Westmore · UDRP decision
FORUM · Case No. FA2508002173322

Yelp-reviewer.com

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of <yelp-reviewer.com>, finding it confusingly similar to Complainant’s YELP mark, that Respondent lacked rights or legitimate interests, and that Respondent registered and used it in bad faith to offer competing review services while displaying Complainant’s mark.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2025-09-18
Panelist(s)
Richard Hill
Complainant
Yelp Inc.
Respondent
Ruslan Rogojinaru
Counsel
Reed Lyon
Disputed domain(s)
yelp-reviewer.com
Citation weightrelies on 12 authorities
Domain history UDRP Intelligence

The timeline behind yelp-reviewer.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 yelp-reviewer.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of yelp-reviewer.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The Panel found that Respondent lacked a legitimate intended use, used the domain to offer competing services in bad faith under Policy ¶ 4(b)(iv), and registered it with actual knowledge of Complainant’s rights, evidenced by the website’s display of Complainant’s mark.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registered and used in bad faithMet

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

Related decisions
Case details
Provider
FORUM
Outcome
Transfer
Decision date
2025-09-18
Panel
Richard Hill
Full decision
11 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Yelp Inc. v. Ruslan Rogojinaru Claim Number: FA2508002173322 PARTIES Complainant is Yelp Inc. ("Complainant"), represented by Reed Lyon, California, USA. Respondent is Ruslan Rogojinaru ("Respondent"), Moldova. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <yelp-reviewer.com>, registered with NameSilo, LLC. PANEL The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding. Richard Hill as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on August 25, 2025; Forum received payment on August 25, 2025. On August 25, 2025, NameSilo, LLC confirmed by e-mail to Forum that the <yelp-reviewer.com> domain name is registered with NameSilo, LLC and that Respondent is the current registrant of the name. NameSilo, LLC has verified that Respondent is bound by the NameSilo, LLC 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 August 28, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of September 17, 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@yelp-reviewer.com. Also on August 28, 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 September 18, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Richard Hill 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 states that, founded in 2004, it owns and operates Yelp.com, a popular local search website, mobile website, and related mobile applications for users to share information about their communities. Complainant, among other things, provides and publishes a forum for members of the public to read and write reviews. The YELP mark is famous, and the public identifies it with Complainant and for use in connection with third-party businesses. As of December 31, 2024, users had posted over 308 million cumulative reviews to the Yelp Service since its inception. In 2024, a survey showed that 96% of Complainant's users hire or buy from a business they found on the Service. Complainant asserts rights in the mark YELP through its registration in the United States in 2006. According to Complainant, the disputed domain name is confusingly similar to its YELP mark as it incorporates the mark in its entirety, while merely adding the generic/descriptive term "reviewer," a hyphen, and the ".com" generic top-level domain ("gTLD"). Complainant alleges that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent is not commonly known by the disputed domain name nor has Respondent been authorized by Complainant to use its mark. Respondent has not used the disputed domain name in connection with a bona fide offering of goods or services. Instead, the disputed domain name resolves to a page for a purported business in an improper attempt to pass the webpage(s) off as the Yelp Service: it displays what appears to be a deceptive review made to look as if it were written by actual users of Complainant's Service. Further, says Complainant, Respondent registered and uses the disputed domain name in bad faith. The resolving website attempts to impersonate Complainant. Respondent had actual knowledge of Complainant's rights to the YELP mark prior to registering the disputed domain name based on Respondent's use of Complainant's mark. Respondent used a privacy service. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant has rights in the mark YELP dating back to 2006 and uses it to provide web sites and mobile applications for users to share information about their communities. The disputed domain name was registered in 2025. Complainant has not licensed or otherwise authorized Respondent to use its mark. The resolving website displays Complainant's mark and purports to provide a review that competes with Complainant's services. 