ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Anthropic, PBC v. Daniel Padron Garcia Case No. D2025-2512 1. The Parties The Complainant is Anthropic, PBC, United States of America (“United States”), represented by Elster & McGrady LLC, United States. The Respondent is Daniel Padron Garcia, Spain. 2. The Domain Name and Registrar The disputed domain name
(the “Disputed Domain Name”) 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 June 25, 2025. On June 26, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On June 26, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 27, 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 July 1, 2025. On July 15, 2025, the Center sent a request for clarification to the Complainant. The Complainant filed a further amended Complaint on July 15, 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 July 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 7, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 8, 2025.
page 2 The Center appointed Nick J. Gardner as the sole panelist in this matter on August 11, 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 a United States corporation. It 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 the 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 owns United States trademark Reg. No. 7645254, registered on January 7, 2025 for the word CLAUDE. It also owns International trademark Reg. No. 1745622, registered on July 10, 2023 for the word CLAUDE. These trademarks are referred to as the “CLAUDE trademark” in this decision. The most recent Claude model, Claude 4, was released on May 22, 2025. The Claude model family is available in at least 175 countries. The Disputed Domain Name was registered on April 18, 2024. It resolves to a website (the “Respondent’s Website”) which impersonates the Complainant. For example its landing page states as follows: “Welcome to Claude AI, Anthropic’s safety-first family of large-language models — now entering the Claude 4 era. Harness frontier performance, transparent reasoning and enterprise-grade trust in one powerful platform. Prefer native apps? Grab our desktop and mobile apps here to chat without juggling browser tabs”. The Respondent’s Website includes a disclaimer, only visible after extensive scrolling, which reads as follows “© 2025 ai-claude.net | This website is purely informational and is managed by enthusiasts of artificial intelligence. We are not the official site for any AI product, nor do we sell any AI-related products”. 5. Parties’ Contentions A. Complainant The Complainant’s contentions can be summarized as follows. The Disputed Domain Name is similar to the CLAUDE trademark. The Respondent has no rights or legitimate interests in the term “claude”. In consequence the Complainant alleges that the Disputed Domain Name was registered and is being used in bad faith. The Complainant says the Respondent’s intent to mislead Internet users is also evidenced by the content located on the Respondent’s Website, and includes, but is not limited to, the use of the Complainant’s registered trademarks, favicon logo identifiable with the Complainant, and textual content claiming to be associated with “Claude.” This supports a finding of bad faith use and registration. It says that by using the Disputed Domain Name, the Respondent intentionally attempted to attract for commercial gain, Internet users to the Respondent’s Website, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of the Respondent's Website or of a product or service on the Respondent's Website. The Complainant says that the Respondent’s use of a disclaimer on its website is insufficient to avoid a finding of bad faith. B. Respondent The Respondent did not respond to the Complainant’s contentions.
page 3 6. Discussion and Findings Preliminary Matters The Panel notes that no communication has been received from the Respondent. However, given the Complaint and Written Notice were sent to the relevant addresses disclosed by the Registrar, then the Panel considers that this satisfies the requirement in paragraph 2(a) of the UDRP Rules to “employ reasonably available means calculated to achieve actual notice”. Accordingly, the Panel considers it is able to proceed to determine this Complaint and to draw inferences from the Respondent’s failure to file any Response. While the Respondent’s failure to file a Response does not automatically result in a decision in favour of the Complainant, the Panel may draw appropriate inferences from the Respondent’s default (see, e.g., Verner Panton Design v. Fontana di Luce Corp, WIPO Case No. D2012-1909). Substantive Matters To succeed, in accordance with paragraph 4(a) of the Policy, the Complainant must satisfy the Panel that: (i) the Disputed Domain Name is identical with 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; (iii) the Disputed Domain Name has been registered and is being used in bad faith. A. Identical or Confusingly Similar The Complainant has rights in the CLAUDE trademark. The Panel finds the Disputed Domain Name is confusingly similar to this trademark. Previous UDRP panels have consistently held that domain names are identical or confusingly similar to a trademark for purposes of the Policy “when the domain name includes the trademark, or a confusingly similar approximation, regardless of the other terms in the domain name” (Wal-Mart Stores, Inc. v. Richard MacLeod d/b/a For Sale, WIPO Case No. D2000-0662). It is established that, where a mark is incorporated in a disputed domain name, the disputed domain name is considered to be confusingly similar to the registered mark (WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7). It is also established that the addition of a descriptive term (such as here “ai”) to a disputed domain name does not prevent a finding of confusing similarity under the first element (WIPO Overview 3.0, section 1.8). It is also well established that the generic Top-Level Domain (“gTLD”), in this case “.net”, does not affect the Disputed Domain Name for the purpose of determining whether it is identical or confusingly similar. See, for example, Rollerblade, Inc. v. Chris McCrady, WIPO Case No. D2000-0429. Accordingly, the Panel finds that the Disputed Domain Name is confusingly similar to the Complainant’s trademark and hence the first condition of paragraph 4(a) of the Policy has been fulfilled. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances any of which is sufficient to demonstrate that a respondent has rights or legitimate interests in a domain name: (i) before any notice to the respondent of the dispute, 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) the respondent has been commonly known by the domain name, even if the respondent has acquired no
