Westmore · UDRP DecisionOnlyfans-xnxx.rest
The Panel ordered transfer of <onlyfans-xnxx.rest>. It found the domain confusingly similar to the Complainant’s ONLYFANS mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith through a competing adult-entertainment website intended to trade on the Complainant’s goodwill. The transfer was expressly stated to be without prejudice to any rights asserted by the third-party owner of the XNXX trademark.
The timeline behind onlyfans-xnxx.rest
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 onlyfans-xnxx.rest — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a complainant’s complete mark with another trademark may remain confusingly similar and may aggravate affiliation concerns where both marks relate to similar services. It also shows a panel addressing the practical complication of transferring a domain that contains a third party’s trademark by making the order expressly without prejudice to that third party’s rights.
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 Fenix International Limited v. Huang Hui, Ndb Case No. D2025-4639 1. The Parties The Complainant is Fenix International Limited c/o Walters Law Group, United States of America (“United States”). The Respondent is Huang Hui, Ndb, United States. 2. The Domain Name and Registrar The disputed domain name <onlyfans-xnxx.rest> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 7, 2025. On November 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 11, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 22, 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 amendment to the Complaint on November 24, 2025. The Center verified that the Complaint together with the amendment to 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 Complaint, and the proceedings commenced on November 25, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 15, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 16, 2025. page 2 The Center appointed Steven Auvil as the sole panelist in this matter on December 26, 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 website <onlyfans.com> that allows users to post and subscribe to audiovisual content on the World Wide Web. The Complainant registered the domain name <onyfans.com> on January 29, 2013. The Complainant owns trademark registrations for its ONLYFANS brand including: European Union registration number 017912377 registered on January 9, 2019 for ONLYFANS; European Union registration number 017946559 registered on January 9, 2019 for ONLYFANS; United Kingdom registration number UK00917912377 registered on January 9, 2019 for ONLYFANS; and United States registration number 5769267 registered on June 4, 2019 for ONLYFANS. According to the Complaint, the disputed domain name was registered by the Respondent on July 20, 2025, and resolves to a website offering adult entertainment services, including content “pirated” from the Complainant’s users in direct competition with the Complainant’s services. 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. The Complainant first contends that the disputed domain name is confusingly similar to the Complainant’s ONLYFANS mark. According to Complaint, the disputed domain name consists of the Complainant’s entire ONLYFANS mark with the only difference being the inclusion of the third-party trademark “xnxx” and the use of the generic Top-Level Domain (“gTLD”) “.rest”. The Complainant contends that the third-party trademark is being used to provide adult-oriented content and that these additions do not differentiate the disputed domain name from the Complainant’s ONLYFANS mark so as to avoid a confusing similarity finding. The Complainant next contends that the Respondent has no rights or legitimate interests in the disputed domain name. According to the Complaint, the Respondent has no connection or affiliation with the Complainant and has not received any authorization, license, or consent, whether expressed or implied, to use the Complainant’s ONLYFANS mark in a domain name or otherwise. The Complainant further contends that the Respondent is not commonly known by the disputed domain name. Moreover, the Complainant contends that the Respondent is using the disputed domain name to host a commercial website that advertises services. Finally, the Complainant contends that the Respondent has registered and has used the disputed domain name in bad faith. First, the Complainant contends that the Respondent pirated material from the Complainant’s website on the disputed domain name website. Second, the Complainant sent a cease-and- desist letter to the Respondent on September 26, 2025, demanding that the Respondent stop using and cancel the disputed domain name, and Respondent did not respond. Third, the Complainant asserts that the Respondent registered the disputed domain name to divert Internet traffic from the Complainant’s website to a site offering adult entertainment content, including pirated material from the Complainant’s users, in direct competition with the Complainant’s platform. page 3 The Complainant requests that the disputed domain name be transferred to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 15(a) of the Rules: “[a] Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable.” Paragraph 4(a) of the Policy directs that the Complainant must prove each of the following to obtain relief: (i) that the disputed domain name is identical or confusingly similar to a trademark or a service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. In view of the Respondent’s failure to submit a Response, the Panel is entitled to accept as true the allegations set forth in the Complaint (unless the evidence is clearly contradictory), and to derive reasonable inferences from the evidence presented. Based on the foregoing guidance, the Panel makes the following findings and conclusions based on the allegations and evidence contained in the Complaint, and reasonable inferences drawn from the evidence presented. 