Westmore · UDRP DecisionDuelbits-canada.com
The Panel ordered transfer of <duelbits-canada.com>. It found the domain confusingly similar to the Complainant’s DUELBITS trademark, concluded that the unrebutted record established no rights or legitimate interests, and found bad-faith registration and use because the domain purported to offer the same services as the Complainant while attracting users through confusion and redirecting them to a competitor’s website.
The timeline behind duelbits-canada.com
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 duelbits-canada.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a complete casino trademark with a geographic term can create both confusing similarity and a risk of implied affiliation. The case was especially strong on bad faith because the domain was used in the same commercial field, displayed the trademark, and diverted users to a competitor.
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 Liquid Entertainment N.V. v. David McGri, FidgetsGuide Case No. D2026-2016 1. The Parties The Complainant is Liquid Entertainment N.V., Curaçao, Netherlands (Kingdom of the), represented by Law Office of Adam Gonnelli LLC, United States of America. The Respondent is David McGri, FidgetsGuide, United States of America. 2. The Domain Name and Registrar The disputed domain name <duelbits-canada.com> is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 10, 2026. On May 11, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 13, 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 (“Super Privacy Service LTD c/o Dynadot”) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 15, 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 May 16, 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 May 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 7, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 10, 2026. page 2 The Center appointed Nayiri Boghossian as the sole panelist in this matter on June 17, 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, Liquid Entertainment N.V., owns and operates a cryptocurrency casino called DUELBITS and owns a trademark registration for DUELBITS, i.e. Curaçao Trademark Registration No. 21019, registered on February 22, 2024. The Complainant holds a gaming license in Curaçao, Netherlands (Kingdom of the). The disputed domain name was registered on February 7, 2026 and redirects to an online cryptocurrency casino, featuring the Complainant’s trademark, while also diverting Internet users to a competitor’s website. 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 confusingly similar to a trademark or service mark in which the Complainant has rights. The disputed domain name incorporates the Complainant’s trademark in its entirety. The addition of “canada” does not distinguish the disputed domain name. The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has not licensed or otherwise authorized Respondent to use its mark. Use of the Complainant’s trademark creates a misleading impression of affiliation. The Respondent is not commonly known by the disputed domain name. The Respondent is not making any legitimate noncommercial or fair use. The Complainant contends that the disputed domain name was registered and is being used in bad faith. When a user attempts to sign-up, they are redirected to the website of “Golden Crown Casino”. The disputed domain name was registered six years after the Complainant began using the trademark DUELBITS. The Respondent has used a privacy shield. The trademark DUELBITS is not a dictionary word. There is no disclaimer on the website of the Respondent. 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. 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. page 3 The entirety of the mark 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, “canada” may bear on assessment of the second and third elements, the Panel finds the addition of such term 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 activity here, claimed passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Furthermore, the Panel finds that the nature of the disputed domain name carries a risk of implied affiliation. WIPO Overview 3.1, section 2.5.1. 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. In the present case, the Panel notes that the Respondent must have been aware of the Complainant’s trademark as the disputed domain name was registered two years after the registration of the Complainant’s trademark and purports to offer the same services as those of the Complainant. 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. The Panel notes that the disputed domain name is being used in bad faith since the Respondent is trying to attract Internet users to its website as well as to a competitor’s website by creating a likelihood of confusion page 4 with the Complainant’s trademark as to the disputed domain name’s source, sponsorship, affiliation or endorsement, an activity clearly detrimental to the Complainant’s business in accordance with paragraph 4(b)(iv) of the Policy. Panels have held that the use of a domain name for illegitimate activity here, claimed, 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 <duelbits-canada.com> be transferred to the Complainant. /Nayiri Boghossian/ Nayiri Boghossian Sole Panelist Date: June 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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