Micro Electronics, Inc., long-time owner of the MICRO CENTER mark and operator of microcenter.com and AI-focused PCs and systems, filed a UDRP against the domain Microcenter.ai, registered in 2024.
The domain was parked with PPC links to direct competitors and had at one point resolved to a fake “Windows Defender / Trojan spyware” lock-screen page. The panel had no trouble finding the domain identical to MICRO CENTER (ignoring the TLD) and noting Micro Center’s long-standing US registrations dating back to 1989.
The Respondent tried a series of arguments the panel dismissed as unfounded: that .ai signals a different industry and audience than .com, that GoDaddy’s ad algorithms and not him controlled the PPC links, that ICANN somehow permits indefinite “under development” parking, and that he intended a non-monetized AI discussion forum so there could be no bad faith or profit involved.
The panel held that .ai doesn’t cure confusion when paired with a famous tech mark, that PPC links to competitors undercut any claim of bona fide use, that UDRP law—not ICANN boilerplate—governs, and that “profit” under the Policy includes any benefit, not just cash.
With actual knowledge of MICRO CENTER, use of a distinctive mark in the same AI/tech space, and mala fide landing pages, the panel found no rights or legitimate interests and clear bad faith registration and use.
Final decision: Transfer of the domain Microcenter.ai to Complainant.
Copyright © 2025 DomainGang.com · All Rights Reserved.DECISION
Micro Electronics, Inc. v. David Carpenter
Claim Number: FA2510002186053
PARTIES
Complainant is Micro Electronics, Inc. (“Complainant”), represented by Joseph M. Manak of Law Offices of Joseph M. Manak PC, New York, USA. Respondent is David Carpenter (“Respondent”), New Hampshire, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is microcenter.ai, registered with GoDaddy.com, LLC.
PANEL
The undersigned certifies that he has acted independently and impartially and to the best of their knowledge has no known conflict in serving as Panelist in this proceeding.
Gerald M. Levine as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on October 30, 2025; Forum received payment on October 30, 2025.
On October 30, 2025, GoDaddy.com, LLC confirmed by e-mail to Forum that the microcenter.ai domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, LLC 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 November 3, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of November 28, 2025 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@microcenter.ai. Also on November 3, 2025, 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.
A timely Response was received and determined to be complete on November 28, 2025.
On December 3, 2025, the Complainant filed an Additional Submission.
On December 9, 2025, the Respondent filed an Additional Submission.
On December 1, 2025, pursuant to Complainant’s request to have the dispute decided by a single-member Panel, Forum appointed Gerald M. Levine 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.
RELIEF SOUGHT
Complainant requests that the domain name be transferred from Respondent to Complainant.
PARTIES’ CONTENTIONS
A. Complainant
The Complainant states that it sells a wide variety of technology goods and services under its registered MICRO CENTER trademark. This includes, inter alia, computers, desktops, laptops, tablets, computer gaming equipment and games, various software, drones, crypto mining devices, mobile phones, computer networking products and services, various electronics, hardware, accessories and related products and services, such as computer construction and repair, online and in Complainant’s twenty nine (29) brick and mortar locations in the United States. It has also adopted and registered the domain microcenter.com and does its online computer and electronics’ business at its Micro Center Web Store.
In addition to the foregoing products and services, Complainant markets and sells artificial intelligence personal computers (“AI PCs”) under Complainant’s MICRO CENTER registered trademark. Its AI PCs function at trillions of operations per second, optimize resource allocation, automate routine tasks, streamline workflows, and perform other high level tasks. Complainant also offers PC systems having powerful Central Processing Units (“CPUs”) as well as AI Neural Processing Units (“NPUs”).
The Complainant alleges that the Respondents lacks rights and legitimate interests and registered and is using microcenter.ai in bad faith. More specifically, microcenter.ai resolves to a website with pay-per- click hyperlinks; by way of example:
microcenter.ai
Build Your Own Gaming PC
Desktop PC Deals
Office Depot Desktop Computers
When clicked, the pay-per-click hyperlinks lead to other websites selling products and providing product listings that compete directly with those sold by Complainant and Complainant’s website, i.e., – computing and electronics products, for example, DELL, HP, LENOVO, INTEL and OMEN. This misconduct amounts to lack of legitimate rights and interests as well as bad faith.
