Copart-iaai-api.com

The timeline behind copart-iaai-api.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 Copart, Inc. v. Людмила Захаровна Тырса Claim Number: FA2510002186152 PARTIES Complainant is Copart, Inc. ("Complainant"), represented by Rob LeBlanc, of Greenberg Traurig, LLP, Texas, USA. Respondent is Людмила Захаровна Тырса ("Respondent"), Ukraine. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <copart-iaai-api.com>, registered with Internet Invest, Ltd. dba Imena.ua. 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. Nathalie Dreyfus as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on October 30, 2025; Forum received payment on October 30, 2025. On October 31, 2025, Internet Invest, Ltd. dba Imena.ua confirmed by e-mail to Forum that the <copart-iaai-api.com> domain name is registered with Internet Invest, Ltd. dba Imena.ua and that Respondent is the current registrant of the name. Internet Invest, Ltd. dba Imena.ua has verified that Respondent is bound by the Internet Invest, Ltd. dba Imena.ua 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 October 31, 2025, Forum served the Complaint and all Annexes, including a Ukrainian and English Written Notice of the Complaint, setting a deadline of November 20, 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@copart-iaai-api.com. Also on October 31, 2025, the Ukrainian and English 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. A timely Response was received and determined to be complete on November 6, 2025. An Additional Submission was filed by the Complainant on November 6, 2025. Respondent submitted a further reply on November 7, 2025. On November 7, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nathalie Dreyfus 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. RELIEF SOUGHT Complainant requests that the domain name be transferred from Respondent to Complainant. PRELIMINARY ISSUE: LANGUAGE OF PROCEEDING According to the Registrar, the registration agreement is written in Ukrainian. Rule 11(a) provides that the language of the proceedings is the language of the registration agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the case. Complainant filed its Amended Complaint in English and additional submissions in English and requests that these proceedings be conducted in English. The Panel finds persuasive evidence to suggest the likely possibility that Respondent is to a material degree conversant and proficient in the English language. Factors which previous panels have seen as important include evidence showing that the respondent can understand the language of the complaint, the language of the domain name, the content on any web pages resolving from the domain name, prior correspondence between the parties, and potential unfairness or unwarranted delay in ordering translation of the pleadings and the Decision." See Copart, Inc. v. hu xiao long, FA 2098970 (Forum June 19, 2024). The website located at the Disputed Domain Name features only English language content. It follows that the Respondent is familiar with the English language as its response and additional submission are written in English.. Finally, Respondent registered the Disputed Domain Name in connection with the ".com" generic Top-Level Domain, which primarily targets English speaking Internet users, Complainant has provided sufficient evidence of Respondent's proficiency in English. For the reasons set forth above, the Panel determines that the proceedings should continue in English. PARTIES' CONTENTIONS A. Complainant The Complainant's contentions can be resumed as follows: First, the domain name is identical or confusingly similar to the Complainant's well-known COPART trademark. The domain wholly incorporates the COPART trademark as its first and dominant element and adds "IAAI" (a competitor's name) and the descriptive term "API", which only increases the likelihood that Internet users will believe the site is an official or authorized data platform jointly operated by Copart and IAAI. Second, the Respondent has no rights or legitimate interests in the domain name. The Respondent is not affiliated with Copart, not authorized to use the COPART trademark, and not commonly known by that name. The website misuses the COPART trademark and logo and presents itself as "Copart-IAAI-API.com – Your One-Stop Solution for Auto Auction Data". It also reproduces Copart's protected images and data without permission. The Respondent charges between $200 and $500 per month for alleged VIN decoder and API plans, falsely suggesting legitimate access to Copart and IAAI auction data. The site contains no disclaimer, and its only purpose is to capitalize on the Complainant's reputation for commercial gain. Third, the domain name was registered and is being used in bad faith. COPART is a famous trademark worldwide, and the Respondent could not plausibly have been unaware of it. The Respondent intentionally chose a domain name combining two well-known competitors' trademarks in order to attract users by creating confusion as to source, affiliation, sponsorship, or endorsement. The website monetizes Copart's proprietary auction data and copyrighted photos, constitutes clear impersonation, and exploits users seeking Copart's legitimate services. Prior UDRP decisions involving Copart confirm that such conduct constitutes opportunistic bad faith. B. Respondent The Respondent's contentions can be resumed as follows: The Respondent requests that the Complaint be denied in its entirety and that the disputed Domain Name remain with the Respondent. First, the Respondent contends that the Domain Name is not confusingly similar to the Complainant's COPART Trademarks. In fact, although the domain name includes the word "Copart", its use is purely descriptive and nominative, to indicate the category of data sources accessible via the API. According to the Respondent, the Domain Name is not identical to Complainant's trademarks because it includes two unrelated auction names and