Westmore · UDRP decision
WIPO · Case No. D2025-4538

Kamagamesr.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <kamagamesr.com>. It found the domain confusingly similar to the Complainant’s KAMA GAMES mark because it reproduced the mark in its entirety with only the added letter “r”. The Respondent lacked rights or legitimate interests, and the domain had previously resolved to a website displaying the Complainant’s mark and offering competing betting and gaming services. That conduct demonstrated intentional attraction for commercial gain through confusion. The domain’s subsequent inactive status did not prevent a finding of bad faith under the passive-holding doctrine.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-26
Panelist(s)
Wong Wai Man, Deanna
Complainant
Kamagames Entertainment Group Limited
Respondent
haosha
Disputed domain(s)
kamagamesr.com
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind kamagamesr.com

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

Westmore reconstructs the full history behind kamagamesr.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of kamagamesr.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a one-letter addition to a trademark can satisfy confusing similarity and, when paired with a competing website displaying the mark, support findings of false affiliation and commercial-gain bad faith. It also shows that taking the website offline before the decision does not necessarily cure earlier abusive use or prevent application of passive-holding principles.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

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

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-26
Panel
Wong Wai Man, Deanna
Full decision
13 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Kamagames Entertainment Group Limited v. haosha Case No. D2025-4538 1. The Parties The Complainant is Kamagames Entertainment Group Limited, United Kingdom, represented by Kosnahan Law, United Kingdom. The Respondent is haosha, China. 2. The Domain Name and Registrar The disputed domain name <kamagamesr.com> is registered with Domainipr Limited (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on November 3, 2025. On November 4, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 5, 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 Protecton Services c/o Domainipr Limited) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 6, 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 an amended Complaint in English on November 11, 2025. On November 6, 2025, the Center informed the parties in Chinese and English, that the language of the registration agreement for the disputed domain name is Chinese. On November 11, 2025, the Complainant requested English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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 in English and Chinese of the Complaint, and the proceedings commenced on November 14, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 4, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 10, 2025. The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on December 18, 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 company incorporated in the United Kingdom. The Complainant’s KAMA GAMES trademarks and brand are licensed to approve third parties for the international exploitation, on the Complainant’s behalf, of certain software products and mobile applications. The Complainant’s software and mobile applications operate primarily in the betting and social gaming sector and offer games with casino- style themes, including, inter alia, mobile poker, casino slot games, roulette, and “8 Ball Pool by Pokerist”. The Complainant owns an international trademark portfolio for its KAMA GAMES brand, including, but not limited to, the following trademark registrations: United Kingdom Trademark Registration No. UK00910675585, registered on February 8, 2014, in International Classes 9, 35, 38, 41, and 42; and European Union Trademark Registration No. 010675585, registered on February 8, 2014, in International Classes 9, 35, 38, 41, and 42. The Complainant operates a website at “www.kamagames.com”. The disputed domain name was registered on September 8, 2025, and is therefore of a later date than the Complainant’s abovementioned trademark registrations. The Complainant provides evidence that the disputed domain name directed to a website prominently displaying the Complainant’s trademarks at the top of the website and was offering competing betting and gaming services to Internet users. However, the Panel notes that on the date of this Decision, the disputed domain name points to an inactive website. 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 trademarks in which the Complainant has rights. The Complainant asserts that it owns and has long used the KAMA GAMES mark in connection with its social casino gaming software and mobile applications, and that this mark is recognizable in its entirety within the disputed domain name. According to the Complainant, the addition of the letter “r” to the KAMA GAMES mark does not prevent a finding of confusing similarity and constitutes a minor typographical variation insufficient to dispel the overall impression that the disputed domain name is associated with the Complainant. As to absence of rights or legitimate interests, the Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name as it has not authorized, licensed, or otherwise permitted the Respondent to use its KAMA GAMES mark, nor to register any domain name incorporating that mark. The Complainant further asserts that the Respondent is not commonly known by the disputed domain name, and that the Respondent’s use of the disputed domain name does not constitute a bona fide page 3 offering of goods or services, nor a legitimate noncommercial or fair use, but instead seeks to take unfair advantage of the Complainant’s trademark reputation. As to bad faith, the Complainant contends that given the distinctiveness and prior use of the KAMA GAMES mark, the Respondent must have been aware of the Complainant and its rights at the time of registration. The Complainant maintains that the Respondent registered the disputed domain name in order to create a likelihood of confusion with