Westmore · UDRP DecisionIslamicreliefworldwide.com
The Panel ordered transfer of <islamicreliefworldwide.com>. It found the domain identical to the Complainant’s ISLAMIC RELIEF WORLDWIDE trademark, found that the unrebutted record established the Respondent’s lack of rights or legitimate interests, and concluded that the exact-match domain had been registered and used in bad faith despite remaining inactive. The bad-faith finding relied on the trademark’s distinctiveness and reputation, the domain’s composition, the inferred knowledge of the Complainant, the absence of any demonstrated good-faith use, the lack of a response, and passive holding principles.
The timeline behind islamicreliefworldwide.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 islamicreliefworldwide.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how an exact-match registration of a distinctive charitable organization’s mark can satisfy the bad-faith element even when the domain is inactive. The combination of earlier trademark rights, the complainant’s lengthy prior ownership of the same domain, the mark’s specificity and reputation, and the registrant’s failure to provide any credible intended use made passive holding decisive.
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 Islamic Relief Worldwide v. Ivan Eliseev Case No. D2025-5012 1. The Parties The Complainant is Islamic Relief Worldwide, United Kingdom, represented by SafeNames Ltd., United Kingdom. The Respondent is Ivan Eliseev, Kazakhstan. 2. The Domain Name and Registrar The disputed domain name <islamicreliefworldwide.com> is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 3, 2025. On December 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 3, 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 Purposes) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 4, 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 on December 5, 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 the 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. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 29, 2025. page 2 The Center appointed John Swinson as the sole panelist in this matter on January 6, 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 The Complainant is a global humanitarian non-governmental organization and charity that provides emergency aid and support to Muslim populated countries and communities in-need through long-term projects providing, for example, education, healthcare and water supply. Founded in 1984, the Complainant is headquartered in Birmingham, United Kingdom, and has a network of offices, branches and affiliated partners spanning more than 40 countries across 4 continents. The Complainant hosts a website under the domain name <islamic-relief.org> for its fund-raising efforts. This online platform allows supporters to donate to the Complainant’s operations, access the ISLAMIC RELIEF resources, and stay informed of the latest updates and news regarding the Complainant’s aid progress. The Complainant has operated this online platform since 2014. At one time, the Complainant previously owned the disputed domain name and operated its services from the disputed domain name for 15 years between 2003 and 2018 before its incidental lapse. The Complainant owns a portfolio of registered trademarks for ISLAMIC RELIEF and ISLAMIC RELIEF WORLDWIDE, including European Union Trade Mark registration number 005806062 for ISLAMIC RELIEF WORLDWIDE that has a registration date of April 24, 2008. The disputed domain name was registered on July 16, 2025. The disputed domain name does not resolve to an active website. The Complainant sent to the Respondent cease-and-desist notifications on October 6 and 13, 2025. The Respondent did not respond to such notifications. 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. In summary, the Complainant contends that that it is well-known. For example, the Complainant has been subject to extensive media publication for its efforts throughout the years. As examples, the Complainant refers to the Complainant’s global partnership with the United Nations Children’s Fund (UNICEF) to reach at- risk children in 2021; and the Complainant’s appeal to raise GBP 2 million for Pakistani flood victims, covered by the British Broadcasting Corporation in 2010. The Complainant owns registered trademarks for ISLAMIC RELIEF and ISLAMIC RELIEF WORLDWIDE. The disputed domain name is identical to the Complainant’s ISLAMIC RELIEF WORLDWIDE mark. The Respondent does not have any trademark rights to the terms ISLAMIC RELIEF WORLDWIDE. There is also no evidence that the Respondent retains any unregistered trademarks to the term ISLAMIC RELIEF WORLDWIDE, nor any similar terms. Neither has the Respondent received any license from the Complainant to use domain names featuring the ISLAMIC RELIEF WORLDWIDE trademark. page 3 Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create the presumption of bad faith. The Complainant owned and operated the disputed domain name for an extensive 15-year period from 2003 until 2018. Therefore, the Respondent’s simplest of due diligence would have shown the Complainant and its ISLAMIC RELIEF WORLDWIDE brand. Given this, it would be difficult for the Respondent to deny knowledge of Complainant and its ISLAMIC RELIEF WORLDWIDE operations. The Complainant sent cease-and-desist notifications to the Respondent. These notices were sent out to put the Respondent on notice of the Complainant’s trademarks and rights, and with a view to resolve the matter amicably. However, the Respondent provided no response. Previous UDRP decisions have stated that a lack of reply to a cease-and-desist notice prior to commencing the proceedings infers bad faith behavior. The disputed domain name does not resolve to an active website. This does not preclude a finding of bad faith use under the doctrine of passive holding. The Respondent has been party to a previous UDRP proceeding in which the panel found the Respondent to have engaged in illegal activity from the domain name subject to the dispute. Barry Callebaut AG, and Barry Callebaut Belgium NV v. Ivan Eliseev, WIPO Case No. D2025-1955. The Respondent has the capability to engage in similar activity from the disputed domain name, given its identicality to the Complainant’s ISLAMIC RELIEF WORLDWIDE mark. The Complainant submits this is further evidence of bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all of the elements enumerated in paragraph 4(a) of the Policy have been satisfied, namely: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. The onus of proving these elements is on the Complainant. 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. WIPO Overview 3.0, section 1.2.1. The entirety of the ISLAMIC RELIEF WORLDWIDE 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. page 4 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. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Generally speaking, a finding that a domain name has been registered and is being used in bad faith requires an inference to be drawn that the respondent in question has registered and is using the disputed domain name to take advantage of its significance as a trademark owned by (usually) the complainant. 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 Complainant provided evidence of its use and reputation of its ISLAMIC RELIEF and ISLAMIC RELIEF WORLDWIDE trademarks. The Complainant’s marks are highly specific. The Respondent has not asserted that the Respondent was unaware of the Complainant or its ISLAMIC RELIEF WORLDWIDE trademark. In such circumstances, the Respondent cannot credibly claim to have been unaware of the Complainant’s marks or fund-raising activities. Accordingly, the Panel infers that the Respondent knew that its registration of the disputed domain name would be identical or to the Complainant’s mark. WIPO Overview 3.0, section 3.2.2. The Respondent has not used the disputed domain name. The Complainant relies upon the doctrine of passive holding, which is set out in Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003, and other cases. Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. The Respondent had provided no evidence of any actual or contemplated good faith use by it of the disputed domain name. It also appears that the Respondent had taken steps to conceal its true identity. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, the composition of the disputed domain name, and the lack of response or any evidence of the Respondent’s intended use of the disputed domain name, and finds that in the page 5 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 <islamicreliefworldwide.com> be transferred to the Complainant. /John Swinson/ John Swinson Sole Panelist Date: January 19, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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