page 4 trademark or service mark rights; or (iii) the respondent is 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. None of these apply in the present circumstances. The Complainant has not authorised, licensed, or permitted the Respondent to register or use the Disputed Domain Name or to use CLAUDE trademark. The Complainant has prior rights in the CLAUDE trademark which precede the Respondent’s acquisition of the Disputed Domain Name. The Complainant has therefore established a prima facie case that the Respondent does not have any rights or legitimate interests in the Disputed Domain Name and thereby the burden of production shifts to the Respondent to produce evidence demonstrating rights or legitimate interests in respect of the Disputed Domain Name (see, for example, Do The Hustle, LLC v. Tropic Web, WIPO Case No. D2000-0624; Croatia Airlines d.d. v. Modern Empire Internet Ltd., WIPO Case No. D2003-0455). Furthermore, the Panel considers that the composition of the disputed domain name, consisting of the entirety of the Complainant’s trademark and the term “ai-” which directly relates to the Complainant’s business/products and services under the CLAUDE trademark, carries a risk of implied affiliation with the Complainant. WIPO Overview 3.0, section 2.5.1. Panels have also held that the use of a domain name for illegitimate activity, here, claimed impersonation/passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel therefore finds that the Respondent has failed to produce any evidence to establish his rights or legitimate interests in the Disputed Domain Name. Accordingly, the Panel finds the Respondent has no rights or any legitimate interests in the Disputed Domain Name and the second condition of paragraph 4(a) of the Policy has been fulfilled. C. Registered and Used in Bad Faith In the present circumstances the fact that the Disputed Domain Name resolves to the Respondent’s Website which impersonates the Complainant’s own website leads the Panel to conclude the registration and use were in bad faith. Under paragraph 4(b) of the Policy a non-exhaustive list of factors evidencing registration and use in bad faith comprises: (i) circumstances indicating that you have registered or you have acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or (ii) you have registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location. In the present circumstances the Panel finds that factor (iv) applies as the Respondent was seeking to achieve commercial gain by impersonating the Complainant. Factor (iii) also applies given the
page 5 Respondent’s Website directly impersonates the Complainant’s own official website. The content of the Respondent’s Website seems to be primarily aimed at reviewing and commenting on the Complainant’s CLAUDE-branded AI products. It does not appear to be competing with the Complainant. The Respondent’s Website does however contain various pop-up or click-through advertising links and the Panel infers the Respondent earns commercial revenue for traffic these attract – this amounts to commercial gain within paragraph 4(b)(iv) of the Policy. The Panel also notes that the Respondent has not filed a Response and hence has not availed himself of the opportunity to present any case of good faith that he might have. The Panel infers that none exists. The Panel considers that the Respondent’s use of a disclaimer is insufficient to cure the Respondent’s bad faith. See Bayerische Motoren Werke AG v. Ralfs Liepins, Birojs 2B SIA, WIPO Case No. D2025-0067 where the panel found that the disclaimer would “go unnoticed by most Internet users, who will most likely believe that they are on a website operated by or affiliated with the Complainant”. In the present case the disclaimer is not particularly prominent and a visitor has to scroll down a considerable distance to find it. This issue is discussed in the WIPO Overview 3.0, section 3.7: “How does a disclaimer on the webpage to which a disputed domain name resolves impact a panel’s assessment of bad faith?” “In cases where the respondent appears to otherwise have a right or legitimate interest in a disputed domain name, a clear and sufficiently prominent disclaimer would lend support to circumstances suggesting its good faith. For example, where a respondent is legitimately providing goods or services related to the complainant’s mark only (see Oki Data and its progeny discussed at 2.8), the presence of a clear and sufficiently prominent disclaimer can support a finding that the respondent has undertaken reasonable steps to avoid unfairly passing itself off as related to the complainant, or to otherwise confuse users. On the other hand, where the overall circumstances of a case point to the respondent’s bad faith, the mere existence of a disclaimer cannot cure such bad faith. In such cases, panels may consider the respondent’s use of a disclaimer as an admission by the respondent that users may be confused.” For the reasons discussed above the Panel does not consider the Respondent has a right or legitimate interest in the Disputed Domain Name and accordingly the Panel does not consider the disclaimer, even if it was more prominent, assists the Respondent. Accordingly, the Panel finds that the Disputed Domain Name has been registered and is being used in bad faith and the third condition of paragraph 4(a) of the Policy has been fulfilled. 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. /Nick J. Gardner/ Nick J. Gardner Sole Panelist Date: August 22, 2025
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