ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Wikimedia Foundation, Inc. v. Joseph Lewis, Ecommerce Company; Monica Lawrence; Kevin Lesnar, Infinity Project Manager; Mercury Digital; Names Redacted Case No. D2025-3035 1. The Parties Complainant is Wikimedia Foundation, Inc., United States of America (“United States”), represented by Zacco Sweden AB, Sweden. Respondents are Joseph Lewis, Ecommerce Company; Monica Lawrence; Kevin Lesnar, Infinity Project Manager; Mercury Digital, United States, and Names Redacted. 1 2. The Domain Names and Registrars The disputed domain name is registered with Name SRS AB; and are registered with GoDaddy.com, LLC; is registered with NameCheap, Inc.; , , , and are registered with Dominet (HK) Limited; and are registered with Name.com, Inc. (collectively, the “Registrars”). The Panel will refer to the disputed domain names collectively as the “Domain Names”, and singly as “Domain Name”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 29, 2025. On July 30, 2025, the Center transmitted by emails to the Registrars requests for registrar verification in connection with the Domain Names. On July 30 and 31, August 4, 2025, the Registrars transmitted by emails to the Center its verification response disclosing registrant and contact information for the Domain 1The Respondents appear to have used the names of third parties when registering two disputed domain names, and . In light of the potential identity theft, the Panel has redacted the two Respondents’ names from this Decision. However, the Panel has attached as Annex 1 to this Decision an instruction to the concerned Registrars regarding transfer of the disputed domain names, which includes the names of the Respondents. The Panel has authorized the Center to transmit Annex 1 to the Registrars as part of the order in this proceeding, and has indicated Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788.
page 2 Names which differed from the named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email to Complainant on August 14, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting that Complainant either file separate complaint(s) for the Domain Names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all Domain Names are under common control. Complainant filed an amendment to the Complaint on August 15, 2025. The Center verified that the Complaint together with the amendment to the 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 named Respondents of the Complaint, and the proceedings commenced on August 20, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 9, 2025. The Response was filed with the Center by Respondent Monica Lawrence on August 20, 2025. Respondents also sent email communications to the Center on August 20, 25, and 26, 2025. The Center appointed Robert A. Badgley as the sole panelist in this matter on September 19, 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 Complainant asserts: “The Wikimedia Foundation, Inc. (“WMF” or “Complainant”) is a nonprofit charitable organization dedicated to encouraging the growth, development, and distribution of free, multilingual, educational content. WMF was founded in 2003 and today manages 14 free knowledge projects built and maintained by a community of thousands of active volunteers, known as the ‘Wikimedia movement.’ The many well-known projects managed by WMF include Wikipedia, a free, online encyclopedia compiled, edited, and maintained by over 115,000 active contributors, […]. WMF provides technological, legal, fundraising, and administrative support for these projects, which together represent one of the most-visited web properties in the world.” “WMF also supports the Wikimedia movement by overseeing a network of organizations around the world, including Wikimedia chapters, thematic organizations, and user groups. These organizations, which share WMF’s mission, support Wikimedia movement activities within a specified geographical region by collecting donations, organizing local events, and promoting current Wikimedia projects such as Wikipedia. Currently, there are 38 chapters, over 146 user groups, and 2 thematic organizations that span over 38 countries and 6 continents.” Complainant owns numerous trademark registrations for WIKIPEDIA in more than 100 jurisdictions, including: United States Reg. No. 3,040,722, registered on January 10, 2006; International Reg. No. 839132, registered on December 16, 2004; and European Union Reg. No. 012847836, registered on December 4, 2014. Complainant’s main website is at the domain name . Prior UDRP panels have recognized the fame of Complainant’s WIKIPEDIA mark. See, e.g., Wikimedia Foundation, Inc. v. Ahmed Ali, Mercury Digital; Mercury Digital; Joseph Lewis, Ecommerce Company; Andrew Ellis, WikiMakers; Muhammad Ali Khalid; Muhammad Ali Khalid, WikiExperts, WIPO Case No.
