Teslasharehubs.com

The timeline behind teslasharehubs.com

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.

NATIONAL ARBITRATION FORUM DECISION Tesla, Inc. v. Steve Chow Claim Number: FA2506002163145 PARTIES Complainant is Tesla, Inc. ("Complainant"), represented by Chad Jalandoni of ArentFox Schiff LLP, District of Columbia, USA. Respondent is Steve Chow ("Respondent"), Washington, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <teslasharehubs.com>, registered with Ultahost, Inc. PANEL The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding. The Honorable Neil Anthony Brown KC as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on June 27, 2025; Forum received payment on June 27, 2025. On July 8, 2025, Ultahost, Inc. confirmed by e-mail to Forum that the <teslasharehubs.com> domain name is registered with Ultahost, Inc. and that Respondent is the current registrant of the name. Ultahost, Inc. has verified that Respondent is bound by the Ultahost, Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy"). On July 8, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 28, 2025 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@teslasharehubs.com. Also on July 8, 2025, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts. Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. On July 29, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed The Honorable Neil Anthony Brown KC as Panelist. Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent. RELIEF SOUGHT Complainant requests that the domain name be transferred from Respondent to Complainant. PARTIES' CONTENTIONS A. Complainant Complainant made the following contentions. 1. The Complainant is a United States company engaged in the manufacture and sale of motor vehicles and related goods and services and has been so engaged since at least as early as 2003. 2. The Complainant provides its goods and services under the trademark for TESLA. 3. The Complainant acquired its registered trademark rights in the TESLA trademark by virtue of its registration of that trademark in the United States Patent and Trademark Office ("USPTO"), registration number 4443472, registered on December 3, 2013, and other trademarks registered domestically and internationally for TESLA (collectively "the TESLA trademark"). 4. The TESLA trademark has attracted substantial goodwill and is uniquely associated with the Complainant's goods and services. 5. As well as its trademark, the Complainant has registered the <tesla.com> domain name that it uses in its business and in particular for its website at www.tesla.com, where it markets its goods and services under the TESLA trademark. 6. The Respondent registered the <teslasharehubs.com> domain name on February 14, 2016 ("the disputed domain name") well after the Complainant had established its aforesaid trademark rights in 2013. 7. The disputed domain name embodies, without the consent of the Complainant, the TESLA trademark, with the addition of the words "share" and "hubs" and the generic Top Level Domain ".com". 8. The disputed domain name is confusingly similar to the TESLA trademark. 9. The Respondent has no rights or legitimate interests in the disputed domain name. That is so because: (a) the Respondent is not commonly known by the disputed domain name within the meaning of Policy ¶ 4(c)(ii); (b) the Respondent has not been licensed or authorized by the Complainant to use the TESLA trademark or to register a domain name incorporating that trademark; (c) the Respondent is impersonating and passing itself off as the Complainant; (d) the Respondent has registered and used the domain name to perpetrate a fraud and for phishing; (e) the Respondent has not used the domain name for a bona fide offer of goods or services within the meaning of Policy ¶ 4(c)(i); (f) the Respondent has not used the disputed domain name for a legitimate, noncomnmercial or fair use within the meaning of Policy ¶ 4(c)(iii); and (g) there is no other ground on which it could conceivably be shown that the Respondent has a right or legitimate interest in the disputed domain name. 10. The Respondent has registered and used the disputed domain name in bad faith. That is so because: (a) the Respondent has registered and used the domain name to perpetrate a fraud, for phishing and to trade on and benefit from the Complainant's goodwill; (b) the Respondent has not used the disputed domain name for any legitimate purpose; (c) at the time the Respondent registered the disputed domain name, it had actual knowledge of the Complainant, its business and its trademark which had been used by the Complainant for several years; (d) the Respondent has registered and used the domain name to impersonate the Complaint; (e) the Respondent registered and used the domain name in breach of Paragraph 2 of the Policy; and (f) all of the acts, facts, matters and circumstances revealed by the evidence have shown that the Respondent registered and used the disputed domain name in bad faith. The evidence will therefore establish that the Complainant has been able to make out all of the grounds it must establish and that it is entitled to the relief that it seeks. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS 1. The Complainant is a United States company engaged in the manufacture and sale of motor vehicles and related goods and services and has been so engaged since at least as early as 2003. 2. The Complainant provides its goods and services under the trademark for TESLA. 3. The Complainant acquired its registered trademark rights in the TESLA trademark by virtue of its registration of that trademark in the United States Patent and Trademark Office ("USPTO"), registration number 4443472, registered on December 3, 2013, and other trademarks registered domestically and internationally for TESLA (collectively "the TESLA trademark"). 4. The Respondent registered the <teslasharehubs.com> domain name on February 14, 2016 ("the disputed domain name") well after the Complainant had established its aforesaid trademark rights in 2013. 5. The Respondent has registered the disputed domain name and used it to resolve to a website purporting to offer a genuine and official investment when in fact the website and its alleged offering were a fraud on internet users, deceptive, infringed and tarnished the Complainant's trademark, impersonated and passed the Respondent off as the Complainant, disrupted the Complainant's business and generated confusion. 6. By reason of the matters aforesaid, and as established by the evidence, the disputed domain name is confusingly similar to the TESLA trademark, the Respondent has no rights or legitimate interests in the disputed domain name and the disputed domain name has been registered and used in bad faith. 7. Accordingly, the disputed domain name should be transferred from the Respondent to the Complainant. DISCUSSION Paragraph 15(a) of the Rules instructs this Panel to "decide a 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." Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred: (1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (2) Respondent has no rights or legitimate interests in respect of the domain name; and (3) the domain name has been registered and is being used in bad faith. In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint"). Identical and/or Confusingly Similar The first question that arises is whether the Complainant has rights in a trademark or service mark on which it may rely. The evidence is that the Complainant provides its aforesaid goods and services under the TESLA trademark. The evidence shows that the Complainant acquired its registered trademark rights in the TESLA trademark by virtue of its registration of that trademark in the United States Patent and Trademark Office ("USPTO"), registration number 4443472, registered on December 3, 2013, and other trademarks registered domestically and internationally for TESLA (collectively "the TESLA trademark"). The trademark is registered in the name of the Complainant, is registered with respect to automobiles and structural parts therefor and is in current use. All of the aforesaid facts have been established by documentary evidence that the Panel has examined and finds to be in order. The Complainant has thus established its trademark rights as required by Policy ¶ 4(a)(i) and hence its standing to bring this proceeding. The next question that arises is whether the disputed domain name is identical or confusingly similar to the Complainant's TESLA trademark. The Panel finds that the disputed domain name is confusingly similar to the TESLA trademark. That is because it embodies the TESLA trademark, with the addition of the words "share" and "hubs" and the generic Top Level Domain ".com". When a domain name includes a trademark, as in the present case, it is more likely than not that the domain name is confusingly similar to the trademark. In the present case it is obviously so. Thus, internet users would read the domain name as invoking the TESLA trademark and the well-known and popular motor vehicles of that name provided by the Complainant under its trademark. The domain name, secondly, includes the words "share" and "hubs" run together to read "sharehubs". This would probably be taken by most internet users to mean, as the Complainant suggests, a central hub for the sharing of official information relating to the Complainant or, possibly, as a source of information concerning the shares or other financial information relating to the Complainant. Thus, internet users would read the domain name as invoking the TESLA trademark and the well-known and popular vehicles its makes and other services also provided by the Complainant, leaving the effect of the word TESLA as the dominant and most important aspect of the domain name. All of this makes the domain name similar to the trademark and confusingly so, because it raises the question whether the domain name is an official and genuine domain name of the Complainant or not. The Top Level Domain ".com" is disregarded in making this comparison as it does not inform the reader one way or the other whether a domain name is confusingly similar to a trademark, as all domain names must have such an extension. Thus, the disputed