Essay by Mr. Gerald M. Levine
Help! Someone has registered a Domain Name Corresponding to my Trademark.
Help! I’m being Accused of Squatting on Someone’s Trademark.
PART 1: UNSORTING THE CLEAR FROM THE UNCLEAR
In the vast percentage of UDRP cases—a number that has varied over the years but is currently in the 95% range—panelists have found accused registrants to be indefensibly cybersquatting. These are the “clear cases” that UDRP was crafted to suppress. This is not to say that the distance between clear and unclear is instantly discernable in all cases. There is always a point on a continuum where clear transmutes to unclear and at that point the determination as to which side of the line a dispute sits becomes increasingly exposed to error or the complainant has misjudged and finds itself in the 5% class of dismissals. Continue Reading here.
We hope you will enjoy this edition of the Digest (vol. 5.18) as we review these noteworthy recent decisions with expert commentary. (We invite guest commenters to contact us):
‣ Panel: Complaint Was Brought to Harass Respondent Spa Owner (renewcda .com *with commentary)
‣ Panel: Domain Name Was Part of an Apparent Ruse, Targeting UK Human Rights Organization (libertyhumanrights .org *with commentary)
‣ DNW.COM: “Indian IVF giant Indira IVF recovers stolen domain”
(indiraivf .com *with commentary)
‣ Is Intention Necessary for Bad Faith? (mento .ai *with commentary)
‣ Intent is a Necessary Element of Cybersquatting (milanjournal .com *with commentary)
Panel: Complaint Was Brought to Harass Respondent Spa Owner
RENU MEDISPA, L.L.C. v. Angela Sattler / Aesthetics, NAF Claim Number: FA2503002143814
<renewcda .com>
Panelist: Mr. Steven M. Levy (Chair), Ms. Sandra J. Franklin and Mr. David H. Bernstein
Brief Facts: The Complainant provides medically supervised spa services and has online presence at <renumedispa .com>. The Complainant is the owner of the trademark RENU MEDISPA, which is registered in the states of Idaho, Oregon, Montana, and Washington. The disputed Domain Name <renewcda .com>, registered on February 25, 2018, has been used by the Respondent for “Renew Aesthetics & IV Hydration Bar” in Coeur d’Alene, Idaho since that date. Although the Complainant claims to have learned of the Respondent’s use in 2021, it took no action until January 2023, when its attorney wrote a letter to the Respondent. The Complainant subsequently filed litigation, in the Idaho courts, in March 2024, and the court, in one of these cases, denied Complainant’s motion for a preliminary injunction and temporary restraining order. The litigation is currently pending and the parties have engaged in discovery and motion practice.
The Complainant alleges that the disputed Domain Name was registered and is used in bad faith because it resolves to a website offering competing services primarily to profit from and exploit the Complainant’s RENU Mark by misdirecting internet users. The Respondent contends that it chose a descriptive word in the field of medical spas (“renew”), combined with a geographically descriptive moniker (“CDA” for “Coeur d’Alene”). It was not aware of the Complainant at the time it adopted and registered the disputed Domain Name. The Complainant did not then (nor does it now) have an exclusive right to restrict others in the medical spa field from using the word “renew.” The Respondent further contends that it has continuously been in operation for six years and has become recognized as providing services in the medical spa industry.
Held: The Complainant submitted state trademark registrations from Idaho, Oregon, Montana, and Washington, but provided no proof these were obtained through substantive examination to confirm the mark’s distinctiveness. As such, the Panel declines to accept the proffered state registration certificates as sufficient proof of the Complainant’s rights in the claimed RENU MEDISPA trademark. The Panel next turns its attention to the question of whether the Complainant has established common law trademark rights. The Complainant’s sole evidence is a website screenshot showing the RENU MEDISPA logo, which is insufficient. There is also no proof that the mark is widely recognized by consumers as identifying the Complainant’s goods or services. Therefore, the Panel finds the evidence inadequate to establish common law trademark rights in the term RENU MEDISPA.
