Westmore · UDRP DecisionSridharyerramreddy.com
The Panel denied the Complaint because the Complainant did not establish trademark rights in his personal name, SRIDHAR YERRAMREDDY. Although the record showed professional accomplishments, media recognition, and an association with Steer Health, it did not show that the personal name was used in commerce as a distinctive source identifier for particular goods or services. The first UDRP element therefore failed, and the Panel did not reach the second or third elements.
The timeline behind sridharyerramreddy.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 sridharyerramreddy.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates the distinction between professional prominence and trademark rights in a personal name. Even where an exact-match domain targets a named executive and is allegedly operated by a former employee, the UDRP complainant must first prove that the name functions commercially as a distinctive identifier of goods or services. Evidence of biography, followers, media attention, and leadership of a company did not satisfy that threshold here.
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 Sridhar Yerramreddy v. Jonathan Svilar Case No. D2026-3097 1. The Parties The Complainant is Sridhar Yerramreddy, United States of America (“United States”), self-represented. The Respondent is Jonathan Svilar, United States. 2. The Domain Name and Registrar The disputed domain name <sridharyerramreddy.com> is registered with Squarespace Domains LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 15, 2026. On July 15, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 15, 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 (Privacy Protection Service / John Doe) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 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 amended Complaint on July 15, 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 July 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 5, 2026. The Respondent sent an email communication to the Center on July 15, 2026. The Center appointed Scott W. Blackmer as the sole panelist in this matter on August 6, 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. page 2 4. Factual Background The Complainant is an engineer and businessman. He is the founder and CEO of Steer Health Inc (“Steer Health”), a company established in 2021 and based in Irving, Texas, United States that provides artificial intelligence (“AI”) solutions for enterprises in the healthcare industry, as described on its website at “www.steerhealth.io”. 1 The Complainant does not have a relevant trademark registration but claims unregistered, common-law rights in his personal name SRIDHAR YERRAMREDDY as a word mark due to its long-term use in connection with his professional activities. As mentioned on the Steer Health website, the Complainant formerly worked at Oculus Health and determined to build a company “for the AI era”. The Steer Health website displays a photo and article about the Complainant receiving the 2026 Hearst Health prize in June 2026 for “AI & Smart Health” on behalf of Steer Health, at an event sponsored by Hearst Health and the UCLA Center. The Complaint annexes links to media announcements about the Hearst Health prize awarded to Steer Health, referring to the Complainant by name and title as president and founder of Steer Health. The Panel notes that the Complainant’s LinkedIn profile has nearly 8,000 followers. He posts his own comments about medical applications of AI and his participation in health information technology events, and others post comments on his remarks. His LinkedIn profile shows that he was a founder of Oculus Health and its CEO for 8 years, after working in information technology positions for other organizations for 15 years following his university education in India and the United States. The LinkedIn profile does not mention publications to his credit but lists him as co-inventor of a patent filed in the United States in 2015. The profile indicates that the Complainant has been a member of IEEE (the Institute of Electrical and Electronics Engineers) since 2015 and is also a member of HIMSS (the Healthcare Information and Management Systems Society). The LinkedIn profile mentions that the Complainant is also a volunteer with the Bengali- based Akshita Foundation assisting children with education and basic needs. The disputed domain name was created on May 18, 2026, and is registered to the Respondent Jonathan Svilar, listing a postal address in the State of California and a Gmail contact email address. The Complainant identifies the Respondent as a “disgruntled former employee of the Complainant’s company”. At the time of this Decision, the disputed domain name resolves only to a landing page headed “Private Site”, with the message, “This site is currently private. If you’re the owner or contributor, log in.” However, the Complainant attaches a screenshot of a “gripe site” to which the disputed domain name formerly resolved, headed “STEERHEALTH”, with the tagline “STEER AWAY FROM STEERHEALTH”. The home page quoted the Complainant’s motto, “Driving market expansion, automating repetitive tasks, and improving outcomes”, followed by the critical parenthetical “(Also cursing at employees, removing negative reviews, and a revolving door.)” The page featured a photo of the Complainant with a “thumbs down” icon superimposed. The home page also included this disclaimer: “Parody site – all review quotes are real sources from Glassdoor & Indeed”. There was an “About” tab on the page as well, which was not included with the Complaint, and no screenshots of the site are available through the Internet Archive’s Wayback Machine. 