page 3 D2024-5078 (noting “the intensive use, fame and distinctiveness of the Complainant’s prior well-known trademarks”); Wikimedia Foundation, Inc. v. Syuzanna Nesterova, WIPO Case No. D2018-1454 (“[I]t is obvious that the WIKIPEDIA Trademark is a well-known trademark.”). The Domain Names were registered at various dates from April 26, 2015 and June 26, 2025. One of the Domain Names (, registered by Kevin Lesnar, Infinity Project Manager) resolves to a Pay-Per-Click (“PPC”) page with German text. Another Domain Name () resolves to a parking page. Four of the nine Domain Names (, , , and ) were registered by Joseph Lewis, Ecommerce Company. According to the evidence submitted by Complainant, two of these four Domain names ( and ) resolve to error pages. The other two ( and ) resolve to similar commercial websites offering “Professional Wikipedia Writing Services in USA”. The Domain Names registered by Mercury Digital () and Monica Lawrence () resolve to websites thematically very similar to the commercial websites at and described above. The final Domain Name () resolves to a website graphically different from the above-mentioned commercial sites, but which also purports to offer similar services: “Increase Your Credibility With Our Wikipedia Page Creation Service in USA”. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Names. B. Respondent Except as discussed below in connection with the Monica Lawrence’s Domain Name, no other Respondent has formally disputed Complainant’s contentions, including the contention that all Domain Names were registered by the same person or entity or are under common control (see discussion below in Section 6.1). Respondent Monica Lawrence (registrant of ) stated in her Response: “We wish to clarify that we are a service provider that assisted our client in registering the disputed domain name, . We did not operate or control the website content ourselves.” Respondent Monica Lawrence also asserted that the term “wiki” is “widely used online in many legitimate domains” and “has become descriptive of collaborative or knowledge-based websites.” Respondent also states that her client offered services distinct from Complainant’s services – “publishing assistance, not encyclopedia services” – and that her client placed a clear disclaimer on its website disavowing any affiliation with Complainant. Because Respondent Monica Lawrence stated that she had registered the Domain Name on behalf of a third-party client, the Center asked Respondent whether the third-party client intended to provide its own response to the Complaint. Monica Lawrence stated that she would confer with the client and revert to the Center. It does not appear from the record that anything further was submitted to the Center.
page 4 6. Discussion and Findings 6.1 Procedural Issue - Consolidation of Multiple Respondents The Complaint together with the amendment to the Complaint was filed in relation to several nominally different Domain Name registrants. Complainant alleges that the Domain Name registrants are the same entity or mere alter egos of each other, or that the Domain Names are under common control. Complainant requests the consolidation of the Complaint against the multiple Domain Name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on Complainant’s request for consolidation. Paragraph 3(c) of the Rules states that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder. In addressing Complainant’s request, the Panel will consider whether (i) the Domain Names or corresponding websites are subject to common control; and (ii) the consolidation would be fair and equitable to all Parties. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.11.2. Among other things, Complainant asserts: “Complainant has reason to believe that these domains are all associated with a larger organization that uses shell companies working as fronts for a hub. First of all, most domains uses [sic] similar domain strings, involving the terms “elite” and “wiki”. […]. Monica Lawrence has also been involved in a consolidated proceeding in another UDRP case (D2019-1899) where Joseph Lewis was one of the respondents. The same is true about Kevin Lesnar, who has been involved as a Respondent in case No. D2024-2343 together with Joseph Lewis. Mercury Digital has also been involved in several different UDRP proceedings involving the Complainant, see e.g. D2024-5346 and D2024-5078 (of which the latter also involved Joseph Lewis/Ecommerce company).” Complainant also asserts that several of the Domain Names were registered in the same year (2025), that most of the Domain Names resolve to websites offering essentially the same services, and other alleged bases for finding that all Domain Names are under common control. In prior UDRP cases in which Respondent Joseph Lewis was held to have acted in bad faith vis-à-vis the subject domain names, Respondents Mercury Digital, Monica Lawrence, and Kevin Lesnar were also respondents in at least one such UDRP case apiece. These coincidences are too remarkable to be put down to mere happenstance. Rather, and in particular in the absence of any denial of affiliation from the various Respondents (and the fact that the websites that have been set up in relation to some of the Domain Names are very similar in substance, look, and feel), the Panel finds it more likely than not that the Domain Names registered under the names of Mercury Digital, Monica Lawrence (whose purported principal never responded to the allegations in the Complaint), and Kevin Lesnar are under common control with the four Domain Names registered by Joseph Lewis. With respect to the Domain Names registered by Names Redacted ( and ), considering the potential identity theft / use of false registration details, the absence of any objections to the consolidation, and the similarities in the composition and use with the other seven Domain Names, the Panel found it is more likely than not that these two Domain Names are under the same control as the other seven Domain Names. The Panel considers all nine Domain Names to be under common control and sees no reason why consolidation of the disputes would be unfair or inequitable to any Party, and the Panel will henceforth refer to the various nominal Respondents mentioned in the preceding paragraph collectively as “Respondent”.
