GW50, LLC d/b/a Trendline SEO v Dmytro Sokhach, Shared Domains OU

WIPO Case No. D2025-2612

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

GW50, LLC d/b/a Trendline SEO v. Dmytro Sokhach, Shared Domains OU

Case No. D2025-2612

1. The Parties

The Complainant is GW50, LLC d/b/a Trendline SEO, United States of America (“United States”), represented internally.

The Respondent is Dmytro Sokhach, Shared Domains OU, Estonia, self-represented.

2. The Domain Name and Registrar

The disputed domain name <startablog123.com> is registered with NameCheap, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 2, 2025. On July 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 4, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (“Whois Privacy Service / Withheld for Privacy ehf”) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 9, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed amended Complaints on July 10, and 17, 2025.

The Center verified that the Complaint together with the amended Complaint satisfied 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 notified the Respondent of the
Complaint, and the proceedings commenced on July 18, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was August 7, 2025. The Response was filed with the Center on July 25, 2025.
The Complainant filed a supplemental filing on July 27, 2025.

page 2

The Center appointed John Swinson as the sole panelist in this matter on July 30, 2025. The Panel finds
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 a business from the United States that provides search engine optimization (SEO) services.

The disputed domain name was registered on February 22, 2014.

The Complainant purchased the disputed domain name on March 13, 2018, for USD 25,000.

The Complainant operated a website at the disputed domain name between 2018 and 2023 and claims to have invested “about USD 55,000 redesigning, expanding, and renewing the site.”. The website at the disputed domain name during this period provided information as to how to start a blog, included a publication called “The Beginner’s Guide to Starting a Blog” and had a link to a third-party web hosting service. The website included branding in logo format that included the words “Start A Blog 123” and an image such as a diamond or a rectangle. On the website, there were headings such as “Is it hard to start a blog?”

The Complainant claims it spent time and money building up traffic to the website at the disputed domain
name. At some unspecified time, the Complainant consolidated several of his blogging brands, and on
October 4, 2020, redirected the disputed domain name to <bloggingtips.com>.

The Complainant discovered that the disputed domain name had lapsed on April 2, 2025. The Complainant apparently incorrectly believed that he had established an auto-renew service with the Complainant’s registrar.

The Respondent registered the disputed domain name on April 3, 2025.

At the date of this Decision, the website at the disputed domain name provides information about starting a blog. The website is titled “StarB123 Your stellar start in blogging”. The website includes “team” information that appears fake and an address in West Nyack, New York, that does not exist. The website also includes blog posts which are dated prior to April 3, 2025.

In April and May 2025, the Complainant sent emails intended for the Respondent to try to re-acquire the disputed domain name but did not receive any response from the Respondent.

On June 2, 2025, the Complainant applied for a United States trademark registration for STARTABLOG123 for services in class 41 for “Providing a website featuring blogs and non-downloadable publications in the nature of articles in the field(s) of blogging, website creation, digital marketing and search-engine optimization.”. The Complainant claimed a date of first use of at least as early as March 13, 2018. See Application Serial No. 99213977.

The Complainant has written a blog post about his experience in this matter, including regarding a complaint under the Policy, at “ which states “UDRP (Uniform Domain-Name Dispute-Resolution Policy) claims require demonstrating bad-faith registration or usage by the new domain holder. With no prior trademark registration, proving my rights to the domain gets trickier. … It’s on the table, but not yet the primary strategy.”

The Respondent has written articles about acquiring expired domain names for their SEO benefits, such as
“ and has spoken on podcasts about this topic, for

page 3

example “

with/id1652074053?i=1000623458150”.

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.

In summary, the Complainant makes the following submissions.

The Complainant has common law rights in STARTABLOG123 going back to 2018.

The Complainant asserts that panels routinely find that the opportunistic drop-catch of a recently-lapsed brand domain constitutes bad faith.

The Respondent is not commonly known by the disputed domain name and the website at the disputed domain name offers no genuine content; the site displays only thin AI-generated material that has no legitimate value.

The Respondent’s use of fabricated contact data on its website at the disputed domain name, a non- functional email address, and a template privacy statement is evidence of deceptive intent and bad faith under the Policy. The Respondent launch a thin site that has low quality AI articles and AI-produced author personas. All contact data on the website at the disputed domain name is fictitious.

The Respondent explicitly markets expired domain names for private blog network link building.

The Respondent registered the disputed domain name one day after it dropped, immediately hid behind a privacy service, and replaced years of authoritative content with thin, AI-generated pages.

B. Respondent

The Respondent contends that the Complainant has not satisfied all three of the elements required under the

Policy for a transfer of the disputed domain name.

