Circus-casino-online.com

The timeline behind circus-casino-online.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 Circus Belgium S.A. v. Melona Richards, Yumeteki Case No. D2026-1567 1. The Parties The Complainant is Circus Belgium S.A., Belgium, represented by COGITUS SRL, Belgium. The Respondent is Melona Richards, Yumeteki, United Kingdom. 2. The Domain Name and Registrar The disputed domain name <circus-casino-online.com> is registered with CNOBIN Information Technology Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 14, 2026. On April 14, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 20,2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to the Complainant on April 21, 2026, requesting the Complainant to submit an amendment to the Complaint to reflect the correct Registrar information. The Complainant filed an amended Complaint on April 21, 2026. The Center verified that the Complaint together with the amended 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 22, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 12, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 19, 2026. The Center appointed Meera Chature Sankhari as the sole panelist in this matter on May 21, 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, Circus Belgium S.A, provides casino services, games of chance and sports betting services and has claimed to own numerous trademarks consisting of the word “circus” across jurisdictions. Some of the registrations owned by the Complainant are: (a) European Union Reg. No. 018670434 for CIRCUS (word) in classes 9, 28, 41, 42 and 43, registered on November 7, 2022; (b) United Kingdom Reg. No. UK00003849721 for CIRCUS (word) in classes 9, 28, 41, 42 and 43, registered on February 24, 2023; (c) Benelux Reg. No.1486574 for CIRCUS CASINO RESORT NAMUR (word) in classes 9, 28, 41, 43 and 44, registered on October 26, 2023; (d) Benelux Reg. No. 1409859 for CIRCUS.BE (word) in classes 9, 28, 37, 41 and 42, registered on April 25, 2020; and (e) European Union Reg. No. 018544938 for (figurative) in classes 9, 28 and 41, registered on March 10, 2022. The Complainant also owns several domain name registrations containing the word “circus”, including the domain name <circus.nl> registered as on April 15, 1997. The Complainant is also owner of the domain name <circus-casino.be> (registered on January 21, 2010) which is used for a gaming platform. The Respondent registered the disputed domain name on March 7, 2024. The disputed domain name resolves to a website that appears to promote online casino and gambling services. The website contains references to the Netherlands (Kingdom of the) and Belgium, and presents content in multiple languages, including French, Dutch, and English. 5. Parties’ Contentions A. Complainant The Complainant contends that its CIRCUS marks are inherently distinctive, strongly associated with the Complainant’s activities and its licensed gambling services in the Netherlands (Kingdom of the) and Belgium. The Complainant also states that it has initiated several opposition and cancellation proceedings before the European Union Intellectual Property Office (EUIPO) and has successfully protected its rights in the CIRCUS marks, and that the EUIPO has accepted the inherent distinctiveness of the mark CIRCUS for casino games, online gambling services and betting services. The Complainant contends that it is the proprietor of the CIRCUS marks and the disputed domain name incorporates the recognizable and distinctive elements “circus” and “casino”, along with the descriptive word “online”. The alterations made by the Respondent are purely technical and non-distinctive under the UDRP and do not prevent a finding of confusing similarity. Thus, the disputed domain name is confusingly similar to the Complainant’s CIRCUS marks. The Complainant contends that the Respondent has been involved in prior UDRP proceedings concerning domain names targeting well-known online casino operators. The pervious panels found that the Respondent registered domain names incorporating third party casino brands combined with generic terms such as “online” and used them to operate deceptive websites falsely suggesting an affiliation with the relevant trademark owners for commercial gain. As per the Complainant, the disputed domain name follows the same pattern and modus operandi and is part of a broader scheme aimed at misleading Internet users and diverting traffic by creating a likelihood of confusion with the Complainant’s CIRCUS marks. The Complainant submits that the disputed domain name was registered and is being used in bad faith. The Complainant contends that the Respondent is neither affiliated with nor authorised by the Complainant to use the CIRCUS marks, nor has the Respondent been commonly known by the disputed domain name. page 3 The Complainant further contends that the Respondent has not made any bona fide offering of goods or services, nor any legitimate non-commercial or fair use of the disputed domain name. The Complainant also contends that the registered device mark of the Complainant under European Union Reg. No. 018544938, has been replicated in a promotion on the website associated with the disputed domain name. The Complainant submits that the content of the disputed domain name has made repeated references to “Circus Casino Leusden”, “Circus Netherlands Casino”, “Circus Casino Belgium”, and “Circus Gran Casino” and euro-denominated bonuses, payment methods, and purported local licensing arrangements and is expressly directed at consumers in the Netherlands (Kingdom of the) and Belgium, and more particularly at Dutch- speaking and Belgian users. The Complainant argues that the disputed domain name is structured so as to suggest that it is connected with, operated by, or endorsed by the Complainant. The Complainant contends that the disputed domain name makes repeated and highly specific textual use