Westmore · UDRP decision
WIPO · Case No. D2026-1771

Maxlnone.org

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <maxlnone.org>. It found the domain confusingly similar to Complainant’s MAXL and MAXL ONE marks, that Respondent had not established a legitimate noncommercial criticism use, and that the domain was registered and used in bad faith. Central to the decision were the domain’s close imitation of MAXL ONE, the risk of implied affiliation, favorable references to competing products, Respondent’s unsupported consumer-advocacy claims, the unexplained GoFundMe link, and removal of the original website after the Complaint was filed.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-22
Panelist(s)
Nahitchevansky, Georges
Complainant
Intellectus Dominus, LLC
Respondent
Alexander Troche, Deviratech LLC
Disputed domain(s)
maxlnone.org
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind maxlnone.org

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 maxlnone.org — 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 granted. Panel ordered transfer of maxlnone.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates the distinction between protected criticism in principle and using a domain that closely imitates a trademark without clearly signaling criticism. The result rested not merely on negative commentary, but on the combined effect of the mark-mimicking domain, implied-affiliation risk, references to alternatives, and Respondent’s failure to provide evidence explaining the project’s operator, sources, funding link, purpose, and post-Complaint changes.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-22
Panel
Nahitchevansky, Georges
Full decision
16 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Intellectus Dominus, LLC v. Alexander Troche, Deviratech LLC Case No. D2026-1771 1. The Parties Complainant is Intellectus Dominus, LLC, United States of America (“United States”), represented by Esca Legal LLC, United States. Respondent is Alexander Troche, Deviratech LLC, United States. 2. The Domain Name and Registrar The disputed domain name <maxlnone.org> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 24, 2026. On April 27, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 28, 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 (Registrant of maxlnone.org, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on April 29, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on May 4, 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 Respondent of the Complaint, and the proceedings commenced on May 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 27, 2026. The Response was filed with the Center on May 5 and 6, 2026. page 2 The Center appointed Georges Nahitchevansky as the sole panelist in this matter on June 9, 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 Complainant, Intellectus Dominus, LLC, is a product development and e-commerce company in the automotive cleaning and detailing industry. Complainant promotes a variety of car care products under the name and mark MAXL, including a cleaning, protection and maintenance spray under the name and mark MAXL ONE. Complainant owns, inter alia, a trademark registration in the United Sates for the MAXL mark in connection with its cleaning products (No. 7,076,248) that issued to registration on June 6, 2023 and a pending application for the mark MAXL ONE mark (Serial No. 98960940) that was filed on January 14, 2025 with a claimed first use date of December 18, 2024. The application for MAXL ONE is currently subject to a pending opposition proceeding by a party unrelated to this matter. Complainant also owns and uses the domain name <maxl.com> for a website concerning Complainant’s MAXL products, including its MAXL ONE spray product. Respondent appears to be based in the United States and his Deviratech LLC company appears to offer web development consultancy services. Respondent registered the disputed domain name on January 14, 2026. At some point after registering the disputed domain name, Respondent began using such for a website that used the title “Maxlnone.org” with the legend “The Truth About Maxlone” followed by the following text: “Marketed as a revolution. Revealed as a risk. Before you spray ‘Triphene’ on your paint, understand the chemistry and the cost.” The rest of the website included a purported cost, longevity and marketing claim analysis, alleged customer reviews on the MAXL ONE product, recommendations on protecting a vehicle’s finish, comparisons of competing products, information concerning “Maxlnone.org” and its claimed mission and a link to the website at <gofundme.com>. With regard to the link such simply stated “Donate to our Cause” and appeared after a header that read as follows: “The subject product company has been trying to shut us down – We will not comply.” Currently, Respondent’s website resolves to a web page that provides that the website is offline for recalibration, explains that the disputed domain name is not affiliated with any brand or product and that “we are an independent research node,’ and includes a preview for an interactive car wash simulator. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Complainant maintains that it “has gained recognition as a pioneer in the car care industry through its scientifically-advanced MAXL® car products” including its MAXL ONE spray product. Complainant further maintains that it has received much praise for its products and thus has rights in the MAXL and MAXL ONE marks on account of its use of, registration and pending application for these marks. Complainant contends that the disputed domain name is identical to the MAXL mark as it fully incorporates the MAXL mark and is confusingly to the MAXL ONE mark as it mirrors the structure of Complainant’s MAXL ONE mark by merely converting the word “one” into “none”. Complainant argues that Respondent has no rights or legitimate interests in the disputed domain name as Respondent (i) is not affiliated with Complainant and has no rights in the MAXL or MAXL ONE marks, and (ii) has not used the disputed domain name for a bona fide offering of goods or services. In that regard, page 3 Complainant asserts that Respondent is using the disputed domain name, which is closely similar to Complainant’s MAXL ONE mark, to “misleadingly divert consumers and tarnish Complainant’s trademarks”. Complainant notes that Respondent claims on its website to operate as a consumer protection watchdog