Comply.academy

The timeline behind comply.academy

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Imelda Álvarez Estrada v. Stavrosa Fattas Case No. D2026-2270 1. The Parties The Complainant is Imelda Álvarez Estrada, United States of America, (“United States”) represented by Legarreta y Asociados SC, Mexico. The Respondent is Stavrosa Fattas, Cyprus, represented by S.M. Parparinos & Partners LLC (Aliant Law Parparinos), Cyp rus. 2. The Domain Name and Registrar The disputed domain name <comply.academy> is registered with GoDaddy.com, LLC (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 27, 2026. On May 27, 2026, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On May 27, 2026, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the disputed domain name which dif f ered f rom the named Respondent (Registration Private/Domains By Proxy LLC) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on May 28, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on June 2, 2026. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on June 3, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 23, 2026. The Response was filed with the Center on June 22, 2026. The Center appointed Warwick A. Rothnie as the sole panelist in this matter on July 7, 2026. The Panel f inds 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. page 2 4. Factual Background The Complainant is the f ounder and Chief Executive Of f icer of Comply Academy. According to the Complaint the Complainant has more than 20 years of prof essional experience in the legal, integrity and compliance fields, providing consulting, training, and conference services internationally to a wide range of industries, business associations, chambers of commerce, and non-governmental organizations. The Complainant was Legal Director and Compliance Officer at Sandoz Mexico, f rom 2007 to 2010. Then the Complainant was the Regional Compliance Officer at Novartis for Latin America and Canada f rom 2010 to 2018. The Complainant’s qualifications include the iCECOM certification and the Internationally Certif ied Compliance Professional (ICCP) certification. The Complainant has completed specialized programs at the University of Miami. The Complainant is also a certif ied ISO 37001 auditor. According to the Complaint, the Comply Academy operates in Mexico and the United States. In 2017, the Complainant registered the domain name <complyacademy.com>. Now, the Comply Academy promotes and provides its services from the website to which that domain name resolves. According to the website at the time this decision is being prepared, Comply Academy provides corporate integrity (ethics and compliance) training to transf orm organizational culture. Some parts of the website are bilingual, being in both Spanish and English. The main parts of the website, including in particular those promoting the training programs on offer, are in Spanish only. While the link to the contact form is labelled in both Spanish and English (“Contacto/Contact”), the f orm itself is in Spanish. The telephone number is a Mexican listing and the office or academy address is in Mexico. The f ooter of the landing page states, “Comply Latam, S.C. Todos los derechos reservados Copyright © 2026.” Similarly, the documents in Annex 7 to the Complaint, which are put forward as evidence of the Complainant's prior use of the Comply Academy mark in commerce, are also in Spanish. Not all the documents bear obvious dates, the oldest date being September 2020. The website prominently f eatures the logo: This device is the subject of the Complainant’s three registered trademarks: (1) Mexican Registered Trademark No 2396579 which was registered on May 17, 2022 in respect of a range of goods in International Class 16; (2) Mexican Registered Trademark No 2396580 which was also registered on May 17, 2022 in respect of a range of services in International Class 41; and (3) United States Registered Trademark No 8028018, which has been registered in the Principal Register since November 18, 2025 in respect of a range of consulting and educational services in International Classes 35 and 41. The United States registration bears an endorsement that the colours red, white and black are claimed as a f eature of the mark. There is also a second endorsement that “no claim is made to the exclusive right to use the f ollowing apart from the mark as shown: Comply Academy”. The registration also claims that the class 35 services were f irst used in commerce in January 2024. The details of the Mexican trademarks have been provided in Spanish and have not been translated into English. According to the WhoIs report, the disputed domain name was registered on February 19, 2021. page 3 The disputed domain name resolves to a website of f ering “leading industry training” in compliance. The website offers online courses leading to a number of certificates issued under the aegis of The Association of Governance Risk & Compliance such as a Certif icate in Compliance through courses accredited by the London Institute of Banking and Finance (LIBF). Depending on the course, the price f or enrolment is GBP350 or GBP750. The landing page of the website bears a copyright notice “© Comply Academy Ltd” and amongst other things states that “Comply Academy is brand name of Comply Academy Ltd”. Comply Academy Ltd is incorporated in the United Kingdom and has its offices in London. The Respondent incorporated Comply Academy Ltd in November 2022 and is the sole director and secretary. The website bears alongside the logo of The Association of Governance Risk & Compliance a logo: 5. Discussion and Findings