In summary, the Respondent makes the following submissions.

The disputed domain name is composed of generic and descriptive terms. The phrase “start a blog” is commonly used in the blogging and digital marketing industry, and the addition of “123” is a non-distinctive numeric suffix.

At the time the Respondent acquired the disputed domain name, the Complainant had no registered trademark rights.

The Complainant has not demonstrated common law rights. There is no evidence of brand recognition, advertising, revenue, traffic, or consumer association with the term “StartABlog123”

The disputed domain name consists of a descriptive phrase that aligns with the Respondent’s intended and actual use – educational or informational content related to starting a blog. Usage of domain names containing dictionary words consistent with their common meaning may support a finding of legitimate interest.

page 4

The disputed domain name was not registered for the purpose of selling it to the Complainant or any
competitor for a profit exceeding documented out-of-pocket cost. The Respondent never contacted the

Complainant with any sale offer, and the disputed domain name has not been listed for sale.

The Respondent had no knowledge of the Complainant or any rights (registered or unregistered) at the time
of acquisition. The disputed domain name was acquired based on its descriptive value, not to exploit the
Complainant’s mark.

Given that the Complainant lost the disputed domain due to its own inaction, and only subsequently filed for trademark protection before initiating this Complaint, there is reason to believe the proceeding was filed in bad faith to improperly use the UDRP mechanism to acquire a generic domain. The Respondent requests the Panel to consider a finding of Reverse Domain Name Hijacking.

C. Complainant’s Supplemental Filing

On July 27, 2025, the Complainant filed a supplemental submission.

Paragraphs 10 and 12 of the Rules grant the Panel sole discretion to determine the admissibility of unsolicited supplemental filings. While paragraph 10(d) states that: “The Panel shall determine the admissibility, relevance, materiality and weight of the evidence”, paragraph 12 provides that: “In addition to

the complaint and the response, the Panel may request, in its sole discretion, further statements or
documents from either of the Parties”. As a general matter, unsolicited supplemental filings are generally
discouraged, unless specifically requested by the panel.

The Complainant has not shown reasons that convince the Panel that a supplemental submission is warranted or that there are exceptional circumstances in this case. Even if the Panel considered the supplemental submission, the result would not differ because the supplemental submission did not provide

new arguments to address the issues discussed below that the Panel decides against the Complainant.

6. Discussion and Findings

To succeed, the Complainant must demonstrate that all of the elements enumerated in paragraph 4(a) of the

Policy have been satisfied, namely:

(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the

Complainant has rights;

(ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and

(iii) the disputed domain name has been registered and is being used in bad faith.

The onus of proving these elements is on the Complainant.

An asserting party needs to establish that it is, more likely than not, that the claimed fact is true. An asserting party cannot meet its burden by simply making conclusory statements unsupported by evidence. To allow a party to merely make factual claims without any supporting evidence would essentially eviscerate the requirements of the Policy as both complainants or respondents could simply claim anything without any proof. For this reason, UDRP panels have generally dismissed factual allegations that are not supported by any bona fide documentary or other credible evidence. Captain Fin Co. LLC v. Private Registration, NameBrightPrivacy.com / Adam Grunwerg, WIPO Case No. D2021-3279.

page 5

A. Identical or Confusingly Similar

It is well accepted that the first 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.

Based on the evidence before the Panel, the Complainant does not hold any registered trademark rights. A pending trademark application would not by itself establish trademark rights within the meaning of UDRP paragraph 4(a)(i). WIPO Overview 3.0, section 1.1.4.

The Respondent relies upon common law trademark rights.

To establish unregistered or common law trademark rights for purposes of the UDRP, the complainant must show that its mark has become a distinctive identifier which consumers associate with the complainant’s goods and/or services.

Relevant evidence demonstrating such acquired distinctiveness includes a range of factors such as (i) the duration and nature of use of the mark, (ii) the amount of sales under the mark, (iii) the nature and extent of advertising using the mark, (iv) the degree of actual public (e.g., consumer, industry, media) recognition, and (v) consumer surveys.

Specific evidence supporting assertions of acquired distinctiveness should be included in the complaint; conclusory allegations of unregistered or common law rights, even if undisputed in the particular UDRP case, would not normally suffice to show secondary meaning. WIPO Overview 3.0, section 1.3.

The Complainant has provided evidence to show some pages of the website at the disputed domain name in 2018 and at other dates, and some data regarding “anchors” in respect of the disputed domain name (which is not summarized or explained in the Complaint). The Complainant stated that it spent money redesigning the website, but did not provide any specific details or proof of such expenses. The Complainant provided no information as to the traffic to the website at the disputed domain name, advertising costs, number of

customers, revenue generated by the business and the like. In short, there is no evidence of reputation of
the STARTABLOG123 trademark.