The Complainant also alleges that at one point microcenter.ai resolved to a “Trojan Spyware” infected website that locks the user’s computer. The Respondent’s website directs the user to a purported “Microsoft Windows Defender Security – Warning” which states that “Access to this PC has been blocked for security reasons” and “Threat Detected-Trojan Spyware[.]” The Complainant contends that this conduct demonstrates lack of bona fide offerings of goods and services and a lack legitimate interests in the Disputed Domain Name. It also demonstrates bad faith in the registration and use of the domain.
Finally, the Complainant contends that the Respondent uses a privacy shield to hide its identity. Respondent Registration Private also hides its true identity and location information by using Registrar’s, GoDaddy’s contact information on Respondent’s Whois page to give the false impression that Respondent has disclosed its own address in Whois.
B. Respondent
The Respondent denies that microcenter.ai is identical or confusingly similar to microcenter.com. This is principally because the Top-Level Domains (TLDs) are different––the Complainant’s domain uses “.com”, which (according to the Respondent) is universally recognized for commercial websites, while the Respondent’s domain uses “.ai” which is associated with artificial intelligence and technology-focused services. According to the Respondent, this creates distinct impressions and purposes understood by the consuming public.
The Respondent states further that whereas microcenter.com is primarily associated with retail sales of computer hardware and electronics, microcenter.ai is intended for AI-related content, tools, or services, which is a separate industry and audience. It argues that this difference in business model and target audience reduces any likelihood of confusion.
The Respondent continues that while the Complainant’s trademark rights relate to Micro Center as a retail brand, the AI services or technology platforms convey a descriptive or generic meaning (artificial intelligence), not a brand association.
Finally, the Respondent argues that Internet users understand that TLDs matter. A domain ending in “.ai” signals a technology or AI focus, not a retail store. According to the Respondent, this difference in semantic meaning and industry context prevents confusion.
C. Procedural Issue: Additional Submissions
The UDRP Rules provide for a Complaint and Response and do not contemplate supplemental filings except by permission of the Panel. They are generally discouraged and tend to be permitted only in exceptional circumstances where additional supporting evidence is required in reply to unanticipated facts, or fairness calls for an opportunity to respond to the opposing party. See WIPO Overview 3.0, sections 4.6 and 4.7.
However, disregarding these admonitions, the Complainant on December 3, 2025 and the Respondent on December 9, 2025 submitted unsolicited supplemental submissions. Both additional submissions are essentially enlargements of the parties’ pleadings, but as their purpose is to correct purported factual misstatements the Panel has given them a thoughtful read and decided to receive them into the record.
The Complainant takes issue with the Respondent’s description of its business, that it is just a “retail store.” It states that this is misleading because, essentially, it minimizes the breadth and depth of the Complainant’s business. “Further, since Complainant actually sells .ai computers and software, consumers are likely to be confused by the use of the microcenter.ai domain by an unauthorized third party.” Complainant further notes that Respondent admits that “[t]he domain has never been developed, launched, or used for any commercial activity. It has remained parked with GoDaddy since registration.” Response, page 7. Complainant states that “Respondent neglects to describe any efforts or preparatory steps to make use of the domain. Respondent merely asserts that it has an intention to use the domain to create a public forum for discussions about AI.”
In its turn, Respondent takes issue with the Complainant’s assertions that it lacks rights or legitimate interests or that it registered and is using microcenter.ai in bad faith. It denies in full the Complainant’s statement that Respondent’s “intent is to trade off on Complainant’s well known and found mark in the computer and software markets instead of developing his own brand. The Complainant’s statement is unfounded and further disproved.”
In its Additional Submission Respondent goes on to dispute the Complainant’s allegation that “there is no good faith connection between MICRO CENTER and Respondent’s alleged intention to create an .ai public forum sometime in the future. Clearly, the Respondent seeks to pass himself off as Micro Center and Micro Center’s goodwill and reputation.”
