The domain JaquelKnight.com was originally owned and used by choreographer JaQuel Knight but expired following a management lapse. It was later acquired at auction by a Turkish person, leading to a UDRP filing.
Knight and his company J.K. Creatives argued that the Respondent had no rights to the domain and had initially redirected it to a site featuring Knight’s likeness, then later to a gambling site. Knight cited common law rights to his name as a trademark and a pending US trademark application for “Star Power by JaQuel Knight.”
However, the Panel found that while Knight is a public figure, he did not provide sufficient evidence that his name functioned as a source identifier under UDRP standards. A registered trademark or demonstrated use of the name as a mark in commerce was lacking. Because the Complainant failed to establish trademark rights, the WIPO Panel did not evaluate the remaining elements.
Final decision: Deny the transfer of the domain jaquelknight.com to the Complainant.
Copyright © 2025 DomainGang.com · All Rights Reserved.ARBITRATION AND MEDIATION CENTER – ADMINISTRATIVE PANEL DECISION
JaQuel Knight, J.K. Creatives, Inc. v. Hidayet Koca
Case No. D2025-18991. The Parties
The Complainant is JaQuel Knight, J.K. Creatives, Inc., United States of America, represented by Prince Lobel Tye LLP, United States of America (“United States”).
The Respondent is Hidayet Koca, Turkiye.
2. The Domain Name and Registrar
The disputed domain name jaquelknight.com is registered with GoDaddy.com, LLC (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 12, 2025. On May 13, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 14, 2025, 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 Respondent (Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on the same day, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on the same day, transmitting it on copy to the Respondent, who sent an informal email communication in response, requesting clarifications.
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 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 4, 2025. The Response was filed with the Center on May 15, 2025. On the same day, the Center sent an email communication to the Parties inviting them to consider suspending the proceeding to implement a settlement agreement between the Parties and indicating that, if the Parties wished to explore settlement options, the Complainant should submit a request for suspension by May 20, 2025. On May 21, 2025, the Complainant sent an email communication to the Center stating that the Parties were not able to reach mutual agreement to resolve the matter and that the Complainant wished to continue with the proceeding.
The Respondent sent a further email communication to the Center on May 28, 2025.
On June 5, 2025, the Center sent an email communication to the Parties indicating that it would proceed to Panel Appointment.
The Center appointed Luca Barbero as the sole panelist in this matter on June 10, 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.
On June 17, 2025, the Panel issued Procedural Order No.1 (“Panel Order”), asking the Complainant to provide additional information and/or evidence to show adequate use as a source identifier of his name, and claimed trademark, in commerce. The Panel further granted the Respondent a period to comment on any submissions to be filed by the Complainant.
The Complainant filed its reply to the Panel Order on June 19, 2025. The Respondent did not provide any reply to the Complainant’s submissions.
4. Factual Background
The Complainant has been filed by JaQuel Knight, who is the CEO of the company J.K. Creatives, Inc.
The Complainant is a choreographer and creative known for his work with celebrities such as Beyonce, Megan Thee Stallion, Christina Aguilera, Jay-Z, Pharrell Williams, and Jennifer Lopez. He gained global fame at age 18 after choreographing Beyonce’s viral “Single Ladies” performance, and he recently choreographed and produced the artist Megan Thee Stallion’s most recent world tour and her performance at the Coachella Valley Music and Arts Festival in Indio, California.
The Complainant has obtained a large social media following, consisting of over 170,000 followers on Instagram, over 25,000 followers on TikTok, and over 12,500 followers on X. In addition, he has won several awards including two MTV Video Music Awards (VMAs), a BET Video of the Year Award, and an Essence Film Festival Award; he has also been nominated for several other VMAs and an IHeartRadio Music Award.
The Complainant participated in a global marketing campaign for H&M stores in 2022 and his work is regularly featured in broadcast, news, and streaming media as well as high profile publications, where he is referred to by his full name, JaQuel Knight. He was featured on the cover of Billboard Magazine as well as on other publications such as the BBC website, NPR, Business Insider, Yahoo! Entertainment, Forbes, Hollywood Reporter, Agolde, Creative Arts Agency Speakers, Broadway Dance Center, Dance Magazine and Slate Magazine.
In addition to his work with global performing artists, the Complainant also offers Master Class and Industry Intensive dance events around the world. Tickets to these events, as well as merchandise and a creative catalogue, were previously sold on the website to which the disputed domain name jaquelknight.com resolved and, currently, can be purchased on the website “www.shopjaquelknight.com”.
The Complainant founded and operates the JaQuel Knight Foundation, a non-pro.t organization designed to support dancers across United States.
The Complainant is the owner of the United States trademark application No. 99017850 for STAR POWER BY JAQUEL KNIGHT (word mark), filed on January 24, 2025, in international classes 5, 14, 18, 21, 25 and 32.
The disputed domain name jaquelknight.com was registered on March 16, 2013, and currently resolves to a blank page. According to the Complainant’s submissions, the disputed domain name was initially owned and used by the Complainant, but it was allowed to expire after the Complainant’s termination of his former business manager who was in charge of the maintenance of the website and of the disputed domain name. The Complainant has submitted, and the Respondent has not denied, that the disputed domain name was then sold at auction, on or about April 27, 2025, to the Respondent.
