Westmore · UDRP DecisionUdemy.help
The Panel ordered transfer of <udemy.help>. It found the domain identical to the Complainant’s UDEMY trademark, found no rights or legitimate interests because the Respondent did not rebut the Complainant’s prima facie case and the domain was inactive, and found bad-faith registration and use based on the mark’s reputation, the domain’s identity to the mark, the association created by the “.help” gTLD, passive holding, and the Respondent’s failure to answer cease-and-desist communications.
The timeline behind udemy.help
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 udemy.help — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how an exact-match trademark domain paired with a support-oriented gTLD can carry significance beyond the first-element comparison. Although “.help” was disregarded when comparing the mark and domain, the Panel treated it as increasing the risk that users would perceive the domain as an official support channel. The case also demonstrates application of passive-holding principles where the domain displayed no substantive active content.
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 Udemy, Inc. v. Shubham Kumar Case No. D2026-1671 1. The Parties The Complainant is Udemy, Inc., United States of America (“United States”), represented by SafeNames Ltd., United Kingdom. The Respondent is Shubham Kumar, India. 2. The Domain Name and Registrar The disputed domain name <udemy.help> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 20, 2026. On April 21, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 22, 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 (Redacted) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 27, 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 amended Complaint on April 29, 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 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 20, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 27, 2026. page 2 The Center appointed Taras Kyslyy as the sole panelist in this matter on June 3, 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 an online course provider, allowing users (businesses, professionals and students) access to over 250,000 courses for the purposes of e-learning. The Complainant was founded in 2010 and is headquartered in San Francisco, California, United States, and has offices in Denver, United States, Brazil, Ireland, and Türkiye. The Complainant’s service is available in 78 languages and has over 84 million learners utilizing its platform across more than 180 countries. The Complainant has approximately 5,000 employees and a revenue of USD 790 million as of 2026. The UDEMY brand is derived from the phrase “academy of you”, a portmanteau of “you” (“u”) and “academy”, which reflects the Complainant’s focus on a personalized and individual learning and skill development experience. The Complainant holds several registered trademarks for the term UDEMY, including for instance European Union registration No.011006319, registered on November 28, 2012, and Indian registration No. 2768272, registered on July 4, 2014. The Complainant uses its main website “www.udemy.com” to offer its products and services. The offerings under the UDEMY brand, have a global reach, amassing just over 71 million visits in March 2026. Online users can access free or paid courses by creating an account and searching the UDEMY platform. The courses are provided through the online platform, and the course material can be downloaded therefrom. The Complainant has also established a social media presence and uses their trademark UDEMY to promote their services under this name, in particular on LinkedIn (1.6 million followers), Facebook (8.5 million followers), X (formerly “Twitter”) (290.8 thousand followers), and Instagram (3.6 million followers). The Complainant was awarded for being in the “World’s Top EdTech Companies” in 2025 and was listed in the “Best Online Learning Services for 2026”. The disputed domain name was registered on March 11, 2026, and resolves to a parked webpage provided by the Registrar. The Complainant sent a cease and desist letter notices to the Respondent. However, the Respondent provided no response to these notices. 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 the disputed domain name is identical or confusingly similar to the Complainant’s trademark. The disputed domain name is identical to the Complainant’s trademark. In respect of the generic Top-Level Domain (“gTLD”) “.help” featured in the disputed domain name, the Complainant requests that the Panel disregard this under the first element as it is a standard registration requirement. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent does not have any trademark rights to the term UDEMY. There is also no evidence that the Respondent retains any unregistered trademark rights to the same term. Neither has the Respondent received any license from the Complainant to use domain names featuring the Complainant’s page 3 trademark. The Respondent has not used, nor prepared to use, the disputed domain name in connection with a bona fide offering of goods or services. The disputed domain name resolves to a parked webpage. Where a domain name points to such nominal use, it does not constitute a bona fide offering of goods and services. On the contrary, it constitutes non-use of the disputed domain name. The Respondent has not used the disputed domain name for any purpose since its registration. Such non-use cannot demonstrate that the Respondent has used or made any demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services, which cannot confer rights on the Respondent. The Respondent is not commonly known by the distinctive term “Udemy”, nor is offering any legitimate goods or services by the same term. Therefore, there is no plausible reason for the registration of the disputed domain name, other than the motive of taking advantage of the goodwill and reputation attached to the Complainant’s trademark. The disputed domain name’s resolution to a parked webpage is not a legitimate noncommercial or fair use of it. Given the distinctive nature of the Complainant’s trademark, there can be no current or perceivable future fair use of the disputed domain name. The disputed domain name consists of the Complainant’s trademark in its entirety with no additions. Where a domain name is identical to a complainant’s trademark, this composition carries a high risk of implied affiliation. Additionally, the use of the gTLD, “.help”, is likely to be understood by the Complainant’s customers as an official help or support service used by the Complainant. Such use does not support a finding of fair use or legitimate interests in the disputed domain name. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The Complainant’s trademark registrations predate the creation date of the disputed domain name by over thirteen years. Furthermore, the Complainant’s trademark has accrued substantial goodwill and reputation since the Complainant’s establishment in 2010. All the top results from performing a Google search of the terms “Udemy” and “Udemy help” pertain to the Complainant’s trademark and services. Moreover, the Complainant’s trademarks are also accessible for Internet users to view on public trademark databases. The simplest degree of due diligence would have made the Respondent aware of the Complainant’s trademark rights. The disputed domain name replicates the Complainant’s trademark in its entirety. The Respondent’s choice of the disputed domain name’s composition exacerbates the finding of bad faith as it likely misleads Internet visitors into thinking that the disputed domain name is associated with the Complainant’s online services. The disputed domain name does not resolve to any active content. The non-use of the disputed domain name does not prevent a finding of bad faith. The Complainant’s trademark had a strong reputation and was widely known. The Respondent had provided no evidence of any actual or contemplated good faith use by it of the disputed domain name. The Respondent had taken active steps to conceal its true identity. It was not possible to conceive any plausible actual or contemplated active use of the disputed domain name by the Respondent that would not be illegitimate, such as being a passing off, an infringement of consumer protection legislation, or an infringement of the Complainant’s rights under trademark law. The Complainant’s trademark has no ordinary or dictionary meaning, only in relation to its services, which have garnered a substantial reputation through its use. The passive holding of the disputed domain name that is identical to the Complainant’s trademark creates an association that it could be one of the Complainant’s official websites, which is indicative that there is no actual, contemplated or conceivable good faith use that can be made of the disputed domain name. The Complainant sent a cease and desist letter notices to the Respondent. However, the Respondent provided no response to these notices. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. 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. page 4 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 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 applicable gTLD in a domain name (e.g., “.com”, “.club”, “.nyc”) is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. Thus, the Panel disregards gTLD “.help” for the purposes of the confusing similarity test. WIPO Overview 3.1, section 1.11.1. 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. The available evidence does not confirm that the Respondent is commonly known by the disputed domain name, which could demonstrate its rights or legitimate interests (see, e.g., World Natural Bodybuilding Federation, Inc. v. Daniel Jones, TheDotCafe, WIPO Case No. D2008-0642). The Complainant did not license or otherwise agree for use of its prior registered trademarks by the Respondent, thus no actual or contemplated bona fide or legitimate use of the disputed domain name could be reasonably claimed (see, e.g., Sportswear Company S.P.A. v. Tang Hong, WIPO Case No. D2014-1875). The Respondent has no rights or legitimate interests in the disputed domain name resolving to an inactive website (see, e.g., Philip Morris USA Inc. v. Daniele Tornatore, WIPO Case No. D2016-1302). Noting the high risk of implied affiliation between the disputed domain name and the identical well-known trademark of the Complainant, the Panel finds that there is no plausible fair use to which the disputed domain name could be put that would not have the effect of being somehow connected to the Complainant (see, e.g., Instagram, LLC v. Super Privacy Service LTD c/o Dynadot / Zayed, WIPO Case No. D2019-2897). 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. page 5 In the present case, the Panel notes that the Respondent registered disputed domain name identical to the Complainant’s trademark. The mere registration of a domain name that is identical or confusingly similar to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. The Panel is convinced that the Complainant’s trademark is well established through long and widespread use and the Complainant has acquired a significant reputation and level of goodwill in its trademark internationally. The Panel also takes note that the disputed domain name is almost identical to the Complainant’s domain name <udemy.com>. Thus, the Panel finds that the disputed domain name identical to the Complainant’s trademark was registered in bad faith. WIPO Overview 3.1, section 3.1.4. Panels have found that the non-use of a domain name would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name featuring choice of gTLD “.help” creating risk of association with the help support of the Complainant to the users of its services, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Moreover, the Respondent failed to respond to the Complainant’s cease and desist letter, and did not provide any good reason to justify this, which confirms the bad faith (see, e.g., Compagnie Generale des Etablissements Michelin v. Vaclav Novotny, WIPO Case No. D2009-1022). 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 <udemy.help> be transferred to the Complainant. /Taras Kyslyy/ Taras Kyslyy Sole Panelist Date: June 16, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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