Westmore · UDRP decision
FORUM · Case No. FA2602002204700

Sesameaivoice.com

TransferFORUM-indexed · informational, not legal advice

The Panel ordered transfer of <sesameaivoice.com> after finding that Complainant established common-law rights in SESAME, the domain was confusingly similar, Respondent lacked rights or legitimate interests, and Respondent registered and used the domain in bad faith through impersonation, actual knowledge, and opportunistic registration following media coverage of Complainant's launch.

Outcome
Transfer
At a glance
Provider
FORUM
Outcome
Transfer
Decision date
2026-03-05
Panelist(s)
Richard Hill
Complainant
Sesame AI, Inc.
Respondent
jackson chen
Counsel
James R. Davis
Law firm
Morgan, Lewis & Bockius LLP
Disputed domain(s)
sesameaivoice.com
Citation weightrelies on 17 authorities
Domain history UDRP Intelligence

The timeline behind sesameaivoice.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 sesameaivoice.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 sesameaivoice.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The Panel found bad-faith registration and use because Respondent registered the domain shortly after Complainant's launch and significant media attention, used it to impersonate Complainant, knew of Complainant's rights because the website referred to Complainant and its products, and acted opportunistically.

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
2026-03-05
Panel
Richard Hill
Full decision
14 min read · hosted by Westmore