Considering all the evidence submitted, the Panel finds, by a preponderance of the evidence, that the Complainant has failed to establish that the Respondent’s use of its name and domain name is causing actionable confusion (a finding that is consistent with the court’s finding in the Idaho Litigation). There is also no dispute that the Respondent has been known as Renew Aesthetics & IV Hydration Bar for seven years and is located in Coeur d’Alene, Idaho. Additionally, the Respondent owns an Idaho trademark for RENEW AESTHETICS. While this state registration isn’t enough to prove trademark rights under the Policy, it shows the Respondent has formalized its business, supporting its claim that the disputed Domain Name use is legitimate in terms of the Policy. Lastly, the Complainant has not come forth with any assertions or evidence to show that the disputed Domain Name was chosen and used with prior knowledge of the Complainant’s claimed mark and to target the Complainant’s business in bad faith.
RDNH: The Complainant knew, or should have known, that it could not succeed in establishing any of the UDRP elements given the favorable ruling for the Respondent on the Complainant’s motion for a preliminary injunction and temporary restraining order in the Idaho Litigation. The fact that the Complainant did not disclose the existence of that court decision in the complaint (which was filed more than four months after the decision was issued) is bad faith withholding of material evidence and shows that the Complainant should have known it could not succeed in a claim under the Policy. The Complainant also failed to inform the Panel that its two applications to register RENU MEDISPA before the USPTO were refused and that the Complainant expressly abandoned both of those applications.
These facts lead the Panel to conclude that the present proceedings were brought in an effort to harass the Respondent. A finding of RDNH is especially appropriate here given that the Complainant is ‘represented by competent legal counsel,’ and counsel is not expected to ‘initiate a proceeding that is quite clearly devoid of merit.’ Attorneys are expected to have an appreciation for the jurisprudence of the forums in which they practice.” Domain Name Arbitration, 7.11-D.1 (Gerald M. Levine, Legal Corner Press, 2nd ed. 2019), citing Sustainable Forestry Management Limited v. SFM.com and James M. van John ‘Infa dot Net’ Web Services, D2002-0535 (WIPO Sep. 13, 2002). See also Electrosoft Services, Inc. v. TechOps / SyncPoint, FA 1969515 (Forum Dec. 9, 2021) and WIPO Jurisprudential Overview 3.0, at 4.16.
Complaint Denied (RDNH)
Complainant’s Counsel: Stacey L. Beaumont of Hawley Troxell Ennis & Hawley LLP, USA
Respondent’s Counsel: Mark W. Hendricksen of Wells St. John P.S., USA
Comment by ICA General Counsel, Zak Muscovitch: Congratulations to the Panel for wading through a somewhat complicated case and reaching the right conclusion. There are several notable aspects to the decision, including the below;
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U.S. state trademark registrations are unhelpful to a Complainant without information supplied by a Complainant to demonstrate that these registrations were obtained through substantive examination of its applications which shows that the states considered whether the applied-for mark was distinctive.
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Merely submitting a screenshot of a Complainant’s website is insufficient to demonstrate common law trademark rights. To meet this evidentiary burden, a complainant generally must show extensive and continuous use in commerce of a mark that is inherently distinctive or, if the mark is descriptive, that the mark has developed a secondary meaning with respect to the complainant and its business.
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Some attribution of knowledge of a complainant’s trademark, whether actual or based upon a conclusion that a respondent should have known of the mark, is inherently prerequisite to a finding of bad faith under the Policy. Given Respondent’s lack of knowledge of Complainant, its registration of the disputed domain name cannot possibly have been in bad faith.
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The fact that Complainant did not disclose the existence of a harmful court decision in the complaint is bad faith withholding of material evidence and shows that Complainant should have known it could not succeed in a claim under the Policy. Complainant also failed to inform the Panel that its two applications to register RENU MEDISPA before the USPTO were refused and that Complainant expressly abandoned both of those applications. Seeendnote i. These facts lead the Panel to conclude that the present proceedings were brought in an effort to harass Respondent.
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A finding of RDNH is especially appropriate here given that Complainant is “‘represented by competent legal counsel,'” and counsel “is not expected to ‘initiate[] a proceeding that is quite clearly devoid of merit.’ Attorneys are expected to have an appreciation for the jurisprudence of the forums in which they practice.” Here, Complainant is represented by legal counsel and the Panel notes that this law firm has represented parties in at least eighteen prior UDRP cases, most of them successfully. It is therefore surprising that it would have proceeded with the current claim despite the various and obvious indications that it could not succeed.
