Westmore · UDRP decision
WIPO · Case No. D2026-0072

Lazarusai.com, Lazarus.enterprises

Complaint deniedWIPO-indexed · informational, not legal advice

The Panel denied the Complaint because Complainant failed to prove bad-faith registration. Respondent registered both Domain Names before Complainant began using LAZARUS as a trademark and was then a founder and principal of Complainant. Competing accounts concerning corporate authority, ownership, intent, and control could not be resolved without discovery and cross-examination, which are unavailable under the UDRP. The Panel did not reach confusing similarity or rights or legitimate interests and declined to find Reverse Domain Name Hijacking.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-03-04
Panelist(s)
Badgley, Robert A.
Complainant
Lazarus Enterprises, Inc.
Respondent
Ariel Elizarov
Counsel
Michael Best & Friedrich, LLP
Disputed domain(s)
lazarusai.com, lazarus.enterprises
Citation weightCited by 1 later decision
Domain history UDRP Intelligence

The timeline behind lazarusai.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 lazarusai.com — 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
Outcome by domain

How each disputed name was decided in this proceeding.

lazarusai.comDenied
lazarus.enterprisesDenied
Verified public record
Outcome & remedy
Complaint denied. lazarusai.com remained with the respondent.
Reverse Domain Name Hijacking
RDNH requested by the respondent; not found.
Westmore Insight

This decision illustrates the UDRP's limits where a domain dispute arises from a founder-company relationship and turns on contested corporate ownership, authority, and asset-control questions. Even substantial corporate use of domain names and allegations of a later lockout did not establish bad-faith registration where the registrations preceded the asserted trademark use and the registrant was a founder and principal of the company.