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 disputed domain name incorporates Complainant's YELP mark in its entirety, merely adding the generic/descriptive term "reviewer", a hyphen, and the generic top-level domain ("gTLD") ".com." Panels have found such alterations to a mark to be insufficient in overcoming a finding of confusing similarity under Policy ¶ 4(a)(i). See Morgan Stanley v. Eugene Sykorsky / private person, FA 1651901 (Forum Jan. 19, 2016) (concluding that the addition of a generic term and top level domain to a trademark is inconsequential under a Policy ¶ 4(a)(i) analysis.); see also Vanguard Group Inc. v. Proven Fin. Solutions, FA 572937 (Forum Nov. 18, 2005) (holding that the addition of both the word "advisors" and the gTLD ".com" did not sufficiently alter the disputed domain name to negate a finding of confusing similarity under Policy ¶ 4(a)(i)); see also Sports Auth. Mich. Inc. v. Batu 5, FA 176541 (Forum Sept. 23, 2003) ("The addition of a hyphen to Complainant's mark does not create a distinct characteristic capable of overcoming a Policy ¶ 4(a)(i) confusingly similar analysis."). Therefore, the Panel finds that the disputed domain name is confusingly similar to Complainant's mark under Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant has not licensed or otherwise authorized Complainant to use its mark. Respondent is not commonly known by the disputed domain name: when a response is lacking, relevant WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name under Policy ¶ 4(c)(ii). See Chevron Intellectual Property LLC v. Fred Wallace, FA 1626022 (Forum July 27, 2015) (finding that the respondent was not commonly known by the <chevron-europe.com> domain name under Policy ¶ 4(c)(ii), as the WHOIS information named "Fred Wallace" as registrant of the disputed domain name). Here, the WHOIS information for the disputed domain name lists the registrant as "Ruslan Rogojinaru". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii). The resolving website purports to offer a review that competes with the services offered by Complainant. Panels have held that using another's mark to resolve to a website that offers products or services in competition with a Complainant's business is not using the domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use. See Coachella Music Festival, LLC v. josh greenly / All Access Tickets, FA 1629217 (Forum Aug. 10, 2015) (finding that the respondent had failed to provide a bona fide offering of goods or services or a legitimate noncommercial or fair use of the disputed domain name as required under Policy ¶ 4(c)(i) and Policy ¶ 4(c)(iii), where the respondent was using the disputed domain name to host a web page that featured links to services that competed with those of the complainant); see also See General Motors LLC v. MIKE LEE, FA 1659965 (Forum Mar. 10, 2016) (finding that "use of a domain to sell products and/or services that compete directly with a complainant's business does not constitute a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy ¶ 4(c)(iii)"). Thus, the Panel finds that Respondent fails to use the disputed domain name to make a bona fide offering of goods or services under Policy ¶¶ 4(c)(i) or (iii). And the Panel finds that Respondent does not have rights or legitimate interests in the disputed domain name. Registration and Use in Bad Faith Respondent (who did not reply to Complainant's contentions) has not presented any plausible explanation for its use of Complainant's mark. In accordance with paragraph 14(b) of the Rules, the Panel shall draw such inferences from Respondent's failure to reply as it considers appropriate. Accordingly, the Panel finds that Respondent did not have a legitimate use in mind when registering the disputed domain name. Indeed, as already noted, the resolving website purports to offer competing services. This constitutes bad faith registration and use under Policy ¶ 4(b)(iv). See Asbury Auto Group Inc v Tex. Int'l Prop Assocs FA 958542 (Forum May 29, 2007) (finding that the respondent's use of the disputed domain name to compete with the complainant's business would likely lead to confusion amongst Internet users as to the sponsorship or affiliation of a competing business and was therefore evidence of bad faith and use); see also See Xylem Inc. and Xylem IP Holdings LLC v. YinSi BaoHu YiKaiQi, FA 1612750 (Forum May 13, 2015) ("The Panel agrees that Respondent's use of the website to display products similar to Complainant's, imputes intent to attract Internet users for commercial gain, and finds bad faith per Policy ¶ 4(b)(iv)."). Accordingly, the Panel finds bad faith registration and use per Policy ¶ 4(b)(iv). Further, Respondent registered the disputed domain name with actual knowledge of Complainant's mark: the resolving website displays Complainant's mark. While constructive notice is insufficient to demonstrate bad faith, actual knowledge of a complainant's rights in a mark prior to registration may be evidence of bad faith per Policy ¶ 4(a)(iii). See Custom Modular Direct LLC v. Custom Modular Homes Inc., FA 1140580 (Forum Apr. 8, 2008) ("There is no place for constructive notice under the Policy."); see also Orbitz Worldwide, LLC v. Domain Librarian, FA 1535826 (Forum Feb. 6, 2014) ("The Panel notes that although the UDRP does not recognize 'constructive notice' as sufficient grounds for finding Policy ¶ 4(a)(iii) bad faith, the Panel here finds actual knowledge through the name used for the domain and the use made of it."); see also Univision Comm'cns Inc. v. Norte, FA 1000079 (Forum Aug. 16, 2007) (rejecting the respondent's contention that it did not register the disputed domain name in bad faith since the panel found that the respondent had knowledge of the complainant's rights in the UNIVISION mark when registering the disputed domain name). The Panel finds that Respondent had actual knowledge of Complainant's rights in the mark prior to Respondent's registration of the disputed domain name and that this constitutes bad faith under Policy ¶ 4(a)(iii). 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 <yelp-reviewer.com> domain name be TRANSFERRED from Respondent to Complainant. Richard Hill, Panelist Dated: September 18, 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.

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