ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION DRIP DROP HYDRATION, INC v. Grant W. Carey, Grant Carey- Yerac Strategic Solutions Case No. D2025-4148 1. The Parties Complainant is DRIP DROP HYDRATION, INC, United States of America (“United States”), represented by Venable, LLP, United States. Respondent is Grant W. Carey, Grant Carey- Yerac Strategic Soltions, United States. 2. The Domain Name and Registrar The disputed domain name (the “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 October 9, 2025. On October 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On October 13, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (REGISTRANT UNKNOWN) and contact information in the Complaint. The Center sent an email to Complainant on October 14, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on October 14, 2025. Complainant filed a second amendment to the Complaint on October 17, 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 Respondent of the Complaint, and the proceedings commenced on October 20, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 9, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on November 10, 2025. Respondent submitted an email
page 2 communication to the Center on November 12, 2025, requesting a return call as soon as possible. On November 13, 2025, the Center acknowledged receipt of Respondent's email, reminded Respondent to copy the other Party in all communications, and confirmed the Center remained available if needed. No further communications were received from Respondent. The Center appointed Robert A. Badgley as the sole panelist in this matter on November 13, 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 was founded in 2008. Complainant describes itself as “a rapidly growing hydration supplement brand sold nationwide online and in stores at retailers like Target, Walmart, and CVS.” Complainant owns the domain name and uses that domain name to host its commercial website. Complainant also has a social media presence, with more than 68,000 Facebook followers and more than 61,000 Instagram followers. Complainant has registered the trademark DRIP DROP or DRIPDROP in at least 20 jurisdictions around the world. Annexed to the Complaint is a list of Complainant’s registered trademarks in various jurisdictions including China, India, European Union, and Brazil. In the United States, Complainant holds several registered marks. For instance, Complainant holds United States Reg. No. 3,932,601 for the word mark DRIP DROP, registered on March 15, 2011, in connection with “oral hydration solutions in flavored powder, for medical use; electrolyte replacement solutions,” with an October 15, 2010, date of first use on commerce. Complainant also holds United States Reg. No. 5,904,195 for the word mark DRIPDROP, registered on November 5, 2019, in connection with “powder for making non-alcoholic, non-carbonated fruit flavored drinks,” with an October 15, 2010, date of first use in commerce. The Domain Name was registered on March 15, 2025. The Domain Name resolves to a parking page apparently set up by the Registrar. The page features a picture of a lake and the words: DRIP DROP Launching Soon The page then says, “Contact Us.” 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 Name. B. Respondent Respondent did not reply to Complainant’s contentions.
page 3 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Name: (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 The Panel concludes that Complainant has rights in the trademarks DRIP DROP and DRIPDROP through registration and use demonstrated in the record. The Panel also concludes that the Domain Name is confusingly similar to those marks. The Domain Name is comprised of Complainant’s marks plus the letters “com.” In the Panel’s view, notwithstanding the additional letters, the mark remains recognizable within the Domain Name. Complainant has established Policy paragraph 4(a)(i). B. Rights or Legitimate Interests 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 elements: (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. While 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 often impossible 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. 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 Panel concludes that Respondent lacks rights or legitimate interests in respect of the Domain Name. Respondent has not come forward in this proceeding to articulate any bona fide basis for registering the Domain Name, or to dispute the plausible allegations and evidence presented by Complainant. The words “drip drop” in combination may of course be used as a term or a phrase in ordinary English. Respondent, however, has not come forward to claim any such basis for registering the Domain Name. Moreover, even if such a use had been contemplated, the additional letters “com” – immediately preceding the generic Top-Level Domain (“gTLD”) “.com” – bespeak mischief. The addition of “com” right before a .com gTLD in a domain name has often been done as a form of typosquatting, just as many domain names registered for dubious reasons have included the letters “www” at the very beginning of the Second-Level Domain (e.g., ). Without any input from Respondent, the Panel finds it more likely than
page 4 not that the Domain Name was registered here for no legitimate purpose, but with an intent to mislead Internet users seeking Complainant’s website and perhaps its products. Complainant has established Policy paragraph 4(a)(ii). C. Registered and Used in Bad Faith 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 that Respondent has registered and used the Domain Name in bad faith. The Panel incorporates here its discussion above in the “Rights or Legitimate Interests” section. The Panel concludes, on this undisputed record and in view of Respondent’s choice of a Domain Name fully incorporating Complainant’s trademark and adding the letters “com” right before the “.com” gTLD, that Respondent had Complainant and its marks DRIP DROP and DRIPDROP in mind when registering the Domain Name. Panels have found that the non-use of a domain name, including a blank or “coming soon” page, would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. In the circumstances of this case, including Respondent’s choice of an apparent typosquatting-motivated Domain Name, the Panel concludes that Respondent’s non-use of the Domain Name to date does not prevent a finding of bad faith use within the meaning of the Policy. Complainant has established Policy paragraph 4(a)(iii). 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 Name be transferred to Complainant. /Robert A. Badgley/ Robert A. Badgley Sole Panelist Date: December 2, 2025
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