Westmore · UDRP DecisionGo88x.app, G088.app, Play-go88.com
The Panel ordered transfer of all three disputed domain names. It found them confusingly similar to the Complainant’s registered GO88 mark, including <g088.app>, which substitutes the numeral “0” for the letter “o.” The Respondent did not rebut the Complainant’s prima facie showing under the second element. On bad faith, the Panel relied on the composition and timing of the registrations, the parties’ overlapping gaming activities, prior redirection of the domains to gambling websites displaying GO88, the absence of a plausible explanation for the Respondent’s selection, evidence concerning a broader registration pattern, and the circumstances of the domains’ current passive holding.
The timeline behind go88x.app
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 go88x.app — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how a complainant can prevail despite incomplete proof of its earliest claimed common-law use when it has registered rights predating the disputed domains and additional evidence of earlier brand use. It also shows that a respondent’s ownership of a separate, earlier domain containing the same term does not by itself establish legitimate interests, particularly where the associated presentation appears to copy the complainant’s branding. Prior active redirection followed by passive holding can remain probative of bad faith.
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 Central Professional Unit Solution Co. Ltd. v. Srdan Andelkovic, Sunwin Vibes Limitada Case No. D2025-5111 1. The Parties The Complainant is Central Professional Unit Solution Co. Ltd., Cambodia, represented by Ella Grant, Cambodia. The Respondent is Srdan Andelkovic, Sunwin Vibes Limitada, Costa Rica, self-represented. 2. The Domain Names and Registrar The disputed domain names <go88x.app>, <g088.app>, and <play-go88.com> are registered with Nicenic International Group Co., Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 9, 2025. On December 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On December 11, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. In response to the Center’s email regarding the remedy, on December 11, 2025, the Complainant clarified its choice of the remedy. The Center verified that 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 December 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 5, 2026. The Response was filed with the Center on December 30, 2025. The Center appointed Evan D. Brown as the sole panelist in this matter on January 8, 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. page 2 On January 9, 2026, the Complainant submitted an unsolicited Supplemental Filing. On January 27, 2026, the Panel issued Administrative Panel Procedural Order No. 1 inviting the Complainant to file submission evidencing its claimed use of the domain name <go88.com> and the GO88 trademark since 2011, and the Respondent to comment on the Complainant’s unsolicited Supplemental Filing and submission in response to the Procedural Order No. 1. The Complainant made its submission on January 31, 2026. The Respondent did not provide any comments. On February 13, 2026, the Complainant sent an email communication submitting a UDRP decision rendered against the Respondent. 4. Factual Background The Complainant provides gaming services online and through its mobile application. It owns the trademark GO88 and enjoys the benefits of registration of that mark in a number of jurisdictions around the world. For example, it owns Cambodian trademark Reg. No. KH/2025/99708 for the mark GO88, registered on July 29, 2025, and German Reg. No. 302025109332 for the mark GO88, registered on June 11, 2025. The Complainant also asserts common law rights in its GO88 marks arising from use as early as 2011. The Complainant operates its official website under the domain name <go88.com>. The Respondent filed its trademark application No. UK00004217829 on June 12, 2025 for GO88. Upon receipt of the Complainant’s cease and desist letter, the Respondent withdrew its trademark application, and the trademark application was withdrawn on October 10, 2025. According to the WhoIs information, the disputed domain names were registered on the following dates: - <play-go88.com> October 21, 2025; - <go88x.app> November 13, 2025; and - <g088.app> November 23, 2025. The record shows that the disputed domain names at one time all redirected to gambling websites displaying the sign GO88. The disputed domain names do not associate with any active websites now. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain names are identical or confusingly similar to the Complainant’s trademark; that the Respondent has no rights or legitimate interests in respect of the disputed domain names; and that the disputed domain names were registered and are being used in bad faith. The Complainant asserts that it has owned and used the domain name <go88.com> since 2011. The Complainant notes while its company was registered in 2023, the domain name <go88.com> was registered by Mr. Niran, the sole owner of the Complainant, through one of his affiliates in 2011. In 2017, this domain name was officially transferred to Mr. Niran as shown in a copy of the transfer invoice dated August 5, 2017, provided by the Complainant. The Complainant further contends that GO88 is a distinctive and arbitrary combination of the term GO and the number 8 repeated twice. The Complainant submitted Supplemental Filing in which it reiterated and expanded its allegations of bad faith. In particular, the Complainant asserts that the Respondent has engaged in a pattern of cybersquatting within the meaning of paragraph 4(b)(ii) of the Policy, relying on Reverse WhoIs evidence which, according to the Complainant, shows that the Respondent has registered numerous domain names that are identical or confusingly similar to trademarks of the Complainant