Westmore · UDRP DecisionNetbahisadresi.com, Netbahisgirisi.net, Netbahissikayet.com
The Panel denied the Complaint because the Complainant failed to establish trademark rights for purposes of the first UDRP element. The cited United Kingdom trademark application was pending and filed in the name of TM Enfield Ltd, while the alleged assignment to the Complainant was unsupported by documentary evidence. The evidence also did not establish claimed common law rights. The second and third elements were not reached.
The timeline behind netbahisadresi.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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How each disputed name was decided in this proceeding.
This decision illustrates that evidence suggesting targeting or imitation does not eliminate the complainant's threshold obligation to prove ownership of trademark rights. A pending application, particularly one filed in another party's name, did not establish standing, and unsupported assertions of assignment and common law rights remained insufficient despite multiple opportunities to supplement the record.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Can Saygun v. Gene M Bleich, seo Case No. D2025-5396 1. The Parties The Complainant is Can Saygun, United Kingdom, self-represented. The Respondent is Gene M Bleich, seo, United States of America. 2. The Domain Names and Registrar The disputed domain names <netbahisadresi.com>, <netbahisgirisi.net>, and <netbahissikayet.com> are registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 23, 2025. On December 24, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain names. On December 24, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact inf ormation f or the disputed domain names which dif f ered f rom the named Respondent (Privacy service provided by Withheld f or Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 26, 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 27, 2025. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on December 30, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was January 19, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on January 22, 2026. page 2 The Center appointed Jeremy Speres as the sole panelist in this matter on January 26, 2026. The Panel f inds 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. The Panel issued Procedural Order No. 1 on January 27, 2026, inviting the Complainant to substantiate its claimed trademark rights with evidence by February 1, 2026, and giving the Respondent an opportunity to comment by February 6, 2026. The Complainant responded on the same day. The Panel issued Procedural Order No. 2 on January 28, 2026, querying various aspects of the Complainant’s response to Procedural Order No. 1 and giving the Complainant a f urther opportunity to substantiate its trademark rights by February 2, 2026, inviting the Respondent to comment by February 7, 2026. The Complainant f iled its response on January 29, 2026. No response was received f rom the Respondent to either procedural order. 4. Factual Background The Complainant does not provide much detail about its business or its trademark, and very little is supported by evidence. As f ar as the Panel can glean, the Complainant owns the domain name <netbahis.com>, which redirects to the website “www.343netbahis.com”, which in turn appears to be an online betting and gaming website operating under the NETBAHIS brand. The Complainant claims to own United Kingdom Trademark Application No. UK00004313564 NETBAHIS in class 41, f iled on December 19, 2025, in the name of TM Enf ield Ltd. The Complainant claims common law rights in the NETBAHIS mark. The disputed domain names were registered on May 26, 2025. The evidence in the record establishes that the disputed domain names all previously resolved to betting and gaming websites using NETBAHIS logos that are highly similar if not identical to the logo employed on the Complainant’s website ref erenced above. Presently, <netbahisadresi.com> does not resolve to any website, whilst the remaining two disputed domain names continue to resolve to the website advertising online betting and gaming services bearing a similar NETBAHIS logo. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain names. Notably, the Complainant contends as f ollows. He is the owner of the NETBAHIS trademark, which was acquired by assignment prior to the f iling of the Complaint. The NETBAHIS mark has been continuously and exclusively used in commerce in connection with online betting and gaming services for a substantial period of time prior to the registration of the disputed domain names, and thus enjoys common law rights and is well known. The Respondent makes prominent and repeated textual use of the NETBAHIS trademark on the disputed domain name’s websites, including through buttons that redirect users to the Complainant’s off icial website, while the surrounding pages are f illed with advertisements and promotional links to competing online betting services. As such, the disputed domain names are used in bad faith to attract Internet users for commercial gain by misleading them into believing that the websites are operated by, affiliated with, or endorsed by the Complainant. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 first claimed, in the amended Complaint, that he is the “registered owner of the trademark ‘NETBAHIS’, which is registered and used in connection with online betting and gaming services.” In support of this, he provided a “Certificate of Filing” issued by the United Kingdom Intellectual Property Of f ice f or the trademark application referenced in the Factual Background section above. The Panel viewed the online records for this trademark application and found that the application was still pending, and was, f urthermore, f iled in the name of “TM Enf ield Ltd”. 1 In Procedural Order No. 1, the Panel pointed out that a pending trademark application does not establish trademark rights. The Panel also noted that the Complainant had not explained why the applicant f or the trademark is named dif f erently to the Complainant, and noted that no evidence had been provided supporting the Complainant’s contention that its mark was well known and enjoyed common law rights. The Panel specifically referred the Complainant to relevant sections of the WIPO Overview 3.0 in these regards. The Panel invited the Complainant and the Respondent to comment on these issues. In his response to Procedural Order No. 1, the Complainant stated as f ollows: “The Complainant conf irms that it is the owner of the NETBAHIS trademark, which was acquired by assignment prior to the f iling of the Complaint. At the time of f iling, the trademark registration process was ongoing, and the Complainant had already submitted the of f icial provisional / temporary ownership documentation evidencing the acquisition of trademark rights. The f inal registration certificate is expected to be issued shortly (within approximately one month), as conf irmed by the trademark authority.” No evidence was supplied in support of these contentions. No assignment agreement or any other documentary evidence was provided. He also stated: “The NETBAHIS mark has been continuously and exclusively used in commerce in connection with online betting and gaming services for a substantial period of time prior to the registration of the disputed domain names.” He based this claim on his ownership and operation of <netbahis.com>. The only evidence provided in this respect was a screenshot from his Registrar account page showing the validity period for the <netbahis. com> domain name for “Sep 20 2024 - Sep 20 2026”. No f urther evidence was provided in support of his claimed longstanding usage of that domain name, nor the Complainant’s contentions that his NETBAHIS mark is well known and enjoys common law rights. 1 In accordance with its powers articulated inter alia in paragraphs 10 and 12 of the Rules, the Panel is entitled to conduct limited independent research into matters of public record. WIPO Overview 3.0, section 4.8. page 4 Noting that the Complainant is unrepresented and noting that the disputed domain names’ websites have all made use of a logo that is highly similar if not identical to the logo employed on the website to which the Complainant’s <netbahis.com> domain name redirects, the Panel again gave the Complainant an opportunity to substantiate its trademark rights with evidence in Procedural Order No. 2. The Panel specifically encouraged the Complainant to seek representation from counsel experienced in matters under the Policy. The Complainant’s response was to make the same claims, and to ref er to the same evidence, that he supplied in his response to Procedural Order No. 1. In the circumstances, there is insufficient evidence before the Panel supporting the Complainant’s claims of registered and unregistered trademark rights. The Complainant was given three opportunities to properly set out his case, and was specifically encouraged to seek representation f rom counsel, which the Complainant failed to do. The Panel f inds the f irst element of the Policy has not been established. 7. Decision For the f oregoing reasons, the Complaint is denied. /Jeremy Speres/ Jeremy Speres Sole Panelist Date: February 10, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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