Westmore · UDRP DecisionBlockechange.com
The Panel ordered transfer of <blockechange.com> after finding it confusingly similar to Complainant's registered BLOCKCHANGE mark, finding Respondent lacked rights or legitimate interests, and finding bad-faith registration and use based on actual knowledge and diversion to a competing financial-services website.
The timeline behind blockechange.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 blockechange.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The Panel found that Respondent had actual knowledge of the BLOCKCHANGE mark when registering the Domain Name and intentionally used the misspelled mark to redirect users to a website offering competing financial and cryptocurrency investment services. This established bad-faith registration and use under Policy ¶ 4(b)(iii).
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
NATIONAL ARBITRATION FORUM DECISION Blockchange Ventures I GP, LLC v. Feven Mebratu / BlockChange Claim Number: FA2511002187643 PARTIES Complainant is Blockchange Ventures I GP, LLC ("Complainant"), represented by Vanessa A. Ignacio of Lowenstein Sandler LLP, New Jersey, USA. Respondent is Feven Mebratu / BlockChange ("Respondent"), Netherlands. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <blockechange.com> ("Domain Name"), registered with NameCheap, Inc. 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. Nicholas J.T. Smith as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on November 7, 2025; Forum received payment on November 7, 2025. On November 8, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <blockechange.com> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, 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 November 13, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of December 3, 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@blockechange.com. Also on November 13, 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 December 4, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nicholas J.T. Smith 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 is an American company founded in 2017 that provides specialist investment services specializing in cryptocurrency companies and blockchain technologies. Since 2017 Complainant has offered financial services under the BLOCKCHANGE mark. Complainant has rights in the BLOCKCHANGE mark through its registration with the United States Patent and Trademark Office ("USPTO") (e.g. Reg. No. 5,676,113, registered on February 12, 2019). Respondent's <blockechange.com> domain name is confusingly similar to Complainant's BLOCKCHANGE because it contains a minor misspelling of the mark, merely adding the letter "e" and the ".com" generic top-level domain ("gTLD"). Respondent has no rights or legitimate interests in the <blockechange.com> domain name. Respondent is not commonly known by the Domain Name, nor has Complainant authorized, licensed, or otherwise permitted Respondent to use the BLOCKCHANGE mark. Respondent does not use the Domain Name in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use. Rather the Doman Name resolves to a website ("Respondent's Website") where Respondent offers financial management services, specifically investment services in cryptocurrency, that are in competition with Complainant's offerings. Respondent registered and uses the <blockechange.com> domain name in bad faith as it disrupts Complainant's business by offering competing services. Furthermore, Respondent had actual knowledge of Complainant's rights in the BLOCKCHANGE mark prior to registering the Domain Name, given the fame and longtime use of the mark as well as the Respondent's use of the Domain Name to offer competing services. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant holds trademark rights for the BLOCKCHANGE mark. The Domain Name is confusingly similar to Complainant's BLOCKCHANGE mark. Complainant has established that Respondent lacks rights or legitimate interests in the use of the Domain Name and that Respondent registered and has used the Domain Name in bad faith. 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 Complainant has rights in the BLOCKCHANGE mark through its registration of the mark with the USPTO (e.g. Reg. No. 5,676,113, registered on February 12, 2019). Registration of a mark with the USPTO is sufficient to demonstrate rights in the mark per Policy ¶ 4(a)(i). See DIRECTV, LLC v. The Pearline Group, FA 1818749 (Forum Dec. 30, 2018) ("Complainant's ownership of a USPTO registration for DIRECTV demonstrate its rights in such mark for the purposes of Policy ¶ 4(a)(i)."). The Panel finds that the <blockechange.com> domain name is confusingly similar to the BLOCKCHANGE mark because it contains a minor misspelling of the BLOCKCHANGE mark, merely adding the letter "e" and the ".com" gTLD. Changing a single letter in a mark is insufficient to negate confusing similarity under Policy ¶ 4(a)(i). See Am. Online, Inc. v. David, FA 104980 (Forum Apr. 10, 2002) ("The misspelling of a famous mark does not diminish the confusingly similar nature between the marks and the disputed domain names."); see Omaha Steaks International, Inc. v. DN Manager / Whois-Privacy.Net Ltd, FA 1610122 (Forum July 9, 2015) (finding, "The domain name differs from the mark only in that the domain name substitutes the letter 'a' in the word 'steak' with the letter 'c' and adds the generic Top Level Domain ('gTLD') '.com.' These alterations of the mark, made in forming the domain name, do not save it from the realm of confusing similarity under the standards of the Policy."). The Panel finds Complainant has satisfied Policy ¶ 4(a)(i). Rights or Legitimate Interests Complainant alleges