Westmore · UDRP decision
WIPO · Case No. D2026-0451

Upwork-accounts-rent.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <upwork-accounts-rent.com>. It found the domain confusingly similar to the Complainant’s UPWORK mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The domain resolved to a website offering rental and leasing of purportedly verified UPWORK accounts.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Panelist(s)
Takács, Zoltán
Complainant
Upwork Global LLC
Respondent
Nicholas Abraham
Disputed domain(s)
upwork-accounts-rent.com
Domain history UDRP Intelligence

The timeline behind upwork-accounts-rent.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for upwork-accounts-rent.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of upwork-accounts-rent.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining a recognizable platform mark with terms describing unauthorized account rental can satisfy all three UDRP elements. The account-rental website content was particularly important because it both undermined any claim to legitimacy and demonstrated awareness of the trademark when the domain was registered.

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
Panel
Takács, Zoltán
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Upwork Global LLC v. Nicholas Abraham Case No. D2026-0451 1. The Parties The Complainant is Upwork Global LLC, United States of America (“United States”), represented by Fidus Law Chambers, India. The Respondent is Nicholas Abraham, United Arab Emirates. 2. The Domain Name and Registrar The disputed domain name <upwork-accounts-rent.com> is registered with Name SRS AB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 4, 2026. On February 4, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 5, 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 (Unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 5, 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 February 9, 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 February 10, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 2, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 3, 2026. The Center appointed Zoltán Takács as the sole panelist in this matter on March 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 operates a freelancing online platform that connects freelancers with prospective clients from around the world. In March 2022 the Complainant was named to Time’s list of TIME 100 Most Influential Companies of 2022. The Complainant is, among others, owner of the United States Trademark Registration No. 5237481 for the word mark UPWORK registered on July 4, 2017, and the International Trademark Registration No. 1383791 for the word mark UPWORK registered on October 17, 2017. The Complainant is also owner of the domain name <upwork.com>, which was registered on January 30, 2002, and resolves to its principal website. The disputed domain name was registered on June 16, 2025, and has been used to resolve to a website that offers services for the rental and leasing of purportedly verified UPWORK accounts registered on the Complainant’s platform. 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 which incorporates its mark with the addition of the descriptive terms “accounts” and “rent” is confusingly similar to the mark; - the Respondent has no rights or legitimate interests in respect of the disputed domain name since it is unable to rely on any of the circumstances set out in paragraphs 4(c)(i), (ii), or (iii) of the Policy; - the Respondent’s registration of the disputed domain name which incorporates the Complainant’s mark and the use of the disputed domain name for hosting a website that offers mostly the Complainant’s services is indication of the Respondent’s awareness of the Complainant’s mark; - the Respondent’s use of the disputed domain name is designed to circumvent the Complainant’s services and accounts by facilitating unauthorized access to the Complainant’s platform potentially leading to fraud and identity theft, as well as to violation of the Complainant’s Terms of Use which prohibit the sale, rental, leasing, sharing or transfer of user accounts. The Complainant requests that the disputed domain name be transferred from the Respondent to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings A complainant must evidence each of the three elements required by paragraph 4(a) of the Policy in order to succeed on the complaint, namely that: (i) the 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 domain name; and (iii) the domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar 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. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced and recognizable within the disputed domain name. Although the addition of other terms, here “accounts” and “rent” may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.8. 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. Although the overall burden of proof in UDRP proceedings is 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. Having reviewed the available record, the Panel finds the Complainant has established a prima facie 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 forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. According to the documentary evidence submitted by the Complainant the Respondent has been using the disputed domain name to host a website that offers services for the rental and leasing of purportedly verified UPWORK accounts registered on the Complainant’s platform. page 4 The Panel notes that it is evident that the Complainant has not authorized, licensed or allowed the Respondent to use its mark in the disputed domain name or in any other way that would confer validity or legitimacy upon such use. Despite the lack of authorization or relationship, the Respondent falsely refers to the UPWORK accounts advertised on its website as “verified” and “safe”. Such use clearly demonstrates the Respondent’s intention to trade off the Complainant’s reputation. The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name, and 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. Having reviewed the record, the Panel finds that the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. In the present case, the Panel notes that the Complainant’s mark predates the registration of the disputed domain name which incorporates the mark. This fact, coupled with the use of the disputed domain name to host a website that offers predominantly the Complainant’s services is evidence of the Respondent’s awareness of the Complainant’s mark at registration within the meaning of paragraph 4(b)(iv) of the Policy. Therefore, the disputed domain name was registered and is being used in bad faith. The Panel finds that the Complainant has established the third element of the Policy. 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 <upwork-accounts-rent.com> be transferred to the Complainant. /Zoltán Takács/ Zoltán Takács Sole Panelist Date: March 23 , 2026

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

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