as well as those of unrelated third parties. The Complainant contends that this conduct demonstrates a pattern of preventing trademark owners from reflecting their marks in corresponding domain names. The Complainant further alleges that the Respondent has copied trademarks, logos, user interface layouts, and other brand assets of multiple trademark owners, page 3 which the Complainant submits constitutes additional evidence of malicious intent and bad faith registration and use. The Complainant contends that the Respondent’s claim of independent persons using the trademark GO88 is incorrect. The Complainant also has its affiliates to file trademark applications on its behalf, such as the one mentioned in Annex 4 to the Response, Viet Nam Trademark No. 4-0579877-000 for GO88 GO88.COM, and another United States of America Trademark No. 7766504 for GO88 GO88.COM. These individuals have assigned their respective trademark applications to the Complainant through the trademark assignment agreements. The Complainant also submits that as per the public information available on the Costa Rica Registry’s website, the Respondent registered its company in 2025, only after the Complainant’s establishment of it common law rights over GO88 and with a sole intention to infringe the registered trademarks of the Complainant and other entities. The Complainant further points out that the domain name <go88.net.vc> was registered in December 2023, and had been used since 2024, however, the Respondent was not established until 2025. B. Respondent The Respondent argues generally that the Complainant overstates its rights in the GO88 mark. The Respondent contends that the Complainant’s website is directed exclusively to the Vietnamese market, as evidenced by its Vietnamese-language content, Vietnamese contact details, and locally targeted social media channels, a context the Complainant fails to acknowledge. According to the Respondent, in Viet Nam the term “go88” has for many years been used by multiple, unrelated gambling service providers as a common or descriptive designation for gaming services rather than as an identifier of a single commercial source. To support this assertion, the Respondent has provided a screenshot of the Viet Nam Trademark No. 4-0579877-000 for GO88 GO88.COM applied by an individual and screenshots of other websites using the term “go88”. The Respondent therefore disputes the Complainant’s claim to exclusive rights in the term and maintains that the request to “block” the disputed domain names lacks factual, logical, and legal foundation. The Respondent also challenges the Complainant’s assertion of use dating back to 2011, noting that the Complainant’s corporate entity was incorporated only in 2023 and that available traffic data suggests meaningful use of the website began much later. On the first element, the Respondent argues that the disputed domain names are not identical to the Complainant’s registered trademarks or domain name and differ in certain respects, while acknowledging that they contain the term “go88” for purposes of paragraph 4(a)(i) of the Policy. The Respondent maintains, however, that “go88” lacks distinctiveness in the Vietnamese market, where it is widely used by multiple gambling service providers. The Respondent further submits that the Complainant has not demonstrated ownership of registered trademark rights in Viet Nam, as the international trademark designations covering Viet Nam remain pending. According to the Respondent, the Complainant’s trademark registrations in other jurisdictions do not reflect genuine market use, given that the Complainant’s services are directed solely at Vietnamese users. The Respondent contends that these circumstances indicate an attempt to monopolize a commonly used trade name in the Vietnamese gaming sector rather than evidence of exclusive trademark rights. As for the second element, the Respondent asserts that it has rights or legitimate interests in the disputed domain names. The Respondent states that it is the lawful registrant of the disputed domain names, which were registered in October–November 2025, and that it also owns and operates the website at “www.go88.net.vc”, registered on December 12, 2023. The Respondent relies on documentary evidence and archived records showing use of that website in commerce as early as May 2024. The Respondent further states that it is the holder of a valid gambling licence issued by the Anjouan Gaming Authority and operates in accordance with the applicable regulatory framework. The Respondent emphasizes that the disputed domain names themselves have remained passive, were shut down almost immediately after registration, and are not accessible either globally or from specific jurisdictions, including the United Arab Emirates and the United Kingdom. page 4 And concerning the third element, the Respondent asserts that the disputed domain names were neither registered nor used in bad faith. The Respondent argues that the Complaint fails to establish any of the circumstances of bad faith set out in paragraph 4(b) of the Policy, and instead relies on vague, speculative, and unsupported allegations. The Respondent denies having registered the disputed domain names for sale to the Complainant, to prevent the Complainant from reflecting its mark in a corresponding domain name, or to disrupt the Complainant’s business, and notes that no evidence of such conduct has been provided. The Respondent further rejects allegations of potential phishing or fraudulent use as hypothetical, emphasizing that the disputed domain names have remained inactive and inaccessible since shortly after registration. According to the Respondent, its trademark filing was undertaken as a defensive measure to formalize long- standing use of “go88” in Viet Nam, particularly in response to the Complainant’s recent trademark filings made with an intention to gain unfair advantage over the Respondent and other users of the same trade name in the local market. The Respondent also underscores that it registered and used a “go88” domain name in commerce prior to the Complainant’s claimed trademark rights, and maintains that the Complaint reflects an attempt by the Complainant to appropriate a widely used name in the Vietnamese gaming market rather than evidence of bad faith on the Respondent’s part. The Respondent finally reiterates that the Complainant attempts to establish that it has a long history in using the GO88 brand, and it is the sole owner and creator of the GO88 brand, while in fact, the Complainant’s history of use of the GO88 brand is almost the same as others. 