1 Noting the general powers of a panel articulated in paragraphs 10 and 12 of the Rules, it is commonly accepted that a panel may undertake limited factual research into matters of public record, as the Panel has done in these proceedings. WIPO Overview of WIPO Panel Views on Select UDRP Questions, Third Edition (“WIPO Overview 3.1”), section 4.8. The Panel notes that the online database of the Delaware (United States) Division of Corporations lists Steer Health Inc as an active corporation incorporated on May 13, 2021. The online database of the Texas Comptroller shows that Steer Health Inc has been registered to transact business in Texas since October 6, 2022, but that its registration status with the Texas Secretary of State is currently “inactive”. The Complainant is listed as the company’s director and president on the public information report for the year 2025. page 3 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 to his personal name in which he claims common law rights and argues that the Respondent has no rights or legitimate interests in the disputed domain name, as the Respondent is not known by a corresponding name and has no permission to use the Complainant’s mark. The Complainant argues that the Respondent’s gripe site was not a legitimate use of the disputed domain name, which is identical to the mark without including a derogatory term and therefore carries a heightened risk of implied association. The Complainant contends that “[a] disgruntled former employee who registers a domain name exclusively to execute a retaliatory harassment campaign against his former CEO cannot claim a bona fide offering of goods or services, nor a legitimate noncommercial or fair use.” The Complainant observes that the Respondent, a former employee, clearly was aware of the Complainant and his mark. The Respondent was hired on May 4, 2026, and signed a Confidentiality and Assignment Agreement (annexed to the Complaint), including a provision agreeing not to make disparaging statements concerning the company or its officers. Two weeks later, the Respondent was terminated “due to poor performance” and registered the disputed domain name on the same day. The Complainant asserts that the derogatory content on the Respondent’s former gripe site, including the use of a copyrighted photo of the Complainant without permission, violated the non-disparagement agreement and serve as evidence of bad faith in an attempt to damage the Complainant’s reputation and disrupt the Complainant’s business. B. Respondent The Respondent did not submit a formal Response. In an email dated July 15, 2026, the Respondent stated as follows: “According to the WIPO website, a complaint is to be filed for instances ‘when your brand is misused to deceive consumers online.’ “There’s no deception or misuse here. The website compiles publically [sic] available information regarding the complaintant [sic] and is linked back to its original sources. The site does not solicit anything from anyone visiting the site, it’s merely an informational site.” 6. Discussion and Findings A. Identical or Confusingly Similar It is possible both to ground a UDRP complaint on an unregistered mark and to establish that one’s personal name has acquired distinctiveness as such a mark. The consensus view on the general approach to unregistered marks is summarized in WIPO Overview 3.1, section 1.3: “To establish unregistered or common law trademark rights for purposes of the UDRP, the complainant must show that its mark has become a distinctive identifier which consumers associate with the complainant’s goods and/or services. Relevant evidence demonstrating such acquired distinctiveness (also referred to as secondary meaning) includes a range of factors such as (i) the duration and nature of the use of the mark (which may include social media presence and engagement), (ii) the amount of sales under the mark and during which time period, (iii) the nature and extent of advertising using the mark – including evidence of expenditures over a relevant time period, (iv) the degree of actual public (e.g., consumer, industry such as trade and professional page 4 associations, media) recognition, and (v) consumer surveys. The fact that a respondent is shown to have been targeting the complainant’s mark (e.g., based on the manner in which the mark is used on the related website or impersonating documents or other instruments) may also support the complainant’s assertion and evidence that its mark has achieved significance as a source identifier. The claimed mark must also be used as a source identifier of goods or services e.g., on a website or on products or packaging used in commerce, provided that the mark, as used, is linked to the goods or services that are being branded with the mark; this may include use by the complainant on