Fullercompliance.com

The timeline behind fullercompliance.com

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

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 Fuller Compliance, Inc. v. Anastasiia Kytsiuk Case No. D2026-1507 1. The Parties The Complainant is Fuller Compliance, Inc., United States of America (“United States”), internally represented. The Respondent is Anastasiia Kytsiuk, Ukraine. 2. The Domain Name and Registrar The disputed domain name <fullercompliance.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 9, 2026. On April 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 10, 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 (Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 13, 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 14, 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 April 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 8, 2026. The Center appointed Jeremy Speres as the sole panelist in this matter on May 22, 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. Further Procedural Considerations Under paragraph 10 of the Rules, the Panel is required to ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case, and also that the administrative proceeding takes place with due expedition. Since the Respondent has provided an address purportedly located in Ukraine, which is subject to an international conflict at the date of this Decision that may impact case notification, it is appropriate for the Panel to consider, in accordance with its discretion under paragraph 10 of the Rules, whether the proceeding should continue. Having considered all the circumstances of the case, the Panel is of the view that it should continue. The Panel has reached this conclusion in part because the Panel recognizes that the Center employed all reasonably available means calculated to achieve actual notice to the Respondent. In particular, the Center successfully sent the Notification of the Complaint to the email address disclosed for the Respondent by the Registrar in its Registrar Verification Response. There is no indication that the email notification has not been successfully delivered. Furthermore, as discussed below, the Panel notes that the disputed domain name was likely acquired by the Respondent circa April 2026, during the international conflict, suggesting that the Respondent is able to access the Internet, maintain control of the disputed domain name, and should have received at least electronic notice of this proceeding. Finally, for the reasons which are set out later in this Decision, the Panel has no serious doubt that the Respondent acquired and has used the disputed domain name in bad faith. The Panel therefore concludes that the Respondent has been given a fair opportunity to present her case, and so that the administrative proceeding takes place with due expedition the Panel will proceed to a Decision accordingly. 5. Factual Background The uncontested facts are as follows. The Complainant, incorporated in 2006, provides business consulting services, primarily to manufacturers of pharmaceuticals, medical devices and biologic products regulated by the United States Food and Drug Administration. The Complainant does not own any registered trademarks but claims common law rights based on its longstanding use of its FULLER COMPLIANCE mark since at least 2006, when the entity was formed as a Limited Liability Company (“LLC”). The disputed domain name was registered on January 21, 2004, and presently redirects to a Registrar parking page containing articles relating to compliance training services, as well as related search pages containing third party pay-per-click (“PPC”) advertisements. The Complainant’s evidence establishes that it previously used the disputed domain name for its website from at least as early as 2008 until at least 2025. 6. 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. The Complainant contends that the disputed domain name was owned and used by the Complainant for roughly 20 years prior to its acquisition by the Respondent. Although this is not stated directly in the Complaint, the Complainant appears to suggest that the disputed domain name was inadvertently allowed to lapse by the Complainant or its Internet service provider. page 3 The Complainant contends that the disputed domain name was acquired and has been used by the Respondent in bad faith inter alia for the primary purpose of selling the disputed domain name to the Complainant for valuable consideration in excess of the Respondent’s out-of-pocket costs, or for disrupting the Complainant’s business. B. Respondent The Respondent did not reply to the Complainant’s contentions. 7. Discussion and Findings 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 claims common law trademark rights, but the only evidence supplied in this respect in the Complaint is a) company registration and conversion records; b) Internet Archive screenshots of the Complainant’s website hosted at the disputed domain name going back to 2008; c) payments to the Complainant’s Internet service provider for 2025 and 2026; and d) a screenshot of the Complainant’s LinkedIn page showing 390 followers. In the Panel’s view, this is insufficient, on its own, to establish common law rights. WIPO Overview 3.1, section 1.3. Nevertheless, as discussed below in relation to bad faith, it is likely that the Respondent’s intentions were to take advantage of confusion with the Complainant’s mark for the Respondent’s commercial gain. In the interests of justice, and in accordance with its duty to conduct these proceedings with due expedition as set out in paragraph 10(c) of the Rules, the Panel has independently 1 conducted brief Internet searches for the Complainant’s claimed FULLER COMPLIANCE mark. The results prominently feature the Complainant’s business under this mark. The Panel also notes that the Complainant has been in operation since 2006 under this mark, and the Complainant’s evidence establishes that it used the disputed domain name for its consulting services website from at least as early as 2008 until at least 2025. Coupled with the Complainant’s evidence referenced above, these findings support the conclusion that the mark has acquired distinctiveness through use. As discussed below, it is likely that the Respondent sought to target the Complainant’s mark. The fact that a respondent is shown to have been targeting a complainant’s mark may also support the complainant’s assertion and evidence that its mark has achieved significance as a source identifier. WIPO Overview 3.1, section 1.3. The Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.1, section 1.3. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. The Panel finds the first element of the Policy has been established. 1 In accordance with its powers articulated inter alia in paragraphs 10 and 12 of the Rules, the Panel is entitled to conduct limited independent research into matters of public record. WIPO Overview 3.1, section 4.8. page 4 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 disputed domain name is identical to the Complainant’s mark and has been used for commercial advertising relating to the Complainant’s industry. 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. Use of a domain name to host PPC links does not represent a bona fide offering where such links compete with or capitalize on the reputation and goodwill of the complainant’s mark, as in this case. WIPO Overview 3.1, section 2.9. The Panel finds 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. For the following reasons, the Panel finds that it is more likely than not that the Respondent registered and has used the disputed domain name to take advantage of a likelihood of confusion with the Complainant’s mark for the Respondent’s commercial gain, falling squarely within paragraph 4(b)(iv) of the Policy. The Panel’s limited independent viewing of historical WhoIs, hosting, nameserver and Internet Archive records for the disputed domain name point to the disputed domain name having been registered and used by the Complainant since at least 2008, until the disputed domain name lapsed circa April 2026 and was then transferred away from the Complainant’s prior registrar to the current Registrar. This corroborates the Complainant’s claims to have previously owned and used the disputed domain name, and its suggestion that the disputed domain name was inadvertently allowed to lapse. The disputed domain name has been used to host PPC links which advertise services apparently competitive with those of the Complainant, which is an indicator of targeting for commercial gain. See Dr. Martens International Trading GmbH, Dr. Maertens Mark eting GmbH v. Private Whois Service, WIPO Case No. D2011-1753. Although the advertisements may be served programmatically by a third party, the Respondent cannot disclaim responsibility for them. WIPO Overview 3.1, section 3.5. The Panel recognises that the composition of the disputed domain name may be read as a descriptive phrase in the compliance industry, with “fuller compliance” potentially suggesting enhanced compliance. Given that the disputed domain name has been used to advertise services in the compliance space, potentially consistent with the meaning of the disputed domain name’s composition, the Respondent may have rights or legitimate interests in the disputed domain name. WIPO Overview 3.1, section 2.9. However, page 5 the Panel considers that it is more likely than not that the disputed domain name was chosen less for its semantic value and more for its brand value associated with the Complainant and the domain name’s longstanding use by the Complainant. “Fuller compliance” may have a descriptive meaning relevant to compliance services as addressed above, however, it is a somewhat awkward and unnatural phrase in that context. The word “fuller”, as opposed to “full”, implies something less than total or absolute compliance, which is an odd way to market compliance services, where presumably anything less than total compliance would be problematic. There is also no evidence before the Panel suggesting that it is commonplace to use such a phrase in this way in the compliance sector, and the Panel’s own limited Internet searches suggest that it is not widely used as such. Given that creation date of the disputed domain name has not changed since the Complainant registered the disputed domain name, it can be assumed that the disputed domain name was acquired through an expired- domain name process, such as an auction or similar acquisition mechanism, and that it didn’t fall back into the pool of available domain names. The Respondent then can be taken to have been aware that the disputed domain name was previously owned by someone else. Coupled with the unusual composition of the disputed domain name addressed above and the fact that the FULLER COMPLIANCE mark is prominently associated with the Complainant online, it is likely that the Respondent was or should have been alerted to the fact that somebody else may have trademark rights that might conflict with the Respondent’s acquisition and use of the disputed domain name. This points to bad faith. WIPO Overview 3.1, section 3.2.2. In the absence of any explanation from the Respondent, and given that the disputed domain name is prominently associated with the Complainant online, the Panel therefore considers it more likely than not that the disputed domain name was not chosen because of its semantic value, but rather because of its longstanding association with the Complainant’s mark, which points to targeting. The Panel draws an adverse inference from the Respondent’s failure to take part in the present proceedings where an explanation is certainly called for. WIPO Overview 3.1, section 4.3. The Panel finds that the Complainant has established the third element of the Policy. 8. 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 <fullercompliance.com> be transferred to the Complainant. /Jeremy Speres/ Jeremy Speres Sole Panelist Date: May 26, 2026

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