Westmore · UDRP DecisionHealio.ai
The Panel denied the Complaint because the Complainant failed to prove that the Respondent lacked rights or legitimate interests in <healio.ai>. Although the domain name was identical to the Complainant’s registered HEALIO mark, the Respondent supplied plausible contemporaneous evidence of preparations beginning in 2017–2018 for an independently conceived AI and genomics venture branded “HealioAI.” The Panel did not reach bad faith and declined the Respondent’s request for a finding of Reverse Domain Name Hijacking.
The timeline behind healio.ai
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 healio.ai — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that contemporaneous evidence of preparations for an independently conceived business can establish a respondent’s rights or legitimate interests even where the complainant’s identical trademark predates the domain registration and the domain later becomes inactive. The case also shows the importance of evidence concerning a mark’s reputation at the registration date when the complainant seeks to infer respondent awareness.
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 The Wyanoke Group v. Karmei Tse Morin Case No. D2025-4909 1. The Parties Complainant is The Wyanoke Group, United States of America, internally represented. Respondent is Karmei Tse Morin, United States of America. 2. The Domain Name and Registrar The disputed domain name <healio.ai> (the “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 November 25, 2025. On November 26, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On November 26, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email to Complainant on November 27, 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 December 2, 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 December 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 28, 2025. Respondent sent an email to the Center on December 9, 2025. The Response was filed on December 19, 2025. The Center appointed Robert A. Badgley as the sole panelist in this matter on January 14, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration page 2 of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background Complainant holds trademark registrations for the word mark HEALIO with the United States Patent and Trademark Office (“USPTO”). First, Complainant owns USPTO Reg. No. 4185601, registered on August 7, 2012, in connection with “Providing a web site featuring technology that enables physicians to access news and information and resources in clinical medicine” with a September 29, 2011, date of first use in commerce. Second, Complainant owns USPTO Reg. No. 4952129, registered May 3, 2016, in connection with “Downloadable electronic newsletters in the field of clinical medicine research, news, and industry information” and “Medical journals and newsletters in the field of clinical medicine research, news, and industry information” with an October 31, 2014, date of first use in commerce. Complainant owns the domain name <healio.com> and uses that domain name to host its commercial website. Complainant does not spend a great deal of time discussing its business or the extent to which its trademarks enjoy renown among consumers. In particular, the record contains very little insight into the extent to which Complainant’s marks were known at the time the Domain Name was registered. Annexed to the Response is a November 4, 2025, article in PR Newswire which bore the headline: “HEALIO launches ‘HEALIO AI’ platform for health care professionals with insights updated daily to support patient care.” The Domain Name was registered on February 15, 2018. The Domain Name currently does not resolve to an active website. Complainant asserts that the Domain Name has never been used for any bona fide offering of goods or services. According to Complainant, the Domain Name “has resolved for years either to a Google-generated 404 error page [...] or to a bare, non-substantive shell page, and has shown no active content and no evidence of legitimate activity since approximately 2021...” According to Respondent, she registered the Domain Name because she and her colleague “JK” were developing a proposed “artificial intelligence driven genomics platform.” Respondent asserts: “The disputed domain name <healio.ai> corresponds directly to Respondent’s independently conceived and used business name HealioAI, which Respondent adopted beginning in 2017–2018 for a bona fide artificial intelligence and genomics venture. As demonstrated in the record, ‘HealioAI’ was used as a unitary coined term, derived from ‘Heal + IO + AI,’ and not as a reference to Complainant’s publishing brand or trademark. ‘HealioAI’ is a coined term derived from: ● Heal — improving health outcomes ● IO — data input/output ● AI — artificial intelligence” Annexed to the Response are documents showing Respondent’s efforts to solicit investors for this enterprise while using the name “HealioAI,” as well as JK’s use of a stylized logo “HealioAI” at a Stanford University conference in October 2018 at which JK gave a presentation. Also annexed to the Response are screenshots of a “publicly accessible prototype website developed for Respondent’s HealioAI venture and hosted at “cranky-leavitt-b23c15.netlify.app.” According to Respondent, this site “was live and publicly accessible during the period 2018–2021.” page 3 This website displays the “HealioAI” name and branding, describes an AI-based genomics platform, and identifies Respondent, JK, and other colleagues as founders and contributors of their incipient enterprise. For a time, the site bore the following notice: “Copyright ⓒ HealioAI 2018.” Based on the record presented, it appears that Respondent’s business venture lost momentum in 2021 and it also appears to have been abandoned or suspended. There is very little discussion of this in the record. Complainant alleges that, between October 20, 2025, and November 3, 2025, Complainant’s GoDaddy broker sent twelve separate purchase inquiries to the WhoIs-listed contact, all of which were ignored. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. B. Respondent Respondent asserts that she came up with the idea of the Domain Name, without regard to or knowledge of Complainant or its trademark, in order to develop her business, as described above. Respondent asserts that the contemporaneous evidence she annexed to the Response confirms her demonstrable preparations to use the Domain Name in connection with a bona fide offering of services. Respondent also asks that the Panel make a finding that Complainant has submitted its Complaint in an attempt at Reverse Domain Name Hijacking. 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Name: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) Respondent has no rights or legitimate interests in respect of the Domain Name; and (iii) the Domain Name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The Panel concludes that Complainant has rights in the trademark HEALIO through registrations demonstrated in the record. The Panel also concludes that the Domain Name is identical to that mark. Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests Pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Name, among other circumstances, by showing any of the following elements: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Domain Name or a name corresponding to the Domain Name in connection with a bona fide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by page 4 the Domain Name, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. The Panel concludes, on the record provided, that Complainant has failed to establish that Respondent lacks rights or legitimate interests in the Domain Name. There is enough plausible evidence in the record that Respondent registered the Domain Name, for reasons unrelated to Complainant or its mark, in order to pursue a legitimate business. As noted above, although Complainant had registered trademarks before Respondent registered the Domain Name, there is nothing in the record to suggest that Complainant’s HEALIO mark was so well known that one should infer that Respondent more likely than not was aware of that mark. Respondent’s explanation and evidence of demonstrable preparations before notice of this dispute compel a finding that Complainant has not met its burden of proving that Respondent has no rights or legitimate interests vis-à-vis the Domain Name within the meaning of the above-quoted Policy paragraph 4(c)(i). The Complaint fails. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy provides that the following circumstances, “in particular but without limitation,” are evidence of the registration and use of the Domain Name in “bad faith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Domain Name registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of its documented out of pocket costs directly related to the Domain Name; or (ii) that Respondent has registered the Domain Name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) that by using the Domain Name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel need not decide this element, given its holding above on the “Rights or Legitimate Interests” element. D. Reverse Domain Name Hijacking Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking (“RDNH”) or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.0, section 4.16. On the record presented, the Panel declines to make an RDNH finding against Complainant. At the time the Complaint was filed, Complainant had a registered trademark to which the Domain Name was identical. Since 2021, it appears that the Domain Name had not been put to any use. (It is not clear whether Complainant did much digging into possible use of the Domain Name prior to 2021.) It would not have been far-fetched for Complainant to conclude that the Domain Name may have changed hands between the original registration in 2018 and the period of non-use since 2021. The Parties had no direct page 5 communications before this Complaint was filed, and hence Respondent had never articulated to Complainant its bona fides before this proceeding was initiated. In these circumstances, the Panel cannot characterize this case as one in which Complainant knew its UDRP case was doomed to fail, which circumstance can form the basis for an RDNH finding. In sum, this case does not warrant a finding of RDNH. 7. Decision For the foregoing reasons, the Complaint is denied. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: January 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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