Due to the findings below in respect of the third element of the Policy, however, the Panel does not need to reach a conclusion as to whether the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy in view of the claims and (scant) evidence provided by the Complainant.

B. Rights or Legitimate Interests

The Panel is troubled by the website at the disputed domain name created by the Respondent. The website appears to be misleading and deceptive in several respects. On its face, it is not a website of a bona fide business. However, in view of the findings below in respect of the third element of the Policy, the Panel does not need to make a definitive finding on the second element of the Policy.

C. Registered and Used in Bad Faith

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.

Generally speaking, a finding that a domain name has been registered and is being used in bad faith requires an inference to be drawn that the respondent in question has registered and is using the disputed domain name to take advantage of its significance as a trademark (usually) owned by the complainant.

page 6

In the present case, both the Complainant and the Respondent are sophisticated businesses both involved in SEO. The Respondent promotes a strategy of acquiring expired domain names to boost website traffic from backlinks.

Where registration occurs through registering recently expired domain names or drop-catching, the registrant is objectively aware that another person held the registration immediately prior. This, in effect, puts the registrant on notice that another person (at least the immediately prior registrant) may have rights in a trademark to which the domain name is identical or confusingly similar. Supermac’s (Holdings) Limited v. Domain Administrator, DomainMarket.com, WIPO Case No. D2018-0540 (“Supermac”).

Thus, panels in previous UDRP cases have ruled against respondents who have employed drop-catching services, in part because the very use of such a service means that the respondent knew that it was acquiring a domain name that someone else had previously owned, and that such acquisition was perhaps because of its value as a trademark.

., Photomaton v.

Not all drop-catching cases, however, lead to a ruling against the respondent. See, e.galbeit imperfect, for potential conflicting trademarks).

As with other issues, each case must be reviewed on its own merits. Datacap Systems, Inc. v. Domain

Admin, XYZ Invest LLC, WIPO Case No. D2023-0858.

Forever I Am, Inc v. Domain Admin, HugeDomains.comD2021-1550

As stated in , WIPO Case No. which the present case.

involved registration of an expired domain name: “Complainant has made numerous assertions that
Respondent’s registration was in bad faith, but has provided little if any evidence. What Complainant did not
argue or present evidence (if it existed) for was any suggestion that Respondent’s acquisition of the Domain
Name was due to the latter’s knowledge of the former’s pre-existing business reputation and goodwill
(whether based on a purported duty to search or otherwise) and a desire to capitalize therefrom, as opposed
to a conscious decision merely not to renew its domain name registration. Based on the evidence
presented, there is little to no support for a finding that Respondent registered the Domain Name in bad faith.

In the present case, the Respondent asserts: “The Respondent had no knowledge of the Complainant or any rights (registered or unregistered) at the time of acquisition. The domain name was acquired based on its descriptive value, not to exploit the Complainant’s mark.” This is believable. The Complainant had no pending or registered trademark rights at the time the Respondent registered the disputed domain name, and as stated above, the Complainant’s evidence of its reputation in the STARTABLOG123 trademark is not strong to say the least.

The Respondent appears to own a portfolio of domain names, and there is no evidence that the Respondent has a practice of registering domain name because of third party trademark value. Unlike Supermac, there is no evidence that the Respondent offered the disputed domain name for sale to the Complainant or any other person; to be clear, this is but one factor, and if there were evidence on e.g., paragraph 4(b)(iv) that would be relevant to the case outcome.

The Complainant argues that the website at the disputed domain name is not bona fide and that a “deliberate back-dating of every post” means that the website at the disputed domain name is not a genuine publication “but a façade designed to feign long-standing use”. This is both true, and it moreover does speak to a level of sophistication that may imply that the Respondent was aware of the traffic generated by the Complainant using the disputed domain name and sought to profit from that (as the Complainant puts it “to retain link equity”), but of itself, does not demonstrate that the Respondent registered or used the disputed domain name in bad faith under the Policy.

The Panel finds the third element of the Policy has not been established.

page 7

D. Reverse Domain Name Hijacking

Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad

faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.0, section 4.16.

The Complainant made arguments, although unsuccessful, as to why the Complainant met the elements of
the Policy. The Complainant had owned the disputed domain name and let it lapse by accident. The

Complainant provided case references in respect of cases involving drop-catching. The Panel does not
consider that the Complainant filed the case in bad faith, and this is not a case of Reverse Domain Name

Hijacking.

7. Decision

For the foregoing reasons, the Complaint is denied.

/John Swinson/
John Swinson
Sole Panelist
Date: August 13, 2025