ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Anthropic, PBC v. Simon Jones Case No. D2025-1669 1. The Parties The Complainant is Anthropic, PBC, United States of America (“United States” or “U.S.”), represented by Elster & McGrady LLC, United States. The Respondent is Simon Jones, United States. 2. The Domain Name and Registrar The disputed domain name is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 24, 2025. On April 25, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 25, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 5, 2025, 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 May 8, 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 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was May 29, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 2, 2025.
page 2 The Center appointed Evan D. Brown 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. 4. Factual Background The Complainant is in the artificial intelligence business. It has developed a family of large language models (LLMs) which it markets and promotes using the mark CLAUDE. The first model was launched in March 2023 and garnered significant attention, including from Amazon, which invested an initial USD 4 billion in the company. The Complainant has provided evidence of extensive press regarding Complainant’s release of its Claude model and the corresponding sense in which the CLAUDE mark has developed strength since its 2023 launch. The Complainant also enjoys the benefits of registration of the mark CLAUDE, see United States Reg. No. 7645254, registered on January 7, 2025. According to the WhoIs records, the disputed domain name was registered on March 29, 2024. The Respondent has used the disputed domain name to publish a webpage impersonating the Complainant. It goes so far as to contain language stating: “Welcome to Claude AI! We are a dynamic and forward-thinking artificial intelligence company dedicated to revolutionizing the way businesses operate.” 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 did not respond to the Complainant’s contentions. 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 all three of these elements have been met 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. Id. This element requires the Panel to consider two issues: first, whether the Complainant has rights in a relevant mark; and second, whether the disputed domain name is identical or confusingly similar to that mark. The Complainant has established rights in the CLAUDE mark by submitting evidence of both its federal registration and its common law rights. In particular, the Complainant has shown significant use and recognition of the CLAUDE mark well prior to the registration of the disputed domain name, including major media coverage and a substantial investment by Amazon in 2023. These facts support a finding of common
page 3 law rights in the mark. See WIPO Overview 3.0, section 1.3. 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 further demonstrated its rights in the CLAUDE mark by providing a copy of its U.S. registration. See WIPO Overview 3.0, section 1.2.1. The disputed domain name incorporates the CLAUDE mark in its entirety with the term “ai”. This addition does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s CLAUDE mark. See WIPO Overview 3.0, section 1.8. The CLAUDE mark remains clearly recognizable in the disputed domain name. It is standard practice when comparing a disputed domain name to a complainant’s trademarks to not take the extension into account. See WIPO Overview 3.0 at 1.11.1. The Panel finds that the Complainant has established this first element under the Policy. B. Rights or Legitimate Interests The Panel evaluates this element of the Policy by first looking to see whether the Complainant has made a prima facie showing that the Respondent lacks rights or legitimate interests in respect of the disputed domain name. If the Complainant makes that showing, the burden of production shifts to the Respondent. See WIPO Overview 3.0, section 2.1; AXA SA v. Huade Wang, WIPO Case No. D2022-1289. On this point, the Complainant asserts, among other things, that: (1) the Respondent has not used the disputed domain name in connection with a bona fide offering of goods or services, instead using it to impersonate the Complainant in a misleading manner; (2) the Respondent’s website content falsely suggests affiliation with or authorization by the Complainant, which is likely to confuse users and cannot confer legitimate interests; (3) the Respondent is using the disputed domain name to attract customers for commercial gain by capitalizing on the likelihood of confusion with Complainant’s CLAUDE mark, which undercuts any claim of rights or legitimate interests; (4) the Complainant has never granted the Respondent any license, permission, or authorization to use the CLAUDE mark or any confusingly similar variation in a domain name; and (5) the Respondent has not been commonly known by the disputed domain name or the CLAUDE mark and appears to have concealed its identity using false or misleading WhoIs information, further evidencing a lack of legitimate interests. The Panel finds that the Complainant has made the required prima facie showing. The Respondent has not presented evidence to overcome this prima facie showing. And nothing in the record otherwise tilts the balance in the Respondent's favor. The use of a domain name for illegal activity such as impersonation or passing off can never confer rights or legitimate interests on a respondent. Société des Produits Nestlé S.A. v. Great Homes, jobs-nestle.com, WIPO Case No. D2024-2911; WIPO Overview 3.0, section 2.13.1. Accordingly, the Panel finds that the Complainant has established this second element under the Policy. C. Bad Faith The Policy requires a complainant to establish that the disputed domain name was registered and is being used in bad faith. The Respondent has used the disputed domain name to create a website that purports to be operated by the Complainant, including using language such as “Welcome to Claude AI! We are a dynamic and forward-thinking artificial intelligence company...”, which falsely implies a connection with the Complainant. This is clear evidence of bad faith registration and use under paragraph 4(b)(iv) of the Policy, which applies when a domain is used intentionally to attract, for commercial gain, Internet users by creating a likelihood of confusion with the complainant’s mark.
page 4 In addition, the Complainant has provided evidence that the Respondent sent deceptive DMCA copyright infringement notices to others – another indicator of intentional misconduct and bad faith. The Panel finds that the Complainant has established this third element under the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name be transferred to the Complainant. /Evan D. Brown/ Evan D. Brown Sole Panelist Date: June 24, 2025
Full & Egal Universal Law Academy