Westmore · UDRP decision
WIPO · Case No. D2025-4965

Udemy.blog

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <udemy.blog>. It found the domain identical to the Complainant’s UDEMY mark, found no rights or legitimate interests after the Respondent failed to rebut the Complainant’s prima facie case, and held that passive non-use did not prevent a finding of bad-faith registration and use given the mark’s distinctiveness and the domain’s identical composition.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-13
Panelist(s)
Oghigian, Haig
Complainant
Udemy, Inc.
Respondent
Hiroki Ogawa, Ogawa Hiroki
Disputed domain(s)
udemy.blog
Domain history UDRP Intelligence

The timeline behind udemy.blog

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 udemy.blog — 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 udemy.blog.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision is a straightforward example of transfer based on an exact-match domain and passive holding. The Panel did not require active website content where the domain reproduced a distinctive mark, implied affiliation, lacked an apparent legitimate explanation, and remained unrebutted after the Respondent’s default.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-13
Panel
Oghigian, Haig
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Udemy, Inc. v. Hiroki Ogawa, Ogawa Hiroki Case No. D2025-4965 1. The Parties The Complainant is Udemy, Inc., United States of America, represented by SafeNames Ltd., United Kingdom. The Respondent is Hiroki Ogawa, Ogawa Hiroki, Japan. 2. The Domain Name and Registrar The disputed domain name <udemy.blog> is registered with GMO Internet, Inc. d/b/a Discount-Domain.com and Onamae.com (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on November 28, 2025. On November 28, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 1, 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 Protection Service by onamae.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 1, 2025, providing the registrant and contact information disclosed by the Regis- trar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint in English on December 3, 2025. On December 1, 2025 the Center informed the parties in Japanese and English, that the language of the registration agreement for the disputed domain name is Japanese. On December 3, 2025, the Complainant confirmed its request that English 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 require- ments of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uni- form 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 Com- plaint in Japanese and English, and the proceedings commenced on December 4, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 24, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 26, 2025. The Center appointed Haig Oghigian as the sole panelist in this matter on December 30, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declara- tion of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, para- graph 7. 4. Factual Background The Complainant, Udemy, Inc., is an online course and e-learning platform based in the United States of America. Founded in 2010, the Complainant has offices in the United States of America, Türkiye, Brazil, and Ireland. The Complainant employs more than 5,000 individuals and offers over 250,000 courses in 77 languages to over 81 million registered users in more than 180 countries. The Complainant owns numerous trademark registrations for “UDEMY”, such as but not limited to: Trademark Country Registration Number Registration Date UDEMY United States of America 4314406 April 2, 2013 UDEMY European Union 011006319 November 28, 2012 UDEMY Australia 1704475 July 21, 2014 The Complainant operates its website at <udemy.com> and others. The disputed domain name was registered by the Respondent on October 19, 2025; it does not resolve to an active website. The Respondent is apparently located in Kanagawa, Japan. 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 identical or confusingly similar to a trademark or service mark in which the Complainant has rights. The Complainant demonstrated ownership of numerous trademark registrations for UDEMY in numerous ju- risdictions. The Complainant states that the disputed domain name is identical to the UDEMY mark in which the Complainant has rights. The Complainant adds that the distinctiveness of the UDEMY mark, as well as the Complainant’s industry recognition should be taken into account when assessing the first element. The Complainant adds that disputed domain name is identical to the Complainant’s UDEMY mark, only with the addition of the generic Top-Level Domain (“gTLD”) “.blog”. The Complainant further adds that numerous past decisions have disregarded gTLDs when establishing the first element. - The Respondent has no rights or legitimate interests in respect of the disputed domain name. page 3 The Complainant argues that it has demonstrated rights to the UDEMY mark, and that there is no evidence that the Respondent is commonly known by the disputed domain name or owns any registered trademarks including the term “udemy”. The Complainant further asserts that at no point has the Respondent been li- censed to use its marks, nor is the Respondent affiliated with the Complainant. Furthermore, the disputed domain name is passively held. There is no evidence of any actual or contemplated good faith use of the disputed domain name for any bona fide offering. The Complainant once again stresses the distinctiveness of the UDEMY mark, which has no generic or common usage, which the Complainant argues is fully repro- duced in the disputed domain name. - The disputed domain name has been registered and being used in bad faith. The Complainant states that the registration of the Complainant’s trademarks predates the registration of the disputed domain name by over twelve years. Nonetheless, the Respondent has chosen to use the distinc- tive term “udemy” in the disputed domain name in its entirety. The Complainant further states that a simple online search of the term “udemy” would have led to the Respondent being aware of the Complainant and its mark. The Complainant therefore alleges that it is very likely that the Respondent registered the disputed domain name using the trademark UDEMY intentionally in order to take advantage of the reputation of the trademark and the Complainant’s goodwill, taking advantage of the Complainant’s reputation. The Com- plainant states that the disputed domain name was used in bad faith as it reproduces the Complainant’s mark UDEMY, which, if used to resolve to an active web page, may mislead the potential consumers by cre- ating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation and making the general public believe that the paid services advertised on the website are actually official and authorized by the Complainant. 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 Japanese. 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 reg- istration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including the fact that the Complainant and the Complainant’s representatives are based in English speaking countries, and that the Respondent used an English-language gTLD in the disputed domain name, indicating some knowledge of English. 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 Ques- tions, 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 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 trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Se- lected 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. 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 identical 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 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 re- spondent. 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 evi- dence, 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 – which the Panel notes is identical to the mark which gives rise to an inference that it is somehow affiliated with the Complainant (when it is not). 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. 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 estab- lishes 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 engaged in passive holding of a domain which re- produced a distinct mark, which has no common usage beyond that of the Complainant’s business. The Respondent clearly reproduced the Complainant’s mark, in its entirety, without authorization or fair use quali- fication. 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 Panels have found that the non-use of a domain name (including a blank 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 – being identical to the mark which gives rise to an inference that it is somehow affiliated with the Complainant (when it is not), 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. 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 <udemy.blog> be transferred to the Complainant. /Haig Oghigian/ Haig Oghigian Sole Panelist Date: January 13, 2026

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

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