Westmore · UDRP decision
WIPO · Case No. D2026-0088

Reveart.org

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <reveart.org>. It found the domain confusingly similar to the Complainant’s REVE mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The Panel relied particularly on the incorporation of REVE with the term “art”, the domain’s use for competing AI image services, its registration shortly after the Complainant announced its software, and the Respondent’s failure to rebut the Complainant’s case.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-20
Panelist(s)
Braun, Lynda M.
Complainant
Reve AI, Inc.
Respondent
xiao Xiao
Counsel
Waterman Legal
Disputed domain(s)
reveart.org
Citation weightrelies on 5 authorities
Domain history UDRP Intelligence

The timeline behind reveart.org

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 reveart.org — 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
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of reveart.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a complainant may establish bad-faith targeting even when its formal trademark application and registration postdate the disputed domain. The Panel relied on earlier use, a public software announcement, close temporal proximity, the domain’s industry-specific composition, and directly competing use. It also shows the significance of adding a term that reinforces, rather than distances, the domain’s association with the complainant’s business.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-20
Panel
Braun, Lynda M.
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Reve AI, Inc. v. xiao Xiao Case No. D2026-0088 1. The Parties The Complainant is Reve AI, Inc., United States of America (“United States”), represented by Waterman Legal, United States. The Respondent is xiao Xiao, United States. 2. The Domain Name and Registrar The disputed domain name <reveart.org> (the “Disputed Domain Name”) is registered with Spaceship, Inc. (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 Disputed Domain Name. On January 9, 2026, 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. 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 January 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 5, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 6, 2026. The Center appointed Lynda M. Braun as the sole panelist in this matter on February 10, 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 4. Factual Background The Complainant, a Delaware corporation, is a software company that provides innovative and advanced artificial intelligence (“AI”) powered tools that allow users to create and edit high-quality images from text prompts and image-to -image generation. The Complainant has common law trademark rights in the REVE trademark that date back to February 5, 2025. The Complainant also owns the following registered trademark through the United States Patent and Trademark Office (“USPTO”): REVE, United States Registration No. 7994787, filed on March 27, 2025, and registered on October 21, 2025, in International Class 42. The Complainant also owns several pending trademark applications in many jurisdictions worldwide, including, but not limited to, the United States, Mexico, Australia, New Zealand, Brazil, the European Union, Canada, India, and the United Kingdom. The foregoing registered and pending trademarks will hereinafter be referred to as the “REVE Mark”. The Complainant owns the domain names <reve.com> and <reve.art>, which resolve to its official website at “www.reve.com” and “www.reve.art”, where it promotes and offers its software and AI tools and services. The Disputed Domain Name was registered on March 25, 2025, and resolves to a website that advertises AI software for managing and editing images, which is nearly identical to, and competes with, the Complainant’s website. 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. Notably, the Complainant contends that: - the Disputed Domain Name is confusingly similar to the Complainant’s REVE Mark because the Disputed Domain Name contains the REVE Mark in its entirety, followed by the term “art”, and then followed by the generic Top-Level Domain (“gTLD”) “.org”, which does not prevent a finding of confusing similarity; - the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because, among other things, the Complainant has not authorized the Respondent to register a domain name containing the REVE Mark, and the Respondent has never been commonly known by the Disputed Domain Name; and - the Disputed Domain Name was registered and is used in bad faith because, among other things, the Respondent used the Disputed Domain Name to impersonate the Complainant or to suggest sponsorship or endorsement by the Complainant for the purpose of deceiving unsuspecting consumers. The Complainant seeks the transfer of the Disputed Domain Name in accordance with paragraph 4(i) of the Policy. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings In order for the Complainant to prevail and have the Disputed Domain Name transferred to the Complainant, the Complainant must prove the following (Policy, paragraph 4(a)): (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 was registered and is being used in bad faith. A. Identical or Confusingly Similar Paragraph 4(a)(i) of the Policy requires a two-fold inquiry: a threshold investigation into whether a complainant has rights in a trademark, followed by an assessment of whether the disputed domain name is identical or confusingly similar to that trademark. The Panel concludes that in the present case, the Disputed Domain Name is confusingly similar to the REVE Mark as explained below. 