Westmore · UDRP DecisionAiloadlink.com
The Panel ordered transfer of <ailoadlink.com>, finding it confusingly similar to Complainant’s LOADLINK mark, that Respondent lacked rights or legitimate interests, and that Respondent registered and used it in bad faith. The domain was initially inactive and later resolved to what the Panel found was an AI-created dummy website purporting to offer competing services.
The timeline behind ailoadlink.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 ailoadlink.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The Panel found that Respondent had actual knowledge of the LOADLINK mark when registering the domain and intended to capitalize on its reputation. It further found bad-faith use based on inactive holding under the totality of the circumstances and, alternatively, use of an AI-created dummy website purporting to offer directly competing services.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
NATIONAL ARBITRATION FORUM DECISION Loadlink Technologies Corporation v. Rajun Allen Claim Number: FA2606002227802 PARTIES Complainant is Loadlink Technologies Corporation ("Complainant"), represented by Nicole K. McLaughlin of Duane Morris, LLP, Pennsylvania, USA. Respondent is Rajun Allen ("Respondent"), Texas, USA. REGISTRAR AND DISPUTED DOMAIN NAME The domain name at issue is <ailoadlink.com> ("Domain Name"), registered with IONOS SE. 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 June 17, 2026; Forum received payment on June 17, 2026. On June 18, 2026, IONOS SE confirmed by e-mail to Forum that the <ailoadlink.com> domain name is registered with IONOS SE and that Respondent is the current registrant of the name. IONOS SE has verified that Respondent is bound by the IONOS SE 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 June 22, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 13, 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@ailoadlink.com. Also on June 22, 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 July 14, 2026, 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 a Canadian company that since 2001, has offered transportation and freight management software and related services under the LOADLINK mark. Complainant has rights in the LOADLINK mark through Complainant's registration of the mark with the United States Patent and Trademark Office ("USPTO") (e.g. Reg. No. 4,093,069 registered January 31, 2012). Respondent's <ailoadlink.com> domain name is confusingly similar to Complainant's LOADLINK mark as it includes Complainant's entire mark and adds the generic/descriptive abbreviation "ai" and the gTLD ".com." Respondent lacks rights or legitimate interests in the <ailoadlink.com> domain name. Respondent is not commonly known by the Domain Name, nor has Respondent been authorized by Complainant to use the LOADLINK mark. Additionally, Respondent does not use the Domain Name for any bona fide offering of goods or services or legitimate noncommercial or fair use. Instead, the Domain Name resolves to an inactive webpage. Respondent registered and uses the <ailoadlink.com> domain name in bad faith. The Domain Name resolves to an inactive webpage. Respondent had actual knowledge of Complainant's rights in the LOADLINK mark based on Complainant's long-term use of the mark for transportation and freight management software and related services. B. Respondent Respondent failed to submit a Response in this proceeding. FINDINGS Complainant holds trademark rights for the LOADLINK mark. The Domain Name is confusingly similar to Complainant's LOADLINK mark. Complainant has established that Respondent lacks rights or legitimate interests in 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 3.1 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 rights in the LOADLINK mark through its registration of the mark with the USPTO (e.g., Reg. No. 4,093,069 registered January 31, 2012). Registration of a mark with the USPTO is generally sufficient to establish 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 <ailoadlink.com> domain name is confusingly similar to Complainant's LOADLINK mark because it incorporates Complainant's mark in its entirety, adding only the descriptive or generic term "ai" (a common abbreviation for "artificial intelligence") and the gTLD ".com." Addition of generic or descriptive words and a gTLD does not sufficiently distinguish a domain name from a mark under Policy ¶ 4(a)(i). See Skechers U.S.A., Inc. and Skechers U.S.A., Inc. II v. Svensson Viljae, FA 1784650 (Forum June 1, 2018) (finding confusing similarity where "[t]he disputed domain name <skechers-outlet.com> adds a hyphen and the generic term 'outlet' to Complainant's registered SKECHERS mark, and appends the '.com' top-level domain."). 