In rebuttal, the Respondent’s repeats that “there is no financial gain from creating a public forum directed around artificial intelligence-based conversations. [Thus i]t cannot be ‘clear’ that the Respondent seeks to pass himself off as Micro Center as nothing has been done to demonstrate that he has. [. . .] Therefore, the statement of the Respondent ‘clearly’ seeking to leverage Micro Center’s good will and reputation is falsely made.”
The Respondent continues: “the following statement by the Complainant that ‘it is transparent that Respondent seeks to mislead consumers into believing that he is associated with, or sponsored by, Micro Center’ is unfounded” fails because the facts “demonstrate[ ] the exact opposite. It asserts that by; 1) parking the domain for free, 2) intentionally preventing any search engine optimization (SEO) in an attempt to steer traffic to his website microcenter.ai, 3) working for free, without any desire to monetize the website, to create a public facing domain surrounding artificial intelligence-based conversations. Lack of monetization as well as ongoing hosting/maintenance costs demonstrate that the Respondent is providing a service, free of charge, for the collective of a technological group of like-minded individuals.” Thus, “In no way has bad faith been demonstrated.”
FINDINGS
Having taken all these allegations, contentions, assertions and proof into account, the Panel finds that
1. The Complainant has rights to the Trademark MICRO CENTER by virtue of its ownership of the Trademark and Service Mark MICRO CENTER, Registration No. 1,552,264 registered on the Principal Register of the United States Patent and Trademark Office (“USPTO”) in International Classes 37, 41 and 42 on August 15, 1989; and Registration No. 3,020,431 on the Principal Register in International Class 35, on November 29, 2005.
2. The Respondent acquired microcenter.ai on June 21, 2021 with actual knowledge of the Complainant’s trademark rights.
3. The Respondent lacks rights or legitimate interests in microcenter.ai as it incorporates in whole Complainant’s trademark and violates the Complainant’s exclusive right to its trademark; and
4. The Respondent registered and is using microcenter.ai 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: the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and Respondent has no rights or legitimate interests in respect of the domain name; and the domain name has been registered and is being used in bad faith.
Identical and/or Confusingly Similar
It is well accepted that the first element functions primarily as a standing requirement. The Complainant must demonstrate that it has a mark in which it has a right, and that having done so it must show that the disputed domain name is identical or confusingly similar to that mark.
The Panel finds that the Complainant has demonstrated that it has a registered trademarks for MICRO CENTER that predate the Respondent’s acquisition of microcenter.ai by many years. 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 3.0, section 1.7.
Having compared microcenter.ai and MICRO CENTER side by side, the Panel concludes that the domain name is unquestionably identical to the mark. Respondent’s contention that it is neither identical nor confusingly similar because the top level domain is the country code ai is not an issue for consideration under the first element for the reason that regardless whether the top level domain is generic or a two letter country code, it is no more than a functional necessity. See, F. Hoffmann-La Roche AG v. Macalve e-dominios S.A. WIPO Case No. D2006-0451 (“It is [ ] well established that the specific top level of a domain name such as “.com”, “.org” or “.net” does not affect the domain name for the purpose of determining whether it is identical or confusingly similar.”).
Singularly, an issue has arisen with regard to the use of the country code ai because it is also an acronym for Artificial Intelligence. This issue was considered by the Panel in Toptal, LLC v. Davit Manukyan, FA 2185326 (Forum Nov. 21, 2025) in which it notes “that, in its current list of country codes, and with respect to “.ai”, Wikipedia observe that, as well as signifying Anguilla, “.ai” is “unofficially used by tech companies specializing in AI (Artificial Intelligence.” The Respondent invokes this distinction in arguing that microcenter.ai is neither identical nor confusingly similar to the Complainant’s mark. There is no merit to this contention.
Applying these considerations to this case only makes the disputed domain name even more obviously identical or confusingly similar because it indicates the notion of the well-known MICRO CENTER trademark being used in an “AI” as well as “tech” field, which of course are the fields in which the Complainant uses the trademark.
Accordingly, the Panel finds that the Disputed Domain Name is identical to the MICRO CENTER Mark in which Complainant has rights and Complainant has thus satisfied its burden under paragraph 4(a)(i) of the Policy.