letterhead or invoices or email headers and signatures.” Such evidence is notably lacking in the present case with respect to the claimed mark SRIDHAR YERRAMREDDY. The Complainant’s attached evidence of distinctiveness is essentially his professional biography and media recognition surrounding the June 2026 Hearst Health award to Steer Health, which he received on behalf of the company. WIPO Overview 3.1, section 1.5.2 includes more specific guidance, based on accumulated panel decisions concerning personal names as unregistered marks: “The UDRP does not explicitly provide standing for personal names that are not registered or otherwise protected as trademarks. Where a personal name is being used as a trademark (i.e., as a source-identifier in trade or commerce), the complainant may be able to establish unregistered or common law rights in the name for purposes of standing to file a UDRP case where the name is used in commerce as a distinctive identifier of the complainant’s goods or services. Merely having a famous name (such as a businessperson or cultural/political leader who has not demonstrated use of their personal name in a trademark/source-identifying sense), or authoring an article or giving a speech, or making broad unsupported assertions regarding the use of such name in trade or commerce, would not likely demonstrate unregistered or common law rights for purposes of standing to file a UDRP complaint.” The panel in Kenes Rakishev v. Felix Sater, Regency Capital Group, WIPO Case No. D2025-1072 (“Kenes”), pointed out that some early UDRP decisions accepted claims of well-known business figures that their personal names should be treated as unregistered marks because they were strongly linked to the reputations of their respective companies. This is largely the Complainant’s argument, pointing to his position as founder and CEO first of Oculus Health and then of Steer Health. The panel in Kenes correctly observed that this approach had since been supplanted by the consensus view represented in the WIPO Overview. Rather than focusing on the professional reputation of the businessperson and his or her links with a particular company, the issue is the same as with other unregistered marks: is the personal name used in a trademark sense to distinguish specific goods or services offered on the market? This has been found to be the case with certain businesspeople, for example, who market their consulting services, speaking engagements, or publications in their own names rather than in their capacity as officers or representatives of their companies. See, e.g., Monty and Pat Roberts, Inc. v. J. Bartell, WIPO Case No. D2000-0300; Steven Rattner v. BuyThisDomainName (John Pepin), WIPO Case No. D2000-0402. By contrast, even very famous businesspeople have failed to establish unregistered trademark rights in their personal names because they could not show that the personal name was used as a mark associated with particular goods or services. See, e.g., Thomas Pritzker, The Pritzker Organization, LLC v. Richard Brown, WIPO Case No. D2009-0911. Here, the Complainant’s professional activities are distinguished but do not distinctively “brand” particular products with his personal name. The recent media reports clearly associate him with the company he leads, Steer Health, but his personal name is not used as a mark for the services advertised on the Steer Health website, and there is no evidence in the record that the Complainant is marketing books or speaking engagements, for example, under his name. In short, the record does not support the conclusion that the Complainant’s personal name has acquired secondary meaning as a common law trademark because it is associated in the market with specific goods or services. page 5 The Panel finds on this record that the first element of the Policy has not been established. B. Rights or Legitimate Interests As the Complainant has failed to establish the first element under the Policy, there is no need to reach a finding under the second element. Nevertheless, the Panel notes that while the Respondent’s former website appears to have been intended as a genuine criticism site, the growing consensus, as reported in WIPO Overview 3.1, section 2.6.2, is that even a general right to legitimate criticism does not necessarily extend to registering or using a domain name that is identical to a trademark, given the high risk of confusion and impersonation. C. Registered and Used in Bad Faith Since the Complainant has failed to establish the first element under the Policy, there is no need to address this element. 7. Decision For the foregoing reasons, the Complaint is denied. 2 /W. Scott Blackmer/ W. Scott Blackmer Sole Panelist Date: August 6, 2026 2 This decision does not, of course, determine contractual or other legal issues that are beyond the scope of the UDRP or foreclose remedies that may be available depending on a fuller development of the facts. For example, United States federal law (15 U.S.C. sec. 8131) provides a civil remedy in some circumstances if a person registers a domain name confusingly similar to the name of another living person with intent to profit from its sale.
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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