Anthropic, PBC v Lester Doyle
WIPO Case No. D2025-3146
•24-09-2025
| ARBITRATION AND MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
Anthropic, PBC v. Lester Doyle
Case No. D2025-3146
1. The Parties
The Complainant is Anthropic, PBC, United States of America (“United States”), represented by Elster &
McGrady LLC, United States.
The Respondent is Lester Doyle, United States.
2. The Domain Name and Registrar
The disputed domain name <anthropic.icu> is registered with NameSilo, LLC (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 6, 2025. On August 7, 2025, the Center transmitted by email to the Registrar a request for registrar verif ication in connection with the disputed domain name. On August 7, 2025, the Registrar transmitted by email to the Center its verif ication response, disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Administrator Domain, See PrivacyGuardian.org) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 8, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the
Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on
August 13, 2025.
The Center verif ied that the Complaint together with the amended Complaint satisf ied the formal
requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for
Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for
Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).
In accordance with the Rules, paragraphs 2 and 4, the Center formally notif ied the Respondent of the Complaint, and the proceedings commenced on August 14, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 3, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s default on September 4, 2025.
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The Center appointed William F. Hamilton as the sole panelist in this matter on September 10, 2025. The Panel f inds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.
4. Factual Background
The Complainant is one of the leading artificial intelligence (AI) safety and research companies focused on building reliable, interpretable, and steerable AI systems.
The Complainant owns the United States Patent and Trademark Office registration Reg. No. 7,491,942 for the mark ANTHROPIC (the “Mark”), applied for on June 16, 2023, and registered on September 3, 2024.
The disputed domain name was registered on December 15, 2024, and resolves to a website that of fers third-party pay-per-click (“PPC”) competitive advertisements, including one referencing the Complainant’s product.
5. Parties’ Contentions
A. Complainant
The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
Notably, the Complainant argues that the disputed domain name is confusingly similar to its Mark. The Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name, and there is no evidence indicating that the Respondent is commonly known by that name. Additionally, the Complainant states that the Respondent is neither a licensee nor affiliated with the Complainant in any way. Furthermore, the Complainant claims it has not authorized the Respondent to use the Mark. Moreover, the Complainant argues that the disputed domain name was registered and is used in bad faith for commercial gain, misleading Internet users into believing that the disputed domain name resolves to a website that the Complainant endorses, is connected to, or sponsors.
B. Respondent
The Respondent did not reply to the Complainant’s contentions
6. Discussion and Findings
Paragraph 4(a) of the Policy lists three elements that a complainant must satisfy to succeed. The
Complainant must demonstrate that:
(i) the domain name is identical or confusingly similar to a trademark or service mark in which the
Complainant has rights; and
(ii) the Respondent has no rights or legitimate interests in respect of such domain name; and
(iii) the domain name has been registered and is being used in bad faith.
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A. Identical or Confusingly Similar
It is well accepted that the f irst element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect to the Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.
The entirety of the Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Top- Level Domain (“TLD”) “.icu” is viewed as a standard registration requirement and as such is disregarded under the f irst element confusing similarity test. WIPO Overview 3.0, section 1.11.
The Panel f inds the f irst element of the Policy has been established.
B. Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name.
Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is of ten primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1.
Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise.
The disputed domain name resolves to a website offering PPC links. The use of the disputed domain name identical to the Mark for a PPC site with a link to the Complainant’s AI product does not constitute a bona fide of fering of goods or services nor a legitimate noncommercial or fair use under the Policy. WIPO Overview 3.0, section 2.9.
C. Registered and Used in Bad Faith
The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:
(i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of -pocket costs directly related to the domain name; or
(ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from ref lecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or
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(iii) you have registered the domain name primarily for the purpose of disrupting the business of a
competitor; or
(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.
Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1.
The disputed domain points to a PPC website that directly references the Complainant and its product, likely with the commercial goal of earning click-through revenue by linking to third-party sites. These activities qualify as bad faith registration and use under paragraph 4(b)(iv) of the Policy. WIPO Overview 3.0, section 3.5. The Panel sees no plausible reason for the Respondent’s registration of the domain name other than to prof it from the Mark’s goodwill. WIPO Overview 3.0, section 3.2.2. Additionally, the Panel notes that the Respondent has set up email records related to the disputed domain name, which, given the circumstances, further supports the f inding of bad faith registration and use.
The Panel f inds that the Complainant has established the third element of the Policy.
7. Decision
For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <anthropic.icu> be transferred to the Complainant.
/William F. Hamilton/
William F. Hamilton
Sole Panelist
Date: September 24, 2025
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