Sfanti Grup Solutions SRL v Kamrul Hasan, Optosoft-IT, Shishir Amhed, MD

WIPO Case No. D2024-5089

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Sfanti Grup Solutions SRL v. Kamrul Hasan, Optosoft-IT, Shishir Amhed, MD
NOYON ALI, MICHEAL FUNSTON, Shivkumar Yadav, Ansh Ansh,
HENRIQUE MANUEL, MKH LTD, priceevaw aw, Rifat Islam

Case No. D2024-5089

1. The Parties

The Complainant is Sfanti Grup Solutions SRL, United States of America (“United States”), represented by
Walters Law Group, United States.

The Respondents are Kamrul Hasan, Optosoft-IT, Bangladesh; Shishir Amhed, Bangladesh; MD NOYON ALI, Bangladesh; MICHEAL FUNSTON, United States; Shivkumar Yadav, India; Ansh Ansh, Bangladesh; HENRIQUE MANUEL, MKH LTD, Portugal; priceevaw aw, United States; and Rifat Islam, Bangladesh.

2. The Domain Names and Registrars

The disputed domain name <megaapersonal.com> is registered with NameCheap, Inc.

The disputed domain names <megaperesonals.com>, <megapersonaals.com>, and <megappersonals.com> are registered with Cosmotown, Inc.

The disputed domain names <megaperrsonals.com>, and <megaperssonals.com> are registered with
Hostinger Operations, UAB.

The disputed domain names <megapersonalclassified.com>, and <megapersonalsus.com> are registered with Dreamscape Networks International Pte Ltd.

The disputed domain name <megapesronals.com> is registered with Purple IT Ltd,

The disputed domain names <megaapersonals.com>, <megapersohals.com>, and <megapersonalas.com>
are registered with GMO Internet, Inc. d/b/a Discount-Domain.com and Onamae.com (collectively, “the

Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 10,
2024. On December 11, 2024, the Center transmitted by email to the Registrar a request for registrar

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verification in connection with the disputed domain names. On December 11, 2024, December 13, 2024, December 16, 2024, December 20, 2024, January 9, 2025, and January 17, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (WhoisPrivacy Protection Service, Redacted, Privacy Protect, LLC, Domain Administrator Private Registry Authority, Shivkumar Yadav) and contact

information in the Complaint.

The Center sent an email communication to the Complainant on January 23, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all disputed domain names are under common control. The Complainant filed an amended

Complaint on January 27, 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 Respondents of the
Complaint, and the proceedings commenced on February 4, 2025. In accordance with the Rules, paragraph
5, the due date for Response was February 24, 2025. The Respondents did not submit any formal
response. The Respondents sent email communications to the Center on February 4, 2025, February 21,
2025 and February 24, 2025. On March 7, 2025, the Center informed the Parties that it would proceed with
panel appointment.

The Center appointed Alistair Payne as the sole panelist in this matter on March 13, 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 owns and operates the websites at “ and “ and has used these domains since 2004 and 2020 respectively in connection with websites from which it offers social introduction and dating services. The Complainant owns United States trade mark registration number 6432591 for MEGAPERSONALS registered on July 27, 2021.

Each of the disputed domain names was registered in the period July 29, 2024 to October 28, 2024. At the time of filing of the Complaint, each of the disputed domain names resolved to a website page that appears to be a copy of one of the Complainant’s website pages and each of them featured the MEGAPERSONALS trade mark in the context of ostensibly providing an Internet based social introduction or dating service.

5. Parties’ Contentions
A. Complainant

The Complainant submits that the complaints for the disputed domain names should be consolidated. It says that the evidence suggests that the registrants of the disputed domain names are either one and the same person, entity, or network or are somehow connected to each other and are under common control.

The Complainant notes that the disputed domain names all share similar structural elements and all except for <megapersonalsus.com> are typosquatted versions of the Complainant’s trade mark that contain an extra letter, drop a letter, reverse letters, or replace a letter with a visually similar letter. It also notes that one of

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those typosquatted domain names, also includes the additional word “classified” and one includes the
abbreviation “us” for United States.

According to the Complainant, the disputed domain names all lead to websites which appear to be visually similar to the Complainant’s website and replicate either the home page, log-in page, or “Create a Post Page” of the Complainant’s website. The Complainant suspects that these copycat websites were created to fraudulently collect log-in credentials from the Complainant’s users for phishing and hacking purposes. It notes that many of the disputed domain names use the same registrar and privacy service and confirms that none of the registrants responded to the Complainant’s cease and desist letter. It also observes that all of the disputed domain names were registered within the same four-month span, and many disputed domain names were registered within days of each other, sometimes at the same registrar and other times at different registrars but with substantially similar typosquatting effects. The Complainant also says that two of the disputed domain names were registered under the same name. Shishir Amhed likely registered three disputed domain names under an alias, Ansh Ansh. Finally, the Complainant notes that all but one of the dispute domain name registrations use a Gmail address, and many of the disputed domain name registrations list addresses in Bangladesh. For these reasons, says the Complainant, it is most likely that the disputed domain names were registered by the same person or entity or under common control and should therefore be consolidated.