The three-part test
Identical or Confusingly Similarnot_reached
Rights or Legitimate Interestsnot_reached
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
Complaint denied
Decision date
2026-03-04
Panel
Badgley, Robert A.
Full decision
13 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Lazarus Enterprises, Inc. v. Ariel Elizarov Case No. D2026-0072 1. The Parties Complainant is Lazarus Enterprises, Inc., United States of America (the “United States”), represented by Michael Best & Friedrich, LLP, United States. Respondent is Ariel Elizarov, United States, self-represented. 2. The Domain Names and Registrar The disputed domain names <lazarusai.com> and <lazarus.enterprises> (the “Domain Names”) are registered with Squarespace Domains II LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 8, 2026. On January 9, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Names. On January 9, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Names which differed from named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email to Complainant on January 12, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant did not amend the Complaint. 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 Respondent of the Complaint, and the proceedings commenced on January 26, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 15, 2026. On February 13, 2026, Respondent requested an extension to file Response under paragraph 5(b) of the Rules, which the Center granted the same day, setting the due date for Response as February 19, 2026. The Response was filed with the Center on February 18, 2026. page 2 The Center appointed Robert A. Badgley as the sole panelist in this matter on February 20, 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 Complainant alleges as follows: “Complainant owns common law trademark rights in LAZARUS for software development and computer engineering. In addition to its trademark rights in the word mark LAZARUS, Complainant also owns common law trademark rights, covering the same goods and services, for a LAZARUS logo...” [...] “Complainant creates and develops artificial intelligence tools to help its customers automate their businesses and better serve their clients. Since at least as early as October 16, 2019, Complainant has used LAZARUS for developing AI products and services.” “One of Complainant’s LAZARUS software offerings was developed at least as early as 2019 and utilized AI to improve cancer detection. In or around 2023, Complainant developed an AI tool to help automate document intake and analysis. Complainant continued to build on this tool, and now has a suite of AI products that use machine learning to analyze data. Complainant develops its products to serve the public sector, insurance, healthcare, financial services, and manufacturing industries.” “Complainant’s LAZARUS products and services are particularly popular in the insurance industry. Approximately 20% of the top global insurers use LAZARUS. One out of every three medical records that is faxed will touch a LAZARUS product. Approximately half of the prior authorizations for insurance in the Northeastern United States are processed by LAZARUS.” Annexed to the Complaint are various screenshots showing Complainant’s use of the Domain Name <lazarusai.com> to host a commercial website as early as October 2019. Complainant also provides photos of Complainant using the LAZARUS logo at various trade conventions. Complainant also asserts: “Third party publications report on LAZARUS. For example, Complainant (under its LAZARUS name) has been included in articles from CNBC, The SaaS News, Business Insider, and Forbes.” Complainant asserts: “Complainant’s revenues for its LAZARUS products and services are approximately $10mm+.” It is unclear whether this is an annual figure or an aggregate figure. There is no allegation in the record that Complainant holds a registered trademark. Complainant asserts: “Complainant was formed in 2019. At the time of formation, Complainant’s CEO and founder, Ariel Elizarov, owned the disputed domains. At that time, the disputed domains were in an account owned by Elizarov. Elizarov and Complainant intended that Complainant should own the account with the disputed domains. To that end, they updated the ‘owner of record’ in the account logs to identify Complainant’s primary corporate account as the owner.” “From 2019 to the present, Complainant has paid all fees associated with the disputed domains. In 2019, Complainant’s website went ‘live’ on lazarusai.com. The website represented itself as owned by ‘Lazarus Enterprises Inc.’” page 3 By way of example, Complainant provides a screenshot from the Wayback Machine (“www.archive.org”) showing that, on December 16, 2019, the privacy policy for the website under the Domain Name <lazarusai.com> identified the site as being owned and operated by Lazarus Enterprises Inc. Complainant asserts that it used the Domain Name <lazarus.enterprises> as the domain for its email server, and that employees of Complainant all had email addresses as “[...]@lazarus.enterprises”. The Domain Name <lazarus.enterprises> was registered on October 5, 2017, and the Domain Name <lazarusai.com> was registered on May 23, 2018. According to Respondent’s sworn affidavit, he personally registered both Domain Names on the foregoing dates and paid the registration fees from his personal funds. He also states in the affidavit that he has owned the Domain Names continuously since their initial registration. Respondent’s affidavit states further: “I was the founder and controlling principal of the business that became Complainant. I am and remain the Company’s majority stockholder and Chairman of the Board. On December 23, 2025, I became the Company’s sole director. As of December 24, 2025, I became the Company’s sole executive officer, serving as Executive Chairman. Any actions taken with respect to the disputed domain names were taken in good faith and in my capacity as founder, Executive Chairman of the Board and corporate officer.” It thus appears that, when the Complaint in this proceeding was filed, Complainant was not aware that Respondent was Complainant’s founder Ariel Elizarov. In this regard, the Complaint states: “From 2019 through early Fall 2025, Elizarov continued to work as Complainant’s CEO. The account with the dispute domains listed Complainant as its owner. The lazarusai.com domain continued to host Complainant’s website and lazarus.enterprises continued to be used as the domain for Complainant’s email server.” “In October 2025, Elizarov decided to resign from Complainant to pursue other opportunities. Complainant continued to operate its website at lazarusai.com and its email server through the domain lazarus.enterprises.” “On December 25, 2025, without warning, Respondent entered the domain account and removed access from all Complainant’s authorized users. The account – and domains – were commandeered by Respondent. Upon information and belief, Complainant believes that Respondent further changed the ownership of the domains without Complainant’s consent. Complainant is unable to access its account and related materials. Complainant communicated with all current employees and officers who have the ability to make changes to the domains and their ownership; the relevant employees and officers were not involved in the changes.” “Complainant recognizes that Elizarov may have continued to have access. As part of Elizarov’s departure, Elizarov and Complainant were working through some remaining issues to wrap up Elizarov’s connections with