Westmore · UDRP decision
WIPO · Case No. D2026-0634

Genesis-biosciences.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <genesis-biosciences.com>. It found the domain confusingly similar to the registered GENESIS BIOSCIENCES mark because it incorporated the mark in its entirety, with only a hyphen added. The Complainant established a prima facie case that the Respondent lacked rights or legitimate interests, which the Respondent did not rebut with relevant evidence. Bad faith was found from the substantially later registration, the domain's exact incorporation of the distinctive mark, the closely mirroring registrant organization name, the under-construction page, and the absence of a legitimate explanation for registration or non-use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-20
Panelist(s)
Hamilton, William F.
Complainant
CKM Holdings Inc. Genesis Biosciences LLC
Respondent
Mike Clark, Genesis BioScience Research LLC,
Disputed domain(s)
genesis-biosciences.com
Domain history UDRP Intelligence

The timeline behind genesis-biosciences.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 genesis-biosciences.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
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of genesis-biosciences.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain reproducing a two-word mark with only a hyphen can satisfy confusing similarity and how passive holding may support bad faith when combined with substantially earlier trademark rights, an unexplained registration, a closely mirroring registrant organization name, and no evidence of legitimate intended use.

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
2026-04-20
Panel
Hamilton, William F.
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Genesis Biosciences LLC and CKM Holdings Inc. v. Mike Clark, Genesis BioScience Research LLC Case No. D2026-0634 1. The Parties The Complainants are Genesis Biosciences LLC, and CKM Holdings Inc., United States of America (“United States”) represented by Michelmores LLP, United Kingdom. The Respondent is Mike Clark, Genesis BioScience Research LLC, United States. 2. The Domain Name and Registrar The disputed domain name <genesis-biosciences.com> is 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 February 13, 2026. On February 16, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On February 17, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which dif f ered f rom the named Respondent (Redacted f or Privacy, Genesis BioScience Research LLC) and contact information in the Complaint. The Center sent an email communication to the Complainants on February 17, 2026, providing the registrant and contact inf ormation disclosed by the Registrar, and inviting the Complainants to submit an amendment to the Complaint. The Complainants f iled an amended Complaint on February 18, 2026. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal 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 f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on March 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 1, 2026. The Respondent sent an email communication to the Center on April 9, 2026. The Center commenced the panel appointment process the same day. page 2 The Center appointed William F. Hamilton as the sole panelist in this matter on April 10, 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 Complainants are a global biosciences company headquartered in Lawrenceville, Georgia, United States, specializing in biotechnology research, microbial and antimicrobial product development, and environmentally responsible manuf acturing. The parent and trademark holding company of the Complainant Genesis Biosciences LLC, CKM Holdings Inc., holds the following registered trademarks f or GENESIS BIOSCIENCES: • United Kingdom Registration No. UK00908269698, filed April 30, 2009, registered February 22, 2010; • European Union Registration No. 008269698, filed April 30, 2009, registered February 22, 2010; and • United States Registration No. 4140613, filed September 22, 2009, registered May 15, 2012. The marks cover goods and services in International Classes 1, 5, 40, and 42, including biological preparations, microbial products, waste treatment services, and scientific research services. CKM Holdings Inc. has licensed use of the marks to Genesis Biosciences LLC, which has used them continuously in commerce since registration. The Complainants will hereinafter be referred to as the “Complainant”. The Complainant operates websites at the domain names <genesisbiosciences.com/uk/>, <genesisbiosciences.us/>, and <genesisbiosciences.it/>, registered in 2009, 2010, and 2017 respectively. The disputed domain name <genesis-biosciences.com> was registered on January 10, 2026, by the Respondent, whose registrant organization was identified by the Registrar as Genesis BioScience Research LLC. The disputed domain name resolves to an under-construction page displaying only the domain name, with no indication of intended use or a completion timeline. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the three elements required under the Policy f or a transf er of the disputed domain name. The Complainant contends that it holds registered trademark rights in GENESIS BIOSCIENCES in the United Kingdom, the European Union, and the United States, and that the disputed domain name is identical or confusingly similar to those marks. The Complainant notes that the disputed domain name incorporates the mark in its entirety, dif f ering only by the addition of a hyphen between the two words, which the Complainant submits is not distinctive and is likely to be disregarded by consumers. The Complainant further notes that the “.com” generic Top-Level Domain (“gTLD”) is disregarded for purposes of this comparison. