Westmore · UDRP DecisionSizzling-hot.xyz
The Panel ordered transfer after finding that <sizzling-hot.xyz> was confusingly similar to the Complainant’s SIZZLING HOT trademark, that the Respondent had no rights or legitimate interests, and that the domain name had been registered and used in bad faith. The domain was used to offer slot games and gambling services, which corresponded to the Complainant’s casino-game activities.
The timeline behind sizzling-hot.xyz
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 sizzling-hot.xyz — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a direct-targeting pattern in which a domain reproduces a casino-game trademark with only a hyphen and is then used for closely corresponding slot-game and gambling services. The decision also demonstrates how a respondent’s failure to rebut a prima facie case can be decisive under the rights-or-legitimate-interests element.
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 Novomatic AG v. Kieran Holmes Case No. D2026-0042 1. The Parties The Complainant is Novomatic AG, Austria, represented by Salomonowitz Attorneys-at-Law, Austria. The Respondent is Kieran Holmes, Af ghanistan. 2. The Domain Name and Registrar The disputed domain name <sizzling-hot.xyz> is registered with NameCheap, Inc. (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 7, 2026. On January 7, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On January 8, 2026, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Redacted for Privacy, Privacy Service Provided by Withheld f or Privacy ehf) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on January 8, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on January 9, 2026. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” o r “UDRP”), the Rules f o r 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 January 13, 2026. In accordance with the Rules, paragraph 5, the due date f or Response was February 2, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on February 4, 2026. page 2 The Center appointed George R. F. Souter as the sole panelist in this matter on February 11, 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. 4. Factual Background The Complainant is an Austrian company offering casino games. The Complainant has provided the Panel with evidence of widespread registration of its SIZZLING HOT trademark in respect of , inter alia, casino games, including the European Union trademark registration No. 005179387, registered on December 7, 2007 and United States of America registration No. 86311460, registered on September 15, 2015. The disputed domain name was registered on November 4, 2025 and used to offer slot games and gambling services. 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 name. Notably, the Complainant contends that it’s SIZZLING HOT trademarks are so well known that the Respondent without doubt was aware of them when registering the disputed domain name, and ref ers to its f amous slot games. The Complainant states that, so far as it has been able to establish, the Respondent is not generally known by the disputed domain name, and that the Complainant has never authorized the use of its trademark in connection with the registration of a domain name, or otherwise. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview of WIPO Panel Views on Selected UDRP Questions (“WIPO Overview 3.1”), section 1.2. and 1.7. The Panel f inds the mark is wholly contained in the disputed domain name. Accordingly, the disputed domain name is conf usingly similar to the mark f or the purposes of the Policy. WIPO Overview 3.1, section 1.7. The mere addition of a hyphen in the disputed domain name does not disturb this f inding. The Panel f inds the f irst element of the Policy has been established. page 3 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 of ten 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Moreover, the Panel f inds that the composition of the disputed domain name, which incorporates the Complainant’s trademark in its entirety with the addition of a hyphen carries a risk of implied af f iliation. WIPO Overview 3.1, section 2.5.1. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel considers it implausible that the disputed domain name was adopted without having the Complainant’s SIZZLING HOT trademark in mind, and the subsequent use of the disputed domain name f o r a website purporting to of f er slot games and gambling services co nf irms this inf erence. The Panel f inds that the disputed domain name was registered in bad f aith. Panels have held that the use of a domain name f ound to be conf usingly similar to a complainant’s trademark in connection with the sale of the same or similar goods to those sold by the Complainant constitutes use of the domain name in bad f aith. Having reviewed the record, the Panel f inds the Respondent’s use of the disputed domain name in the circumstances of the present case constitutes use in bad f aith under the Policy. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <sthling-hot.xyz> be transf erred to the Complainant. /George R. F. Souter/ George R. F. Souter Sole Panelist Date: February 25, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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