of the Complainant’s brand and business identifiers. Further, the Respondent has specifically targeted the Complainant’s business in the Netherlands (Kingdom of the) and had the Complainant in mind while preparing the content of the website associated with the disputed domain name. The Complainant further contends that the disputed domain name has mixed references to several jurisdictions including a Malta Gaming Authority logo and stating that the disputed domain name is licensed by Belgian Gaming Commission and expanded operations under license in other jurisdictions. The disputed domain name presented these claims in a vague, inconsistent, unverifiable manner and consists of fragments of regulatory language and references to recognized gambling authorities in order to simulate the appearance of a lawful and trustworthy operator. The Respondent is appropriating concrete elements of the Complainant’s real-world operations and market presence in order to create an impression of legitimacy and association. The Complainant contends that the disputed domain name was registered long after the Complainant had secured its rights in the CIRCUS marks. The Complainant submits that operating a casino in the Netherlands (Kingdom of the) is subject to a strict licensing regime, and that the Respondent targets the Dutch market through the disputed domain name without such authorisation and therefore operates illegally and unlawfully. The Complainant contends that the disputed domain name redirects users to third-party online gambling platforms, which operate outside any regulatory framework applicable in the Netherlands (Kingdom of the) or Belgium and are characteristic of “offshore” or “black market” gambling. The Respondent’s use of the disputed domain name to attract Internet users by impersonating the Complainant and redirecting them to such unregulated third-party platforms constitutes an illegitimate commercial use aimed at diverting users for financial gain, in a manner that is both misleading and unlawful. Thus, the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant also submits that it is inconceivable that the Respondent was unaware of the Complainant and its rights at the time of registration of the disputed domain name. Given the contents of the disputed domain name it is evident that it is a carefully constructed page designed to impersonate a legitimate platform of the Complainant’s brand. The disputed domain names explicit references to Leusden and to “Circus Gran Casino” evidence that they mirror the Complainant’s real-world operations and publicly reported partnership in that location and also mimicking the structure and appearance of an official operator’s website and creating the impression of an authorised platform. The Complainant submits that the Respondent uses the disputed domain name to attract Internet users by creating a likelihood of confusion with the Complainant’s trademarks and to redirect those users to third-party gambling platforms. Thus, the activities of the Respondent in connection with the disputed domain name are in bad faith. The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 4 6. Discussion and Findings The Panel is satisfied that the Complainant has established each of the elements required under the Policy for a transfer of the disputed domain name. 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 CIRCUS is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. Although the addition of other terms here, “casino” and “online”, may bear on assessment of the second and third elements, t he 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. WIPO Overview 3.1, section 1.8. The Panel finds 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. Panels have held that the use of a domain name for illegitimate activities here, passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. page 5 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. In the present case, the Panel notes that the Respondent has been involved in a prior UDRP proceeding concerning a domain name targeting an online casino operator. Glitnor Marketing Ltd v. Melona Richards, Yumeteki, WIPO Case No. D2025-2675. The Respondent’s conduct in the present case, viewed together with that prior proceeding, reflects a pattern of impersonating third-party online gambling operators. WIPO Overview 3.1, section 3.1.2. In the present matter, the Respondent has adopted the CIRCUS mark of the Complainant whilst adding the generic terms “casino” and “online” and using a nearly identical logo. Further, as demonstrated in Annex 8 of the Complaint, the website associated with the disputed domain name displays the CIRCUS name and a logo similar to the Complainant’s above-mentioned device mark, and contains references to “Online Casino Circus” “Circus Casino Leusden” and “Circus Gran Casino Leusden”, which supports a finding that the Respondent intended to impersonate or pass itself off as being associated with the Complainant, thereby directly echoing the Complainant’s actual business activities in the Netherlands (Kingdom of the). The Panel concurs with the Complainant that these are not random geographic or commercial references considering that they correspond to the Complainant’s genuine Dutch- facing operations. The Panel agrees that this demonstrates that the Respondent had the Complainant specifically in mind when registering the disputed domain name and preparing the website content, all of which is in bad faith. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. Panels have held that the use of a domain name for illegitimate activity, here, passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. 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 <circus-casino-online.com> be transferred to the Complainant. /Meera Chature Sankhari/ Meera Chature Sankhari Sole Panelist Date: June 4, 2026

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