The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain names.

Notably, the Complainant contends that it owns registered trade mark rights for its MEGAPERSONALS trade mark and that all of the disputed domain names except for <megapersonalsus.com> contain a typosquatted version of the Complainant’s trade mark – such as containing an extra letter, dropping a letter, reversing letters, or replacing a letter with a visually similar letter. In addition, says the Complainant, one of the

disputed domain names also contains the word “classified” – an additional word which describes the services offered by the Complainant and another of the disputed domain names also contains the letters “us” which is a common abbreviation for United States, where the Complainant offers its services. Noting that a domain name which consists of a common, obvious, or intentional misspelling of a trade mark is considered by

panels to be confusingly similar to the relevant mark for the purposes of the first element of the Policy and that once the Complainant’s mark is obvious in the disputed domain name that an additional word does not prevent a finding of confusing similarity, the Complainant submits that each of the disputed domain names is confusingly similar to its registered trade mark.

The Complainant submits that the Respondents have no connection or affiliation with the Complainant and marks for the disputed domain names. It says that there is no evidence to indicate that the Respondents are known by the text of the disputed domain names and accordingly that the Panel should presume that the Respondents are not known by the text of the disputed domain names.

has not received any authorisation, licence, or consent, whether express or implied, to use the
MEGAPERSONALS trade mark in the disputed domain names, or in any other manner. It says that the

The Complainant also says that the Respondents are using identical or confusingly similar disputed domain names to direct Internet users to websites that are copies of the Complainant’s website pages. For this reason, says the Complainant, it is very probable that an Internet user might be misled into thinking that the webpages of the disputed domain names are related to or even operated by the Complainant. It notes that previous panels have consistently held that such use is not a bona fide offering of goods or services and further, that the use of the Complainant’s logo on the websites located at the disputed domain names

demonstrates an intention to falsely suggest an affiliation with or sponsorship by the Complainant. It says that the Respondents can claim no rights to, or legitimate interests in, the disputed domain names, because the websites contain the Complainant’s logo.

The Complainant also submits that the disputed domain names resolve to websites that are designed to look like the Complainant’s website in order to deceive users into providing their log-in credentials to the

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Respondents and that the Respondents’ use of the disputed domain names to engage in phishing of the
Complainant’s users’ log-credentials is not in connection with a bona fide offering of goods or services.

As far as registration in bad faith is concerned, the Complainant submits that the disputed domain names were registered between July 29, 2024 and October 28, 2024, after the Complainant attained rights in the MEGAPERSONALS trade mark. The Complainant says further that it is well-settled that the practice of typosquatting is evidence of bad faith registration and that the use of the disputed domain names to divert Internet traffic from the Complainant’s site to copycat websites for phishing purposes and to deceptively collect the log-in credentials of the Complainant’s users is further evidence of registration in bad faith. It also notes that one of the Respondents appears to be a serial cybersquatter.

The Complainant submits that as the websites at the disputed domain names look identical to the Complainant’s Home Page, log-in Page, and “Create a Post page” that based on these similarities and the unauthorised use of the Complainant’s MEGAPERSONALS trade mark and logo an Internet user could readily assume that the Respondents are affiliated with the Complainant and be induced to provide personal data to the Respondents for purposes that cannot be legitimate and which are deceptive and indicative of bad faith. The Complainant also says that the disputed domain names direct to websites that are designed to deceive the Complainant’s users into unknowingly providing their log-in credentials to the Respondents for phishing purposes and that this clearly constitutes bad faith use.

B. Respondents

The Respondents did not formally reply to the Complainant’s contentions. However, on February 4, 2025, an email communication was received from the email address associated with the disputed domain name <megapersonalas.com> who claimed to have no involvement in this disputed domain name. On February 21, 2025 and February 24, 2025, email communications were received from the email associated with the disputed domain name <megaapersonal.com> who claimed that it is not the owner of the website at this disputed domain name and requested to close this website.

6. Discussion and Findings
Consolidation: Multiple Respondents

The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules.

The disputed domain name registrants did not comment on the Complainant’s request.

Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder.

In addressing the Complainant’s request, the Panel will consider whether (i) the disputed domain names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition

(“WIPO Overview 3.0”), section 4.11.2.

