ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION BlackRock Finance, Inc. v. Roman Seidel, Anastasia Ismailova, Eugen Doerr, Steve Jones, Stealles SRV LTD, Belen Michael, Alfons Arndt Case No. D2025-3239 1. The Parties The Complainant is BlackRock Finance, Inc., United States of America (“United States”), represented by Day Pitney LLP, United States. The Respondents are Roman Seidel, Germany, Anastasia Ismailova, Russian Federation, Eugen Doerr, Germany, Steve Jones, Stealles SRV LTD, Malaysia, Belen Michael, Hong Kong, China, and Alfons Arndt, Germany. 2. The Domain Names and Registrars The disputed domain names , , , and are registered with PDR Ltd. d/b/a PublicDomainRegistry.com. The disputed domain names , , , , , and <2xblackrock.net> are registered with Web Commerce Communications Limited dba WebNic.cc. The disputed domain names , , , , , , and are registered with RU-CENTER-MSK (Regional Network Information Center, JSC dba RU-CENTER). The disputed domain names , , , , , , , , , , and <2x-blackrock.com> are registered with Mat Bao Corporation (the “Registrars”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on August 12, 2025. On August 13, 18, and 22, 2025, the Center transmitted by email to the Registrars requests for registrar verification in connection with the disputed domain names. On August 14, 15, 20, and 25, the Registrars transmitted by email to the Center their verification responses disclosing registrant and contact
page 2 information for the disputed domain names which differed from the named Respondents (Domain Admin, Whoisprotection.cc / GDPR Masked / STEVE JONES) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 25, 2025 with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrars, requesting the Complainant to either file separate complaint(s) for the disputed 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. The Complainant filed amended Complaints on August 29 and September 4, 2025. On August 25, 2025 the Center informed the Parties in Russian and English, that the language of the registration agreement for the disputed domain names , , , , , , and is Russian. On August 29 and September 4, 2025, the Complainant confirmed its request that English be the language of the proceedings. The Respondents did not submit any comments on the Complainant’s submission. The Center verified that the Complaint together with the 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 Respondents in English and Russian of the Complaint, and the proceedings commenced on September 5, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 25, 2025. The Respondents did not submit any response. Accordingly, the Center notified the Respondents’ default on September 26, 2025. The Center appointed Ganna Prokhorova as the sole panelist in this matter on October 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. In Procedural Order No. 1 dated October 7, 2025, the Panel requested additional evidence regarding the relationship between the various named registrants. On October 9, 2025, the Complainant submitted a Supplemental Filing with annexes containing historical WHOIS records and screenshots of the websites to which the disputed domain names resolve. None of the Respondents replied to the Panel’s Procedural Order or otherwise participated in these proceedings. 4. Factual Background The Complainant is a subsidiary of BlackRock, Inc., one of the world’s largest asset management firms. Founded in 1988, the BlackRock group manages approximately USD 12.5 trillion in assets for clients worldwide. The Complainant and its affiliates offer investment management, risk management, advisory services, and related financial services across the globe. The Complainant holds rights in the BLACKROCK trademarks in jurisdictions around the world, including for example United States Registration No. 2,417,737 (registered January 2, 2001) for financial services in class 36. According to the Complaint, the Complainant’s BLACKROCK mark has been used continuously for decades and is widely recognized in connection with high-quality financial and investment services. All of the disputed domain names were registered in late July or early August 2025. At the moment of issuing this decision, all disputed domain names resolve to inactive webpages. While the disputed domain names were active, they resolved to nearly identical websites. Each such website prominently displayed the Complainant’s official BLACKROCK logo and branding, as well as a photograph of the Complainant’s CEO. The webpages purport to announce the “Biggest Crypto Giveaway of $100,000,000” by the Complainant,