domain name is confusingly similar to the TESLA trademark. The Complainant has thus made out the first of the three elements that it must establish under the Policy. Rights or Legitimate Interests It is now well established that the Complainant must first make a prima facie case that the Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii) and that, if the prima facie case is made out, the burden then shifts to the Respondent to show that it does have such rights or legitimate interests. See Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)). The Panel finds on the evidence that the Complainant has made out a prima facie case that arises from the following considerations. The Respondent has no rights or legitimate interests in the disputed domain name on all of the grounds relied on by the Complainant, namely: (a) the Respondent is not commonly known by the disputed domain names within the meaning of Policy ¶ 4(c)(ii); there is no evidence that the Respondent is known by the domain name, either commonly or at all, and there is no evidence that it is known by any name other than its own, which is Steve Chow; (b) the Respondent has not been licensed or authorized by the Complainant to use the TESLA trademark or to register a domain name incorporating the trademark; thus it could not be contended that the domain name was registered and used with anything like consent of the Complainant who of course is opposed to this registration and use and has brought this claim to obtain the domain name: (c) the Respondent is impersonating and passing itself off as the Complainant; this ground has clearly been established by the evidence; the Respondent is perpetrating a fraud and to do so it has impersonated the Complainant to take advantage of its famous and prestigious name; this is amply shown by Annex F which is "Screenshots of the Website at the Disputed Domain Name"; in other words it is what unsuspecting internet users see when they go to the website to which the offending domain name resolves; here they are greeted by an investment proposal where all they have to do is take out a membership, hand their money over and they will receive a 400% return, with the first payment materializing in "3 business days"; those who join up at the Gold Membership level are promised that they will also receive a Tesla Model 3 vehicle, as well as their 400% and those who join up at the Executive level will receive their 400% and also a Tesla Cybertruck; some indication of the financial expertise of those promoting this fraud can be seen by their repeated use of the word "invetment" (sic) and other misspellings; more significantly, the fraud is perpetrated by the repeated use of the Complainant's TESLA trademark; the whole thing is obviously a fraud carried out under the imprimatur of the Complainant's name and trademark; it has also been successful, at least to some extent, as is seen by Annex G which is "Consumer Complaint Regarding the Disputed Domain Name and Representative Images of Communications, Deposits Made, Membership Card, and Fake Passport"; this shows the actual experience of a consumer who "invested" and lost $60,000 through this fraudulent scheme, apparently believing the blandishments offered by the Respondent, including that the obviously fake passport of Mr. Elon Musk that it allegedly provided was genuine; it is also clear that, in all probability, one of the driving forces behind this subterfuge was to obtain personal and financial information from internet users; the Panel will not burden the reader by reciting any more content from the offending website, other than to say that this content is in evidence, it is extensive and it proves beyond any doubt that the Respondent registered and used the domain name for a fraud and that this negates entirely any suggestion that the Respondent could have a right or legitimate interest in the domain name which it does not have; (d) the Respondent has registered and used the domain name to perpetrate a fraud and for phishing; this has already been established by the evidence; (e) the Respondent has not used the domain name for a bona fide offer of goods or services within the meaning of Policy ¶ 4(c)(i); there is nothing bona fide in what the Respondent has done, and the expression mala fide is more appropriate; (f) the Respondent has not used the disputed domain name for a legitimate, noncomnmercial or fair use within the meaning of Policy ¶ 4(c)(iii); there is nothing legitimate in the Respondent's conduct, it was clearly commercial and it was not fair, either to the Complainant or to internet users in general; and (g) it is obvious from the evidence that there is no other ground on which it could conceivably be shown that the Respondent has a right or legitimate interest in the disputed domain name. The Complainant has thus made out a persuasive and detailed case on the evidence for all of the grounds it relies on to show that the Respondent does not have a right or legitimate interest in the disputed domain name. All of these matters make out the prima facie case against the Respondent. The Respondent has not filed a