6. Discussion and Findings 6.1. Procedural Issue – Supplemental Filing The Panel notes that the Complainant submitted an unsolicited Supplemental Filing on January 9, 2026. While unsolicited supplemental filings are generally discouraged, the Panel has discretion under paragraphs 10 and 12 of the Rules to determine the admissibility, relevance, materiality, and weight of the evidence, and to request or admit further submissions where appropriate. In the circumstances of this case, the Panel finds that the Supplemental Filing addresses issues raised in the Response and provides additional helpful information, particularly as relevant to the assessment of bad faith. The Panel therefore admits the Supplemental Filing into the record and has taken it into account, attaching such weight to it as the Panel considers appropriate. The Panel further notes while the Respondent was given the opportunity to comment on the Complainant’s Supplemental Filing as stated in the Procedural Order No.1 but chose not to do so. 6.2. Substantive issues To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain names are 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 names, and (iii) the disputed domain names have been registered and are being used in bad faith. The Panel finds that all three of these elements have been met in this case. A. Identical or Confusingly Similar Under paragraph 4(a)(i) of the Policy, the Complainant must establish that the disputed domain names are identical or confusingly similar to a trademark or service mark in which it has rights. This element functions primarily as a standing requirement and involves a straightforward comparison between the disputed domain names and the textual components of the Complainant’s mark. As summarized in WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7, the test is whether the relevant trademark is recognizable within the disputed domain names. In this case, the disputed domain names incorporate the mark GO88, or a visually equivalent variant thereof. The Panel notes that one of the disputed domain names replaces the letter “o” with the numeral “0.” Such a substitution does not prevent a finding of confusing similarity. Panels have consistently held that minor typographical variations, including the substitution of letters with visually similar numerals, constitute a form of typosquatting and do not dispel confusing similarity (see WIPO Overview 3.1, section 1.9). page 5 The Respondent argues that the Complainant has not demonstrated ownership of registered trademark rights in Viet Nam. The Panel notes that the jurisdiction(s) where the trademark is valid is not considered relevant to panel assessment under the first element. See WIPO Overview 3.1, section 1.1.2. The Respondent also argues that the mark GO88 lacks distinctiveness in the Vietnamese market and is commonly used by multiple gambling service providers. While these arguments may be relevant to the assessment of rights or legitimate interests or bad faith, they do not negate a finding of confusing similarity for purposes of paragraph 4(a)(i) of the Policy. As noted in WIPO Overview 3.1, section 1.7, issues concerning the strength, distinctiveness, or alleged descriptiveness of a mark are generally addressed under the second and third elements of the Policy. Accordingly, the Panel finds that the disputed domain names, including the variant containing the numeral “0” in place of the letter “o,” are confusingly similar to a trademark in which the Complainant has rights. The requirement of paragraph 4(a)(i) of the Policy is therefore satisfied. B. Rights or Legitimate Interests The Panel evaluates this element of the Policy by first assessing whether the Complainant has made a prima facie showing that the Respondent lacks rights or legitimate interests in respect of the disputed domain names. If the Complainant makes that showing, the burden of production shifts to the Respondent to demonstrate rights or legitimate interests in the domain names, although the overall burden of proof remains with the Complainant. See WIPO Overview 3.1, section 2.1. The Complainant asserts, among other things, that: (1) the Respondent has not been authorized, licensed, or otherwise permitted by the Complainant to use its trademark; and (2) any use of the disputed domain names by the Respondent would falsely suggest an affiliation with the Complainant. The Panel finds that the Complainant has made the requisite prima facie showing. The Respondent, to whom the burden of production shifts, has not come forward with evidence demonstrating rights or legitimate interests in the disputed domain names. The mere ownership of another domain name incorporating the term “go88”, without more, does not establish rights or legitimate interests within the meaning of paragraph 4(c) of the Policy. Moreover, the screenshot of the website to which the Respondent refers (as reflected in the Internet Archive capture) displays the design mark that is virtually identical to the Complainant’s mark. This circumstance further undermines the Respondent’s assertion of independent rights or legitimate use. The Panel further notes that the record includes archived screenshots submitted by the Complainant showing