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant asserts that it has not authorized or licensed the Respondent to use its marks in any manner, that the Respondent is not commonly known by the disputed domain name, and that the Respondent has made no bona fide offering of goods or services in connection with the disputed domain name. page 3 The Complainant contends that the disputed domain name was registered and is being used in bad f aith. The Complainant asserts that given the established reputation of the GENESIS BIOSCIENCES mark, the Respondent must have been aware of the mark at the time of registration. The Complainant f urther asserts that the disputed domain name resolves to an under-construction page, which the Complainant submits constitutes passive holding and is consistent with an intent to capitalize on the goodwill associated with the Complainant's marks. B. Respondent The Respondent did not submit a formal Response to the Complaint. On April 9, 2026, the Respondent sent an inf ormal email communication to the Center. The Respondent stated that the disputed domain name had been used f or email purposes only and that the Respondent no longer used it. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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, Third Edition (“WIPO Overview 3.1”), section 1.7. The disputed domain name <genesis-biosciences.com> incorporates the Complainant's mark in its entirety. The only difference between the mark and the second-level domain is the addition of a hyphen between the words “genesis” and “biosciences”. Panels have consistently found that the addition of a hyphen does not prevent a f inding of conf using similarity. The gTLD “.com” is disregarded as a standard registration requirement. WIPO Overview 3.1, section 1.11.1. The Panel f inds that the disputed domain name is identical or confusingly similar to a trademark in which the Complainant has rights. The f irst 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 dif f icult 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 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. The disputed domain name resolves to an under-construction page, which does not page 4 constitute a legitimate noncommercial or f air use in the circumstances of this case, as discussed f urther below. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. The Complainant's GENESIS BIOSCIENCES mark has been in continuous use since 2009 and is registered in at least three jurisdictions. The Respondent registered the disputed domain name in January 2026, well af ter the Complainant's marks were established. Given the distinctive nature of the GENESIS BIOSCIENCES mark and the Respondent's choice to register a domain name incorporating that mark in its entirety with the sole addition of a hyphen, the Panel finds it implausible that the Respondent was unaware of the Complainant's mark at the time of registration. This inf erence is reinf orced by the f act that the Respondent's registrant organization, Genesis BioScience Research LLC, closely mirrors the Complainant's mark, suggesting f amiliarity with it. Panels have f ound that the non-use of a domain name, including a blank or “coming soon” page, would not by itself prevent a finding of bad faith under the doctrine of passive holding. In considering the totality of the circumstances, panels have found that the registration and non-use of a domain name can still constitute bad f aith under the Policy. WIPO Overview 3.1, section 3.3. The disputed domain name has resolved to an under-construction page since at least January 28, 2026, with no indication of intended use. The Respondent's informal communication to the Center offered no legitimate explanation for the registration and conf irmed that the Respondent has no continuing interest in the disputed domain name. The Panel f inds that the third element of the Policy has been established. 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 <genesis-biosciences.com> be transf erred to the Complainant. /William F. Hamilton/ William F. Hamilton Sole Panelist Date: April 20, 2026

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

Beyond the decision

What Westmore sees around genesis-biosciences.com

The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

Connected to Westmore UDRP Intelligence
115,979 decisions · citations · panelists · parties · domain history
Eleanor · UDRP intelligence
Ask Eleanor about this decision
Ask Eleanor about this decision

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.

Unlocking Eleanor for this case uses 1 of your complimentary Intelligence unlocks· 3 remaining

Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.

Westmore Professional · Unlock the intelligence

The decision is only the beginning.

You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.

Citation Intelligence
How this decision is cited and treated across the corpus.
Panelist Intelligence
The panel's tendencies, outcomes and reasoning patterns.
Domain History
Ownership chronology — creation vs. respondent acquisition.
Opposing-Party Research
Complainant, counsel and portfolio context.
Independent Case Review
Eleanor challenges your filing before the other side does.
Professional Matters
Open, research and manage matters end to end.
$395/month
Unlock Westmore Professional Annual & firm seats available · cancel anytime
Take the next step
Westmore UDRP · find the right service

Westmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

Essential cookies only. Nothing is sold or shared.