Complainant. Thus, Respondent could be Elizarov. Alternatively, Respondent could be an unknown bad actor who hacked the relevant accounts.” “Complainant attempted to resolve this issue with SquareSpace, the Registrar for the domains. SquareSpace also corresponded with Respondent about the issue. Respondent falsely represented that Respondent was a “colleague” of Complainant. As noted above, Complainant already confirmed that none of its current employees and officers are involved in the account changes, and therefore knows that Respondent is not a colleague of Complainant’s personnel.” “After exchanging substantial communication with SquareSpace, SquareSpace reported it was not able to take action and that Claimant needed to file a UDRP claim.” page 4 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Names. In sum, Complainant asserts: “Respondent has no fair or good faith reason as to why it has taken Complainant’s account and locked out Complainant’s employees and officers. Respondent is not Complainant, is not employed by Complainant, is not an owner of Complainant, and is not an officer of Complainant. The domains at issue have long been used by Complainant, in conjunction with offering Complainant’s products and services. Respondent does not have a valid, good faith reason to own or control the disputed domains.” B. Respondent Respondent asserts that, as founder of Complainant, he registered the Domain Names in good faith before Complainant ever began using LAZARUS as a trademark. Respondent argues: “This proceeding arises out of an internal corporate governance dispute following Respondent’s temporary departure and subsequent resumption of corporate authority. It is not a case of cybersquatting.” “While the Complainant in this matter is listed as “Lazarus Enterprises, Inc.” it is the Respondent’s position that the person(s) filing the Complaint on behalf of the entity do not have the corporate power or authority to do so. Thus, all references herein to the ‘Complainant’ shall refer to the person(s) filing the complaint and the Respondent reserves all rights to challenge whether the persons filing had proper corporate authority, which further underscores that this matter concerns internal governance rather than cybersquatting.” “The Uniform Domain Name Dispute Resolution Policy (‘Policy’) is not designed to resolve internal corporate control disputes, asset ownership disagreements, or account access issues.” Respondent seeks a finding of Reverse Domain Name Hijacking (‘RDNH’) against Complainant, arguing that Respondent registered the Domain Names before Complainant began to use LAZARUS as a trademark. Respondent argues further: “While parties are entitled to pursue legitimate claims, the Policy should not be used as leverage in a broader business or governance disagreement where required elements cannot be established. In light of the clear chronology of events and the absence of any plausible basis to establish bad faith registration, Respondent respectfully submits that a finding of Reverse Domain Name Hijacking under Rule 15(e) is warranted.” 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Names: (i) the Domain Names are identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the Domain Names; and (iii) the Domain Names have been registered and is being used in bad faith. page 5 A. Identical or Confusingly Similar Because it appears that there is a broader issue of corporate ownership and control in play between the Parties, and because the Panel finds below that there was no bad faith registration of the Domain Names, the Panel need not decide the issue whether the alleged common law trademark rights in LAZARUS belong to Complainant or to someone else. The Panel will take a pass on this element of the Policy. B. Rights or Legitimate Interests Pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Names, among other circumstances, by showing any of the following elements: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Domain Names or a name corresponding to the Domain Names in connection with a bona fide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Domain Names, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Domain Names, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Again, given the dispute between the Parties regarding ultimate ownership and control of Complainant, a dispute well beyond the competence and remit of this UDRP Panel, the Panel will not address the “Rights or Legitimate Interests” element. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy provides that the following circumstances, “in particular but without limitation,” are evidence of the registration and use of the Domain Names in “bad faith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Names primarily for the purpose of selling, renting, or otherwise transferring the Domain Names registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of its documented out of pocket costs directly related to the Domain Names; or (ii) that Respondent has registered the Domain Names in order to prevent the owner of the trademark or service mark from reflecting the mark in corresponding domain names, provided that Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Names primarily for the purpose of disrupting the business of a competitor; or (iv) that by using the Domain Names, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel concludes that the Complainant has not met its burden of showing that the Domain Names were registered in bad faith. The record appears to be undisputed that, at the time Respondent registered the Domain Names, he was a founder and principal of Complainant. And while Complainant had not begun to use LAZARUS as a trademark at the time the two Domain Names were registered, the Panel is aware of cases where a nascent trademark right, in precisely such a situation as a startup, could support a finding of bad faith because a party is aware of rights that will vest. To this end, Complainant argues: “Complainant was formed in 2019. At the time of formation, Complainant’s CEO and founder [i.e., Respondent], Ariel Elizarov, owned the disputed domains. At that time, the disputed domains were in an account owned by Elizarov. Elizarov and Complainant intended that Complainant should own the account with the disputed domains. To that end, they updated the “owner of record” in the account logs to identify page 6 Complainant’s primary corporate account as the owner. From 2019 to the present, Complainant has paid all fees associated with the disputed domains.” Respondent on the other hand suggests that he acted with authority, and in good faith. (He also asserts that the nascent rights doctrine does not apply, and questions the corporate arrangement underpinning the Complaint; prima facie neither of these arguments is convincing.) Under these circumstances, the Panel is unable to ascertain which version of events should influence the disposition of the Domain Names as that would require discovery and cross-examination which are not possible under the Policy. The Complaint fails. D. Reverse Domain Name Hijacking (“RDNH”) The Panel declines to rule that Complainant has engaged in RDNH in this case. As reflected above, this is matter that requires a deeper exploration of competing versions of facts around the registration of the Domain Names. 7. Decision For the foregoing reasons, the Complaint is denied. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: March 4, 2026

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

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