and has displayed a banner and link to a “gofundme.com” page that is likely to invoke a negative reaction towards Complainant and which is meant to “signal credibility and generate engagement” for Respondent’s self-proclaimed consumer protection watchdog activities – which Complainant maintains are pretextual as the claims made on Respondent’s website concerning Complainant’s MAXL ONE product are unsupported by any supporting documentation, videos, photographs, raw data or any laboratory credentials. Complainant also notes that Respondent has no history of operating criticism, activism or consumer protection websites, and no expertise in car wash products, as Respondent appears to operate a web development consultancy business. Lastly, Complainant contends Respondent has registered and used the disputed domain name in bad faith given that Respondent was clearly aware of Complainant’s brand in view of the popularity of Complainant’s brand and repeated reference to Complainant’s “Maxl One” brand on Respondent’s website. Complainant further contends that Respondent, who operates a web development consultancy, has registered and used the disputed domain name, that is likely to be seen by consumers as being “operated by, sponsored by, or affiliated with Complainant,” to attract consumers to Respondent’s website which disparages Complainant in an attempt to disrupt Complainant’s business. Complainant also motes that Respondent’s claimed watchdog activities are pretextual, particularly as Respondent removed its website after the Complaint was filed and replaced it with a passive website. B. Respondent Respondent rejects Complainant’s contentions Respondent submits that it did not engage in any commercial fundraising activity as the link provided by Complainant was captured when Respondent’s website was under construction and was non-functional and simply informational in nature. Respondent maintains that no funds were solicited. Respondent contends that the disputed domain name was used solely for an independent project evaluating car cleaning methods and had clear language stating that it was not affiliated with any brand and was not intended to mislead users. Respondent argues that there is no evidence that the disputed domain name was registered or used in bad faith to sell such to Complainant, disrupt Complainant’s business or attract users for commercial gain. Respondent further argues that Respondent’s website was “non-commercial, informational use, not bad faith.” 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed Complainant must satisfy the Panel that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name was registered and is being used in bad faith. 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 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 Complainant has shown rights in respect of the MAXL mark by virtue of its United States registration for that mark and for purposes of the first element has established with evidence its common law rights in the mark MAXL ONE. WIPO Overview 3.1, section 1.2.1. Respondent does not contest otherwise. Here, the disputed domain fully incorporates the MAXL mark and plays upon the MAXL ONE mark. Although the addition of the letter “n” to the word “one” may bear on the assessment of the second and third elements, the Panel finds the addition of a letter does not prevent a finding of confusing similarity between the disputed domain name and the MAXL ONE mark for purposes of the Policy WIPO Overview 3.1, section 1.8. The Panel thus finds that 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 a 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. Here, Respondent maintains that its use of the disputed domain name was solely for an independent project evaluating car cleaning methods and had clear language advising that it was not affiliated with any brand and was not intended to mislead users. Respondent’s website included a claim that “Maxlnone.org” is “an independent advocacy website” and that “we exist to protect consumers from misleading marketing claims in the automotive care industry.” Having reviewed the screen shots provided by Complainant showing Respondent’s prior website (which is no longer available), it is apparent that it contains purported commentary, information, and reviews that are critical of Complainant MAXL ONE product. Thus, the issue before the Panel is whether Respondent is making a fair use of the disputed domain name by using such in connection with a website that appears to be critical of Complainant and its business. Under Paragraph 4(c)(iii) of the Policy, the use of a domain name for a fair use such as noncommercial free speech, can in principle support a respondent’s claim to a legitimate interest under the Policy. In assessing cases of claimed free expression, the Panel undertakes a holistic assessment that includes the important initial question of whether a disputed domain name is being used to impersonate Complainant, or put another way, whether the public would perceive the disputed domain name as being affiliated with or authorized by a complainant. WIPO Overview 3.1 at section 2.5.1. Building on this initial inquiry, panels can consider additional factors to assess whether a respondent is using the disputed domain for bona fide noncommercial criticism concerning a complainant or to take advantage of a complainant’s mark in a bad faith or abusive way for the benefit of a respondent. See, e.g., Everytown for Gun Safety Action Fund, Inc. v. Contact Privacy Inc. Customer 1249561463 / Steve Coffman, WIPO Case No. D2022-0473. Looking at the disputed domain name, the Panel first notes that the disputed domain name on its face is a close approximation of Complainant’s MAXL ONE mark. The addition of the letter “n” to create the composite “Maxl None” is not such an obvious change from the MAXL ONE mark and is likely to be mistakenly overlooked by consumers. This creates a certain risk of implied affiliation as a consumer who comes into contact with the disputed domain name may consider the disputed domain name to be linked to Complainant or a website for Complainant’s MAXL ONE product. To be sure, while an argument can be page 5 made that “none” (if read that way, instead of a typo) is critical or derogatory, the disputed domain name is not per se a communicative domain name that would likely be seen as signaling a website critical of Complainant and its MAXL ONE product. If anything, the disputed domain name