Paragraph 4(a) of the Policy provides that in order to divest the Respondent of a disputed domain name, the Complainant must demonstrate each of the f ollowing: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad f aith. Paragraph 15(a) of the Rules directs the Panel to decide the Complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable. A. Identical or Confusingly Similar The f irst element that the Complainant must establish is that the disputed domain name is identical with, or conf usingly similar to, the Complainant's trademark rights. It is well accepted that the f irst element f unctions 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 Selected UDRP Questions, (“WIPO Overview 3.1”), section 1.7. The Complainant has proven ownership of the registered trademarks f or the device set out above. The comparison of the disputed domain name to the Complainant's trademark simply requires a visual and aural comparison of the disputed domain name to the proven trademarks. This test is narrower than and thus different to the question of “likelihood of confusion” under trademark law. Theref ore, questions such as the scope of the trademark rights, the geographical location of the respective parties, the date they were acquired and other considerations that may be relevant to an assessment of inf ringement under trademark law are not relevant at this stage. Such matters, if relevant, may f all f or consideration under the other elements of the Policy. See e.g. WIPO Overview 3.1, section 1.7. page 4 It is usual to disregard the design elements of a trademark under the f irst element as such elements are generally incapable of representation in a domain name. Where the textual elements have been disclaimed in the registration or cannot f airly be described as an essential or important element of the trademark, however, dif f erent considerations may arise. See f or example, WIPO Overview 3.1, section 1.10. In the present case, exclusive rights over use of the words “Comply Academy” other than as part of the logo have been disclaimed in the United States registered trademark. The materials bef ore the Panel do not indicate that a similar disclaimer was entered in the Mexican trademark registrations.. Given the absence of disclaimers f rom the Mexican registered trademarks and bearing in mind that the Complainant has apparently been using the domain name <complyacademy.com> for a number of years, the Panel is prepared to apply the usual rule. Generally, it is permissible to disregard the Top Level Domain (TLD) component as a functional aspect of the domain name system. However, where the second level of the domain name and the TLD together comprise the relevant trademark, their combined ef f ect may be taken into account when making the comparison. WIPO Overview 3.1, section 1.11. In this case, theref ore, the disputed domain name consists of the relevant verbal component of the Complainant’s registered trademark. Accordingly, the Panel f inds that the Complainant has established that the disputed domain name is conf usingly similar to the Complainant’s trademark and the requirement under the f irst limb of the Policy is satisf ied. B. Registered and Used in Bad Faith In the circumstances of this case, it is appropriate next to consider the third requirement under the Policy. Under the third requirement of the Policy, the Complainant must establish that the disputed domain name has been both registered and used in bad faith by the Respondent. These are conjunctive requirements; both must be satisfied for a successf ul complaint: see e.g. Group One Holdings Pte Ltd v. Steven Hafto WIPO Case No . D2017-0183. The Complainant contends that it is inconceivable that the Respondent was unaware of the Complainant’s trade mark when registering the disputed domain name because the combination of “Comply” and “Acad emy” is distinctive in the relevant industry and the Respondent is of f ering identical services to the Complainant. The Complainant f urther contends that, as the Respondent’s services are accessible in Mexico and the United States, there has been clear targeting of the markets in which the Complainant operates and enjoys protection. Further still, the Complainant contends that the Respondent has not provided a credible explanation for adopting the disputed domain name. Finally, the Complainant invokes the Respondent’s use of a privacy service as a f urther indicator of bad f aith. Panels do regularly inf er knowledge of a prior trademark where the disputed domain name and the trademark are the same or confusingly similar. That is particularly so where the trademark is distinctive on the principle that the more distinctive the trademark the less likely the adoption of a conf usingly similar domain name is a coincidence. In such a case, the resemblance usually calls for a convincing explanation of how the respondent came to adopt the domain name. The problem f or the Complainant here, however, is that the words “comply” and “academy” are descriptive, or at least highly suggestive, of the relevant training services as shown by the disclaimer imposed on the United States registered trademark. Their combination may not be descriptive in Mexico where the Complainant’s business appears to be known as “Comply Latam” judging by materials included in Annex 7 to the Complaint. But the Respondent is providing a business based in London in the United Kingdom, where the composite expression is descriptive. page 5 It is well-established that the global reach of the Internet means that the geographical separation of the Respondent from the Complainant’s location does not