ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Fenix International Limited c/o Walters Law Group v. riyazat durrani Case No. D2025-4036 1. The Parties Complainant is Fenix International Limited c/o Walters Law Group, United States of America. Respondent is riyazat durrani, India. 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 October 2, 2025. On October 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 3, 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 Complainant on October 6, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on October 6, 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 Respondent of the Complaint, and the proceedings commenced on October 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 29, 2025. The Response was filed with the Center on October 20, 2025. Accordingly, the Center acknowledged the receipt of the Response on October 21, 2025, and proceeded to Panel appointment.
page 2 The Center appointed Stephanie G. Hartung as the sole panelist in this matter on November 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 Complainant is a company that operates a social media platform at “www.onlyfans.com” which allows users to post and subscribe to audiovisual content on the Internet. Complainant has provided evidence that it is the registered owner of various trademarks relating to its ONLYFANS brand, inter alia, but not limited to, the following: - word trademark ONLYFANS, European Union Intellectual Property Office (EUIPO), registration number: 017912377, registration date: January 9, 2019, status: active; - word trademark ONLYFANS, United States Patent and Trademark Office (USPTO), registration number: 5,769,267, registration date: June 4, 2019, status: active. Moreover, Complainant has demonstrated that it owns since 2013 the domain name , used to operate Complainant’s aforementioned social media platform. Respondent is the founder and director of a company located in India. The disputed domain name was registered on May 14, 2025; it resolves to a website at “www.onlyfan.site”, which is headed “OnlyFan” and offers adult chatting services by connecting Internet users with images of AI created and operated personas having the look of young women referred to as “models” for a dollar-price per each five minutes. On July 22, 2025, Complainant sent a cease-and-desist letter to Respondent demanding to stop using and cancel the disputed domain name, which remained unanswered. Complainant requests that the disputed domain name be transferred to Complainant. Respondent, in turn, requests that the Complaint be denied. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, Complainant contends that its social media platform at “www.onlyfans.com” is one of the most popular websites in the world with more than 305 million registered users, which has become a prime target for cyber-squatters wishing to profit from the goodwill that Complainant has garnered in its ONLYFANS trademark. Complainant submits that the disputed domain name is identical – or, at the very least, confusingly similar – to its ONLYFANS trademark, as it fully and solely incorporates the singular form thereof. Moreover, Complainant asserts that Respondent has no rights or legitimate interests in respect of the disputed domain name since (1) Respondent has no connection or affiliation with Complainant and has not received any authorization, license, or consent, whether express or implied, to use Complainant’s ONLYFANS trademarks in the disputed domain name or in any other manner, (2) Respondent is not commonly known by Complainant’s ONLYFANS trademark and does not hold any trademark rights for the disputed domain name, (3) Complainant has achieved global fame and success in a short time which makes it clear that Respondent knew of Complainant and its ONLYFANS trademark and that Respondent has no rights or legitimate interests in the disputed domain name. Finally, Complainant argues that Respondent has registered and is
page 3 using the disputed domain name in bad faith since (1) the disputed domain name was registered long after Complainant attained registered rights in its ONLYFANS trademark, (2) the disputed domain name is confusingly similar to Complainant’s widely known ONLYFANS trademark which creates a presumption of bad faith, (3) there is no benign reason for Respondent to have registered the disputed domain name if not to target Complainant’s ONLYFANS trademark, and (4) the disputed domain name directs to a commercial website that offers adult entertainment services in direct competition with Complainant’s services, including “arranging subscriptions of the online publications of others”. B. Respondent Respondent contends that Complainant has not satisfied all three of the elements required under the Policy for a transfer of the disputed domain name. Notably, Respondent points to the fact that the descriptive terms “only” and “fan” refer to an exclusive admirer or supporter in a noncommercial, technological context. Respondent argues that the disputed domain name is not identical or confusingly similar to any trademark in which Complainant has rights. Moreover, Respondent submits that it has rights and legitimate interests in respect of the disputed domain name since (1) the Domain Name resolves to a prototype website featuring AI-generated model images, chat interfaces, and voice call simulations powered entirely by artificial intelligence with no human intervention or adult content being involved, (2) Respondent has invested significant resources, including payments to developers for enhancements, and plans to integrate the platform at the disputed domain name under Respondent’s company’s corporate umbrella for scalable AI solutions, (3) Respondent was unaware of Complainant or its ONLYFANS trademark prior to this proceeding and has never sought to profit from or mimic any third party brand, and (4) the use of the disputed domain name constitutes noncommercial, fair use under the Policy. Finally, Respondent asserts that it has neither registered nor is using the disputed domain name in bad faith since (1) the disputed domain name was registered with no knowledge of Complainant’s ONLYFANS trademark and platform and with no intent to target Complainant, (2) the website under the disputed domain name is non-monetized, and (3) passive holding due to technical glitches does not equate to bad faith, especially with documented good-faith investments. 