The National Council for Civil Liberties v Syed Talat Abbas Shah, Action for

WIPO Case No. D2025-0705

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

The National Council for Civil Liberties v. Syed Talat Abbas Shah, Action for
Humanity

Case No. D2025-0705

1. The Parties

The Complainant is The National Council for Civil Liberties, United Kingdom (“UK”), represented by Reed

Smith LLP, UK.

The Respondent are Syed Talat Abbas Shah, Action for Humanity, Pakistan, represented by Nadeem

Ahmed, Pakistan

2. The Domain Name and Registrar

The disputed domain name <libertyhumanrights.org> is registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 20, 2025. On February 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 21, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Respondent sent an informal email communication on February 26, 2025, then a further substantive email on February 27, 2025.

The Center verified that the 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 the due date for Response was March 23, 2025. The Response was filed with the Center on March 7, 2025.

The Center appointed W. Scott Blackmer as the sole panelist in this matter on April 3, 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.

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4. Factual Background

The Complainant is an English non-profit company headquartered in London. The Complainant states that it is better known to the general public simply as “Liberty” since its rebranding in 1989. It is “the UK’s largest independent membership organization and the UK’s oldest human rights campaigning organization”. Founded in 1934, the Complainant has more than 15,000 enrolled members and supporters and campaigns widely to “challenge injustice”, “defend freedom”, and “for everyone in the UK to be treated fairly, with dignity and respect”. The Complainant is a member of the International Network of Civil Liberties Organizations (INCLO).

The Complainant has operated a website at “ since August 2017. Before that, its website was located at the aurally identical “ from February 1999. The Complainant claims more than 780,000 annual visits to its website since 2020. The Complainant’s website is also linked to social media accounts, and the domain name is used to send regular email updates to a list of more than 260,000 subscribers about the Complainant’s advocacy campaigns.

The Complainant has never registered a trademark or service mark. Rather, the Complainant asserts some 16,000 subscribers and sells other “Liberty”- branded literature via the website. The Complainant’s registered offices are at “Liberty House” in London, an address that reflects the name by which it is commonly known and that is publicized in its campaigns and on its website and social media pages, which have more than 200,000 followers. The Complainant’s LIBERTY mark and domain name also appear on its hundreds of emails that are sent to subscribers every year, on placards, flyers, and advertisements used in its advocacy campaigns, and on the merchandise such as T-shirts and pens sold on its website.
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 Complaint
attaches numerous examples of media and public recognition of the Complainant’s involvement in such
campaigns, involving Parliamentary briefings, letter-writing, street protests, court actions, lobbying on laws
and regulations, and public education and awareness, all associating the Complainant with the names
LIBERTY and LIBERTY HUMAN RIGHTS. The record includes evidence of hundreds of thousands of
pounds in annual donations to the Complainant and substantial expenditures on advertising. The Complaint
attaches evidence showing that for web browsers geolocated in the UK, the Complainant’s website is the first

to appear in response to Internet searches for “Liberty Human Rights”, closely followed by the Complainant’s

The disputed domain name was created on August 20, 2020, and is registered to the Respondent Syed Talat Pakistan.[1] This organization maintains a multipage website in English at “ which describes the organization’s mission of defending human rights and demanding accountability, featuring various education and advocacy programs. Mr. Shah is pictured in photos as “Pakistan Chapter Head”. Site visitors are encouraged to join the organization or to submit complaints, in English or Urdu, concerning human rights violations.

[1]The Complaint also named Ahmed Gopang as a Respondent, presumably because his contact details were listed previously on the

The disputed domain name resolves to a single-page website in English (the “Respondent’s website”), under the title “Welcome to Liberty Human Rights”, with the tagline, “Advocating for Human Rights”. The copyright notice is in the name of “Liberty Human Rights”, an organization that is not further identified on the site. The messaging on the page suggests that the website is still under development:

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“Our team is hard at work crafting a unique online experience that we can’t wait to share with you. Thank
you for your patience and support as we embark on this journey together.

Our mission is to advocate for justice, equality, and freedom for all. Through research, education, and advocacy, we strive to bring about positive change in society and hold those in power accountable for their actions.”

Otherwise, the content of the landing page is largely focused on asserting the rights of the Respondent as a domain name owner. Once the Complaint was notified and the administrative proceeding commenced, the disputed domain name was updated with an “Official Notice” that complains that for two years the

Respondent has faced “relentless and unlawful attempts to seize control of this domain” by unnamed entities
falsely alleging cybersquatting and trademark infringement. The text urges readers to share this message
“to raise awareness about ‘Reverse Domain Name Hijacking’ and “[s]tay vigilant against efforts to silence
advocacy platforms”.

A paragraph under the heading “Legal” stresses that ICANN policy gives domain owners the right to “manage and utilize the domain according to their discretion, as well as the right to transfer or sell the domain to another party”, and “the right to accurate representation through the Whois database, ensuring transparency in the domain registration process”. The passage concludes: “At Liberty Human Rights, we uphold these rights to ensure the integrity and security of our domain registration, promoting our mission of advocating for human rights.”

A screenshot archived by the Internet Archive’s Wayback Machine from January 8, 2025, shows that the Respondent’s website on that date did not include the “Official Notice” text but did include an “About Us” paragraph with this claim:

“Liberty Human Rights is a non-profit organization dedicated to promoting and protecting human rights. We
work tirelessly to ensure that all individuals are treated with dignity and respect, regardless of their
background or beliefs.”

