Westmore · UDRP DecisionReve-image.com
The Panel ordered transfer of <reve-image.com> based on the Respondent’s express consent to transfer. Applying section 4.10 of the WIPO Overview 3.1, the Panel issued a simplified decision and did not determine whether the three substantive elements of paragraph 4(a) of the Policy were satisfied.
The timeline behind reve-image.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 reve-image.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This case illustrates that an express, on-record consent to transfer can produce a transfer order without adjudication of confusing similarity, rights or legitimate interests, or bad faith. It is particularly notable because the Respondent reserved all admissions, the identified registered trademarks postdated the Domain Name, and the parties did not complete a standard settlement process.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Reve AI, Inc. v. qiang ma Case No. D2026-1493 1. The Parties 1.1 The Complainant is Reve AI, Inc., United States of America, represented by Waterman Legal, United States of America (“United States” or “US”). 1.2 The Respondent is qiang ma, China. 2. The Domain Name and Registrar 2.1 The disputed domain name <reve-image.com> (the “Domain Name”) is registered with CloudFlare, Inc. (the “Registrar”). 3. Procedural History 3.1 The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 8, 2026. At that time, publicly available WhoIs details did not identify the underlying registrant of the Domain Name. 3.2 On April 9, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On April 10, 2026, the Registrar transmitted by email to the Center its verification response disclosing underlying registrant and contact information for the Domain Name. The Center sent an email to the Complainant on April 10, 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 April 12, 2026. 3.3 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”). 3.4 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on April 13, 2026. In accordance with the Rules, paragraph 5, the due date for the Response was May 3, 2026. On May 3, 2026, a person identifying themselves as “Mhhya” requested an automatic four calendar day extension to submit a response in accordance with page 2 paragraph 5(b) of the Rules, and time for the submission of a response was, therefore, extended to May 7, 2026. 3.5 By a further email to the Center dated May 3, 2026, “Mhhya” stated that they had ceased using the Domain Name and stated as follows: “The website was originally created as a personal demo project while I was learning Next.js. It was not intended to create confusion with the Complainant. Since it was only a demo project, the core functions required for actual use, including login, usage/generation workflow, payment, and other related functions, were not set up for practical operation. In order to avoid any possible confusion and bring this matter to a prompt resolution, I am willing to discuss an orderly transfer of the disputed domain name to the Complainant as part of an amicable settlement. My understanding is that this resolution would be limited to the disputed domain name, with no monetary payment requested from me, each party bearing its own costs, and the proceeding being suspended and terminated after completion of the agreed settlement process.” That email also stated that this individual would be willing to jointly request a suspension of the proceedings for settlement purposes. 3.6 In an email dated May 4, 2026, the Center requested that “Mhhya” identify themselves and explain their relationship with the Respondent. 3.7 In an email dated May 4, 2026, the Complainant stated that it wished the proceedings to continue and did not wish them to be stayed pending settlement. 3.8 On May 6, 2026, the Center received a Response in these proceedings from the same email address as that used by “Mhhya”. The email accompanying that Response was signed using the same name as that disclosed by the Registrar as the underlying registrant of the Domain Name. 3.9 The Center appointed Matthew S. Harris as the sole panelist in this matter on May 20, 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 4.1 The Complainant is a company based in the United States that offers AI-powered image generation and editing tools. The Complainant launched its services on February 5, 2025, and it operates websites promoting its services from the domain names <reve.com> and <reve.art>. 4.2 The Complainant is the owner of various registered trade marks and trade mark applications in a number of jurisdictions that incorporate or comprise the term “reve”. These include the following: (i) United States registered trade mark No. 7994787 for REVE as a standard character mark in class 42 with an application date of March 27, 2025, and with a registration date of October 21, 2025; (ii) International trade mark No. 1883716 for REVE as a word mark in classes 9 and 42. That mark has a registration date of September 19, 2025, and although still pending in a number of designated territories, it proceeded to grant in the United Kingdom and the European Union prior to the filing of the Complaint in these UDRP proceedings. page 3 4.3 The Domain Name was registered on March 22, 2025. At the time the Complaint was filed, it resolved to a website which prominently displayed the text “Reve Image AI Generator”, beneath which appeared the text “Create unique, high-quality images using Reve Image Ai”. The page also described: “Reve Image AI Generator is an advanced AI image creation tool trained from the ground up to excel at prompt adherence, aesthetics, and typography. Create stunning visuals with precise control and beautiful results.” 4.4 The website claimed this service benefited from a five star rating “from 99+ happy users”. The website also offered three different pricing plans with a “Starter” option at USD 6.9, a “Standard” option at USD 19.9 and a “Premium” option at USD 39.9. 