Panel: Domain Name Was Part of an Apparent Ruse, Targeting UK Human Rights Organization
<libertyhumanrights .org>
Panelist: Mr. W. Scott Blackmer
Brief Facts: The UK-based Complainant, founded in 1934, is an English nonprofit better known as “Liberty” since 1989. It is the UK’s largest independent, membership-based, and oldest human rights campaigning organization. It has run the website <libertyhumanrights .org .uk> since August 2017, having previously used <liberty-human-rights .org .uk> from February 1999. The Complainant has never registered a trademark or service mark. Rather, the Complainant asserts unregistered trademark rights in LIBERTY HUMAN RIGHTS and LIBERTY based on acquired distinctiveness in the course of decades of use in connection with human rights campaigns. The disputed Domain Name was created on August 20, 2020, by the Respondent for Action for Humanity, Pakistan. It leads to a single-page English site titled “Welcome to Liberty Human Rights” with the tagline “Advocating for Human Rights.” The Respondent’s organization also has a multipage English website at <actionforhumanity .org .pk>, highlighting human rights advocacy.
The Complainant alleges that the disputed Domain Name reflects bad faith impersonation, an attempt to misdirect Internet users through confusion with the Complainant’s mark for commercial gain, and an attempt to extort money from the Complainant. According to the Complainant, the Respondent’s provision of false contact details imitative of the Complainant (“Liberty Villa” rather than “Liberty House”, at a nonexistent London address using the same telephone number and postcode as the Complainant’s), further supports a finding of bad faith. The Respondent contends that there is no evidence of commercial activity, phishing, or impersonation with the disputed Domain Name, and that it is only meant for such legitimate use in connection with human rights advocacy. The Respondent further denies that there is any evidence of a bad faith “demand” for commercial gain.
Held: The Respondent claims a legitimate interest in using the disputed Domain Name for a noncommercial human rights advocacy website, consistent with the Policy, paragraph 4(c)(iii). However, more than four years after registering the disputed Domain Name, the Respondent’s website only states the team is “hard at work” preparing it, with no evidence of progress. Instead, evidence shows the Domain Name and website imitate the Complainant, especially given the content formerly published on the “Contact” page of the Respondent’s website, giving an address at “Liberty Villa” (much like the Complainant’s “Liberty House”), at a nonexistent London address using the same telephone number and postcode as the Complainant’s. Panels have held that the use of a domain name for illegitimate or illegal activity, here claimed to be phishing for personal information and donations on an imitative site passing off as the Complainant’s, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1.
The Panel further notes that the Respondent was clearly aware of the Complainant, closely imitating the Complainant’s domain name and mounting a website that impersonated the Complainant, including its general humanitarian and civil liberties mission and some of its contact details, including the Complainant’s exact telephone number and displaying a similar headquarters name. At the same time, the Respondent has avoided identifying the operator of the Respondent’s website. Given the nature of the Complainant’s activities as an advocacy organization that organizes campaigns, sells literature, and receives donations, there is a risk that site visitors who believe the disputed Domain Name is affiliated with the Complainant may provide personal details or send donations that are intended for the Complainant. This accords with the example of bad faith found in the Policy, paragraph 4(b)(iv), intentionally attempting to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s mark.
Transfer
Complainant’s Counsel: Reed Smith LLP, UK
Respondent’s Counsel: Nadeem Ahmed, Pakistan
Comment by ICA General Counsel, Zak Muscovitch: At first blush, one may think that this case was headed towards a denial since a domain name like <libertyhumanrights.org> seems like an apt name for a civil rights group. But a closer examination of the facts as the Panel undertook in this case, revealed that rather than a legitimate registration, the domain name appears to have been employed in a ruse. As the Panel noted, the Respondent was clearly aware of the Complainant, closely imitating the Complainant’s domain name and mounting a website that impersonated the Complainant, including its general humanitarian and civil liberties mission and some of its contact details, including the Complainant’s exact telephone number and displaying a similar headquarters name.
