second and third elements of the Policy. Specifically, the Respondent contends that it has rights or legitimate interests in the disputed Domain Name. The Respondent further maintains that it registered the disputed Domain Name well before the Complainant acquired any trademark rights and that it has not used the disputed Domain Name in bad faith.
Held: Here, the undisputed evidence shows that the disputed Domain Name was registered on February 1, 2011. The Complainant, by contrast, claims first use of its ALUMNI VENTURES trademark in commerce in April 2018 and obtained its registrations in 2023, and 2025. Panels generally do not find bad faith where a domain name is registered before the complainant’s trademark rights accrue, see WIPO Overview 3.0, section 3.8.1. There is no evidence in the record that the Respondent acquired the disputed Domain Name after the Complainant’s trademark rights arose, nor any indication that the Respondent registered the domain name with knowledge of the Complainant’s then nascent rights under any of the exceptional scenarios described in section 3.8.2 of the WIPO Overview 3.0. Accordingly, the Panel finds that the Complainant has failed to establish that the disputed Domain Name was registered in bad faith.
RDNH: The Complainant either knew or clearly ought to have known that it could not succeed under the third element of the Policy, as the disputed Domain Name was registered more than seven years before its alleged trademark rights arose. There is no suggestion of facts that would support any recognized exception. In the view of the Panel, the Complainant ignored established Policy precedent as captured in the WIPO Overview 3.0. Accordingly, the Panel finds that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding.
Complaint Denied (RDNH)
Complainant’s Counsel: Litwin Kach, LLP, United States
Respondent’s Counsel: Self-represented
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.