As regards common control, the Panel notes that the disputed domain names are for the most part typosquatted versions of the Complainant’s trade mark with an extra letter, the omission of a letter, a reversal of letters, or the replacement of a letter with a visually similar letter. Only two of the disputed domain names have a different structure being <megapersonalsus.com> and <megapersonalclassified.com>which include the Complainant’s mark or an incorrect spelling of it together with an additional term. At the time of filing of the Complaint, all of the disputed domain names led to websites which appear visually similar to the

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Complainant’s website and replicate either the home page, log-in page, or “Create a Post Page” of its website. The Panel also notes that all of the disputed domain names were registered over approximately a three-month period from July 29, 2024 to October 28, 2024. Many of the disputed domain names are ostensibly owned by registrants based in Bangladesh. It is notable that there was no response by any of the registrants to the Complainant’s cease and desist letter. None of the registrants filed any formal response to the Complaint in these proceedings, while email communications were received from the email addresses associated with the disputed domain names <megapersonalas.com> and <megaapersonal.com> who apparently claimed to have no involvement in these disputed domain names. The Panel notes also that the registrant Shishir Amhed, who has previously found to be a cybersquatter based on past decisions, has also been listed as admin and tech contacts for the three disputed domain names registered with the Registrar Cosmotown, Inc. under the registrant Ansh Ansh. In the Panel’s view these factors point to the strong likelihood that all of the disputed domain names are under common control.

As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party.

Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding.

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 3.0, section 1.7.

The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.

The Panel finds the mark is recognisable within each of the disputed domain names. In all but two examples the Complainant’s mark is a straightforward example of typosquatting. The addition of the abbreviation “us” for United States in <megapersonalsus.com> and the omission of a “s” and addition of the word “classified” in <megapersonalclassified.com> does not prevent a finding of confusing similarity. Accordingly, each of the disputed domain names is confusingly similar to the mark for the purposes of the Policy.

WIPO Overview 3.0, sections 1.7, 1.8 and 1.9.

The Panel finds the first 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 often 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 satisfied the second element. WIPO Overview 3.0, section

2.1.

The Complainant has submitted that the Respondent has no connection or affiliation with the Complainant
and has not received any authorisation, licence, or consent, whether express or implied, to use the
MEGAPERSONALS trade mark in the disputed domain name, or in any other manner. It has asserted that

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the Respondent is not commonly known by the MEGAPERSONALS trade mark and does not hold any trade
marks for the disputed domain names.

The Complainant has provided evidence to show that the Respondent is using confusingly similar disputed domain names to direct Internet users to websites that are copies of the Complainant’s website pages in order to mislead Internet users into thinking that these websites are related to or operated by the

Complainant. This conduct is not consistent with a bona fide offering of goods or services. Neither is the unauthorised use of the Complainant’s MEGAPERSONALS mark on the websites to which each of the disputed domain names resolves consistent with the Respondent having rights or legitimate interests in the disputed domain names.

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 names. 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 names such as those enumerated in the Policy or otherwise.

The Panel finds the second element of the Policy has been established.

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.

In the present case, the Panel notes that the Respondent registered the disputed domain names between MEGAPERSONALS trade mark. The Complainant’s MEGAPERSONALS mark is quite distinctive and in all but two cases the disputed domain names are examples of typosquatting which on its own has been found by previous panels to be evidence of bad faith. As noted above, the other two disputed domain names involve additional elements and/or an omitted letter in the Complainant’s mark but in each case the Panel finds that the MEGAPERSONALS mark is recognisable in each of the disputed domain names. Using the Complainant’s mark or a misspelling of the Complainant’s mark in each of the disputed domain names to divert Internet users to copycat websites which feature the MEGAPERSONALS mark, and which emulate the Complainant’s website pages suggests that the Respondent was more likely than not well aware of the Complainant’s mark and business when it registered each of the disputed domain names.

Under paragraph 4(b)(iv) of the Policy there is evidence of registration and use of the disputed domain name in bad faith where a respondent has used the disputed domain name to intentionally attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s trade mark as to the source, sponsorship, affiliation or endorsement of the website.

In this case the Respondent has used each of the disputed domain names to resolve to a website page which emulates one of the Complainant’s website pages and which features the Complainant’s MEGAPERSONALS trade mark. In short, the Respondent is using each of the disputed domain names to confuse and divert Internet users to a website controlled by the Respondent, but which looks as if it is the Complainant’s website. Whether the purpose of this is to phish for Internet users’ personal details or to compete with the Complainant is unclear, but it is apparent that this fraudulent activity is being undertaken on a considerable scale and for the ultimate commercial benefit of the Respondent. Accordingly, the Panel finds that this conduct fulfills the requirements of paragraph 4(b)(iv) of the Policy which is evidence of registration and use in bad faith.

The Panel finds that the Complainant has established the third element of the Policy.

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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 names <megaapersonal.com>, <megaapersonals.com>,
<megaperesonals.com>, <megaperrsonals.com>, <megapersohals.com>, <megapersonaals.com>,
<megapersonalas.com>, <megapersonalclassified.com>, <megapersonalsus.com>,
<megaperssonals.com>, <megapesronals.com>, and <megappersonals.com> be transferred to the

Complainant.

/Alistair Payne/
Alistair Payne
Sole Panelist
Date: March 27, 2025