page 3 inviting visitors to send cryptocurrency to a specified wallet address with the promise that “we will immediately send back double the amount”. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain names. Notably, the Complainant contends that: (1) the disputed domain names are confusingly similar to the Complainant’s BLACKROCK mark. Each disputed domain name incorporates the BLACKROCK trademark in its entirety. The addition of generic or descriptive terms such as “x2”, “2x”, “25”, “gift”, “get”, “reward”, “bonus” does not prevent a finding of confusing similarity; (2) the Respondents have no rights or legitimate interests in respect of the disputed domain names. The Complainant has never authorized the Respondents to use the BLACKROCK mark, nor to register disputed domain names incorporating it. The Respondents are not affiliated with the Complainant in any way, and there is no evidence that the Respondents are commonly known by “blackrock”. The Respondents are using the disputed domain names to perpetrate a cryptocurrency scam, falsely posing as the Complainant. Such use, essentially a phishing or fraudulent scheme, is inherently illegitimate and cannot be considered a bona fide offering of goods or services. The websites under the disputed domain names are plainly designed to mislead users into sending money, by exploiting the Complainant’s reputation. The Complainant has longstanding prior rights in the BLACKROCK mark, long before the Respondents registered the disputed domain names in 2025. The Respondents registered disputed domain names solely to deceive Internet users, which demonstrates an absence of any legitimate rights or interests; (3) the Respondents registered and are using the domain names in bad faith. Given the fame of the BLACKROCK mark, the Respondents undoubtedly knew of the Complainant and its mark when acquiring the disputed domain names. The deliberate use of the Complainant’s trademark and logo, as well as the image of the Complainant’s CEO, on the scam websites confirms the Respondents’ bad faith intent to target the Complainant. By using the disputed domain names to promote a fictitious USD 100,000,000 giveaway allegedly by the Complainant, the Respondents are intentionally attempting to attract Internet users for commercial gain (in the form of cryptocurrency transfers) by creating a false impression of association with the Complainant. The Respondents’ concealing their identities behind privacy services is evidence of bad faith. The Complainant requests transfer of the disputed domain names to the Complainant. The Complainant also requests consolidation of its claims against the multiple named the Respondents, on the basis that the disputed domain names are under common control and part of a single scheme. B. Respondents No Respondent submitted a Response to the Complaint. Accordingly, there are no contentions from Respondents on record.
page 4 6. Discussion and Findings 6.1. Consolidation: Multiple Respondents The amended Complaint was filed in relation to nominally different domain name registrants. The Complainant alleges that the domain name registrants are the same entity or mere alter egos of each other, or under common control. The Complainant requests the consolidation of the Complaint against the multiple disputed domain name registrants pursuant to paragraph 10(e) of the Rules. The disputed domain name registrants did not comment on the Complainant’s request. 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 the Complainant’s request, the Panel will consider whether (i) the disputed 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. In the present case, the Panel is persuaded that all 28 disputed domain names are controlled by a single person or entity, or a group acting in concert. The record shows a strong pattern of commonalities: all disputed domain names incorporate the BLACKROCK mark and point to virtually identical content (the same BLACKROCK-branded cryptocurrency giveaway). Moreover, every Respondent has registered at least one disputed domain name that incorporates the Complainant’s trademark alongside a combination of the letter “x” and number “2”. The disputed domain names were registered within days of each other, use the same domain name server provider, and the scheme and website design are identical or highly similar across the disputed domain names. Although the WhoIs details revealed several different underlying registrant names and emails, these appear to be aliases or fake identities generated to obscure the true registrant. The Respondents have not come forward to dispute the Complainant’s consolidation request or to argue that they are genuinely independent actors. In view of the unrefuted evidence of common control, the Panel finds that the disputed domain names and corresponding websites are indeed subject to a single controlling mind or entity. As regards fairness and equity, the Panel sees no reason why consolidation of the disputes would be unfair or inequitable to any Party. Moreover, consolidation in a single proceeding will avoid unnecessary duplication, is consistent with the interests of justice, and causes no prejudice to the Respondents, especially since none of them has responded to defend any purported separate interests. Accordingly, the Panel decides to consolidate the disputes regarding the nominally different disputed domain name registrants (referred to below as “the Respondent”) in a single proceeding. 6.2. Language of the Proceeding Pursuant to paragraph 11(a) of the Rules, 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 language of the registration agreements for most of the disputed domain names is English, while for the domain names , , , , , , and , the registration agreements are in Russian.
