Westmore · UDRP decision
WIPO · Case No. D2026-0174

Scrumaliance.org

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <scrumaliance.org>. It found the domain confusingly similar to the Complainant’s SCRUM ALLIANCE trademark because it omitted only one letter “l”. The domain was used for PPC links concerning management training and online Scrum certification courses. Given the near identity to the mark and the Complainant’s official domain, the related PPC links, and the absence of a response, the Panel found no rights or legitimate interests and concluded that the domain was registered and used in bad faith to mislead Internet users regarding the commercial origin of the associated website.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-10
Panelist(s)
Gulliksson, Jonas
Complainant
Scrum Alliance, Inc.
Respondent
JH Kang
Counsel
Frankfurt Kurnit Klein & Selz, PC
Disputed domain(s)
scrumaliance.org
Domain history UDRP Intelligence

The timeline behind scrumaliance.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 scrumaliance.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 scrumaliance.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision is a straightforward example of a one-letter omission typo combined with PPC links related to the trademark owner’s field. The outcome rested on the cumulative force of the earlier registered mark, the close imitation of the official domain, commercially related links, and the absence of any rebuttal or legitimate explanation from the Respondent.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-03-10
Panel
Gulliksson, Jonas
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Scrum Alliance, Inc. v. JH Kang Case No. D2026-0174 1. The Parties The Complainant is Scrum Alliance, Inc., United States of America (“U.S.”), represented by Frankfurt Kurnit Klein & Selz, PC, U.S. The Respondent is JH Kang, Republic of Korea. 2. The Domain Name and Registrar The disputed domain name <scrumaliance.org> 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 15, 2026. On January 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 16, 2026, the Registrar transmitted by email to the Center its verification response, disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Registrant information redacted by Withheld for Privacy / Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on January 19, 2026, 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 amendment to the Complaint on January 22, 2026. The Center verified that the Complaint together with the amendment to 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 28, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 17, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 20, 2026. page 2 The Center appointed Jonas Gulliksson as the sole panelist in this matter on February 24, 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 The Complainant is a U.S. company organized under the laws of Colorado. The Complainant is a non-profit global certifying body for agile and Scrum practitioners. In this regard, the Complainant’s community is comprised of approximately 1.5 million professionals with certified members in 229 countries around the world. The Complainant owns numerous trademark registrations, which include inter alia: - U.S. trademark registration No. 4,017,468 for the mark SCRUM ALLIANCE (registered on August 30, 2011). Furthermore, the Complainant claims it has been using the SCRUM ALLIANCE mark since 2003 and has according to the Complainant devoted and continues to devote substantial time, money and effort in promoting the mark. The Complainant also operates its official website at the domain name <scrumalliance.org>. The disputed domain name was registered on August 17, 2025. At the time of filing of the Complaint, the disputed domain name resolved to a website displaying pay-per-click (“PPC”) links for services in management training and scrum certification online courses. 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 contains the Complainant’s SCRUM ALLIANCE mark in its entirety, creating the same commercial impression as the mark. The disputed domain name is nearly identical to the mark. The disputed domain name misspells the word “alliance” by using “alliance” with one “l” , so consumers are likely to believe that it originates from or is affiliated with, authorized by, or endorsed by the Complainant. Accordingly, the Complainant considers the disputed domain name to be confusingly similar to its earlier trademark rights. Furthermore, the Complainant argues that its rights in the SCRUM ALLIANCE mark were firmly established before the Respondent registered the disputed domain name. Therefore, the Respondent cannot claim any rights to the disputed domain name that are superior to the Complainant’s rights in the SCRUM ALLIANCE mark. The Respondent has not made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services under the SCRUM ALLIANCE mark or the terms “scrum aliance”. The Respondent is not commonly known by the disputed domain name or the SCRUM ALLIANCE mark, nor has the Respondent acquired any legitimate trademark or service mark rights in the disputed domain name. Finally, according to the Complainant, the Respondent registered or acquired the disputed domain name in bad faith. The SCRUM ALLIANCE mark was in high-profile, global use long before the Respondent registered or acquired the disputed domain name. Each of the Complainant’s registrations for the SCRUM ALLIANCE mark predates the Respondent’s registration or acquisition of the disputed domain name. The page 3 Respondent must have had actual knowledge of the Complainant and the SCRUM ALLIANCE mark. At all times, a simple online search for “Scrum Alliance” or “Scrum Aliance” would have returned a large volume of search results solely regarding the Complainant. The Complainant believes that the Respondent has or will intentionally attempt to attract Internet users to their website by creating a likelihood of confusion with the SCRUM ALLIANCE mark. Alternatively, the Respondent registered the disputed domain name solely to resell it to the Complainant or to prevent the Complainant from using its mark in a corresponding domain name or to disrupt the Complainant’s business. The Complainant is also concerned that the Respondent intends to use the disputed domain name for phishing attacks or other malicious activities against the Complainant’s large customer and membership base. Upon information and belief, the Respondent is receiving a share of the ad revenue generated by clicks on the links displayed on the parked page of the disputed domain name. According to the Complainant, there can be little doubt that the Respondent has used and registered the disputed domain name in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy requires the Complainant to prove all three of the following elements: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar It is well established that the first element of the Policy 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 (WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1“), section 1.7). In this case, the Complainant has demonstrated rights in a trademark for the purposes of the Policy (WIPO Overview 3.1, section 1.2.1). The Panel has no difficulty finding that the disputed domain name is confusingly similar to the Complainant’s trademarks, thereby satisfying the first element of the Policy, given that the disputed domain name only differs from the SCRUM ALLIANCE mark by omitting one letter “l”. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides that the following circumstances can be situations in which the Respondent has rights or legitimate interests in a disputed domain name: (i) before any notice to the Respondent of the dispute, the Respondent’s use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or (ii) the Respondent (as an individual, business, or other organization) has been commonly known by the disputed domain name, even if the Respondent has acquired no trademark or service mark rights; (iii) or the Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. page 4 These are illustrative only and are not an exhaustive list of the situations in which a respondent can show rights or legitimate interests in a domain name. While the overall burden of proof in UDRP proceedings is on a complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the often-impossible 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. 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 the present case, the Respondent registered the disputed domain name well after the Complainant began using its trademark and also well after the Complainant registered its trademarks. The Complainant states that it has not authorized the Respondent to use its trademark. Nor is the Respondent affiliated with it. In these circumstances and given that the disputed domain name is nearly identical to the Complainant’s trademark and official domain name, is used to host PPC links related to the Complainant’s offering and that the Respondent has not replied to the Complainant’s contentions, the Panel finds that the Respondent more likely than not intended to trade off the Complainant’s trademark rights and as such its use of the disputed domain name does not constitute legitimate use. Accordingly, the Panel concludes that the Complainant has met its burden and, in the absence of any evidence to the contrary, has established the second requirement under the Policy. 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. 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. For example, previous panels have found that typos of a widely known mark may, depending on the circumstances of the case, indicate bad faith registration of a domain name. The Panel finds, in the absence of a response, that the Complainant has established that the disputed domain name was more likely than not registered and used with the intent to mislead Internet users regarding the commercial origin of the associated website. Upon review of the case record, the Panel concludes that the Respondent’s conduct in registering and using the disputed domain name amounts to bad faith under the Policy. The Panel thus has no difficulty in concluding that the third element of the Policy has been met. page 5 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 <scrumaliance.org> be transferred to the Complainant. /Jonas Gulliksson/ Jonas Gulliksson Sole Panelist Date: March 10, 2026

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

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