provide an automatic defence to a claim of bad f aith. WIPO Overview 3.1, section 3.2.2. The relevance of geographical separation in a particular case requires consideration of a range of factors. These include the distinctiveness of the trademark, the nature of the services each party is offering, what if anything the Respondent has done such as of f ering the disputed domain name for sale at an inf lated price o r is carrying o n what appears to be a genuine non-inf ringing business, whether or not there are other circumstances leading to an inf erence that the Respondent is seeking to trade on the reputation of the trademark and, no doubt, many other matters particular to the case in question. It is possible that the Respondent was aware of the Complainant and her business in choosing the disputed domain name given the two businesses provide the same services. But the Complainant has not suggested that the Respondent has had any dealings with her or her business. While the Complaint does claim that the expression has become closely associated with her services due to extensive and continuous use, international exposure and continuous use, the evidence supplied f alls well short of what would be required to sustain that claim. Further, as the Complaint itself states, the Complainant’s Comply Academy operates in the United States and Mexico. The materials submitted in support of the Complaint relating to that business suggest it is essentially directed at prof essional audiences in Mexico and the Spanish speaking public in the United States. Those materials do not suggest that the Complainant is actively seeking custom in the United Kingdom o r Cyprus in a way which would have lead compliance professionals in those jurisdictions, or those wishing to become compliance prof essionals there, would be aware of the Complainant’s Compliance Academy. The Complaint does not include evidence that the Complainant advertised her Comply Academy in the United Kingdom or Cyprus f or example. The Respondent’s website is accessible f rom the United States and Mexico. The Respondent’s website does proclaim that the LIBF accreditation it offers is globally recognised. So, it is possible that someone f rom the United States or Mexico may choose to enrol in the Respondent’s courses. The website on its face, however, does not appear to be directed at customers and potential customers in either the United States o r Mexico. The pricing for example is in GBP. Of course, sophisticated members of the public in the United States or Mexico may well be prepared pay to enrol in courses being charged in GBP. Anecdotally, however, it is more usual for businesses targeting a market in the United States to specify prices in USD. Mo reo ver, the Respondent’s website does not include content in Spanish, which appears to be the language the Complainant expects her customers to be likely to use. The Panel accepts that a privacy service can be used by the unscrupulous to conceal their identity. Ho wever, privacy services are offered by registrars almost as a matter of routine, often for no further charge. In this case, this particular allegation has even less f orce given there is an active website which clearly identifies the corporate entity claiming to offer the service and its association with relevant learned societies or professional organizations in the United Kingdom. In these circumstances, the Panel does not consider it appropriate to inf er that the Respondent was intending to take advantage of the Complainant’s reputation in her trademark or the name “Comply Academy” when registering the disputed domain name. Accordingly, the Complainant has not established that the disputed domain name was registered in bad faith. As the Complainant has not established that requirement, it cannot establish the third requirement under the Policy and the Complaint must f ail. page 6 C. Rights or Legitimate Interests As the Complaint must fail, no good purpose is served by addressing this requirement. The Panel notes, however, that the record contains evidence that the Respondent has operated a compliance-training business under the name “Comply Academy” and has used the disputed domain name in connection with that business. D. Reverse Domain Name Hijacking The Respondent invites the Panel to make a f inding of reverse domain name hijacking as the Complaint “was brought in the face of a registered company name and visible legitimate business use of the domain, which the Respondent submits should have weighed heavily against f iling.” Paragraph 15(e) of the Rules provides that, if af ter considering the submissions, the Panel f inds that the Complaint was brought in bad f aith, f or example in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad f aith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.1, section 4.16. There is considerable f orce in the Respondent’s contention. On balance, however, the Panel does not consider a f inding of reverse domain name hijacking is appropriate in this case. The Complainant owns trademark registrations for COMPLY ACADEMY, has used that designation in connection with compliance- training services, and was conf ronted with a domain name corresponding to that designation used in connection with similar services. Although the Complaint ultimately fails, the Panel is not persuaded that the Complaint was brought in bad f aith or constituted an abuse of the administrative proceeding. 7. Decision For the f oregoing reasons, the Complaint is denied. /Warwick A. Rothnie/ Warwick A. Rothnie Sole Panelist Date: July 22, 2026

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