Westmore · UDRP DecisionTheraikos.com
The Panel ordered transfer of <theraikos.com> after finding that it was a confusingly similar typographical variant of the THERAKOS mark, that the Respondent lacked rights or legitimate interests, and that registration and use for fraudulent emails impersonating the Complainant and requesting payment into a bank account constituted bad faith.
The timeline behind theraikos.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 theraikos.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a direct typosquatting and impersonation pattern in which a domain differing slightly from an established trademark and corporate domain was used for fraudulent payment communications. The fraudulent email evidence was relevant both to the absence of legitimate interests and to bad-faith registration and use.
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 Therakos Healthcare Limited v. Adrian Reyes Case No. D2026-2175 1. The Parties The Complainant is Therakos Healthcare Limited, Ireland, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Adrian Reyes, United States of America. 2. The Domain Name and Registrar The disputed domain name <theraikos.com> is registered with Hostinger Operations, UAB 3. Procedural History May 20, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 20, 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 Information Redacted/Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 21, 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 May 27, 2026. The Center verified that the Complaint together with the amended Complaint satisfied the formal In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 21, 2026. The Respondent did not submit any response. Accordingly, June 23, 2026. page 2 The Center appointed Nayiri Boghossian as the sole panelist in this matter on June 29, 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 healthcare company, which develops immune cell therapies delivered through extracorporeal photopheresis, and owns, through its affiliated companies, trademark registrations for THERAKOS in numerous jurisdictions such as the following: 1) Canadian Trademark Registration No. TMA852597, registered on June 5, 2013; 2) Swiss Trademark Registration No. 668969, registered on January 29, 2015; and 3) Norwegian Trademark Registration No. 281906, registered on May 21, 2015. The Complainant operates primarily through its domain name <therakos.com> registered since 1995. The disputed domain name was registered on April 8, 2026, and the evidence reflects that it has been used for sending fraudulent email communications impersonating the Complainant and requesting payment to be made into a bank account. The disputed domain name resolves to . 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 the misspelling . The generic Top- The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is neither affiliated with the Complainant, nor has been authorized by the Complainant to use its trademark, or to seek registration of any domain name incorporating said trademark. There is no actual or contemplated bona fide or legitimate use of the disputed domain name. In fact, the disputed domain name was used for the purpose of a fraudulent email scheme. The Respondent is not commonly known by the disputed domain name. The Complainant contends that the disputed domain name was registered and is being used in bad faith. its trademark in 1987. The Respondent sent a fraudulent email posing as the employees of the Complainant and the disputed domain name is a misspelling domain name for sending fraudulent emails and launching a phishing attack constitutes active bad faith use. B. Respondent page 3 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 CWIPO Overview of WIPO Panel Views on WIPO Overview 3.1 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. A typo variant of the mark (where the mark remains sufficiently recognizable) 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, sections 1.7 and 1.9. 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 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 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Panel notes that the nature of the disputed domain name consisting of an inherently misleading typographical error signals an intention on the part of the Respondent to confuse unsuspecting Internet users into believing that the disputed domain name is operated by the Complainant as Internet users may not . Furthermore, panels have held that the use of a domain name for illegitimate activity here, claimed, phishing, 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. 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 4 In the pr trademark as the disputed domain name was registered more than a decade after the registration of the and the disputed domain name has been used in connection with a fraudulent email scheme by impersonating the Complainants employees and requesting payment into a bank account. 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 main 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, claimed, phishing, constitutes bad faith. WIPO Overview 3.1 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 <theraikos.com> be transferred to the Complainant. /Nayiri Boghossian/ Nayiri Boghossian Sole Panelist Date: July 7, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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