The page at that time also featured a “Contact” Gmail address and solicited “feedback and contributions as we continue our mission to promote and protect human rights”.

The Complaint attaches an earlier version of the “Contact” page of the Respondent’s website as it appeared on March 5, 2024. This furnished the email address of Ahmed Gopang and gave “Our Address” as “Liberty Villa, London, SW1P, 2HR”.

This is a postal address, as the Complainant points out, that does not appear to exist, but it showed the same postcode as the Complainant’s, and “Liberty Villa” looked much like the Complainant’s well-known headquarters “Liberty House”.

Importantly, the “Contact” page also displayed a telephone number (oddly, in the “Fax” and “E-Mail” blocks), that was precisely the same telephone number that is listed in several places on the Complainant’s website, such as the “Donations” page.

The Panel notes that “Liberty Human Rights” does not appear in the online database of registered companies maintained by the United Kingdom’s Companies House, nor is it found in the list of nonprofit organizations maintained by the Charity Commission for England and Wales. It also does not appear in an Internet search for organizations by that name.[2]

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Counsel for the Complainant sent a cease-and-desist letter by email to the Respondent and Mr. Gopang on Respondent’s website, on the one hand, and the Complainant’s domain name and website, on the other, demonstrated “passing off” under English law. Mr. Gopang replied on March 13, 2024, insisting that the Respondent was acting within its rights as a domain name registrant under ICANN policy. Mr. Gopang sent another email on May 13, 2024, indicating that “the owner” was open to negotiating a sale of the disputed domain name and that a selling price of GBP 9,500 “reflects the value and potential of the domain”. The Complainant’s representative followed up with an emailed letter on June 4, 2024, referencing the UDRP and accusing the Respondent of cybersquatting.

[2]Noting the general powers of a panel articulated in paragraphs 10 and 12 of the Rules, it is commonly accepted that a panel may

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 contends that the disputed domain name is confusingly similar to its unregistered LIBERTY and LIBERTY HUMAN RIGHTS marks, in which the Respondent has no rights or legitimate interests. The Complainant asserts that there is no evidence that the Respondent is known by a corresponding name apart from the Respondent’s website itself, which is an attempt in bad faith to impersonate the Complainant and does not reflect a bona fide offering of goods or services or a legitimate noncommercial fair use. The Complainant argues 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 (as they mistakenly may pledge donations to the Respondent), 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.

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.

The Respondent asserts that the Complainant’s unregistered trademark claims are “insufficient to establish a prima facie case under the UDRP” and implies that the disputed domain name using the “.org” generic top- level domain name commonly used by non-profits would not be confused with the Complainant’s domain name using the “.uk” country code top-level domain name. The Respondent argues that in any event the Complainant’s claimed marks are generic and descriptive and not established as having a secondary meaning exclusively associated with the Complainant.

The Respondent asserts that it registered the disputed domain name in August 2020 for use with a planned noncommercial website “dedicated to human rights education, advocacy, and awareness”. The Respondent argues that there is no evidence of commercial activity, phishing, or impersonation with the disputed domain name, and that it is only meant such legitimate use in connection with human rights advocacy. The

Respondent denies that there is any evidence of a bad faith “demand” for commercial gain.

The Respondent requests a finding of Reverse Domain Name Hijacking.

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6. Discussion and Findings

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.

The Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.0, section 1.3. Although these individual dictionary words are used by others as well, as is set out above, the Complainant has shown long-term use of LIBERTY and LIBERTY HUMAN RIGHTS in distinct contexts well-advertised to the general public in the UK, associated with substantial publicity and fundraising around the Complainant’s advocacy campaigns over a period of decades.

The entirety of these marks is reproduced within the disputed domain name. Accordingly, the disputed
domain name is identical or confusingly similar to the marks for the purposes of the Policy.

WIPO Overview 3.0, section 1.7.

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.

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 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) (legitimate noncommercial or fair use). However, more than four years after registering the disputed domain name, the Respondent’s website states only that the team is “hard at work” preparing such a website, and the Response offers no evidence supporting such development. There is also no evidence that the Respondent is commonly known by a corresponding name (Policy, paragraph 4(c)(ii)).

Instead, there is evidence that the disputed domain name and the Respondent’s website are imitative of 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.

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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 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

[3]
Complainant’s exact telephone number and displaying a similar headquarters name. At the same time, 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.

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.

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, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s

registration and use of the disputed domain name constitutes bad faith under the Policy.

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

D. Reverse Domain Name Hijacking

The Respondent requests a finding under Paragraph 15(e) of the Rules that the Complaint was brought in bad faith in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder. Given the Panel’s conclusions to the effect that the Complaint is well-founded, the Panel declines to enter such a finding.

[3]It is possible that the Respondent also meant from the outset to offer to sell the disputed domain name to the Complainant for a profit

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 <libertyhumanrights.org> be transferred to the Complainant.

/W. Scott Blackmer/
W. Scott Blackmer
Sole Panelist
Date: April 17, 2025

disputed domain name, and he clearly corresponded on behalf of “the owner”. As his relationship with the registrant is unknown and the

Respondent’s website, and he corresponded with the Complainant as described below. However, he is not the registrant of the referred to as the “Respondent” in this proceeding.

undertake limited factual research into matters of public record, as the Panel has done in this proceeding. WIPO Overview of WIPO
Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 4.8.

(Policy, paragraph 4(b)(i)), as it ultimately did in the course of the Parties’ communications in 2024. But the Panel notes that the
Respondent did not make such an overture for four years, so the Panel does not consider this form of bad faith proven on this record.