that Respondent holds no rights or legitimate interests in the Domain Name. In order for Complainant to succeed under this element, it must first make a prima facie case that Respondent lacks rights and legitimate interests in the Domain Name under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006) and AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) ("Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names."). The Panel holds that Complainant has made out a prima facie case. Complainant asserts that Respondent has no rights or legitimate interests in the Domain Name as Respondent is not commonly known by the Domain Name, nor has Complainant authorized Respondent to use the BLOCKCHANGE mark. Respondent has no relationship, affiliation, connection, endorsement or association with Complainant. WHOIS information can help support a finding that a respondent is not commonly known by the disputed domain name, especially where a privacy service has been engaged. See State Farm Mutual Automobile Insurance Company v. Dale Anderson, FA 1613011 (Forum May 21, 2015) (concluding that because the WHOIS record lists "Dale Anderson" as the registrant of the disputed domain name, the respondent was not commonly known by the <statefarmforum.com> domain name pursuant to Policy ¶ 4(c)(ii)); see also Kohler Co. v. Privacy Service, FA 1621573 (Forum July 2, 2015) (holding that the respondent was not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii) where "Privacy Service" was listed as the registrant of the disputed domain name). The WHOIS lists "Feven Mebratu / BlockChange" as registrant of record. However, there is no affirmative evidence that the Respondent is actually commonly known under the "BlockChange" name as opposed to simply registering the Domain Name under a false name for the purpose of asserting rights or legitimate interests. Even if a respondent appears from the WHOIS record to be known by the domain name, without additional affirmative evidence, it can be concluded that a respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii). See Google Inc. v. S S / Google International, FA 1625742 (Forum Aug. 4, 2015) ("Respondent did identify itself as 'Google International' in connection with its registration of the Disputed Domain Name, and this is reflected in the WHOIS information. However, Respondent has not provided affirmative evidence from which the Panel can conclude that Respondent was commonly known by the Disputed Domain Name before Respondent's registration thereof."); see also Hewlett-Packard Co. v. HP Supplies, FA 282387 (Forum July 22, 2004) ("The Panel finds, because of the prominence of the HP mark, that Respondent's registration under the 'HP Supplies' name does not establish that Respondent is commonly known by the <hpsupplies.com> domain name."). Given the lack of evidence that the Respondent is actually known under a name corresponding to the Domain Name, and Complainant's unrebutted assertions as to absence of any affiliation or authorization between the parties, the Panel finds that Respondent is not commonly known by the Domain Name in accordance with Policy ¶ 4(c)(ii). The Domain Name redirects to the Respondent's Website where Respondent purports to offer financial services in direct competition with the Complainant (and unrelated to any descriptive meaning of the Domain Name). The use of a confusingly similar domain name to redirect to a competing website does not amount to a bona fide offering of goods or services or a legitimate noncommercial or fair use of the name under Policy ¶¶ 4(c)(i) or (iii). 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)"). The Panel finds Complainant has satisfied Policy ¶ 4(a)(ii). Registration and Use in Bad Faith The Panel finds on the balance of probabilities that, at the time Respondent registered the Domain Name, September 28, 2025, Respondent had actual knowledge of Complainant's BLOCKCHANGE mark which had been in use since 2017. Furthermore, there is no obvious explanation, nor has one been provided, for an entity to register a domain name that consists of a minor misspelling of the BLOCKCHANGE mark and use it to redirect visitors to a website offering financial services (including investment services in the cryptocurrency field) that compete with the Complainant other than to take advantage of Complainant's reputation in the BLOCKCHANGE Mark. In the absence of rights or legitimate interests of its own this demonstrates registration in bad faith under Policy ¶ 4(a)(iii). The Panel finds that Respondent registered and uses the Domain Name in bad faith as Respondent used the Domain Name to redirect Internet users to Respondent's own website where Respondent offers financial and investment services in direct competition with Complainant. Using a confusingly similar domain name to divert Internet users to a respondent's competing website can show bad faith registration and use per Policy ¶ 4(b)(iii). See ZIH Corp. v. ou yang lin q, FA 1761403 (Forum Dec. 29, 2017) (finding bad faith where the respondent used the infringing domain name to disrupt the complainant's business by diverting Internet users from the complainant's website to the respondent's website where it offered competing printer products). Accordingly, the Panel finds that Respondent registered and uses the Domain Name in bad faith pursuant to Policy ¶ 4(b)(iii). The Panel finds Complainant has satisfied 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 <blockechange.com> domain name be TRANSFERRED from Respondent to Complainant. Nicholas J.T. Smith, Panelist Dated: December 4, 2025 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page
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