Response and is in default and has thus not rebutted the prima facie case against it. The Complainant has therefore made out the second of the three elements it must establish under the Policy. Registration and Use in Bad Faith It is clear that to establish bad faith for the purposes of the Policy, the Complainant must show that the disputed domain name was registered and used in bad faith. It is also clear that the criteria set out in Policy ¶ 4(b) are not exclusive but that domain name proceedings may also rely on conduct that is bad faith within the generally accepted meaning of that expression. In view of the evidence discussed above, which is equally as applicable to bad faith as it is to rights and legitimate interests and which it is not necessary to repeat here, it is clear that the Complainant has made out all of the grounds relied on. The Respondent has clearly been motivated by bad faith in the registration of the domain name and has continued in that conduct after its registration; the registration was clearly an attempt by the Respondent to use the Complainant's trademark improperly and to solicit internet users to give money to the Respondent under the guise of its being an investment with the Complainant, which it was not, and to give the false impression that money paid to the Respondent would be a genuine investment with the Complainant which it clearly would not be, and that the whole investment structure was genuine when it fact it was deceptive; it is equally clear from the evidence that the Respondent has used the domain name in bad faith in the deception of potential users, amply demonstrated by the evidence referred to above. In particular, it is clear from the evidence that, as the Complainant has submitted: (a) the Respondent has registered and used the domain name to perpetrate a fraud, for phishing and to trade on and benefit from the Complainant's goodwill; this has clearly been established and it is not necessary to repeat the evidence to that effect which has been discussed above; it may also be said here that the effect of the fraud must have been to disrupt the Complainant's business and to generate confusion between the Complainant and the Respondent; (b) the Respondent has not used the disputed domain name for any legitimate purpose; that has also been established, as a fraud cannot be legitimate; (c) at the time the Respondent registered the disputed domain name, it had actual knowledge of the Complainant, its business and its trademark which had been used by the Complainant for many years; the Respondent must have had such actual knowledge to enable it to concoct the subterfuge, of which using the Complainant's trademark and the domain name incorporating it were essential features; (d) the Respondent has registered and used the domain name to impersonate the Complaint; the evidence shows that this is a classic case of impersonation and passing off; (e) the Respondent registered and used the domain name in breach of paragraph 2 of the Policy; clearly the Respondent knew that if it registered the domain name it would infringe and violate the Complainant's trademark rights and yet it went ahead, which was a clear breach of the Policy and the law in general; and (f) all of the acts, facts, matters and circumstances revealed by the evidence have shown that the Respondent registered and used the disputed domain name in bad faith. Finally, in addition to the specific provisions of the Policy and having regard to the totality of the evidence, the Panel finds that, in view of the Respondent's registration of the disputed domain name using the TESLA trademark and in view of the conduct of the Respondent, as shown by all of the available evidence, the Respondent registered and used the disputed domain name in bad faith within the generally accepted meaning of that expression. It is clear that, from the beginning, the Respondent set about targeting the Complainant and internet users, impersonated and passed itself off as the Complainant, infringed and tarnished the Complainant's trademark, and actively sought to mislead internet users to believe that the alleged investment offered on the Respondent's website was a genuine and official offer of a legitimate and honest investment offer with the Complainant, which it was not. The Complainant has thus made out the third of the three elements that it must establish. The Complainant has presented a detailed and persuasive case consisting of evidence that has established all of the constituent elements that must be proved under the Policy. The Complainant has also cited numerous prior UDRP decisions which support all of its contentions. The Complainant is therefore entitled to the relief it seeks, namely transfer of the disputed domain name. DECISION Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED. Accordingly, it is Ordered that the <teslasharehubs.com> domain name be TRANSFERRED from the Respondent to the Complainant. The Honorable Neil Anthony Brown KC Panelist Dated: July 30, 2025 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page

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