DNW.COM: “Indian IVF giant Indira IVF recovers stolen domain”
Indira IVF Hospital Pvt Ltd v. Saurav Shinde, CAC Case No. CAC-UDRP-107301
<indiraivf .com>
Panelist: Mr. Darius Sauliūnas
Brief Facts: The Complainant, established in 1988, is India’s largest fertility service provider with headquarters in Mumbai, Maharashtra, India. Since 2023, the company has been backed by Sweden-based EQT and is preparing for a $400 million IPO in 2025. The disputed Domain Name was originally registered on 19 October 2010 and resolves to the company’s official website. The Complainant last paid for the renewal of the domain name for five years on August 28, 2024, but it discovered in January 2025 that the disputed Domain Name was transferred on October 31, 2024, without authorization to another Registrar, Hostinger. The registrar disclosed the WHOIS information on 25 February 2025, indicating that the registrant is located in Pusad, Maharashtra, India. His LinkedIn profile identifies him as an ethical hacker.
The Complainant alleges that the Respondent, based in the same region as the Complainant, registered or acquired the domain name in bad faith, fully aware of the Complainant’s business and trademarks. The Respondent transferred the domain to a different registrar without authorization and continues to control it despite lacking any connection to the Complainant. The Complainant further alleges that the evidence from the registrar and other online sources confirms the Respondent’s identity and shows a clear link between him and the hacked domain. The website hosted at the disputed domain still displays the Complainant’s content, indicating an intention to impersonate the Complainant and benefit from its established reputation. The Respondent contends that on October 26, 2024, he bought the disputed Domain Name through a peer-to-peer transaction after seeing a Facebook group post. He was interested because of its high traffic and completed the deal on Telegram.
Held: The Respondent did not challenge in his response the evidence that was presented by the Complainant, therefore, the Panel concludes that the Respondent meant Complainant’s trademarks INDIRA IVF when he took over the registration of the disputed Domain Name. Previous UDRP panels categorically held that the use of a domain name for illegal activity, including the unauthorized account access/hacking, impersonation/passing off, or other types of fraud, can never confer rights or legitimate interests on a respondent (WIPO Overview 3.0, para. 2.13.1). The Respondent’s claim that the disputed Domain Name was allegedly purchased via a Facebook group does not negate the fact that this domain name was acquired as a result of the Complainant’s domain names management account being previously hacked. Based on the general legal principle that no right can arise from illegality (ex injuria jus non oritur), the Respondent’s explanation cannot absolve him of liability for the unlawful acquisition of the disputed Domain Name.
The Respondent himself has confirmed in his response that the reason he was interested in buying the disputed Domain Name was in its high traffic. Previous UDRP Panels have also found that a respondent redirecting a domain name to the Complainant’s website can establish bad faith insofar as the respondent retains control over the redirection thus creating a real or implied ongoing threat to the Complainant (section 3.1.4 of WIPO Overview 3.0). This threat finally turned into real damages for the Complainant when the take-over of the disputed Domain Name resulted in the short suspension of the Complainant‘s website for several hours which forced the Complainant to intervene and restore access to its official website in order to prevent reputational and business damage. Therefore, the Panel came to the conclusion that the Respondent both registered (i.e. took-over the registration) and used the disputed Domain Name in bad faith.
Accepted
Complainant’s Counsel: A Raheja, UDRPKing .com
Respondent’s Counsel: Self-represented
Comment by ICA General Counsel, Zak Muscovitch:
First of all, congratulations to our Editor-in-Chief, Ankur Raheja, for successfully recovering the Domain Name for the Complainant.
This case demonstrates that the Policy can be applied to stolen domain names under limited circumstances. Here, the Complainant is a well-known brand in India with 15 years of use and holds registered rights to the marks ‘Indira’ and ‘Indira IVF’ and thereby met the standing requirements of the Policy. In contrast, when the disputed domain name consists of common words and the complainant cannot demonstrate any trademark rights (registered or unregistered), pursuing the UDRP becomes quite challenging even where the Domain Name was stolen or expired inadvertently.
Please read the DNW.com article on this case, here:
https://domainnamewire.com/2025/04/30/indian-ivf-giant-indira-ivf-recovers-stolen-domain/
Is Intention Necessary for Bad Faith?
Mento Technologies Inc. v. Nima Rad, NAF Claim Number: FA2504002149457
<mento .ai>
Panelist: Mr. Clive Elliott K.C.
