Westmore · UDRP decision
WIPO · Case No. D2026-1592

Sankaku.net

Complaint deniedWIPO-indexed · informational, not legal advice

The Panel denied the Complaint. It found the disputed domain name identical to the Complainant’s SANKAKU trademark, but did not reach rights or legitimate interests because the Complainant failed to establish bad-faith registration and use. The Panel emphasized that “sankaku” means “triangle” in Japanese, that the domain had previously been used legitimately for camping and tent products, and that the record did not establish the Respondent’s awareness of or intent to exploit the Complainant’s rights, whether the relevant registration occurred in 2015 or 2023.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-06-12
Panelist(s)
Clark, Douglas
Complainant
Complex Contents Ltd.
Respondent
Jun Hiyama, SAKURA internet Inc.
Disputed domain(s)
sankaku.net
Domain history UDRP Intelligence

The timeline behind sankaku.net

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 sankaku.net — 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 denied. sankaku.net remained with the respondent.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates the difficulty of proving bad faith where a domain consists of a common foreign-language word, has a documented use connected to its ordinary meaning, and the complainant cannot establish reputation, earlier goodwill, respondent awareness, or a reliable later-acquisition date. Uncertainty about ownership history did not shift the ultimate burden from the Complainant.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate Interestsnot_reached
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
Complaint denied
Decision date
2026-06-12
Panel
Clark, Douglas
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Complex Contents Ltd. v. Jun Hiyama, SAKURA internet Inc. Case No. D2026-1592 1. The Parties The Complainant is Complex Contents Ltd., Bulgaria, represented by Sigma Law Group LLC, United States of America (“United States”). The Respondent is Jun Hiyama, SAKURA internet Inc., Japan, self-represented. 2. The Domain Name and Registrar The disputed domain name <sankaku.net> is registered with Japan Registry Services Co., Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on April 15, 2026. On April 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 17, 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. On April 20, 2026, the Center informed the parties in Japanese and English, that the language of the Registration Agreement for the disputed domain name is Japanese. On April 23, 2026, the Complainant submitted the Complaint translated into Japanese. On April 25, 2026, the Complainant submitted an amended Complaint in English with a Japanese translation. 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 in Japanese and English of the Complaint, and the proceedings commenced on April 28, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 18, 2026. The Response was filed in English with the Center on May 16, 2026. Accordingly, the Center acknowledged the receipt of the Response on May 19, 2026. page 2 On May 20, 2026, the Complainant made an unsolicited filing of a Reply to the Response. The Center appointed Douglas Clark 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. 4. Factual Background The Complainant is a limited liability company organized and existing under the laws of Bulgaria. The Complainant operates an online platform under the name SANKAKU providing, among other things, digital content, community features, and related services in the fields of animation, comics, illustration and other visual media. The Complainant is the owner of the SANKAKU trademark in the United States under Trademark Registration No. 8047469, registered on December 2, 2025, and in connection with online entertainment services and related goods and services. The Respondent is purportedly an individual based in Osaka, Japan. The Complainant alleges that it has used the Mark continuously since at least 2008. However, the Articles of Association submitted by the Complainant are dated 2020. The disputed domain name was registered on July 9, 2015. The Complainant alleges that the Respondent acquired, or was first unmasked as the registrant of, the disputed domain name in 2023. The Respondent claims to have been the registered owner of the disputed domain name since 2015. Searches on the Wayback Machine show that the disputed domain name was used between 2015 and 2016 by a Japanese company Sanbariki Co. Ltd. to promote the sales of camping equipment. The disputed domain name then resolved to a parking page for many years. After the Complaint was filed, the disputed domain name started to resolve to the same website that it had resolved to in 2016 for Sanbariki Co. Ltd. The content on the website was dated 2016. It is common ground between the Parties that “Sankaku” means triangle in Japanese. 5. 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. Notably, the Complainant contends that (i) the disputed domain name is identical or confusingly similar to the Complainant’s trademark; (ii) Respondent has no rights or legitimate interests in the domain name; and (iii) Respondent registered and is using the domain name in bad faith. In particular, the Complainant contends that the Respondent registered and is using the disputed domain name in bad faith, including on the basis of its prolonged passive holding and lack of any legitimate use. The Complainant submits that it has no affiliation with the Respondent, nor has it authorized the Respondent to register or use a domain name, which includes the Complainant’s marks, and that the Respondent has no rights or legitimate interests in the registration of the disputed domain name. Rather, the Complainant page 3 contends that the Respondent has acted in bad faith in acquiring the disputed domain name, when the Respondent knew of the Complainant’s rights. B. Respondent The Respondent contends that the Complainant has not satisfied two of the elements required under the Policy for a transfer of the disputed domain name. In particular, the Respondent contends (i) that he has a legitimate interest in the mark and (ii) that the mark was not registered or used in bad faith. The Respondent submits that the term “sankaku” is a common romanization of the Japanese word “三角” meaning “triangle” and its use of the term was based on its ordinary Japanese meaning and in relation to the sale of outdoor and climbing-related products and tent products. 6. Discussion and Findings 6.1 Procedural Issues A. Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Japanese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complainant submitted the Complaint in English and a version translated into Japanese and requested Japanese and English be the language of the proceedings. The Response was filed in English with the Center on May 16, 2026. