Walterwritesai.com

The timeline behind walterwritesai.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Kevin Walter Moore v. leo shi, Bijou Tech Limited Case No. D2025-3745 1. The Parties Complainant is Kevin Walter Moore, Canada. Respondent is leo shi, Bijou Tech Limited, China. 2. The Domain Name and Registrar The Disputed Domain Name <walterwritesai.com> (hereinafter “Disputed Domain Name”) is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 15, 2025. On September 16, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On September 16, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on September 17, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on September 23, 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 Respondent of the Complaint, and the proceedings commenced on September 26, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 16, 2025. Respondent sent email communications to the Center on October 14, 2025, requesting pursuant to Rule 5(b) a four-day extension of time to file his response. Respondent filed a Response on October 19, 2025. Respondent sent an email to the Center on October 21, 2025, transmitting a PDF version of its previously filed documents. page 2 The Center appointed Lawrence K. Nodine as the sole panelist in this matter on November 10, 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 Complainant is a Canadian individual who uses WALTER WRITES (“Mark”) as a trademark for services offered via a website associated with its domain name <walterwrites.ai>. For users who subscribe, Complainant, according to its website, will “make AI content feel like you wrote it. Walter rewrites ChatGPT, Claude, or Gemini content to sound natural and human”. Complainant owns United States trademark registration No. 7,778,427. This registration is based on an application that Complainant filed September 9, 2024. The United States Patent and Trademark Office (“USPTO”) published the Mark for opposition on March 11, 2025, 1 observing that if no objection is filed then the USPTO will issue a registration, typically in about eleven weeks from publication. The registration was issued on schedule on April 29, 2025. In support of the Mark application, USPTO records show Complainant’s attorney submitted a screenshot of Complainant’s webpage showing use of the Mark in commerce. After acknowledging that willful false statements were punishable by fine or imprisonment, the attorney declared that the screenshot had been accessed on September 9, 2024. The attorney also declared that the Mark had been used in commerce at least as early as May 17, 2024. Respondent registered the Disputed Domain Name on March 19, 2025, about a week after the Mark was published for opposition and six weeks before the trademark registration issued. The Disputed Domain Name resolved to a website that offers services similar to those offered by Complainant, claiming in text on the landing page that its software will “[t]ransform your AI-generated text into 100% undetectable, plagiarism- free, human-like content with Walter AI—your trusted tool for seamless and authentic writing”. On September 19, 2025, Respondent began re-directing visitors from the Disputed Domain Name to <writesaihumanizer.com>, which offers the same services. 5. Parties’ Contentions A. Complainant Complainant contends that he has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name. Notably, Complainant contends that the re-directing visitors to Respondent’s “writesaihumanizer.com” website is evidence of bad faith: “This shows the Respondent is deliberately transferring traffic, goodwill, and search value associated with Complainant’s Mark to another infringing domain.” Complainant also contends that “Respondent has embedded Complainant’s mark ‘Walter Writes AI’ repeatedly in the hidden HTML source code of the infringing site”. Complainant contends that Respondent is impersonating Complainant and offers evidence of a subscriber who mistakenly visited Respondent’s site and then reported to Complainant: “So there is a scammer that is trying to im-personate your brand. It might be worth filing a complaint from your side as well, since they are stealing your clients and scamming people at the same time.” 1 The Panel visited the USPTO website to review records relating to the Trademark Registration No. 7,778,427. page 3 B. Respondent Respondent contends that Complainant has not satisfied all the elements required under the Policy for a transfer of the Disputed Domain Name. Respondent emphasizes that he registered the Disputed Domain Name a month before Complainant’s Mark was registered. He says his website was “independently developed and branded prior to any knowledge of Complainant’s alleged trademark”. Respondent also contends that Complainant was responsible for cyber-attacks on his site, defamatory Reddit posts. and threats of physical intimidation. The alleged threats, and the messages related to the cyber-attacks, were sent from email addresses that are different from the email address that Complainant has identified in these proceedings as his preferred address. Respondent alleges that he redirected the Disputed Domain Name to the <writesaihumanizer.com> website as a defensive response to the cyber-attacks and threats. 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 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. Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the Mark is reproduced and recognizable within the Disputed Domain Name. Although the addition of “ai” may bear on assessment of the second and third elements, the Panel finds this addition does not prevent a finding of confusing similarity between the Disputed Domain Name and the Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. Accordingly, the Disputed Domain Name is confusingly similar to the Mark 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 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. page 4 Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent has not rebutted 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 Panel is persuaded Respondent used the Disputed Domain Name to host a website that impersonated Complainant’s website. Complainant offered evidence that one of Complainant’s subscribers mistakenly visited Respondent’s website, which she described to Complainant as “a scammer that is trying to im- personate your brand”. Panels have held that the use of a domain name for impersonation/passing off can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel finds that Respondent registered the Disputed Domain Name in bad faith. Respondent has not offered any evidence that the term “Walter Writes” is descriptive or commonly used with respect to software associated with text generated by artificial intelligence. Given this, it is not plausible that Respondent selected Disputed Domain Name without awareness of Complainant’s Mark and domain name. Moreover, the Disputed Domain Name copies not only the distinctive “Walter Writes” trademark but also incorporates “ai” into the Disputed Domain Name, thereby evidencing an intent to target Complainant’s <walterwrites.ai> domain name. Because the Disputed Domain Name is virtually identical to Complainant’s distinctive trademark, and Respondent has offered no plausible explanation for his selection of the Disputed Domain Name, the Panel finds that it is more likely than not that Respondent was aware of and targeted Complainant when he registered the Disputed Domain Name. Respondent’s primary argument is that he registered the Disputed Domain Name on March 19, 2025, before the Mark was registered on April 29, 2025. However, under United States of America (“United States”) law, a trademark registration confers exclusive rights as of the date the underlying application was filed. 15 U.S.C.1057(c). The application here was filed September 9, 2024, which was well before Respondent registered the Disputed Domain Name. Although registration did not issue until April 29, 2025, Complainant had commenced use of the Mark on May 17, 2024. 2 The statement of first use recited in the trademark application is not by itself evidence of Complainant’s first use date, but the attorney’s declaration under penalty of law is evidence supporting that claimed first use date. Regardless, the September 9, 2024, screenshot of Complainant’s website is evidence that Complainant was using the Mark in commerce as of that date. The screenshot is also supported by Complainant’s attorney’s declaration. Moreover, because the Mark is inherently distinctive, this use would have given rise to common law rights without the need to prove secondary meaning. Accordingly, the Panel finds that Complainant had common law rights in the Mark before Respondent registered the Disputed Domain Name. The Panel also notes that after Complainant’s trademark application had been approved by the USPTO Trademark Examining Attorney, the applied for trademark was published for opposition in the Official Gazette of the USPTO on March 11, 2025, about one week before Respondent registered the Disputed Domain Name on March 19, 2025. This publication was public notice available online that the applied for trademark would be registered unless an opposition proceeding was commenced. Although the constructive notice provisions of United States law do not suffice to prove that Respondent had actual notice of Complainant’s rights, the actual publication on March 11, 2025, of Complainant’s application to register the Mark is relevant. Perhaps it is only coincidence that Respondent registered the Disputed Domain Name one week after 2 Respondent does not offer any evidence of his use of “walter writes” for any purpose before registering the Disputed Domain Name. page 5 publication of notice that the Mark would soon be registered, but this coincidence is corroborating circumstantial evidence that Respondent had an opportunity to be aware of Complainant’s rights. For these reasons, the Panel finds that Complainant had acquired rights in the Mark before the Disputed Domain Name was registered. Moreover, the Panel also finds that Respondent registered the Disputed Domain Name in bad faith anticipation of Complainant’s registration of the Disputed Domain Name. WIPO Overview 3.0, section 3.8.2(iv) (i.e. registering the disputed domain name after Complainant filed a trademark application, may support an inference that the disputed domain name was registered in anticipation of complainant’s nascent rights). The Panel also finds that Respondent has used the Disputed Domain Name to intentionally “to attract, for commercial gain, Internet users to your web site or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product or service on your website or location”. Policy, paragraph 4(b)(iv). Respondent contends that Complainant has sent threatening emails and participated in cyber-attacks directed at Respondent. The accusations are serious and may give rise to civil or criminal liability in national courts, but they do not relate to the conduct of these proceedings. Accordingly, the Panel is not persuaded that the alleged conduct ought to bar Complainant from receiving a transfer of the Disputed Domain Name. 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 <walterwritesai.com> be transferred to Complainant. /Lawrence K. Nodine/ Lawrence K. Nodine Sole Panelist Date: November 30, 2025

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.