5. Parties’ Contentions
A. Complainant
The Complainant contends to have satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
Notably, the Complainant contends that the disputed domain name is identical to the Complainant’s claimed JAQUEL KNIGHT mark in which the Complainant claims common law rights based on the Complainant’s use of JAQUEL KNIGHT in connection with his body of work, his production and choreography, and his Master Class dance events.
The Complainant submits that the Respondent has no rights or legitimate interests in the disputed domain name since the Respondent has not used the disputed domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use, as he initially redirected it to a website displaying the Complainant’s face, logo, catalogue of services, dance exhibitions and merchandise, without having received any authorization to leverage the Complainant’s name or business, nor to use the JAQUEL KNIGHT mark. The Complainant points out that the Respondent’s purchase of the disputed domain name was intended to leverage the goodwill of the Complainant’s business, and to attract clicks from unwitting users who are attempting to access the Complainant’s website, as they have done for the past 20 years.
The Complainant also contends that the Respondent is highly unlikely to be commonly known by the name “JaQuel Knight” as he kept his identity masked in the WhoIs of the disputed domain name and the Complainant has never worked with, met, or heard of the Respondent.
With reference to the circumstances evidencing bad faith, the Complainant states that, after the disputed domain name was allowed to expire by the Complainant’s business manager, the Respondent seized the opportunity to register the disputed domain name and begin reaping the benefits of the Complainant’s goodwill by diverting his unwitting customers and clients.
The Complainant indicates that, after acquiring the disputed domain name, the Respondent initially redirected it to a website which continued to display contents related to the Complainant and, thereafter, to an online gambling site displaying several gambling-related pop-up advertisements.
The Complainant states that the Respondent’s use of a WhoIs privacy service to hide his identity further indicates the nefarious intent behind purchasing the disputed domain name. The Complainant also contends that the Respondent’s unauthorized control of the copyrighted material on the Complainant’s website webpage and his deactivation of many of the website links has created a renewed level of urgency to prevent further disruption to the Complainant’s business and further damage to his brand. The Complainant therefore states that the Respondent is intentionally attempting to attract, for commercial gain, Internet users to his website by usurping the disputed domain name, which was previously owned and used by the Complainant, without authorization.
The Complainant also claims that the Respondent has evidently purchased the disputed domain name because he recognizes the value of the JAQUEL KNIGHT mark and hopes that he will generate impressions from users attempting to reach the Complainant’s website, or to extort the Complainant in paying to recuperate the disputed domain name.
B. RespondentThe Respondent contends that the Complainant has not satisfied all the elements required under the Policy for a transfer of the disputed domain name.
The Respondent states that he legitimately purchased the disputed domain name through an auction conducted by the Registrar after it had expired under its previous registrant and that, at the time of purchase, there was no knowledge or indication provided about any trademark or intellectual property disputes associated with the disputed domain name.
The Respondent also asserts that, upon receiving initial notice of the dispute, the Respondent took immediate action to clear all existing content from the website at the disputed domain name. The Respondent claims that the circumstance that the website to which the disputed domain name resolves is currently completely empty demonstrates his good faith and commitment not to infringe upon any trademarks or other intellectual property rights of the Complainant. He also states that he will not use the disputed domain name in any way that may harm the reputation, trademark, or other intellectual property rights of the Complainant.
6. Discussion and Findings
According to paragraph 15(a) of the Rules: “A Panel shall 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 directs that the Complainant must prove each of the following:
(i) that the disputed domain name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;
(ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) that the disputed domain name has been registered and is being used in bad faith.
A. Identical or Confusingly Similar
It is well accepted that the first element functions primarily as a standing requirement. 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. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7.
The Complainant in this case relies on unregistered trademark rights to his personal name “JaQuel Knight” for the purposes of the Policy.
The Policy does not explicitly provide standing for personal names which are not registered or otherwise protected as trademarks. However, where a personal name is used as a trademark-like identifier in trade or commerce, a complainant may be able to establish unregistered or common law rights in that name for purposes of standing to file a UDRP case where the name in question is used in commerce as a distinctive identifier of the complainant’s goods or services. WIPO Overview 3.0, section 1.5.2.
Based on the documents submitted by the Complainant, the Panel finds that the Complainant has not established unregistered trademark mark rights for the purposes of the Policy, as he has not shown that his name has been used as a distinctive identifier in commerce as in the sense of a trademark, even upon receiving the Procedural Order No. 1 issued.
No doubt the Complainant provided enough evidence to show that he is a very famous choreographer, but none of the evidence submitted shows the use of his name as a trademark. See Margaret C. Whitman v. Domains For Sale, WIPO Case No. D2008-1534.
While the Panel also accepts that the Respondent has clearly targeted the Complainant, there is not enough evidence in the case file that supports the Complainant’s contention that his mark has achieved significance as a source identifier within the standing to file a UDRP complaint.
The Complainant also provided evidence of ownership of a trademark application for STAR POWER BY JAQUEL KNIGHT in the United States. However, a pending trademark application does not by itself establish trademark rights within the meaning of UDRP paragraph 4(a)(i). WIPO Overview 3.0, section 1.1.4.
Therefore, the Panel finds the first element of the Policy has not been established.
In light of the above, and since the Complainant bears the burden of proving each of the elements under paragraph 4(a) of the Policy, it is not necessary for the Panel to further evaluate the Complainant’s arguments under paragraphs 4(a)(ii) and 4(a)(iii) for purposes of this Decision.
7. Decision
For the foregoing reasons, the Complaint is denied.
/Luca Barbero/
Luca Barbero
Sole Panelist
Date: June 30, 2025