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 Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy as the Complainant owns trademarks for ONLYFANS. WIPO Overview 3.0, section 1.2.1. The evidence submitted by the Complainant also supports the conclusion that the disputed domain name is confusingly similar to the Complainant’s ONLYFANS mark. As set forth in WIPO Overview 3.0, section 1.7, when the entirety of a mark is reproduced within the disputed domain name, or “at least a dominant feature of the relevant mark is recognizable in the domain name,” the disputed domain name is deemed confusingly similar to the mark for the purposes of the Policy. Further, “[w]here the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise)” does not prevent a finding of confusing similarity. WIPO Overview 3.0, section 1.8. Here, the disputed domain name is confusingly similar to the Complainant’s ONLYFANS mark because the Respondent has incorporated the entirety of the Complainant’s ONLYFANS mark with the addition of a hyphen and “xnxx”. These differences do not prevent a finding of confusing similarity. See Licensing IP International S.A.R.L. v. Hitoshi Matsumoto, WIPO Case No. D2018-2709. As set forth in section 1.11.1 of the WIPO Overview 3.0, the applicable gTLD (e.g., “.com” or “.org”) is viewed as a standard registration requirement and as such is typically disregarded under the first element’s page 4 confusing similarity test. As such, the use of “.rest” gTLD in the disputed domain name has no bearing on the confusing similarity analysis. The Panel therefore 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. Such circumstances include: (i) before any notice of the dispute, the Respondent used, or prepared to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; (ii) the Respondent (as an individual, business, or other organization) is commonly known by the disputed domain name, even if the Respondent has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or tarnish the trademark or service mark at issue. 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 the production of information that is often only within the knowledge or control of the respondent. Considering this difficulty, 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 registered the disputed domain name that is confusingly similar to Complainant’s mark with the addition of a third-party trademark offering similar services to the Complainant. The combination of the two trademarks thus risks giving the impression that there is a partnership between the Complainant and the third-party trademark owner. Further, the evidence demonstrates that the Respondent is using the disputed domain name to offer competing services. The Panel finds that none of the circumstances listed in paragraph 4(c) of the Policy apply. The Respondent did not respond to the Complaint and provide any evidence demonstrating rights or legitimate interests in the disputed domain name. Under the circumstances, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name and therefore that the second element of paragraph 4(a) of the Policy is satisfied. 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 that, if found by the Panel to be present, is evidence of the registration and use of a 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. page 5 In the present case, the Panel concludes that the Respondent registered and used the disputed domain name in bad faith. First, the disputed domain name incorporates the entirety of the Complainant’s registered ONLYFANS mark with the exception of adding the “xnxx,” resulting in confusing similarity. This alone raises an inference of bad faith. Second, the Panel finds that the Respondent has used the disputed domain name in connection with a website that provides products in direct competition with those of the Complainant. In other words, Respondent is attempting to trade off of the Complainant’s goodwill in its ONLYFANS marks and confuse Internet users into believing that the disputed domain name is affiliated or associated with Complainant. This, too, constitutes evidence of bad faith. See Fenix International Limited v. Withheld for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf / Leon Key, WIPO Case No. D2021-3132 Third, the Respondent has provided no rebuttal evidence demonstrating good faith registration or use by it of the disputed domain name. See Park ’N Fly Service LLC v. Usman Hafeez, WIPO Case No. D2025-1727. Considering these circumstances, including the failure of the Respondent to respond to the Complaint, the Panel finds that the Respondent more likely than not knew of the Complainant’s ONLYFANS mark at the time of registering the disputed domain name and thereafter used the disputed domain name to unfairly capitalize on the Complainant’s ONLYFANS mark. The Panel therefore concludes that the disputed domain name was registered and is being used in bad faith and 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 <onlyfans-xnxx.rest> be transferred to the Complainant. The Panel notes that this results in the transfer to the Complainant of a domain name that includes the trademark XNXX which the Panel understands is owned by a third party. In that respect, the Panel considers it appropriate to clarify that the present decision is explicitly without prejudice to any rights which may be asserted by the owner of the XNXX trademark. /Steven Auvil/ Steven Auvil Sole Panelist Date: January 14, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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