page 5 The Complaint was filed in English. The Complainant requested that English be the language of the proceeding, noting that the Respondent registered the disputed domain names incorporating the Complainant’s mark BLACKROCK, a well-known English term, written in Latin script. This suggests both an understanding of English and an intention to target English-speaking users. See Orlane S.A. v. Yu Zhou He / He Yu Zhou, WIPO Case No. D2016-1763. Furthermore, the only language used on the websites to which the disputed domain names resolve is English. Three of the four Registrars also employ English-language registration agreements, which further supports the conclusion that the Respondent is familiar with English. The Respondent did not make any submissions regarding the language of the proceedings. When determining the language of the proceeding, the Panel must act judicially and in the spirit of fairness and justice to both parties, taking into account all relevant circumstances, including the parties’ ability to understand and use the proposed language, as well as considerations of time and cost. According to section 4.5.1 of the WIPO Overview 3.0, panels have accepted proceeding in a language other than that of the registration agreement where, among others, (i) evidence shows that the respondent can understand the language of the complaint, (ii) the domain name is composed of language/script that is the same as the language/script of the complainant’s mark, and (iii) where the content the webpage under the domain name was in the language other than language of registration agreement. Having considered these factors, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. The evidence shows that most registration agreements are in English, the disputed domain names consist of the English terms “blackrock”, and the associated websites are entirely in English. Requiring the Complainant to translate the Complaint into another language would result in unnecessary delay and expense, particularly given the Respondent’s apparent understanding of English. The Respondent was afforded the opportunity to object to English as the language of the proceeding or to file a Response in another language, but did not do so. In light of all these circumstances, the Panel finds it fair and appropriate to conduct the proceeding in English. 6.3. Substantive issues To succeed, the Complainant must demonstrate that all of the elements enumerated in paragraph 4(a) of the Policy have been satisfied, namely: (i) that the disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) that the disputed domain names were registered and are being used in bad faith. The onus of proving these elements is on the Complainant even though the Respondent failed to submit a Response. Paragraph 15(a) of the Rules directs the Panel to decide the 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.
page 6 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 Mark and the disputed domain names. WIPO Overview 3.0, section 1.7. The Complainant has established rights in the BLACKROCK trademark by virtue of multiple registrations in the United States and internationally and through longstanding and extensive use in connection with financial and investment services. These registrations predate the creation of each of the disputed domain names. The threshold test under the first element is a straightforward comparison between the Complainant’s mark and the disputed domain names to assess whether the mark is recognizable within the disputed domain names. The generic Top-Level Domains (“gTLDs”) (e.g., “.com”, “.net”, “.org”, “.pro”, “.live”, “.today”) are disregarded for the purpose of this comparison. WIPO Overview 3.0, section 1.11.1. Each of the disputed domain names incorporates the BLACKROCK mark in its entirety, with only the addition of terms, numbers, and/or hyphens, such as “x2”, “2x”, “25”, “2025”, “gift”, “get”, “reward”, “rewards”, “bonus”, “early”, “event”, and “register”. The addition of such descriptive, promotional, or meaningless elements does not prevent a finding of confusing similarity where, as here, the Complainant’s mark remains clearly recognizable. See WIPO Overview 3.0, sections 1.8. Hyphens and numeric modifiers do not prevent a finding of confusing similarity as well. This conclusion applies equally where the added term precedes or follows the mark (e.g., and ). Accordingly, the Panel finds that each of the disputed domain names is confusingly similar to the Complainant’s BLACKROCK trademark. The first element of paragraph 4(a) of the Policy is therefore satisfied. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in the disputed domain names. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. The Complainant has made a prima facie showing that the Respondent lacks any rights or legitimate interests in the disputed domain names. The burden of production thus shifts to the Respondent to rebut the Complainant’s case by demonstrating rights or legitimate interests of its own. However, the Respondent has not responded and has not provided any evidence to claim rights or legitimate interests in the disputed domain names. Based on the case record, the Panel finds no indication that the Respondent is known by “blackrock” or any similar name. To the contrary, BLACKROCK is a famous brand of the Complainant, and the Respondent’s use of the Complainant’s trademark appears entirely aimed at impersonating the Complainant. There is also no evidence of any bona fide offering of goods or services by the Respondent. The use of the disputed domain names is plainly illegitimate. The Respondent has used the Complainant’s logo and a picture of the Complainant’s CEO to create fake websites advertising a cryptocurrency “giveaway” in the Complainant’s name. The sole purpose of these sites is to dupe users into sending cryptocurrency to the