the technical term API, making it clear that it is not an official Copart website. Second, the Respondent claims legitimate rights in the Domain Name. According to the Respondent, he operates a genuine business providing a data-integration service (API) for developers, using only publicly available auction data. The use of the words "Copart" and "IAAI" serves to describe compatibility and the origin of publicly available data, which constitutes nominative fair use. Thus, the Respondent is not using the domain to impersonate Copart or to mislead customers. Finally, the Respondent denies any bad faith. The domain was registered to describe a technical API service, not to sell, rent, or exploit Copart's trademarks. The site was never used for phishing, deception, or misrepresentation. The inclusion of "IAAI" and "API" further demonstrates that the intent was only descriptive. Upon receiving notice of this dispute, Respondent immediately removed all potential confusion sources and published clear legal disclaimers. Indeed, the Respondent has: · Rebranded the service visually under the neutral name "Auction History"; · Removed all Copart and IAAI logos and branding; · Added explicit disclaimers across the site (homepage, footer, Privacy Notice, Terms & Conditions); · Implemented a "Legal Notice" acknowledging all trademarks belong to their respective owners; · Stored evidence of these changes According to the Respondent, these actions prove good faith registration and use. C. Complainant's Additional Submissions The Complainant's additional submissions can be resumed as follows: First, the Complainant considers that the facts must be evaluated as they existed as the time of filing. Thus, at the time of filing, there were no disclaimers or distinguishing features that would have signalled the site's independence from Copart. Respondent branded itself using the COPART name, creating the clear impression of affiliation or sponsorship. These facts establish confusion and bad faith at the time of filing, facts which cannot be retroactively erased. Second, the Complainant states the Domain Name itself continues to be confusing or misleading. The Domain Name still combines Copart's trademarks with the name of its competitor and a technical descriptor. Third, the Complainant thinks Respondent's actions reinforce bad faith, rather than rebut it. In fact, Respondent's immediate post-filing deletions of Copart's logo and rebranding efforts confirm that it knew its prior conduct was improper, confusing and opportunistic. D. Respondent's Additional Submissions The Respondent's additional submissions can be summarized as follows: The Respondent asks the Panel to deny the Complaint and allow him to retain the domain name <copart-iaai-api.com>, arguing more broadly that the UDRP should not be used to prevent descriptive uses relating to interoperability services. First, the Respondent reiterates that he operates a legitimate developer API using only publicly available or user-provided data, and that the terms "Copart" and "IAAI" are used nominatively to describe compatible data sources. He repeats that the website is aimed at technical users, does not claim to be official, and does not sell branded goods. Second, the Respondent again denies any bad faith, stating that he did not intend to exploit confusion for commercial gain when registering the domain name. He contends that the Complainant has not demonstrated any intent to mislead or any evidence of actual confusion, and he emphasizes that any early marketing language was quickly corrected. This argument largely restates his previous position. Third, the Respondent repeats that the Complainant's references to the "post-complaint edits" principle are misplaced because, in his view, bad faith was never established in the first place. FINDINGS The Domain Name was registered on May 30, 2024 by Людмила Захаровна Тырса. The Complainant, Copart, Inc. owns the following trademarks: - COPART, the U.S federal trademark N° 3941221, registered on April 5, 2011, and duly renewed in class 35. - COPART, the U.S federal trademark N° 4601885, registered on September 9, 2014, and duly renewed, in class 35 and class 42. - COPART, the U.S federal trademark N° 4601884, registered on September 9, 2014 in class 35 and class 42. - COPART, the Ukraine trademark N° 318041, registered on May 4, 2022 in class 35, 39, 41 et 42. 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. Identical and/or Confusingly Similar The Panel finds that the Complainant has rights in the COPART trademarks based on the registration certificates submitted, showing U.S. federal and Ukrainian trademark registrations dating back to 2011. The Panel further finds that the Domain Name <copart-iaai-api.com> is confusingly similar to the Complainant's COPART trademarks. Indeed, the domain name reproduces in its entirety the Complainant prior trademarks rights "COPART" with the mere addition of other terms, namely "IAAI" and "API". The inclusion of the competitor brand "IAAI" in combination with COPART does not dispel confusion. On the contrary, domain names that combine two competing trademarks are considered confusingly similar to each individual trademark, as each trademark remains clearly recognizable within the domain name. See, e.g., Philip Morris USA Inc. v. WhoisGuard / Mark Jayson David, WIPO Case No. D2016-2194 The inclusion of a descriptive technical acronym as "API" in combination with COPART does not remove the confusing similarity between domain names. See, e.g., IMDb.com, Inc. v. IMDb / API, FA 2073735 (Forum December 29, 2023). It is well established that the complete incorporation of a complainant's trademark in a domain name is sufficient to establish confusing similarity, even where additional words or hyphens appear. Accordingly, the Panel finds that the Complainant has established the first element of the Policy. Rights or Legitimate Interests Paragraph 4(c) of the Policy lists three circumstances in particular, without