AlumniVentures.com UDRP: Reverse Domain Name Hijacking decision

The domain AlumniVentures.com was the focus of a failed UDRP complaint in Alumni Ventures LLC v. SocialNicheGuru.com.

The Complainant, a venture capital firm, argued the domain infringed its ALUMNI VENTURES trademark, registered in 2023 and 2025, with claimed use beginning in 2018. However, the Respondent registered the domain in 2011, a full seven years before the Complainant’s rights arose.

While the Panel acknowledged the domain is identical to the Complainant’s mark, it found no evidence of bad faith. Under established UDRP precedent, a domain registered prior to the existence of trademark rights is rarely considered abusive. The disputed domain had resolved to a standard parked page with no indication of targeting the Complainant.

Making matters worse for the Complainant, the WIPO Panel issued a finding of Reverse Domain Name Hijacking. It ruled that the Complainant knew or should have known the claim would fail under the third element of the UDRP and brought the case anyway.

Final decision: Deny the transfer of the domain AlumniVentures.com with a finding of Reverse Domain Name Hijacking (RDNH.)

ARBITRATION AND MEDIATION CENTER – ADMINISTRATIVE PANEL DECISION
Alumni Ventures LLC v. SocialNicheGuru.com
Case No. D2025-1624

1. The Parties

The Complainant is Alumni Ventures LLC, United States of America (“United States”), represented by Litwin Kach, LLP, United States.

The Respondent is SocialNicheGuru.com, United States.

2. The Domain Name and Registrar

The disputed domain name alumniventures.com is registered with Name.com, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 22, 2025. On April 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On the same day, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name, which differed from the named Respondents (SOCIAL NICHE GURU LLC/ SOCIAL NICHE GURU, INC.) and contact information in the Complaint. The Center sent an email communication to the Complainant on April 29, 2025, providing the registrant and contact information disclosed by the Registrar, and requesting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on April 30, 2025.

The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on May 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was May 22, 2025. The Response was filed with the Center on May 23, 2025. The Respondent sent the email communications to the Center on April 29, 2025, May 2, 2025, and May 23, 2025.

The Center appointed Evan D. Brown as the sole panelist in this matter on May 26, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.

4. Factual Background

The Complainant is in the business of providing venture capital advisory and related services. It owns the trademark ALUMNI VENTURES, for which it enjoys the benefits of registration in the United States (e.g., Reg. No. 7678914, registered on February 4, 2025, with a date of first use in commerce of April 2018; Reg. No. 6958785, registered on January 17, 2023, with a date of first use in commerce of November 10, 2021).

According to the WhoIs records, the disputed domain name was registered on February 1, 2011. As of the filing of the Complaint, the disputed domain name resolved to a parked page showing pay-per-click (PPC) links.

5. Parties’ Contentions

A. Complainant

The Complainant contends that the disputed domain name is identical or confusingly similar to the Complainant’s trademark; that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and that the disputed domain name was registered and is being used in bad faith.

B. Respondent

The Respondent concedes that the disputed domain name is identical to the Complainant’s trademark. However, the Respondent disputes the Complainant’s allegations regarding the second and third elements of the Policy. Specifically, the Respondent argues that it has rights or legitimate interests in the disputed domain name. The Respondent further maintains that it registered the disputed domain name well before the Complainant acquired any trademark rights and that it has not used the disputed domain name in bad faith.

6. Discussion and Findings

To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights, (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name, and (iii) the disputed domain name has been registered and is being used in bad faith.

The Panel finds that the Complainant has not satisfied all three of these elements in this case.

A. Identical or Confusingly Similar

This first element functions primarily as a standing requirement. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the complainant’s trademark and the disputed domain name.

A registered trademark provides a clear indication that the rights in the mark shown on the trademark certificate belong to its respective owner. See Advance Magazine Publishers Inc., Les Publications Conde Nast S.A. v. Voguechen, WIPO Case No. D2014-0657. The Complainant has demonstrated its rights in the ALUMNI VENTURES mark by providing evidence of its trademark registration. See WIPO Overview 3.0, section 1.2.1.

The disputed domain name incorporates the ALUMNI VENTURES mark in its entirety, which is sufficient to find confusing similarity. See WIPO Overview 3.0, section 1.7.

The Panel finds that the Complainant has established this first element under the Policy.

B. Rights or Legitimate Interests

Because the Complainant has not established the third element, discussed below, the Panel declines to address this second element under the Policy.

C. Registered and Used in Bad Faith

The Policy requires a complainant to establish that the disputed domain name was registered and is being used in bad faith.

Here, the undisputed evidence shows that the disputed domain name was registered on February 1, 2011. The Complainant, by contrast, claims first use of its ALUMNI VENTURES trademark in commerce in April 2018 and obtained its registrations in 2023, and 2025.

Panels generally do not find bad faith where a domain name is registered before the complainant’s trademark rights accrue. See WIPO Overview 3.0, section 3.8.1. There is no evidence in the record that the Respondent acquired the disputed domain name after the Complainant’s trademark rights arose, nor any indication that the Respondent registered the domain name with knowledge of the Complainant’s then-nascent rights under any of the exceptional scenarios described in section 3.8.2 of the WIPO Overview 3.0.

Accordingly, the Panel finds that the Complainant has failed to establish that the disputed domain name was registered in bad faith.

D. Reverse Domain Name Hijacking

Paragraph 15(e) of the UDRP Rules permits a panel to declare that a complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The Panel finds such a declaration warranted in this case.

The Complainant either knew or clearly ought to have known that it could not succeed under the third element of the Policy, as the disputed domain name was registered more than seven years before its alleged trademark rights arose. There is no suggestion of facts that would support any recognized exception. In the view of the Panel, the Complainant ignored established Policy precedent as captured in the WIPO Overview 3.0.

Accordingly, the Panel finds that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding.

7. Decision

For the foregoing reasons, the Complaint is denied.

/Evan D. Brown/
Evan D. Brown
Sole Panelist
Date: June 9, 2025

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