Westmore · UDRP DecisionUnitycouncils.org
The Panel ordered transfer of <unitycouncils.org>. It found that The Unity Council had common-law rights in UNITY COUNCIL, that the Domain Name remained confusingly similar despite the addition of the letter “s,” and that Respondent lacked rights or legitimate interests. The undisputed evidence showed that the Domain Name had been used for emails impersonating Complainant and supplying false bank-wire information, which the Panel found to be a fraudulent phishing scheme establishing bad-faith registration and use under Policy paragraph 4(b)(iv).
The timeline behind unitycouncils.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 unitycouncils.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that an unregistered nonprofit name can satisfy the first UDRP element where the record demonstrates source-identifying use. It also shows that a domain need not host an active website to support transfer: use through email for impersonation, false bank-wire instructions, and payment diversion can be decisive under the rights-or-legitimate-interests and bad-faith elements.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION The Unity Council v. Aneres Recruit Case No. D2026-0637 1. The Parties Complainant is The Unity Council, United States of America, internally represented. Respondent is Aneres Recruit, United States of America. 2. The Domain Name and Registrar The disputed domain nam e <unitycouncils.org> (the “Domain Name”) is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was f iled with the WIPO Arbitration and Mediation Center (the “Center”) on February 12, 2026. On February 16, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the Domain Name. On February 16, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact inf ormation f or the Domain Name which differed f rom the named Respondent (Registration Private, Domains by Proxy LLC) and contact inf ormation in the Complaint. The Center sent an email to Complainant on February 25, 2026, providing the registrant and contact inf ormation disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant f iled an amendment to the Complaint on February 25, 2026. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm 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 February 26, 2026. In accordance with the Rules, paragraph 5, the due date f or Response was March 18, 2026. Respondent did not submit any response. Accordingly, the Center notif ied Respondent’s def ault on March 20, 2026. The Center appointed Robert A. Badgley as the sole panelist in this matter on March 31, 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. page 2 4. Factual Background Complainant describes itself as “a nonprofit social equity development corporation organized under the laws of the State of California and recognized as tax-exempt under Section 501(c)(3) of the Internal Revenue Code.” Complainant asserts: “The Complainant has continuously and exclusively used the UNITY COUNCIL name in commerce since at least 1967 in connection with nonprof it, charitable, educational, housing, workf orce development, and community services. Through more than sixty years of continuous public use, the UNITY COUNCIL mark has acquired distinctiveness and secondary meaning identif ying the Complainant as the source of these services.” Complainant does not hold a registered trademark for UNITY COUNCIL. Complainant’s main website is at the domain name <unitycouncil.org>. At that site Complainant prominently uses the mark UNITY COUNCIL. The Domain Name was registered on December 3, 2025. The Domain Name does not resolve to a website. According to Complainant, the Domain Name “has been used to impersonate the Complainant in email communications with vendors and third parties in an attempt to redirect payments.” Annexed to the Complaint are emails sent from an email address using the Domain Name to a third-p arty business partner of Complainant, in which email the sender claims, on behalf of Complainant, that Complainant’s bank wire information has been changed and needs to be updated. Using the same bogus email address, the sender then provided new bank information to the third party, and the latter made at least one payment in accordance with the new bank inf ormation. Subsequently, Complainant asked the third- party business partner about funds that were owing from the partner to Complainant, at which point it was discovered that someone had used a fake email address to impersonate Complainant and abscond with the misdirected f unds. 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 Name. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisf y with respect to the Domain Name: (i) the Domain Name is identical or conf usingly similar to a trademark or service mark in which Complainant has rights; and (ii) 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 f aith. page 3 A. Identical or Confusingly Similar The Panel f inds that Complainant has common law rights in the unregistered mark UNITY COUNCIL through use demonstrated in the record. There is evidence of record that Complainant has been using UNITY COUNCIL on its website as a source identif ier f or its goods and services. The Panel notes f urther that Respondent’s registration of the Domain Name and Respondent’s use of that Domain Name to impersonate Complainant conf irms that Respondent himself recognizes that UNITY COUNCIL serves as a source identifier for Complainant and its services. As such, Respondent is hardly in a position to deny that UNITY COUNCIL is a recognized source identif ier f or Complainant and its services. The Panel also f inds that the Domain Name is conf usingly similar to that mark. The Domain Name is comprised entirely of the UNITY COUNCIL mark plus the letter “s”. In the Panel’s view, the mark remains clearly recognizable within the Domain Name notwithstanding this additional letter. Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests Pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Name, among other circumstances, by showing any of the f ollowing elements: (i) bef ore any notice to you [Respondent] of the dispute, your use of , or demonstrable preparations to use, the Domain Name or a name corresponding to the Domain Name in connection with a bona f ide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Domain Name, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or f air use of the Domain Name, without intent f or commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. The Panel concludes that Respondent lacks rights or legitimate interests in respect of the Domain Name. Respondent has not come forward to articulate any bona fide basis f or registering the Domain Name, and has not disputed the allegations and evidence presented by Complainant. The undisputed record here indicates that Respondent has used the Domain Name in connection with a phishing scam designed to extract payments f rom unsuspecting business partners of Complainant who are given f alse bank wire inf ormation. Complainant has established Policy paragraph 4(a)(ii). 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 Name in “bad f aith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Name primarily f or the purpose of selling, renting, or otherwise transf erring the Domain Name registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, f or valuable consideration in excess of its documented out of pocket costs directly related to the Domain Name; or (ii) that Respondent has registered the Domain Name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Name primarily for the purpose of disrupting the business of a competitor; or page 4 (iv) that by using the Domain Name, Respondent has intentionally attempted to attract, f or commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of conf usion with Complainant’s mark as to the source, sponsorship, af f iliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel concludes, on the record provided here, that Respondent has registered and used the Domain Name in bad f aith. The Panel incorporates its discussion above in the “Rights or Legitimate Interests” section. The undisputed record supports the conclusion that Respondent targeted Complainant’s mark f or purposes of perpetrating a fraudulent phishing scam, in clear violation of the above-quoted Policy paragraph 4(b )(iv). Complainant has established Policy paragraph 4(a)(iii). 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 Domain Name <unitycouncils.org> be transf erred to Complainant. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: April 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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