the Complainant’s mark for commercial gain, including by attracting Internet users to a website associated with the disputed domain name, and that such conduct falls squarely within the circumstances of bad faith registration and use under the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Preliminary Issue: Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the statement that English is the most widely used language in international relations; that the Complainant neither speaks nor reads Chinese and would therefore incur substantial additional cost, time, and delay if required to translate the Complaint and supporting materials or to engage translators; that the disputed domain name is composed entirely of Latin characters and incorporates English words or reads as English; that there is no indication that the Respondent is unfamiliar with English; that the disputed domain name incorporates the Complainant’s trade marks in English, and the associated website content likewise uses the Complainant’s English-language trademarks rather than any Chinese translation thereof; that the disputed domain name is registered under the “.com” generic Top-Level Domain, which suggests an intention to target English-speaking users; and that conducting the proceeding in English would avoid undue delay and unnecessary translation costs and would promote a fair and expeditious resolution of the dispute. The Respondent did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. page 4 6.2 Findings on the Merits 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 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 within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms here, the letter “r” 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 3.0, section 1.8. 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 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 name such as those enumerated in the Policy or otherwise. Moreover, the Panel finds that the Respondent is not commonly known by the disputed domain name, has not been licensed or otherwise authorized by the Complainant to use the KAMA GAMES mark, and has failed to adduce any evidence of use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Instead, upon review of the facts and the evidence submitted in this proceeding, the Panel notes that the disputed domain name directed to an active website prominently displaying the Complainant’s trademark at the top of the website and offering competing betting and gaming services to Internet users. The Panel notes that this suggests that the Respondent is using the disputed domain name to mislead Internet users by creating a misleading affiliation or appearance of a business connection with the Complainant. page 5 However, the Panel notes that on the date of this Decision, the disputed domain name directs to an inactive or blank webpage. In this regard, the Panel finds that holding a domain name passively, without making any use of it, also does not confer any rights or legitimate interests in the disputed domain name on the Respondent in the circumstances of this case (see in this regard earlier UDRP decisions such as Bollore SE v. 赵竹飞 (Zhao Zhu Fei), WIPO Case No. D2020-0691; and Vente-Privee.Com and Vente-Privee.com IP S.à.r.l. v. 崔郡 (jun cui), WIPO Case No. D2021-1685). 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 has registered a domain name which is confusingly similar to the Complainant’s prior trademark for KAMA GAMES, incorporating it in its entirety, merely adding the letter “r”. The Panel also notes that the Complainant’s trademarks in this case predate the registration date of the disputed domain name by several years. Even a cursory Internet search or trademark search at the time of registration of the disputed domain name would have made it clear to the Respondent that the Complainant owned prior rights in its trademarks for KAMA GAMES, and the Panel therefore finds that the Respondent could not have been reasonably unaware of them. This finding is further confirmed by the fact that the Respondent seemed to have registered the disputed domain name in order to mimic the Complainant’s domain name <kamagames.com>, and attempted to create an impression of connection or affiliation with the Complainant on the website which was previously linked to the disputed domain name, including by reproducing the Complainant’s mark in large font at the top of such website and by offering competing betting and gaming services, overlapping with the Complainant’s services. In the Panel’s view, the above elements clearly indicate bad faith on the part of the Respondent, and the Panel therefore finds that it has been demonstrated that the Respondent registered the disputed domain name in bad faith. 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. As to use of the disputed domain name in bad faith, the Complainant provides evidence that the disputed domain name directed to an active website which was offering competing betting and gaming services to Internet users and which showed an intent on the part of the Respondent to create a false impression of a commercial connection with the Complainant, for commercial gain. In fact, on said website, the Respondent particularly and prominently displayed the Complainant’s KAMA GAMES mark on the home page and offered competing betting and gaming services without a proper disclaimer. The Panel concludes from these facts that the Respondent is intentionally attracting Internet users for commercial gain to such website, by creating consumer confusion between the website associated with the disputed domain name and the Complainant’s trademarks. This constitutes direct evidence of the Respondent’s bad faith under paragraph 4(b)(iv) of the Policy. However, on the date of this Decision, the disputed domain name directs to an inactive website. In this regard, panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness or reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. page 6 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 <kamagamesr.com> be transferred to the Complainant. /Deanna Wong Wai Man/ Deanna Wong Wai Man Sole Panelist Date: December 26, 2025

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

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