Brief Facts: The US-based Complainant is a provider of professional development and coaching services together with related software products and services. The Complainant is the registered owner of the US trademark for MENTO registered on March 22, 2022. The Complainant first adopted its trademark in April 2020 and has since then used it continuously in connection with promoting its business. The Respondent registered the Domain Name on March 23, 2023, which the Complainant claims to resolve to a website offering substantially the same professional development and coaching services and related software products and services that are offered by the Complainant under the Complainant’s mark.
The Complainant alleges that its trademark is a coined word or phrase and has no source-identifying meaning other than to designate the Complainant and its brand of professional development and coaching services. The Complainant goes on to claim that consumer confusion is heightened further as the content of the Domain Name offers for sale the same and similar type of professional development and coaching services and software products as the Complainant. The Complainant further alleges that the Respondent has registered and is using the disputed Domain Name in bad faith for the purpose of diverting online traffic premised on consumer confusion and is not a bona fide offering of goods or services.
The Respondent contends that it registered the Domain Name independently and without prior knowledge of the Complainant’s services or mark and that its platform, <mento .ai>, operates as an AI-driven professional social network for connecting professionals and providing AI-generated guidance. The Respondent further contends that it explicitly does not include any person-to-person mentorship modules, which distinctly differs from the Complainant’s person-to-person mentoring services. Additionally, the Respondent contends that upon receiving the initial notice from the Complainant, the Respondent initiated a rebranding process, which is expected to launch by July 2025, and points out that this demonstrates Respondent’s genuine intent and co-operative approach.
Held: The Respondent’s response fails to address the essence of the Complainant’s argument, namely that the parties’ services are either the same or similar in type. That argument seems to have merit and is not refuted by the Respondent’s bare assertion to the contrary. The use of a confusingly similar domain name to deceive and divert customers away from a complainant does not constitute either a bona fide offering of goods or services or a legitimate noncommercial or fair use. See Ripple Labs Inc. v. NGYEN NGOC PHUONG THAO, FA 1741737 (Forum Aug. 21, 2017). Similarly, the use of the Domain Name to offer goods or services that are similar to and potentially compete with those of the Complainant is not bona fide or legitimate. See Coryn Group, Inc. v. Media Insight, FA 198959 (Forum Dec. 5, 2003).
On that basis, the Respondent has failed to make a bona fide offering of goods or services or legitimate noncommercial or fair use of the Domain Name under Policy ¶¶ 4(c)(i) and (iii). Further, the Complainant argues that the Respondent registered and uses the Domain Name in bad faith for the purpose of diverting online traffic, premised on consumer confusion, and is not a bona fide offering of goods or services. The Panel finds that the offer of services that compete or potentially compete with those offered by the Complainant, in this way and as set out above, shows bad faith disruption of the Complainant’s business pursuant to Policy 4(b)(iii). Given the Complainant’s prior use and registration of the Complainant’s trademark, the absence of any adequate explanation for registering and using the disputed Domain Name in a similar commercial field, the Panel is satisfied that bad faith has been established.
Transfer
Complainant’s Counsel: Lindsay M.R. Jones of Merchant & Gould, P.C., Minnesota, USA
Respondent’s Counsel: Self-represented
Comment by ICA General Counsel, Zak Muscovitch: This is a problematic decision in my view. What appears to be missing from the decision, in my view, is any express finding that the Respondent intentionally targeted the Complainant’s trademark. It is simply insufficient under the UDRP to base a finding of bad faith upon mere infringement of a trademark – absent intention. Here, the Panel found that “the offer of services that compete or potentially compete with those offered by Complainant, in this way and as set out above, shows bad faith disruption of Complainant’s business pursuant to Policy”. If this was intentional, i.e. with awareness and purposeful targeting of the Complainant’s trademark, then the Complainant would have a case. But the UDRP does not permit a finding of bad faith where the Respondent merely happened to have registered a domain name which could be infringing upon a Complainant’s trademark without any awareness or targeting. My reading of this case suggests that the Panel may have erroneously applied what amounts to a constructive notice and infringement standard to the case.
