Tod4k.com

The timeline behind tod4k.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 TOD for Advertising Production and Trade WLL v. aimad lambarki Case No. D2025-4456 1. The Parties The Complainant is TOD for Advertising Production and Trade WLL, Qatar, represented by Tmark Conseils, France. The Respondent is aimad lambarki, United Arab Emirates. 2. The Domain Name and Registrar The disputed domain name <tod4k.com> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 29, 2025. On October 29, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 30, 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) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 3, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Respondent sent a number of email communications to the Center on November 3, 2025. The proceedings were suspended on November 3, 2025. The Respondent sent email communications to the Center on November 6 and 7, 2025. On January 27, 2026, the Complainant requested that the proceedings be reinstituted and filed an amended Complaint. The proceedings were reinstituted on February 3, 2026. 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on February 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 23, 2026. The Response was filed with the Center on February 4, 2026. The Center appointed Adam Taylor as the sole panelist in this matter on February 25, 2026. 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 Since 2022, the Complainant has operated a subscription-based sports and entertainment streaming platform under the mark TOD via a website at “www.tod.tv”. The service, which is offered in 4K (high definition) resolution, is available in the Middle East, North Africa, and Türkiye. The Complainant has some 348,000 followers on TikTok and 242,000 on Facebook. The Complainant owns a number of registered trade marks for TOD including International Registration No. 1643638, registered on October 4, 2021, in classes 9, 38 and 41. The disputed domain name was registered on July 27, 2025. As of October 28, 2025, the disputed domain name resolved to a website displaying a streaming service that was branded “NEO”, and which bore the title “Best IPTV Dubai | Best IPTV UAE | Neo4K IPTV” superimposed on large sports-related image. The site offered access to various channels including “TOD STUDIOS”, operated by the Complainant. Mail exchange records have been configured enabling use of the disputed domain name for email. 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. 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. Notably the Respondent contends that: - the disputed domain name was purchased as a personal favour for a friend; - the Respondent did not select, or intend to use, the disputed domain name for itself; - the Respondent was unaware that the disputed domain name could give rise to any dispute; - the Respondent registered the disputed domain name in good faith and with no intention of targeting any name or trade mark; - the Respondent never actively used, or benefitted from, the disputed domain name; and - the Respondent is willing to resolve this dispute amicably and consents to the remedy requested by the Complainant. page 3 6. Discussion and Findings 6.1 Preliminary Issue: Consent to Remedy The Respondent has indicated in its Response that it consents to transfer of the disputed domain name to the Complainant without the need for a decision by the Panel. Many panels will order transfer solely on the basis of a consent to transfer by the respondent on the record, but panels may still find it appropriate to proceed to a substantive decision on the merits in certain circumstances. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.10. In this case, the Panel has decided to proceed to a substantive determination because: (i) the Panel finds a broader interest in recording a substantive decision on the merits – e.g., so that other future UDRP panels can take the matter into account when considering whether there is a pattern of bad faith conduct under paragraph 4(b) of the Policy; and (ii) while consenting to the requested remedy, the Respondent has expressly disclaimed any bad faith. 6.2 Substantive Issues 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 trade mark and the disputed domain name. WIPO Overview 3.1, 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 3.1, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms (here, “4k”) may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. 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 recognised that proving that 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 3.1, 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 page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. As to paragraph 4(c)(i) of the Policy, and as further discussed in section 6.2C below, the Panel considers that the Respondent has used the disputed domain name to intentionally attempt to attract, confuse and profit from Internet users seeking the Complainant’s goods and/or services. Such use of the disputed domain name is not bona fide. 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. First, the disputed domain name consists of the Complainant’s distinctive mark plus “4k”, a term that is highly relevant to the Complainant’s service, given that the Complainant offers its platform in 4K high definition resolution. Second, the Respondent has used the disputed domain name for a website that creates the impression that it is associated with the Complainant by purportedly offering services identical to those of the Complainant, with the lack of any prominent disclaimer. Indeed, the site includes a link to the Complainant’s own channel. The likelihood of confusion is not diminished by the possibility that some users arriving at the Respondent’s site may at some point realise that it is not officially connected with the Complainant. Paragraph 4(b)(iv) of the Policy is concerned with the intentional attracting of Internet users. Here, the disputed domain name creates a risk of implied affiliation with the Complainant, and the Respondent profits from at least some of the traffic intended for the Complainant. The Respondent seeks to evade responsibility by claiming that it acquired the disputed domain name “for a friend”, that it was unaware that the disputed domain name could give rise to any dispute, that it registered the disputed domain name in good faith without any intention of targeting a third party, and that it did not use, or profit from use of, the disputed domain name. The Panel rejects the Respondent’s contentions. The Panel is not convinced by the Respondent’s assertion that it registered the disputed domain name on behalf of a “friend”, given the lack of any supporting evidence. In any case, even if the Respondent was acting as an innocent agent for the ultimate controller of the disputed domain name, it is sufficient under the third element that that person procured registration of, and used, the disputed domain name in bad faith, allegations that the Respondent does not dispute. The Panel finds 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 <tod4k.com> be transferred to the Complainant. /Adam Taylor/ Adam Taylor Sole Panelist Date: March 11, 2026

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