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 LOADLINK 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 "Rajun Allen" as registrant of record. Coupled with 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 Names in accordance with Policy ¶ 4(c)(ii). At the time the Complaint was prepared the Domain Name was inactive and there was apparently no other evidence of any intention to use the Domain Name for any purpose, be it a bona fide offering or legitimate non-commercial use. In the absence of any additional evidence, inactive holding of a disputed domain name is not a bona fide offering of goods or services under Policy ¶ 4(c)(i) or legitimate noncommercial or fair use under Policy ¶ 4(c)(iii). See CrossFirst Bankshares, Inc. v Yu-Hsien Huang, FA 1785415 (Forum June 6, 2018) ("Complainant demonstrates that Respondent fails to actively use the disputed domain name as it resolves to an inactive website. Therefore, the Panel finds that Respondent fails to actively use the disputed domain name for a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (iii)."). However, at the time of the decision the Domain Name resolves to a website that under the Complainant's LOADLINK mark, purported to offer some form of AI-connected transportation and freight management software and related services. However, there is considerable evidence from the content of the website (including the presence of an obviously fake address, the use of Latin placeholder text, copyright dates from before the Domain Name was registered and the use of various other potentially AI-created nonsensical elements) that this website is an AI-created or AI-generated dummy website created for the sole purpose of purporting to assert rights and legitimate interests and the Respondent offers no services of the sort advertised on the website. In the absence of any Response or any other evidence that the services offered are genuine legitimate the Panel is prepared to conclude on the balance of probabilities that Respondent is not actively using the Domain Name for a bona fide offering of goods or services or legitimate noncommercial or fair use under Policy ¶ 4(c)(i) or (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 of registration of the Domain Name, June 3, 2025, Respondent had actual knowledge of Complainant's LOADLINK mark as it would be unlikely for a party to register a domain name that contains the LOADLINK mark and a generic term and resolve it to a website that (at the date of the decision), purports to offer competing transportation and freight management software and related services under the Complainant's LOADLINK mark absent any awareness of Complainant and its LOADLINK mark (and intention to capitalize on Complainant's reputation in its LOADLINK 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 notes that the actions of Respondent in this matter prior to the commencement of the proceeding do not fall under the arguments set out in Policy ¶ 4(b). However, these arguments are merely illustrative rather than exclusive to support a finding of bad faith. See Bloomberg Finance L.P. v. Domain Admin - This Domain is For Sale on GoDaddy.com / Trnames Premium Name Services, FA 1714157 (Forum Mar. 8, 2017) (determining that Policy ¶ 4(b) provisions are mere illustrative of bad faith, and that the respondent's bad faith may be demonstrated by other allegations of bad faith under the totality of the circumstances). It is well accepted that the elements of Policy ¶ 4(b) are not exclusive and that a Panel may consider all of the circumstances of a given case, including passive holding, in making its bad faith analysis. See Telstra Corporation Limited v. Nuclear Marshmallows, Case No. D2000-0003 (WIPO Feb. 18, 2000) (after considering all the circumstances of a given case, it is possible that a "[r]espondent's passive holding amounts to bad faith."); Regions Bank v. Darla atkins, FA 1786409 (Forum June 20, 2018) ("Respondent registered and is using the domain name in bad faith under Policy ¶ 4(a)(iii) because Respondent uses the domain name to host an inactive website.") Respondent has, without alternative explanation, registered a domain name that is confusingly similar to the LOADLINK mark. It has failed to actively use the Domain Name in connection with the offering of services, with the Domain Name resolving to an inactive website prior to the commencement of the proceeding and an AI-created dummy website created for the sole purpose of purporting to assert rights and legitimate interests during the proceeding. Inactive holding of a domain name can be evidence of bad faith under Policy ¶ 4(a)(iii) and, after considering the totality of the circumstances (including the nature of the LOADLINK mark and the use of a AI-created dummy website created for the sole purpose of purporting to assert rights and legitimate interests during the proceeding) and in the absence of any Response or other explanation by Respondent (or any possible good faith use of the Domain Name by Respondent), the Panel finds on the balance of probabilities that this inactive holding of the Domain Name amounts to use in bad faith per Policy ¶ 4(a)(iii). In the alternative, the Panel is satisfied that the use of the Domain Name to resolve to the website in place at the decision, being an AI-created dummy website where Respondent purports to offer competing services in direct competition with the Complainant, is sufficient to show bad faith under the Policy. 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 <ailoadlink.com> domain name be TRANSFERRED from Respondent to Complainant. Nicholas J.T. Smith, Panelist Dated: July 15, 2026 Click Here to return to the main Domain Decisions Page. Click Here to return to our Home Page
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