essentially impersonates the MAXL ONE mark. But putting aside for a moment the close similarity of the disputed domain name to Complainant’s MAXL ONE mark, there are open issues regarding Respondent’s website at the disputed domain name. While Respondent’s website appears critical of Complainant’s MAXL ONE product, the website does provide favorable information on competing alternative care for car finishes. This raises a question of whether Respondent’s website is a dressed up website meant to support alternative products or services, particularly given that Respondent operates a web development consultancy and does not appear to be an actual consumer watchdog type entity protecting consumers as Respondent now claims. Indeed, Respondent has simply made the conclusory claim of being an independent advocacy website without providing any information regarding its activities and certainly provided no evidence to counter Complainant’s assertions that Respondent made claims about Complainant’s MAXL ONE product without providing any substantiating evidence as would typically be the case for a consumer protection entity. While it is not within the Panel’s purview to evaluate the veracity of statements made on Respondent’s website, it is telling that Respondent made a conclusory claim regarding its consumer advocacy activities without providing any evidence or details on its activities -- let alone any explanation why his web development consultancy business registered the disputed domain name. This alone raises the possibility that the disputed domain name and associated website were possibly not created for genuine criticism or consumer advocacy but for another purpose, such as to benefit a competitor of Complainant. Moreover, the legitimacy of Respondent’s actions are further undermined by Respondent’s removal of its website once the Complaint was filed only to be replaced with a web page that provides that the website is offline for recalibration along with a preview for an interactive car wash simulator. Again, because Respondent provides only conclusory statements for its activities, with no supporting evidence, it begs the question as to why a web development consultancy business would register the disputed domain name in the first place. In that regard, it should be noted that Respondent’s comments regarding the link to the “gofundme.com” website that appeared on Respondent’s website ring hollow. The website, as Complainant notes, had a clear link and commentary requesting funding. Complainant argues that the link was likely placed by Respondent to provide legitimacy to Respondent’s website as a consumer advocacy site. Respondent does not contest that there was such a li nk but simply avers it was inactive and non-functional, informational in nature, and that no funds were ever solicited. Respondent says nothing about why it was included in the first place. While having such a link does not render a noncommercial criticism website into a commercial venture per se, the placement of a prominent non-functional link raises a question as to its purpose and whether Complainant is correct that the link is further proof of the pretextual nature of Respondent’s website. Taking all of the above into account, although Respondent has a right to express genuine criticism of Complainant’s products, here the use of the disputed domain name that essentially mimics the MAXL ONE mark with a website, whose bona fides as a consumer advocacy site are questionable given the above noted issues, makes it more likely than not that Respondent is not really engaged in a legitimate non-commercial criticism endeavor but has used the disputed domain name to attract traffic to Respondent’s website for purposes that are likely meant to benefit Respondent or someone Respondent, as a web developer consultant, is working for. 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 6 Given that the disputed domain name essentially copies the MAXL ONE mark, there is little doubt that Respondent was well aware of Complainant’s MAXL ONE mark and registered the disputed domain name to attract and mislead consumers to Respondent’s website. In view of the fact that Respondent operates a web development consultancy business, and given Respondent’s failure to explain or support its actions as noted above with any evidence beyond conclusory statements, it appears more likely than not that Respondent registered and used the disputed domain name opportunistically for the benefit or Respondent or some other party. In finding that Respondent has acted in bad faith, the Panel wants to make clear that it does not question Respondent’s right to fairly criticize Complainant and its MAXL ONE product. The basic issue here is the use of a non-communicative domain name that imitates Complainant’s MAXL ONE mark to divert web traffic to a website that while ostensibly critical of Complainant’s MAXL ONE product appears to promote other car finishing care products and solutions. Moreover, given Respondent’s unsupported conclusory statements and failure to explain its actions such a (i) why a web development company registered the disputed domain name, (ii) why a non-functional link for funding was prominently placed on Respondent’s website, (iii) why Respondent removed its website once a Complaint was filed, or (iv) the basis of Respondent’s claimed consumer advocacy efforts, creates questions as to the legitimacy of Respondent’s claimed consumer advocacy purpose and whether Respondent as a web developer consultant created the website for a client or for some purpose that benefits Respondent. 1 In all, Respondent could have it explained and supported its assertions and actions, but instead chose to make vague conclusory statements that lack any support. The Panel thus finds that 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 <maxlnone.org> be transferred to Complainant. /Georges Nahitchevansky/ Georges Nahitchevansky Sole Panelist Date: June 23, 2026 1 It should be noted that while Respondent's website asserts it is not affiliated with any brand, the website does not appear to have provided any information concerning the actual operator of the website or the source(s) for any of the claims on the website. Respondent never addressed these open issues and simply reiterated its claim of being an independent project evaluating car cleaning methods.

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

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