page 7 Respondent under false pretenses. Such fraudulent activity is the antithesis of a bona fide or legitimate use. UDRP panels have consistently held that using a domain name to carry out a scam, phishing, or other illegal activity can never confer rights or legitimate interests on a respondent. See Virgin Enterprises Limited v. Privacy Protection/ LLC Ruslan Khaziev, WIPO Case No. D2021-2597. In this case, the Respondent’s websites are clearly fraudulent, inviting people to send money with a false promise of doubling it, and they trade on the Complainant’s reputation to seem credible. This use of the Complainant’s mark is inherently illegitimate and not in good faith. Moreover, the very composition of the disputed domain names (the Complainant’s trademark in combination with “x2” / “2x” and other terms suggesting a promotion) falsely implies an affiliation with the Complainant. Any use of a domain name that intentionally seeks to mimic or suggest sponsorship by the trademark owner, in furtherance of deception, is not a “fair” or legitimate use under the Policy. The Panel agrees with the Complainant that the Respondent has no connection or authorization from the Complainant, and is only using the disputed domain names to mislead users for financial gain. The Respondent has not come forward with any plausible claim to own rights or legitimate interests in the disputed domain names. Accordingly, the Panel concludes that the Complainant’s evidence remains unrebutted and demonstrates that the Respondent has no rights or legitimate interests in the disputed domain names. The Complainant has met the requirement of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. The Panel finds that the disputed domain names were registered and are being used in bad faith. The circumstances here fit squarely into the example of bad faith described in the Policy, paragraph 4(b)(iv): the Respondent’s scheme is to attract Internet users to its websites by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, or endorsement of those websites, for the Respondent’s commercial gain (in the form of cryptocurrency “donations”). Several factors support this finding: (1) Registration in Bad Faith The Complainant’s BLACKROCK mark is highly distinctive and well-known internationally in the financial sector. The record shows the Complainant has a significant reputation, and its CEO is a prominent public figure in finance. The timing and content of the registrations leave no doubt that the Respondent targeted the Complainant and its mark. The Respondent registered the disputed domain names all featuring the BLACKROCK mark, within a short period (a span of 10 days), and immediately used them for websites that impersonate the Complainant. It is implausible that the Respondent was unaware of the Complainant; indeed, the only logical conclusion is that the Respondent deliberately chose the term “blackrock” precisely because of the fame and credibility associated with the Complainant’s mark. Prior UDRP decisions recognize that where a mark is well-known and the domain name is obviously connected to the complainant’s business, a respondent’s knowledge and targeting of the mark can be inferred. See See Virgin Enterprises Limited v. Privacy Protection/ LLC Ruslan Khaziev, WIPO Case No. D2021-2597. In this case, given the notoriety of the BLACKROCK mark and the identical nature of the website branding to the Complainant’s, the Panel is convinced that the Respondent registered the disputed domain names with the Complainant’s trademark firmly in mind, intending to exploit it.
page 8 (2) Use in Bad Faith The use of the disputed domain names amplifies the evidence of bad faith. The Respondent has set up websites that prominently feature the Complainant’s logo and the image of the Complainant’s CEO, alongside references to the Complainant in text, all to lend authenticity to a fraudulent cryptocurrency scheme. By doing so, the Respondent blatantly misrepresents that the sites, and the supposed giveaway, are authorized or run by the Complainant or its affiliates, which they are not. The scheme asks users to transfer cryptocurrency to participate in a “giveaway” where their funds will be doubled. The Panel concurs with the Complainant that this is a brazen attempt to confuse users and steal money by trading on the Complainant’s name. Using another’s famous trademark in such a manner, to deceive users into believing they are dealing with the trademark owner, is a textbook example of bad faith use under the Policy. The Respondent is clearly seeking to obtain a commercial benefit (cryptocurrency deposits) by creating a false association with the Complainant. This behavior falls within the scope of paragraph 4(b)(iv) of the Policy, as the Respondent is attempting to attract Internet users to its websites by creating a likelihood of confusion with the Complainant’s mark as to the source or endorsement of those websites and the fictitious promotion. The Respondent’s failure to participate in the proceedings or offer any innocent explanation for its registration and use of the disputed domain names also weighs in favor of a bad faith finding. In summary, the Respondent registered the disputed domain names in order to capitalize on the Complainant’s famous mark, and is using them to host a scam that abuses the Complainant’s identity. This constitutes clear bad faith registration and use of the disputed domain names. The Complainant has therefore proven the third element, paragraph 4(a)(iii) of 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 names , , , , , , , , , , , , , , , , , , , , , , , , , <2x-blackrock.com>, <2xblackrock.net> be transferred to the Complainant. /Ganna Prokhorova/ Ganna Prokhorova Sole Panelist Date: October 22, 2025
Full & Egal Universal Law Academy