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. See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. It is uncontroverted that the Complainant has established rights in the REVE Mark based on its use since February 5, 2025, as well as its registered trademark for the REVE Mark through the USPTO. The consensus view of panels is that “[w]here the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case”. See WIPO Overview 3.1, section 1.2.1. Therefore, the Panel finds that the Complainant has rights in the REVE Mark. The Disputed Domain Name consists of the REVE Mark in its entirety followed by the term “ art”, and then followed by the gTLD “. org”. The test for confusing similarity involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. Here, the REVE Mark is recognizable within the Disputed Domain Name. As stated in section 1.8 of WIPO Overview 3.1, “where the relevant trademark is recognizable within the disputed domain name, the addition of another term (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element”. Thus, the addition of the term “art” to the Complainant’s REVE Mark in the Disputed Domain Name does not prevent a finding of confusing similarity. See e.g., Allianz Global Investors of America, L.P. and Pacific Investment Management Company (PIMCO) v. Bingo-Bongo, WIPO Case No. D2011-0795; and Hoffmann-La Roche Inc. v. Wei-Chun Hsia, WIPO Case No. D2008-0923. Finally, the addition of a gTLD such as “. org” in a domain name is a technical requirement. As such, it is well established that a gTLD may typically be disregarded when assessing whether a disputed domain name is identical or confusingly similar to a trademark. See Proactiva Medio Ambiente, S.A. v. Proactiva, WIPO Case No. D2012-0182 and WIPO Overview 3.1, section 1.11.1. Thus, the Panel finds that the Disputed Domain Name is confusingly similar to the Complainant’s REVE Mark. Based on the available record, the Panel finds that 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. While the overall burden of proof in UDRP proceedings is page 4 on the complainant, panels have recognized that proving that 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 3.1, section 2.1. In this case, given the facts as set out above, the Panel finds that the Complainant has made out a prima facie case. The Respondent has not submitted any arguments or evidence to rebut the Complainant’s prima facie case. Furthermore, and based on the available record, the Complainant has not authorized, licensed, or otherwise permitted the Respondent to use its REVE Mark. Nor does the Complainant have any type of business relationship with the Respondent. There is also no evidence that the Respondent is commonly known by the Disputed Domain Name or by any similar name, nor any evidence that the Respondent was using or making demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services. See Policy, paragraph 4(c). The Respondent created the Disputed Domain Name by combining the Complainant’s REVE Mark with the term “art”, intending to target the Complainant’s platforms and services. As the Respondent’s resolving website purportedly offers competing services, such use does not constitute legitimate or noncommercial fair use under the Policy. Rather, the Panel finds that the Respondent was likely using the Disputed Domain Name for commercial gain. In sum, the Panel finds that the Complainant has established an unrebutted prima facie case that the Respondent lacks rights or legitimate interests in the Disputed Domain Name. Based on the available record, the Panel finds that the second element of the Policy has been established C. Registered and Used in Bad Faith 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. The Panel finds that based on the record, the Complainant has demonstrated the existence of the Respondent’s bad faith registration and use of the Disputed Domain Name pursuant to paragraph 4(a)(iii) of the Policy. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. Having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. The Disputed Domain Name incorporated the REVE Mark in its entirety, resolving to the Respondent’s website that offers competing services. Therefore, it strains credulity to believe that the Respondent had not known of the Complainant or its REVE Mark when registering the Disputed Domain Name. See Myer Stores Limited v. Mr. David John, WIPO Case No. D2001-0763 (“a finding of bad faith may be made where the respondent ‘knew or should have known’ of the registration and/or use of the trademark prior to registering the domain name”). In sum, the Panel finds that the Respondent had the Complainant’s REVE Mark in mind when registering the Disputed Domain Name, another indication of bad faith. Moreover, the use of a domain name to intentionally attempt to attract Internet users to a respondent’s website or online location by creating a likelihood of confusion with a complainant’s mark as to the source, sponsorship, affiliation or endorsement of the registrant’s website or online location for commercial gain page 5 demonstrates registration and use in bad faith. Here, the Respondent’s registration and use of the Disputed Domain Name indicates that such registration and use had been done for the specific purpose of trading upon and targeting the reputation, name, mark, and goodwill of the Complainant. See Madonna Ciccone, p/k/a Madonna v. Dan Parisi and “Madonna.com”, WIPO Case No. D2000-0847 (“[t]he only plausible explanation for Respondent’s actions appears to be an intentional effort to trade upon the fame of Complainant’s name and mark for commercial gain”). Panels have also often found that a respondent has acted in bad faith in registering a disputed domain name when the registration occurred shortly after significant media attention in connection with a complainant’s product launch. WIPO Overview 3.1, Section 3.8.2. The Panel finds that is precisely the case here. The Complainant announced its REVE software on February 5, 2025, garnering immediate buzz and attention. The Respondent registered the Disputed Domain Name on March 25, 2025, only a month and a half after the Complainant’s first use of its trademark on February 05, 2025. Thus, the Panel concludes, on the balance of the probabilities, that the foregoing is evidence of the Respondent’s knowledge of the Complainant’s REVE computer software and AI tools as well of its use and immediate success, which therefore reinforces the finding of registration and use of the Disputed Domain Name in bad faith. Finally, the Panel concludes that the Respondent’s registration of the Disputed Domain Name was an attempt to disrupt the Complainant’s business. The Respondent’s use of the Disputed Domain Name was also likely to confuse Internet users into incorrectly believing that the Respondent was authorized by or affiliated with the Complainant. Based on the available record, the Panel finds that the third element of the Policy has been established 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 <reveart.org> be transferred to the Complainant. /Lynda M. Braun/ Lynda M. Braun Sole Panelist Date: February 20, 2026

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

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