A UDRP was filed against the domain SNSG.com by SNSG Company, LLC, a California rapper’s corporate entity claiming trademark rights dating from 2022. The Complainant argued that the Domain Name was confusingly similar to its SNSG mark and asserted bad faith based on the Respondent’s sale price and passive use.
The Respondent demonstrated that snsg.com was registered in 2003, fifteen years before the Complainant even existed and nearly nineteen years before its trademark rights arose. The Panel found no evidence that the Respondent had ever heard of the Complainant prior to receiving its 2024 purchase inquiry, and no facts suggesting any targeting or opportunistic behavior at the time of registration.
Because there can be no bad-faith registration where a domain predates the complainant’s rights, the case failed outright. The Panel held that passive holding, sale discussions initiated by the Complainant, and a purchase price request could not convert a good-faith 2003 registration into a bad-faith one.
Given that the Complainant ignored settled UDRP principles, pressed forward after being warned, and relied on a theory that “could not possibly succeed,” the Panel held the filing to be abusive.
Final decision: Complaint denied; snsg.com remains with the Respondent. A finding of Reverse Domain Name Hijacking was declared.
Copyright © 2025 DomainGang.com · All Rights Reserved.ARBITRATION AND MEDIATION CENTER – ADMINISTRATIVE PANEL DECISION
SNSG Company, LLC v. Info Case No. D2025-37361. The Parties
The Complainant is SNSG Company, LLC, United States of America (“United States”), internally represented.
The Respondent is Info, Republic of Korea, represented by Cylaw Solutions, India.
2. The Domain Name and Registrar
The disputed domain name snsg.com (the “Domain Name”) is registered with Gabia, Inc. (the “Registrar”).
3. Procedural History
The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on September 15, 2025. On September 16, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On September 17, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (LEE) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 18, 2025, regarding a Complaint deficiency, and providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed “additional supporting evidence” followed by amendments to the Complaint and an amended Complaint in English on September 16, 2025, September 18, 2025, and September 19, 2025, respectively.
On September 18, 2025, the Center informed the parties in Korean and English, that the language of the registration agreement for the Domain Name was Korean. On September 18, 2025, the Complainant requested English to be the language of the proceeding. The Respondent also requested English to be the language of the proceeding on October 17, 2025..
The Center verified that the Complaint together with the amendments to the Complaint and amended Complaints 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 in English and Korean of the Complaint, and the proceedings commenced on September 29, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 19, 2025. The Response was filed with the Center on October 17, 2025.
The Center appointed Ian Lowe as the sole panelist in this matter on November 3, 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. Supplemental filings
On October 17, 2025 the Complainant filed an unsolicited supplemental filing. It dealt firstly with a submission in the Response that the Complainant had been suspended by the California Franchise Tax Board (“FTB”) prior to the filing of the Complaint and that it therefore lacked legal capacity to initiate proceedings under the UDRP. The Complainant stated that it only discovered the fact of its suspension on receipt of the Response and went on to set out the remedial steps it was taking. The Complainant did not attempt to justify the supplemental filing on the grounds that its lack of prior knowledge of the suspension amounted to “exceptional circumstance” (WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.6). However, the Panel notes that this argument could have been raised. The Respondent responded to this element of the supplemental filing in its own supplemental filing on November 4, 2025.
The Panel considers that it is not appropriate for it to attempt to analyze the effect or consequences of a suspension by the California FTB under the appropriate law, whether or not with the benefit of seeking more comprehensive submissions from the Parties by issuing procedural orders. Rather, in light of the Panel’s views on the substantive issues in the case, the Panel will proceed to deal with the Complaint on the assumption that the Complainant did have legal capacity to bring this administrative proceeding under the UDRP.
The Complainant also sought in its supplemental filing to make further submissions that largely comprised rebuttals of the Respondent’s case. The Panel does not accept that it would be appropriate to admit these submissions which, in any event, would have had no bearing on the Panel’s decision.
Accordingly, the Panel declines to accept the Parties’ supplemental filings.
4. Factual Background
The Complaint is very brief and gives almost no details about the Complainant. However, with the benefit of simple Internet searches it appears that the Complainant is the corporate persona of Manuel Alex Cabanyog Mendoza, a Californian rapper known as SNSG. The Complaint states that the Complainant “actively uses ‘SNSG’ as a music artist name and brand name”. 1
The Complainant is the proprietor of United States trademark number 6670576 SNSG (the “Mark”) registered on March 15, 2022.
The Domain Name was registered on June 18, 2003. It does not now resolve, and appears never to have resolved, to an active website.
1The Panel notes its general powers articulated inter alia in paragraphs 10 and 12 of the Rules and has visited the public resources. The Panel considers this process useful in assessing the case merits and reaching a decision. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.8.
On January 25, 2024, the Complainant sent an unsolicited email to the Respondent, asking “Would you be interested in selling the [Domain Name]?” The Respondent responded “I expect a price of 60,000usd for it.”. On January 25, 2024 the Complainant replied: “Way out of my price range I apologize. Thank you! I own the trademark and was hoping to get this name but will use something different.”
On September 18, 2025, after receiving notification of the Complaint, the Respondent wrote to the Complainant pointing out that it had registered the Domain Name on June 18, 2003, that since it had registered the Domain Name before the Respondent acquired trademark rights and had registered a generic four letter combination without any knowledge of the Complainant, it should prove virtually impossible for the Complainant to prove bad faith registration. The Respondent suggested that the Complainant withdraw the Complaint to avoid the panel ruling in its favor with the adverse consequences this would bring and avoid unnecessary costs. Further email correspondence ensued resulting in an agreement that the Complainant would purchase the Domain Name for USD 10,000. However, the agreement was not concluded because the Parties failed to agree on payment terms.