Rights or Legitimate Interests
Under paragraph 4(a)(ii) of the Policy, a complainant has the burden of establishing that a respondent lacks rights or legitimate interests in respect of the disputed domain name, but this burden is light. It is sufficient in the first instance for Complainant to allege a prima facie case, and if the evidence presented is persuasive or yields a positive inference that Respondent lacks rights or legitimate interests, the burden shifts to Respondent to rebut the allegations.
This concept of shifting burdens is clearly explained in Croatia Airlines d.d. v. Modern Empire Internet Ltd., D2003-0455 (WIPO August 21, 2003) in which the Panel held that “[s]ince it is difficult to prove a negative [. . .] especially where the Respondent, rather than complainant, would be best placed to have specific knowledge of such rights or interests—and since Paragraph 4(c) describes how a Respondent can demonstrate rights and legitimate interests, a Complainant’s burden of proof on this element is light.”
Having reviewed the available record, the Panel finds that the Complainant has made a prima facie showing that the Respondent lacks rights or legitimate interests in microcenter.ai and accordingly the Respondent must now come forward to establish that it has rights or legitimate interests in the domain name. It may do this by showing its rights or legitimate interests on proof of any one of the following three circumstances:
(i) before any notice to you of the dispute, your use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or
(ii) you (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or
(iii) you are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.
Of these three circumstances, the Respondent claims rights or legitimate interests under Para. 4(c)(i). It does not deny that on registering microcenter.ai it had actual knowledge of the Complainant’s mark, but it is intent of making a distinction based on the difference between the generic dot com and the country code dot ai. According to this argument, “microcenter.ai is intended for AI-related content, tools, or services, which is a separate industry and audience” from that offered by the Complainant.
While it is correct to say that the addition of the country code ai may imply a use consistent with goods or services relating to artificial intelligence, it is not sufficient to rest a rebuttal on contentions of use unsupported by evidence and where the use to which the domain name resolves is mala fide. See WhatsApp LLC v. Noam Cohen, Case No. DAI2025-0038.
The Complainant adduces evidence that the domain name presently resolves to a PPC landing page (“parked free, courtesy of GoDaddy.com”) containing links to the Complainant’s competitors. Complainant also adduces evidence of an earlier resolution to a “Trojan Spyware” alert page. In responding to this evidence, the Respondent asserts that “it is entirely possible that the Complainant’s computer is compromised and, while visiting websites, it redirected to malicious webpages.” This is purely conjectural and unresponsive to the evidence.
Where the registration of a domain name is intended to be used for a specific purpose which the Respondent outlines it must by definition be a purpose “in connection with a bona fide offering of goods or services.” Here, microcenter.ai currently resolves to a PPC parking page with hyperlinks to competitors. The Respondent brushes this aside on the argument that it is not responsible for the choices of links because they were created by the registrar. It contends that “[a]ny ads or links on the parked page are managed and periodically changed by GoDaddy’s algorithms. Respondent has not configured, selected, or benefited from these ads in any way.”
Assertions of this kind have a long history in UDRP disputes. There are circumstances, not here present, where Registrar generated PPC links may be disregarded or excused. The general view is that infringement of a complainant’s rights negates a defense under Para. 4(c)(i) of the Policy. See Assurant, Inc. v. David Jetter, assurantco llc., WIPO Claim No. D2025-0181 (“The Respondent has parked the disputed domain name for PPC advertising of competing services, and this meets the example of bad faith given in the Policy, paragraph 4(b)(iv)”).
A domain name held for no purpose other than to display links pointing to a complainant’s competitors does not satisfy Para. 4(c)(i) of the Policy. See WIPO Overview (3.0), 2.15: “Apart from the circumstances surrounding their registration, to support a claim to rights or legitimate interests under the UDRP, the use of a disputed domain name must in any event not be abusive of third-party trademark rights.” Also, Section 3.2.2 “Knew or Should have Known.”