use of the GO88 mark at least as early as 2019 on a website that appears to have been controlled by the Complainant. This evidence predates the Respondent’s registration of its domain name <go88.net.vc> in December 2023 and further calls into question the Respondent’s claim to independent rights in the GO88 designation. Nor does the record otherwise demonstrate any demonstrable preparations to use the disputed domain names in connection with a bona fide offering of goods or services. Accordingly, the Panel does not consider the Respondent’s asserted ownership of the domain name <go88.net.vc> sufficient to establish rights or legitimate interests in the disputed domain names. In these circumstances, and notwithstanding the Respondent’s broader assertions regarding the use of the term “go88” in the Vietnamese market or its operation of other domain names, the Panel concludes that the Respondent has failed to rebut the Complainant’s prima facie case. See WIPO Overview 3.1, section 2.10. Accordingly, the Panel finds that the Complainant has established the second element of paragraph 4(a) of the Policy. page 6 C. Registered and Used in Bad Faith Under paragraph 4(a)(iii) of the Policy, the Complainant must establish that the disputed domain names were registered and are being used in bad faith. Paragraph 4(b) of the Policy provides a non-exhaustive list of circumstances that may evidence bad faith. The Complainant argues that the Respondent deliberately targeted its GO88 mark in registering the disputed domain names. The Complainant asserts that the mark GO88 is arbitrary and distinctive, and that the Respondent’s use of the exact mark or a visually similar variant in the disputed domain names is unlikely to be coincidental. The Panel agrees that the composition of the disputed domain names, especially in light of the fact that the Respondent also purports to offer gaming services, supports an inference that the Respondent had knowledge of the Complainant’s rights and intentionally sought to register domain names that evoke the Complainant’s mark. The Respondent appears to assert that it chose the term “go88” in the disputed domain names since it first registered the domain name <go88.net.vc> in December 2023 which have been used in connection with a gambling website since May 2024, and although the Complainant claims to have used the domain name <go88.com> and the GO88 mark since 2011, the Complainant was not established until 2023. The Complainant clarifies that its domain name <go88.com> was registered by Mr. Niran, the sole owner of the Complainant, through one of his affiliates in 2011. While the Complainant does not have direct evidence to support this because the Complainant’s corporate structure and record-keeping practices were not as formalized as they are today, the Complainant has provided the evidence showing that the domain name <go88.com> was officially transferred to Mr. Niran in 2017 and archived screenshots submitted by the Complainant show use of the GO88 mark at least as early as 2019. The Panel also notes that the disputed domain names were registered after the Complainant had secured trademark registrations for the GO88 mark. The Panel further notes the Complainant’s assertion, supported by reverse WhoIs evidence, that the Respondent has engaged in a broader pattern of registering domain names that correspond to the trademarks of the Complainant and unrelated third parties. Moreover, the Panel is aware of a recent UDRP decision involving the Respondent, Sunwin Information Technology LLC v. Srdan Andelkovic, Sunwin Vibes Limitada, Sunwin Vibes, Sunwin Vibes Content Writing Service, Srdan Andelkoic, Sunwin Vibes Limitada, WIPO Case No. D2025-5040. In that case, the panel found that the respondent had targeted the SUNWIN mark. The record shows that the disputed domain names at one time all redirected to gambling websites displaying the sign GO88. The Complainant submits that the disputed domain names, although currently inactive, create a risk of deceptive use such as email fraud or impersonation. Panels have recognized that the passive holding of domain names may, in appropriate circumstances, support a finding of bad faith. In assessing passive holding, the Panel has considered the distinctiveness of the Complainant’s mark, and the prior use of the disputed domain names, and the Panel finds that the current non-use of the disputed domain names does not prevent a finding of bad faith. See WIPO Overview 3.1, section 3.3. The Respondent denies acting in bad faith and argues that the disputed domain names were never used to host content or deceive users. The Respondent also claims that “go88” is a common term in the Vietnamese gaming market. However, the Panel finds these arguments unconvincing based on the case file. The Respondent has not meaningfully explained why it selected the disputed domain names incorporating that exact term or a variation thereof. In the absence of a plausible explanation and given the Respondent’s failure to provide substantiating evidence, the Panel infers that the Respondent more likely than not targeted the Complainant’s mark. Taking into account the composition of the disputed domain names, the timing of registration, the Complainant’s allegations of a broader pattern of abusive conduct, the prior use of the disputed domain names, and the risk of future misuse associated with the disputed domain names that incorporate the Complainant’s mark or a variation thereof, the Panel concludes that the disputed domain names were registered and are being used in bad faith under paragraph 4(a)(iii) of the Policy. page 7 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 names <go88x.app>, <g088.app>, and <play-go88.com> be transferred to the Complainant. /Evan D. Brown/ Evan D. Brown Sole Panelist Date: February 20, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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