page 5 6.2 Substantive Issues Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to each of the Domain Names: (i) the Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) 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 Complainant’s trademark and the Domain Names. WIPO Overview 3.0, section 1.7. The Panel finds that Complainant has rights in the trademark WIKIPEDIA through registration and use demonstrated in the record. The Panel also finds that the Domain Names are confusingly similar to that mark. The dominant element of the mark, WIKI, is clearly recognizable within each of the Domain Names. Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests With respect to each of the Domain Names, pursuant to paragraph 4(c) of the Policy, Respondent may establish its rights or legitimate interests in the Domain Name, among other circumstances, by showing any of the following circumstances: (i) before any notice to you [Respondent] 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 [Respondent] (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 [Respondent] 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. The Panel concludes that Respondent lacks rights or legitimate interests in respect of the Domain Names. With one partial exception, Respondent has not come forward in this proceeding to assert that it is a legitimate business with a legitimate and non-infringing basis for registering the Domain Names. The provision of Wikipedia article writing or editing services, or services to enhance one’s profile on the Wikipedia platform, are by no means illegitimate business pursuits. However, the use of a Domain Name and corresponding website that appears to create a false affiliation between Complainant and the provider of such services is not legitimate within the meaning of the Policy. Prior UDRP panels have made such a finding in the context of this Complainant. See, e.g., Wikimedia Foundation, Inc. v. Ahmed Ali, Mercury Digital; Mercury Digital; Joseph Lewis, Ecommerce Company; Andrew Ellis, WikiMakers; Muhammad Ali Khalid, WikiExperts, WIPO Case No. D2024-5078. With respect to the Domain Name nominally registered by Monica Lawrence, who claimed in a brief Response that she had registered the Domain Name on behalf of a third party, the Panel lends little credence to this Response. First, Monica Lawrence has been involved in a prior UDRP case as Respondent
page 6 together with Joseph Lewis, an association which, in the Panel’s view, undermines her credibility. Second, the alleged third-party principal could not be bothered to assert on its own behalf a justification for having registered the subject Domain Name. Third, although Monica Lawrence asserted some brief substantive arguments, such as no direct competition with Complainant and the presence of a disclaimer, the Panel notes that the website content expressly references Complainant and tends to falsely suggest an affiliation with Complainant, and that the referenced disclaimer is insufficient on its own to support a finding of rights or legitimate interests. Lastly, the Panel notes that Monica Lawrence does not address the fact that the website for the Domain Name is essentially identical to the website of the Domain Name . The Panel also finds that Respondent has no legitimate interest with respect to the Domain Names which resolve to a PPC page, a parking page, or an error page, particularly given the lack of any articulation of an alleged legitimate interest by Respondent. Complainant has established Policy paragraph 4(a)(ii). C. Registered and Used in Bad Faith For each of the Domain Names, paragraph 4(b) of the Policy provides that the following circumstances, “in particular but without limitation,” are evidence of the registration and use of the Domain Name in “bad faith”: (i) circumstances indicating that Respondent has registered or has acquired the Domain Name primarily for the purpose of selling, renting, or otherwise transferring the Domain Name registration to Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of its documented out-of-pocket costs directly related to the Domain Name; or (ii) that Respondent has 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 Respondent has engaged in a pattern of such conduct; or (iii) that Respondent has registered the Domain Name primarily for the purpose of disrupting the business of a competitor; or (iv) that by using the Domain Name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent’s website or other online location, by creating a likelihood of confusion with Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of Respondent’s website or location or of a product or service on Respondent’s website or location. The Panel concludes, on the record provided here, that Respondent has registered and used the Domain Names in bad faith. The Panel incorporates its discussion above in the section 6.2.B. “Rights or Legitimate Interests”. On the record presented here, and in the absence of any corroborating evidence from Respondent, the Panel concludes that Respondent registered the Domain Names in order to target Complainant and its trademark for improper commercial gain, in violation of the above-quoted Policy paragraph 4(b)(iv). In addition, given its involvement in prior UDRP cases, the Panel finds that Respondent has engaged in a pattern of preclusive Domain Name registrations, in violation of the above-quoted Policy paragraph 4(b)(ii). Complainant has established Policy paragraph 4(a)(iii).
page 7 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 Domain Names , , , , , , , and be transferred to Complainant. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: October 5, 2025
Full & Egal Universal Law Academy