5. Parties’ Contentions
A. Complainant
The Complainant contends that the Domain Name is confusingly similar to its SNSG trademark (the “Mark”), that the Respondent has no rights or legitimate interests in respect of the Domain Name, and that the Respondent registered and is using the Domain Name in bad faith.
Notably, the Complainant contends that the Respondent’s demand for USD 60,000 for the Domain Name and the passive holding of the Domain Name evidences and supports a finding of registration and use in bad faith.
B. Respondent
The Respondent contends that the Complainant has not satisfied all of the elements required under the Policy for a transfer of the Domain Name. The Respondent accepts that the Domain Name is identical or similar to a mark in which the Complainant has rights, but it relies on the fact that the Domain Name was registered almost 19 years before the Complainant acquired trademark rights in the SNSG mark and 15 years before the Complainant was founded.
The Respondent claims that it undoubtedly has rights and legitimate interests in the Domain Name because it was the first to register it, without any knowledge of the Complainant that did not then exist for many more years. The Respondent has acquired a number of four-letter domain names because it regards them as inherently valuable and registered the Domain Name because it was a short, brandable acronym.
The Respondent states that there can be no question therefore of its having registered the Domain Name in bad faith, particularly since the Respondent was entirely unaware of the Complainant until it received the email in January 2024. In addition, the Respondent contends that the Complainant’s reliance on passive use evidencing bad faith use is entirely unfounded since any such argument depends on a finding first of bad faith registration.
Addressing the allegations in relation to the offers to sell the Domain Name, the Respondent points out that the initial approach was made by the Complainant (as it turned out) who did not in any event disclose at that stage that it owned a trademark for SNSG. The Respondent submits that there is nothing wrong in responding to a commercial enquiry for purchase of a domain name. It relies on previous Panel decisions finding that responding to a request from a complainant to purchase a domain name is not considered bad faith. The Respondent states that at no stage did it threaten the Complainant but merely pointed out that for the Complainant to continue with the Complaint, after the Respondent had explained why it would almost certainly fail, would have adverse consequences, including in terms of wasted costs.
6.1 Language of the Proceeding
The language of the Registration Agreement for the Domain Name is Korean. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for several reasons, including but not limited to the fact that the Domain Name consists of Latin characters, not Korean, and that the Respondent had previously corresponded with the Complainant in English.
The Respondent also requested English to be the language of the proceeding on October 17, 2025.
Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English.
6.2 Discussion and Findings
For this Complaint to succeed in relation to the Domain Name the Complainant must prove that:
(i) the 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 Domain Name; and
(iii) the 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 has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.
Ignoring the generic Top-Level Domain “.com”, the Domain Name comprises the entirety of the Mark.
Accordingly, the Panel finds that the Domain Name is identical to a trademark in which the Complainant has rights, and the first element of the Policy has been established.
B. Rights or Legitimate Interests
In light of the Panel’s findings in section C below, the Panel does not need to address the question of the Respondent’s rights or legitimate interests in respect of the Domain Name.
The Panel notes, however, that the Respondent submits that it registered the Domain Name on the basis that it was a potentially valuable four-letter acronym (strictly an initialism) many years before the Complainant came into existence or acquired trademark rights. WIPO Overview 3.0, section 2.10.2 indicates that “For a respondent to have rights or legitimate interests in a domain name comprising an acronym, the respondent’s evidence supporting its explanation for its registration (and any use) of the domain name should indicate a credible and legitimate intent which does not capitalise on the reputation and goodwill inherent in the complainants mark.” See section C below.
C. Registered and Used in Bad Faith
The evidence in the case file does not indicate that the Respondent’s aim in registering the Domain Name was to profit from or exploit the Complainant’s trademark. The Domain Name was registered some 15 years before the Complainant came into existence and almost 19 years before the Complainant acquired trademark rights in the Mark. There is no evidence before the Panel that the Respondent became aware of the Complainant before the email from the Complainant in January 2024, and no evidence supporting a finding that the Respondent was likely to have become aware of the rapper behind the Complainant known as SNSG before that time.
It follows that the Panel finds that the Respondent did not register the Domain Name in bad faith targeting of the Complainant or its trademark rights because the Complainant had no trademark rights at the time that the Respondent registered the Domain Name. WIPO Overview 3.0, section 3.8.1.
Although immaterial, therefore, the Panel further finds that there is no evidence of bad faith use by the Respondent. In circumstances where there was no bad faith registration, neither passive use of the Domain Name, nor offers to sell the Domain Name, can be relevant, and there is no other evidence supporting bad faith use.
D. Reverse Domain Name Hijacking
Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.0, section 4.16.
In this case, although the Complaint was prepared by the Complainant acting through its lay representative, even the most casual research into how to prepare a complaint under the UDRP would have made it quite apparent that a complaint based on trademark rights acquired some 19 years after the Domain Name was registered, and 15 years before the Complainant came into existence, could not possibly succeed. Indeed, without any credible evidence of bad faith registration it should also have been quite apparent that the Complainant could not succeed as to any of the three elements; indeed this was pointed out by the Respondent but ignored by the Complainant.
Accordingly, the Panel finds that the Complaint has been brought in bad faith and constitutes an attempt at Reverse Domain Name Hijacking.
7. Decision
For the foregoing reasons, the Complaint is denied.
/Ian Lowe/ Ian Lowe Sole Panelist
Date: November 17, 2025