5. Parties’ Contentions A. Complainant 5.1 The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. In summary, the Complainant contends that the Domain Name is confusingly similar to its REVE trade mark, that the Respondent has no rights or legitimate interests in the Domain Name, and that the Domain Name was registered and used in bad faith. In addition to its various registered trade marks, it claims to benefit from unregistered trade mark rights in the term REVE by reason of the launch and operation of its business in February 2025 and publicity in respect of the same. In this respect it provides copies of various online press articles and social media posts. 5.2 It further contends that the term “image” in the Domain Name increases rather than dispels confusion, because it directly describes the Complainant’s field of activity. It further claims that the Respondent used the Domain Name to operate a website that impersonated or suggested association with the Complainant and thereby intentionally attempted to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant’s mark. B. Respondent 5.3 In his Response, the Respondent contends that the website operating from the Domain Name was a personal demo project created while learning Next.js and AI SaaS website development and based on a generic template. In this respect, the Respondent claims that the site did not have fully functioning login, payment, generation, or related features, contained obvious template remnants, and that the Respondent’s use of the Domain Name ceased after notice of the dispute. 5.4 The Respondent consents to the transfer of the Domain Name, but that consent is provided “without any admission of trademark infringement, bad faith registration or use, cybersquatting, unlawful conduct, liability, damages, costs, or any other wrongdoing to the Complainant”. The Respondent also asks that the Panel order the transfer of the Domain Name “without making findings on the merits beyond what is necessary to give effect to the transfer”. The Respondent observes that the Complainant’s registered trade marks postdate the registration date of the Domain Name and also refers to various claimed errors in the Complaint. However, the Respondent states that none of these issues are of a nature to prevent transfer of the Domain Name to the Complainant. 6. Discussion and Findings 6.1 The Respondent has expressly consented to transfer of the Domain Name. Panels in such circumstances sometimes order transfer without considering the substantive requirements of paragraph 4(a) of the Policy. page 4 6.2 Section 4.10 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), records as follows: “Where parties to a UDRP proceeding have not been able to settle their dispute prior to the issuance of a panel decision using the ‘standard settlement process’ described above, but where the respondent has nevertheless given its consent on the record to the transfer (or cancellation) remedy sought by the complainant, many panels will order the requested remedy solely on the basis of such consent. In such cases, the panel gives effect to an understood party agreement as to the disposition of their case (whether by virtue of deemed admission, or on a no-fault basis). In some cases, despite such respondent consent, a panel may in its discretion still find it appropriate to proceed to a substantive decision on the merits. Scenarios in which a panel may find it appropriate to do so include (i) where the panel finds a broader interest in recording a substantive decision on the merits – notably recalling UDRP paragraph 4(b)(ii) discussing a pattern of bad faith conduct, (ii) where while consenting to the requested remedy the respondent has expressly disclaimed any bad faith, (iii) where the complainant has not agreed to accept such consent and has expressed a preference for a recorded decision, (iv) where there is ambiguity as to the scope of the respondent’s consent, or (v) where the panel wishes to be certain that the complainant has shown that it possesses relevant trademark rights.” 6.3 This section of the WIPO Overview 3.1 is materially unchanged from section 4.10 of WIPO Overview 3.0, which preceded it. 6.4 Further, in Build-A-Bear Workshop, Inc. v. Daniel Keelagher, WIPO Case No. D2025-2769, this Panel referred to its previous practice of issuing a procedural order providing for the parties to indicate whether they objected to the panel issuing a simplified decision (as to the form of which see Staatliche Porzellan- Manufaktur Meissen GmbH v. Richard Gillmeister, WIPO Case No. D2013-1743, Florim Ceramiche S.p.A. v. Light Link Solutions, WIPO Case No. D2015-0667 and Statoil ASA v. gaelle etienne / WhoisGuard Protected, WIPO Case No. D2015-1812) ordering transfer of the domain name. However, in that same decision it then stated as follows: “However, given the clear and longstanding guidance now provided by Section 4.10 of the WIPO Overview 3.0, the Panel no longer considers a Procedural Order to be necessary if a complainant has been made aware of the respondent’s consent and has not actively objected to a simplified decision ordering that transfer.” 6.5 There are aspects of the Response that seek to call the contentions of the Complaint into question. However, the Respondent does not quite cross the line and positively deny bad faith. He merely makes no admissions in this respect. Further, although the Complainant did not want to pause the proceedings to allow for settlement discussions, it has not positively objected to the making of a simplified decision in its favour (cf. Norgine Limited v. Oluwaseun Adeniji, WIPO Case No. D2026-0151). Further, the publication of a simplified decision, to some extent addresses the issue of the broader interest in the reasons and underlying facts of a case being made publicly available. 6.6 In the circumstances, the Panel concludes that it is appropriate to issue a simplified decision in the Complainant’s favour. page 5 7. Decision 7.1 For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the Domain Name, <reve-image.com>, be transferred to the Complainant. /Matthew S. Harris/ Matthew S. Harris Sole Panelist Date: May 21, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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