Also see: https://domainnamewire.com/2025/04/29/this-was-a-bad-udrp-decision/
Intent is a Necessary Element of Cybersquatting
MILAN PRESSE v. Rishikesh Jha, WIPO Case No. D2025-1016
<milanjournal .com>
Panelist: Mr. Assen Alexiev
Brief Facts: The Complainant, established in 1980, is a French publishing house and press group. It publishes various printed books and magazines for children, which are being distributed in a few countries under the brand MILAN. The Complainant also offers online games and activities, written contents and articles for parents and adults, competitions and other events through the domain names <milanpresse .com> (April 21, 1996), and <milanjeunesse .com> (November 10, 2010), both of which resolve to its official website at <milan-jeunesse .com>, which also displays the brand MILAN at its top left corner. The Complainant is the owner of two French trademark registrations registered on October 18, 2006, “MILAN JEUNESSE” (represented in a red box); and “MILAN PRESSE trademark” (represented in a red box). The disputed Domain Name was registered on June 17, 2024 and resolves to an English language website with the heading “MILAN JOURNAL”, which contains diverse articles about various personalities and topics related to fashion, film, music and other industries.
The Complainant alleges that the disputed Domain Name is confusingly similar to its trademarks, because it reproduces entirely their distinctive and dominant element “MILAN” in combination with the dictionary word “journal”, which is closely related to the business of the Complainant and is a synonym of the term “press” (the English equivalent of the French word “presse”). According to the Complainant, the disputed Domain Name is not being used for bona fide activities but was chosen to take advantage of the Complainant’s goodwill. The Respondent submits that “Milan” and “journal” are common terms, as “Milan” is widely associated with fashion due to the city’s international reputation as a fashion capital, while “journal” is a general term used for blogs, articles, and publications, and describes the type of content provided by the Respondent. The Respondent further notes that target audiences for both businesses are entirely separated and not overlapping, making it unlikely that a user would confuse the two brands. The Respondent also submits that “journal” is an English word, while “presse” and “jeunesse” are French words that are not its synonyms.
Held: In addition to referring to the Complainant’s trademark, the “Milan” element of the disputed Domain Name coincides with the name of the Italian city of Milan, and its combination with the “journal” element can be understood as meaning a “journal related to the city of Milan.” Additionally, it seems reasonable to regard the Complainant’s trademarks as being composed of a geographical term and a dictionary term, and the Complainant uses them to designate its activity as an editor of French speaker children’s books and magazines, while the Respondent uses the disputed Domain Name for a website that contains online articles about fashion, personalities, home decoration, culture, and these articles appear to be intended for an English speaking adult audience. The Parties’ respective websites have very different layouts, styles and colors, and the Respondent’s website does not reproduce the Complainant’s logo or anyhow refer to the Complainant.
Considering the above, there is no evidence to contradict the Respondent’s assertion that it has chosen to include “Milan” in the disputed Domain Name as it may evoke fashion due to the connection between Milan and the fashion industry, and not as a reference to the Complainant or its trademarks. It therefore does not appear as more likely than not that the Respondent has registered and used the disputed Domain Name with an intent to target the Complainant’s trademarks. Since intent is a necessary element of cybersquatting, this means that a finding of bad faith under the Policy cannot be made. It may be speculated that there may be grounds for a finding of trademark infringement (which may take place even without intent), but the Panel’s mission is not to take decisions on this issue, which should be left to the courts of competent jurisdiction. The Panel, therefore, finds that the Complainant has not established the third element of the Policy.
Complaint Denied
Complainant’s Counsel: Grant Thornton, France
Respondent’s Counsel: Self-represented
Case Comment by ICA General Counsel, Zak Muscovitch: In contrast to the above <mento .ai> case, the Panel got this case right, by appropriately focusing on the essential and fundamental basis for a finding of bad faith, namely intention. As the Panel rightly noted:
“Since intent is a necessary element of cybersquatting, this means that a finding of bad faith under the Policy cannot be made. It may be speculated that there may be grounds for a finding of trademark infringement (which may take place even without intent), but the Panel’s mission is not to take decisions on this issue, which should be left to the courts of competent jurisdiction.”
As you can also see, the Panel clearly appreciated the difference between trademark infringement and bad faith under the UDRP. With trademark infringement, intention is unnecessary, whereas with bad faith, it certainly is. Well done, Panel!
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.