limitation, that demonstrate rights or legitimate interest of a domain name registrant to a domain name, for the purposes of paragraph 4(a)(ii) of the Policy: (i) before any notice of the dispute, the Respondent's use of, or demonstrable preparations to use the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods and services; or (ii) the Respondent, as an individual, business, or other organization, has been commonly known by the domain name, even if no trademark or service mark rights have been acquired; or (iii) the Respondent is making a legitimate non‑commercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. The Complainant's assertion that Respondent lacks rights or legitimate interests in the Domain Name establishes a prima facie case under the Policy. Once a prima facie case has been established, the burden shifts to Respondent to demonstrate that it does have rights or legitimate interests pursuant to Policy 4(c). Under paragraph 4(c)(i) of the Policy, the Respondent will have rights to or legitimate interests in the Disputed Domain Name if, before any notice of the dispute, it had used or made demonstrable preparations to use the Domain Name in connection with a bona fide offering of goods or services. The Respondent registered a combination of the names of two competitors and a technical term as a domain name and used the domain name to provide a data-integration service (API) for developers, using only publicly available auction data. While the Respondent's website was functional at the time of the Complainant's notice, the Respondent has not provided sufficient evidence to demonstrate that the business conducted via the Domain Name was bona fide to the notice. Indeed, by directly copying Complainant's Trademarks and purporting to offer legitimate services also provided by Complainant without any prior disclaimer, it is clear that the purpose of Respondent's use and registration of the Disputed Domain Name is to create confusion among Internet users, which does not constitute a bona fide offering of goods and services. Additionally, the Panel finds that the Respondent does not own any right on the COPART Trademarks and the Complainant has never authorized or permitted the Respondent to use the COPART Trademarks or use it to register any domain name consisting of the COPART trademarks. Indeed, Respondent never requested Complainant's permission to use Complainant's Trademarks. Additionally, there is no evidence that suggests the Respondent is commonly known by the Domain Name pursuant to Policy 4(c)(ii). Respondent is known to this Panel only as Людмила Захаровна Тырса. Although Respondent expressed his willingness to remove from his website any affiliation, endorsement, or association with Complainant, the Panel finds that the structure of the Domain Name itself conveys such affiliation, endorsement, or association. Any new website to which the domain name redirects is therefore likely to cause initial confusion among internet users, even if that website contains statements excluding any affiliation. Accordingly, the Panel finds that the Respondent has no rights or legitimate interests in respect of the Domain Name. Registration and Use in Bad Faith Paragraph 4(b) of the Policy sets out four illustrative circumstances, which, though not exclusive, shall be evidence of the registration and use of the domain name in bad faith for purposes of paragraph 4(a)(iii) of the Policy, including: (iv). by using the domain name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website or other on-line location, by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent's website or location or of a product or service on its website or location. The Domain Name was registered on May 30, 2022, after the registration of Complainant's Trademarks. Before Complainant initiated proceedings, the disputed Domain Name pointed to a website that used Complainant's intellectual property and claimed to offer information, data and photos relating to Complainant, proving that Respondent was indeed aware of Complainant's rights to the Copart Trademarks when it registered the Domain Name. Respondent's use of the Disputed Domain Name to solicit business and obtain payments for selling data and information owned by Complainant constitutes evidence of bad faith registration and use of the domain name under Policy 4(b)(iv) because Respondent seeks to attract users to its Domain Name for commercial gain. More precisely, by registering and using a domain name that is confusingly similar to the Complainant's trademarks, the Respondent intentionally seeks to attract Internet users to its website for commercial gain by creating a likelihood of confusion as to the source, sponsorship, affiliation, or endorsement of that website. See G.D. Searle & Co. v. James Mahony, FA 112559 (Forum June 12, 2002). Although the Respondent expressed a willingness to remove from his website any references suggesting affiliation, endorsement, or association with the Complainant, the Panel must assess Respondent's conduct before and at the time the Complaint was filed, not changes made after service of the Complaint. In any event, such post-filing edits cannot cure the inherent confusion created by the domain name itself, which continues to combine the COPART trademark with the competitor name "IAAI" and therefore remains confusing regardless of the website's current content. All the circumstances set out above satisfy the Panel that Respondent was fully aware of Complainants' COPART trademarks when Respondent registered the <copart-iaai-api.com > Domain Name and that Respondent registered the domain name in bad faith. This demonstrates registration and use in bad faith to attract users for commercial gain under Policy, 4(b)(iv). 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 <copart-iaai-api.com> domain name be TRANSFERRED from Respondent to Complainant. Nathalie Dreyfus, Panelist Dated: 11/18/2025 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.