Westmore · UDRP decision
FORUM · Case No. FA2602002203375

Cajun-bowfishing.com

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of <cajun-bowfishing.com>, finding it confusingly similar to Complainant's registered CAJUN BOWFISHING mark, that Respondent lacked rights or legitimate interests, and that Respondent registered and used the domain in bad faith to compete with Complainant while using its mark, logo, and images.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2026-02-26
Panelist(s)
Sandra J. Franklin
Complainant
Bear Archery, Inc.
Respondent
Liudmyla Veselovska
Counsel
Charles J. Meyer
Law firm
Woodard, Emhardt, Henry, Reeves & Wagner LLP
Disputed domain(s)
cajun-bowfishing.com
Citation weightrelies on 10 authorities
Domain history UDRP Intelligence

The timeline behind cajun-bowfishing.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 cajun-bowfishing.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 cajun-bowfishing.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The Panel found bad faith under Policy ¶ 4(b)(iv) because Respondent used the domain to compete with Complainant. It also found Respondent knew of Complainant's rights when registering the domain because Respondent used the mark to compete directly with Complainant.

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
2026-02-26
Panel
Sandra J. Franklin
Full decision
8 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Bear Archery, Inc. v. Liudmyla Veselovska Claim Number: FA2602002203375 PARTIES Complainant is Bear Archery, Inc. ("Complainant"), represented by Charles J. Meyer of Woodard, Emhardt, Henry, Reeves & Wagner LLP, Indiana, USA. Respondent is Liudmyla Veselovska ("Respondent"), Ukraine. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <cajun-bowfishing.com>, 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. Sandra J. Franklin as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on February 3, 2026; Forum received payment on February 3, 2026. On February 4, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <cajun-bowfishing.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 February 4, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 24, 2026 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@cajun-bowfishing.com. Also on February 4, 2026, 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 February 25, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Sandra J. Franklin 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 1. Respondent's <cajun-bowfishing.com> domain name is confusingly similar to Complainant's CAJUN BOWFISHING mark. 2. Respondent does not have any rights or legitimate interests in the <cajun-bowfishing.com> domain name. 3. Respondent registered and uses the <cajun-bowfishing.com> domain name in bad faith. B. Respondent did not file a Response. FINDINGS Complainant, Bear Archery, Inc., holds a registration for the CAJUN BOWFISHING mark with the United States Patent and Trademark Office ("USPTO") (Reg. No. 7,624,158, registered December 24, 2024). Respondent registered the <cajun-bowfishing.com> domain name on August 29, 2025, and uses it to compete with 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 Panel finds that Complainant has rights in the CAJUN BOWFISHING mark based on registration with the USPTO. See Brooks Sports, Inc. v. Joyce Cheadle, FA 1819065 (Forum Dec. 28, 2018) (finding that Complainant's registration of the BROOKS mark with the USPTO sufficiently conferred its rights in the mark under Policy ¶ 4(a)(i)). Respondent's <cajun-bowfishing.com> domain name uses the CAJUN BOWFISHING mark and simply adds a hyphen and a top-level domain. These changes do not sufficiently distinguish a disputed domain name from a mark for the purposes of Policy ¶ 4(a)(i). See ADP, LLC. v. Ella Magal, FA 17738958 (Forum Aug. 2, 2017) ("Respondent's <workforce-now.com> domain name appropriates the dominant portion of Complainant's ADP WORKFORCE NOW mark and adds a hyphen and the gTLD ".com." These changes do not sufficiently distinguish the disputed domain name from the ADP WORKFORCE NOW mark.") The Panel therefore finds that Respondent's <cajun-bowfishing.com> domain name confusingly similar to Complainant's CAJUN BOWFISHING mark. The Panel finds that Complainant has satisfied Policy ¶ 4(a)(i). Rights or Legitimate Interests Once Complainant makes a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii), the burden shifts to Respondent to show it does have 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)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests"). Complainant asserts that Respondent has no rights or legitimate interests in <cajun-bowfishing.com> as Respondent is not commonly known by the domain name, and Complainant has not authorized or licensed Respondent to use its CAJUN BOWFISHING mark. The WHOIS information identifies Respondent as "Liudmyla Veselovska". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name, and thus has no rights under Policy ¶ 4(c)(ii). See Radio Flyer Inc. v. er nong wu, FA 1919893 (Forum Dec. 16, 2020) ("Here, the WHOIS information lists "er nong wu" as the registrant and no information suggests Complainant has authorized Respondent to use the RADIO FLYER mark in any way. Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii).") Complainant argues that Respondent also fails to use the <cajun-bowfishing.com> domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use as Respondent uses the domain name to compete with Complainant. Complainant provides screenshots showing that Respondent uses the disputed domain name to offer competing products using Complainant's mark, logo and images. The Panel finds that this is not a bona fide offering of goods or services or a legitimate noncommercial or fair use, and thus Respondent has no rights under Policy ¶¶ 4(c)(i) or (iii). See Ripple Labs Inc. v. Jessie McKoy / Ripple Reserve Fund, FA 1790949 (Forum July 9, 2018) (finding the respondent did not use the domain name to make a bona fide offering of goods or services per Policy ¶ 4(c)(i) or for a legitimate noncommercial or fair use per Policy ¶ 4(c)(iii) where the website resolving from the disputed domain name featured the complainant's mark and various photographs related to the complainant's business). The Panel finds that Complainant has satisfied Policy ¶ 4(a)(ii). Registration and Use in Bad Faith The Panel finds that Respondent registered and uses the <cajun-bowfishing.com> domain name in bad faith to compete with Complainant, demonstrating bad faith under Policy ¶ 4(b)(iv). See Bittrex, Inc. v. Wuxi Yilian LLC, FA 1760517 (Forum Dec. 27, 2017) (finding bad faith per Policy ¶ 4(b)(iv) where "Respondent registered and uses the <lbittrex.com> domain name in bad faith by directing Internet users to a website that mimics Complainant's own website in order to confuse users into believing that Respondent is Complainant, or is otherwise affiliated or associated with Complainant.") The Panel also finds that Respondent registered the <cajun-bowfishing.com> domain name with knowledge of Complainant's rights in the CAJUN BOWFISHING mark, since Respondent uses Complainant's mark to directly compete with Complainant, which constitutes further bad faith under Policy ¶ 4(a)(iii). See Minicards Vennootschap Onder FIrma Amsterdam v. Moscow Studios, FA 1031703 (Forum Sept. 5, 2007) (holding that respondent registered a domain name in bad faith under Policy ¶ 4(a)(iii) after concluding that respondent had "actual knowledge of Complainant's mark when registering the disputed domain name"); see also iFinex Inc. v. xu shuaiwei, FA 1760249 (Forum Jan. 1, 2018) (finding prior knowledge of complainant's mark from Respondent's use of the mark to direct internet traffic to a website which is a direct competitor of the complainant.) The Panel finds that 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 <cajun-bowfishing.com> domain name be TRANSFERRED from Respondent to Complainant. Sandra J. Franklin, Panelist Dated: February 26, 2026 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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