NATIONAL ARBITRATION FORUM DECISION Sesame AI, Inc. v. jackson chen Claim Number: FA2602002204700 PARTIES Complainant is Sesame AI, Inc. ("Complainant"), represented by James R. Davis of Morgan, Lewis & Bockius LLP, District of Columbia, USA. Respondent is jackson chen ("Respondent"), China. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <sesameaivoice.com>, registered with Spaceship, 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. Richard Hill as Panelist. PROCEDURAL HISTORY Complainant submitted a Complaint to Forum electronically on February 10, 2026; Forum received payment on February 10, 2026. On February 10, 2026, Spaceship, Inc. confirmed by e-mail to Forum that the <sesameaivoice.com> domain name is registered with Spaceship, Inc. and that Respondent is the current registrant of the name. Spaceship, Inc. has verified that Respondent is bound by the Spaceship, 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 12, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 4, 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@sesameaivoice.com. Also on February 12, 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 March 5, 2026, 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 it is an artificial intelligence company founded by well-known, repeat technology entrepreneurs. The founders are high-profile and known for success. Complainant exited stealth on February 27, 2025, when they activated their website at <www.sesame.com>; Complainant had been using that domain name since October 2024. Since exiting stealth, Complainant has previewed two of its products, a conversational artificial intelligence ("AI") companion and accompanying eyewear. Complainant's AI voice assistants are named Miles and Maya. Immediately after exiting stealth, Complainant's conversational AI companion amassed global interest as evidenced by countless news articles, blogs, and unfortunately, imitation websites attempting to trade off the goodwill Complainant had created in its inherently distinctive SESAME and SESAME AI trademarks. In particular, there are multiples examples of press coverage of Complainant's software soon after its launch and about 6 days before Respondent registered the disputed domain name. Complainant quickly gained traction globally, being recognized for its innovation and technological advancement which alone garnered global brand visibility by its continued involvement in the AI community. Complainant asserts rights in the mark SESAME through its registration in the United Kingdom on November 21, 2025 (filing date August 27, 2025) and in Switzerland on October 21, 2025 (filing date August 28, 2025). Complainant also asserts common law rights in the marks SESAME and SESAME AI dating back to at least February 27, 2025. Complainant alleges that the disputed domain name is similar to its SESAME mark it incorporates the mark in its entirety and merely adds the generic/descriptive terms "ai" (which stands for "artificial intelligence") and "voice", together with the ".com" generic top-level domain ("gTLD"). According to Complainant, Respondent has no rights or legitimate interests in the disputed domain name. Respondent is not commonly known by the disputed domain name and Complainant has not authorized or licensed to Respondent any rights in its marks. Respondent does not use the disputed domain name for a bona fide offering of goods or services or a legitimate noncommercial or fair use. Instead, the resolving website impersonates Complainant, referring to it and its products. Further, says Complainant, Respondent registered and uses the disputed domain name in bad faith. The resolving website impersonates Complainant. Respondent registered the disputed domain name with actual knowledge of Complainant's rights in its mark. Respondent engaged in opportunistic bad faith registration. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant has rights in the SESAME mark and uses it to provide AI-powered services. Complainant's rights in its mark precede the registration of the disputed domain name. Complainant has not licensed or otherwise authorized Respondent to use its mark. The disputed domain name was registered on March 5, 2025. The resolving website impersonates Complainant, referring to it and its products. 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 asserts common law rights in its SESAME mark. Common law rights are sufficient to establish rights in a mark under Policy ¶ 4(a)(i). See Artistic Pursuit LLC v. calcuttawebdevelopers.com, FA 894477 (Forum Mar. 8, 2007) (finding that Policy ¶ 4(a)(i) does not require a trademark registration if a complainant can establish common law rights in its mark). Common law rights may be established through evidence of secondary meaning in the mark such as longstanding use, evidence of an identical domain name, media recognition, and promotional material and advertising. See Marquette Golf Club v. Al Perkins, 1738263 (Forum July 27, 2017) (finding that Complainant had established its common law rights in the MARQUETTE GOLF CLUB mark with evidence of secondary meaning, including "longstanding use; evidence of holding an identical domain name; media recognition; and promotional material/advertising."). Here, Complainant extensively used its SESAME mark in various promotional and advertising materials from its launch of its services on February 27, 2025 and was the subject of a wide variety of third-party commentary. Therefore, the Panel finds that Complainant has established common law rights in its SESAME mark, with rights predating the registration of the disputed domain name. The disputed domain name incorporates Complainant's SESAME mark in its entirety and merely adds the generic/descriptive terms "ai" (which stands for "artificial intelligence") and "voice", together with the ".com" generic top-level domain ("gTLD"). Under Policy ¶ 4(a)(i), adding a gTLD and/or generic terms and/or relevant or meaningless letters is generally insufficient in differentiating a disputed domain name from the mark it incorporates. See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognisable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element."); 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 Home Depot Product Authority, LLC v. Angelo Kioussis, FA 1784554 (Forum June 4, 2018) ("The domain name contains the mark in its entirety, with only the addition of the generic letters 'sb' and the digits '2018,' plus 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."). 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 Respondent is not licensed or otherwise authorized to use Complainant's mark and is not commonly known by the disputed domain name: under Policy ¶ 4(c)(ii), WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name. 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)). Here, the WHOIS information for the disputed domain name lists the registrant as "jackson chen". Thus the Panel finds that Respondent is not commonly known by the disputed domain name pursuant to Policy ¶ 4(c)(ii). Complainant presents evidence showing that Respondent uses the disputed domain name to attempt to impersonate Complainant. This does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. See Edible Communities v. Thoreau, FA 1158554 (Forum Apr. 16, 2008) ("[R]espondent's use of the disputed domain name [<theedibleaustin.com>] to pass itself off as [c]omplainant shows that [r]espondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(c)(i) as well as Policy ¶ 4(c)(iii)."); see also Digg v. Digg, FA 1220833 (Forum Oct. 9, 2008) (finding no legitimate interest in respondent's use of the domain name <digg-inc.com> because "[r]espondent is attempting to pass itself off as [c]omplainant" and such "actions do not constitute a bona fide offering of goods or services under Policy ¶ 4(c)(i) or a legitimate noncommercial or fair use under Policy ¶ 4(c)(iii)."); see also LF, LLC v. Kas Is / cas issen, FA 1958712 (Forum Sept. 9, 2021) ("Complainant has made out a prima facie case" where "Respondent's websites pretend to be a blog offering information on how to access Complainant's employee portal website, but the real purpose of the websites is to divert traffic from Complainant's legitimate <myloweslife.com> site through passing off."). 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 a legitimate noncommercial or fair use under Policy ¶ 4(c)(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 The WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition ("WIPO Jurisprudential Overview 3.1") states under 3.8.2: As an exception to the general proposition described above in 3.8.1 [where a respondent registers a domain name before the complainant's trademark rights accrue, panels will not normally find bad faith on the part of the respondent], in certain limited circumstances where the facts of the case establish that the respondent's intent in registering the domain name was to unfairly capitalize on the complainant's nascent (typically as yet unregistered) trademark rights, panels have been prepared to find that the respondent has acted in bad faith. Such scenarios include registration of a domain name: (i) shortly before or after announcement of a corporate merger, (ii) further to the respondent's insider knowledge (e.g., a former employee), (iii) further to significant media attention (e.g., in connection with a product launch or prominent event), or (iv) following the complainant's filing of a trademark application. Here, the record shows that the disputed domain name was registered shortly after Complainant's announcement of its Sesame AI services, and further to significant media attention in connection with the launch of those services. Thus, even if Complainant's trademark rights did not predate the registration of the disputed domain name – which they do – the Panel would find bad faith registration. See also the discussion of opportunistic bad faith below. 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, Respondent uses the disputed domain name to attempt to impersonate Complainant. This evinces bad faith registration and use under Policy ¶ 4(a)(iii). See American International Group, Inc. v. Walter Busby d/b/a AIG Mergers and Acquisitions, FA 156251 (Forum May 30, 2003) (the resolving website gave every appearance of being associated or affiliated with Complainant's business); see also Mortgage Research Center LLC v. Russell Miranda, FA 993017 (Forum July 9, 2007) (Respondent is implying an affiliation with Complainant, and consumers seeking Complainant's products and services may become confused when encountering Respondent's website). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii). Further, Respondent registered the disputed domain name with actual knowledge of Complainant's mark: the resolving website refers to Complainant and its products. 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 its mark prior to Respondent's registration of the disputed domain name and that this constitutes bad faith under Policy ¶ 4(a)(iii). Finally, the Panel finds that Respondent registered the disputed domain name opportunistically, because it registered it domain name shortly after extensive media coverage of the launch of Complainant's Sesame AI services. This constitutes bad faith registration and use. See GridPoint, Inc. v. Matt Giovanini, FA 1909399 (Forum Oct. 5, 2020) ("Under Policy ¶ 4(a)(iii), opportunistic bad faith may be demonstrated by a Respondent registering a disputed domain name that integrates a distinct or famous mark, around the time of a certain event that creates interest or value in the disputed domain name."); see also Amazon Technologies, Inc. v. harshit dhingaun, FA 1619696 (Forum June 10, 2015) ("Respondent registered the contested domain names within days after the announcement of Complainant's sponsorship of India Fashion Week, thus demonstrating opportunistic bad faith in the registration and subsequent use of the domains."). Thus, the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii) on this ground also. 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 <sesameaivoice.com> domain name be TRANSFERRED from Respondent to Complainant. March 5, 2026, Panelist Dated: Richard Hill 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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