In DigiPoll Ltd. v. Raj Kumar, WIPO Claim No. D2004-0939 the Panel noted that “Respondent’s intentions were not sufficient to support its para. 4(c)(i) defense.” Such is the case here. The Respondent cannot explain away the creation of a PPC page with hyperlinks to a complainant’s competitors by pretending that it is offering a service distinctive from the Complainant. If it could, respondents would merely have to allege its intentions without have to prove them.
Nor can the Respondent rest on an assertion that “ICAAN does not stipulate a timeframe or specifically prevent the parking of domain (either indefinitely or during construction).” The Respondent is mistaken in believing that ICANN stipulates to the development of the law under the UDRP. The applicable law develops entirely independent of ICANN. Any time frame is determined by evidence of bona fide offering of goods or services. The Panel does not find that the Respondent has satisfied the “bona fide offering of goods or services” burden let alone that is has shown “demonstrable preparations” for any such use.
If the time frame could be indefinite or even prolonged while offering a supposed service incorporating a complainant’s mark, the UDRP would lose it efficacy in suppressing cybersquatting.
The Respondent’s final argument rests on its self-professed intention that “working for free, without any desire to monetize the website, to create a public facing domain surrounding artificial intelligence-based conversations” somehow insulates it from liability. Such a concept has no basis under UDRP jurisprudence. Neither does the Respondent’s belief that “[l]ack of monetization as well as ongoing hosting/maintenance costs demonstrate that the Respondent is providing a service, free of charge, for the collective of a technological group of like-minded individuals” support rights or legitimate interests. This follows because altruistic intentions for a domain name that incorporates a distinctive mark runs afoul of Para. 4(c)(i) of the Policy.
Accordingly, the Complainant has satisfied Para. 4(a)(ii) of the Policy.
Registration and Use in Bad Faith
Having determined that Respondent lacks rights or legitimate interests, the Complainant must then prove on the balance of probabilities both that the disputed domain name was registered in bad faith and that it is being used in bad faith. The consensus expressed in WIPO Overview 3.0, section 3.1.4. is that “the mere registration of a domain name that is identical or confusingly similar [. . .] to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith.”
This does not mean that a respondent lacking rights or legitimate interests is for that reason alone liable for registering and using the disputed domain name in bad faith, but it does mean that upon persuasive proof that a respondent registered and is using a domain name in bad faith that the Respondent come forward with proof that it registered and is using the disputed domain name in good faith.
The Panel finds that Respondent’s rebuttal falls short of demonstrating that it registered and is using microcenter.ai in good faith. See JUUL Labs, Inc. v. Nics Telekomunikasyon A.S., FA 1890140 (Forum Apr. 24, 2020) (“[W]here a disputed domain name is so obviously connected with such a well-known name, product or service, its use by someone with no connection to the name, product or service indicates opportunistic bad faith”); See also Google LLC v. Noboru Maruyama/ Personal, FA 1879162 (Forum Mar. 3, 2020) (the registration and use of a domain name that is confusingly similar to a trademark with which the respondent has no connection is evidence of bad faith.).
Further to its rebuttal, Respondent submits that “According to the ICANN Uniform Domain Name Dispute Policy (UDRP), bad faith requires evidence of intent to profit, mislead, or harm the complainant.” This is not correct if by this the Respondent takes “profit” to mean monetary gain. Panelists have construed the concept of “profit” to mean any benefit of any kind.
Taking into account the totality of evidence, the Panel finds that the Respondent’s conduct and the fact that it had actual knowledge of the Complainant and its mark supports the conclusion that its registration and use of microcenter.ai was in bad faith.
The Panel finds further that the Respondent registered the dot ai domain name with actual knowledge of the Complainant’s trademark rights. Even if the Panel were to disregard proof that the disputed domain name had previously resolved to a Trojan Spyware page, it is evident that in registering a domain name incorporating a well-known mark that offers goods and services that include artificial intelligence that the Respondent was in bad faith territory.
The Respondent’s overall conduct therefore supports a finding of bad faith registration and use of the disputed domain name under paragraph 4(b)(iv) of the Policy. Therefore, the Complainant succeeds on this element.
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 microcenter.ai domain name be TRANSFERRED from Respondent to Complainant.
Gerald M. Levine, Panelist
Dated: December 12, 2025