6. Discussion and Findings Under paragraph 4(a) of the Policy, Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) that Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. A. Identical or Confusingly Similar First, 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 ONLYFANS 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. Complainant has shown rights in respect of its ONLYFANS trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. Moreover, such trademark is almost entirely reproduced within the disputed domain name, simply in a misspelled/typo-squatted version by omitting the letter “s”, but is still recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to Complainant’s ONLYFANS trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The fact that the disputed domain name includes a misspelling/typo-squatting of Complainant’s ONLYFANS trademark is not at all inconsistent with such finding of confusing similarity, as UDRP panels
page 4 agree that misspelled domain names are even considered to be confusingly similar under the UDRP. WIPO Overview 3.0, section 1.9. The Panel, therefore, holds the first element of the Policy has been established. B. Rights or Legitimate Interests Second, paragraph 4(c) of the Policy provides a list of circumstances in which Respondent may demonstrate rights or legitimate interests in a disputed domain name. 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. Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. In particular, Respondent has neither been granted a license nor has it otherwise been authorized by Complainant to use its ONLYFANS trademark, either as a domain name or in any other way. Also, there is no reason to believe that Respondent’s name somehow corresponds with the disputed domain name, and Respondent does not appear to have any trademark rights associated with the non-dictionary terms “onlyfans” and/or “onlyfan” on its own. Further, the disputed domain name not only is confusingly similar to Complainant’s well-reputed ONLYFANS trademark, but even constitutes a misspelled/typo-squatted version thereof by omitting the letter “s”, absent any credible explanation by Respondent as to why it needed to rely on the very term “onlyfan” in the disputed domain name for the purpose of operating an adult content website (which does not likely exist). Finally, such website at the disputed domain name, which is headed “OnlyFan” and offers adult chatting services by connecting Internet users with images of AI created and operated personas having the look of young women referred to as “models” for a dollar-price per each five minutes is obviously – and contrary to Respondent’s allegations – operated for the purpose of generating some commercial gain. Therefore, such use of the disputed domain name obviously aims at somehow profiting from the reputation connected to Complainant’s undisputedly well-known ONLYFANS trademark and neither qualifies as bona fide nor as legitimate noncommercial or fair within the meaning of paragraph 4(c) of the Policy. The Panel, therefore, finds the second element of the Policy has been established, too. C. Registered and Used in Bad Faith Third, 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 facts of this case allow this Panel to conclude that, on the balance of probabilities (see WIPO Overview 3.0, section 4.2), Respondent was aware of Complainant’s rights in the ONLYFANS trademark when registering the disputed domain name and that the latter is somehow directed thereto. Not only is Complainant’s ONLYFANS trademark undisputedly well-known as has been found in many
page 5 earlier UDRP decisions (see e.g., Fenix International Limited v. WhoisGuard, Inc., WhoisGuard Protected / Marry Mae Cerna, WIPO Case No. D2021-0327). Also, the term “onlyfan” in the disputed domain name constitutes an obvious misspelling or typo-squatting of Complainant’s well-known ONLYFANS trademark by omitting the letter “s” and is, therefore, directly targeting Complainant and the latter. Moreover, the term “onlyfan” is plainly also not a generic term. Finally, Respondent has brought nothing forward as to why it needed to rely on this very term in the disputed domain name for the purpose of operating an adult content website. Such circumstances are clear enough indications for this Panel to conclude that Respondent obviously aimed at taking unfair advantage of Complainant’s ONLYFANS trademark. In this context, UDRP panels have long held that this gives rise to find for bad faith acting on the part of Respondent (see WIPO Overview 3.0, sections 3.1. as well as 3.12). Also, it can be drawn from those circumstances that Respondent obviously aimed at somehow taking unfair advantage of Complainant’s ONLYFANS trademark, and, more concretely, intentionally attempted to attract, for commercial gain, Internet users to its own website by creating a likelihood of confusion with this trademark as to the source, sponsorship, affiliation or endorsement of Respondent’s website, and so serve as evidence of registration and use of the disputed domain name in bad faith within the meaning of paragraph 4(b)(iv) of the Policy. The Panel, therefore, holds that Complainant has established the third element of the Policy, too. 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 Complainant. /Stephanie G. Hartung/ Stephanie G. Hartung Sole Panelist Date: November 25, 2025
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