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, and considerations of time and costs (see WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.5.1). In this regard, the Panel notes that the Respondent has demonstrated an ability to communicate in English by submitting a Response in English. Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceedings shall be English. B. Complainant’s Request to Issue an Order to Registrar to Disclose Ownership History The Complainant requests the Panel to issue an Order to the Registrar to clear up the registration history. While on one level this is understandable, it is moot as the UDRP does not provide for discovery. Further, the matters requested are beyond that which the Registrar may even be able to know, e.g., the identity of prior registrants. While a panel may have had the power to order the production of further evidence from a respondent, the Panel does not consider it necessary to make an order in this case. Any such order would not, as explained below, affect the outcome. C. Complainant’s Supplemental Filing The Complainant filed a Supplemental Filing in Reply to the Respondent’s Response. Although supplemental filings are not provided for under the Policy or the Rules, the Panel has discretion to admit them. In the present case, the Panel considers that some parts of the Supplemental Filing are matters that could have been dealt with in the Complaint. However, other parts do narrow the issues before the Panel page 4 and for this reason, the Supplemental Filing does not give rise to procedural unfairness. The Panel therefore admits the Complainant’s supplemental submissions. Given its decision below, the Panel did not consider it necessary to request a rejoinder from the Respondent. 6.2 Substantive Issues 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 3.1, section 1.7. The disputed domain name is identical to the Complainant’s mark other than the generic Top-Level Domain (“gTLD”). The disputed domain name incorporates the Complainant’s mark in its entirety. WIPO Overview 3.1, section 1.8. Accordingly, the Panel finds that the disputed domain name is identical to a trademark in which the Complainant has rights, and that the Complainant has satisfied the first element of paragraph 4(a) of the Policy. The Panel notes that the Respondent is based in Japan and the Complainant does not have a registered trademark in Japan. However, it is also well-established that the jurisdiction where the Complainant’s trademark is registered is not relevant consideration in respect of the first element but may be relevant to the second and third elements. WIPO Overview 3.1, section 1.1.2. B. Rights or Legitimate Interests The Panel finds below that the disputed domain name has not been registered and used in bad faith. It is accordingly not necessary to determine if the Respondent has rights and legitimate interests. C. Registered and Used in Bad Faith The Complainant relies on the Respondent becoming the registrant of the disputed domain name in 2023 and passive holding to support its allegation of registration and use in bad faith. On the available evidence, it is unclear as to when the Respondent registered the disputed domain name. The disputed domain name was registered in 2015. It is clear that at the time, Sanbariki Co. Ltd. made legitimate use of the disputed domain name to promote its camping equipment. The Complainant alleges that the Respondent only became the registrant in 2023 based on an analysis of Who-Is searches. The underlying searches are not provided. The Respondent in his Response does not, however, make clear his relationship with Sanbariki Co. Ltd. The Panel does not, however, have to seek to resolve these factual issues. The Panel does not consider on the facts of this case that the mere passive holding of the dictionary word “sankaku” can support an allegation of registration and use in bad faith. “Sankaku” means “triangle” in Japanese. The use that was made of the disputed domain name by Sanbariki Co. Ltd. in relation to shape and design of its logo (which was a triangle) and tent products was unobjectionable. There is no evidence that the Complainant is so well known that use by anyone else of “sankaku” would create some link in a consumer’s mind with the Complainant. In this case, the Complainant only relies on a United States registered trademark and not on any Japanese registration. A search of the Japanese page 5 trademark register would not reveal any mark of the Complainant. 1 Further the Complainant’s claimed use since 2008 cannot be made out from the evidence on the record. The Complainant’s own evidence is that it was incorporated in 2020. There is no evidence that it acquired goodwill in the name from another entity. The record does not establish that the Respondent was aware of the Complainant or its mark at the time of registration of the disputed domain name – whether that was in 2015 or 2023, nor that the Respondent sought to take advantage of any such rights. WIPO Overview 3.1, section 3.2. On one version of events, the current direction to prior web content would support a case that the Respondent was the original registrant in 2015 (in which case the lack of awareness of the Complainant, and use for outdoor products even more strongly supports the Respondent’s case). However, a second possible version is that the Respondent only more recently became the registrant and somehow copied the 2015 content to give his registration cover. This is implicitly argued by the Complainant based on the Respondent’s failure to show evidence of an unbroken chain of control. However, the ultimate burden falls to the Complainant. The Complainant also alleges in this respect that product packaging of the Respondent refers to a <sankaku.me> domain name and that this undermines his case; while it is indeed a different domain name, it also shows use of the same term (sankaku) in the same descriptive or suggestive manner. The Panel finds that the Respondent did not register and has not used the disputed domain name in bad faith. The Panel finds that the third element of the Policy has not been established. 7. Decision For the foregoing reasons, the Complaint is denied. /Douglas Clark/ Douglas Clark Sole Panelist Date: June 12, 2026 1 The Panel has done its own search and the Complainant does not have a registration for SANKAKU in Japan. For the Panel’s power to conduct its own research, see WIPO Overview 3.1, para 4.8

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

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