DECISION
CONTRACTPOD TECHNOLOGIES LTD. v. Fred Ju
Claim Number: FA2506002162186
PARTIES
Complainant is CONTRACTPOD TECHNOLOGIES LTD. ("Complainant"), London, UK, represented by Isabelle Jung Greenberg of CRGO Law, Florida, USA. Respondent is Fred Ju ("Respondent"), Connecticut, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <leah.ai>, registered with NameCheap, Inc.
PANEL
Alan L. Limbury, as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on June 23, 2025. Forum received payment on June 23, 2025.
On June 24, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <leah.ai> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").
On June 25, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 15, 2025 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@leah.ai. Also on June 25, 2025, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.
A timely Response was received and determined to be complete on June 25, 2025.
On June 25 and 26, 2025, Respondent sent unsolicited Additional Submissions to Forum. On June 26, 2025, Complainant submitted an unsolicited reply, to which Respondent sent an unsolicited response on June 27, 2025. The Panel has taken these into consideration.
On June 26, 2025, pursuant to the Parties' requests to have the dispute decided by a single-member Panel, Forum appointed Alan L. Limbury as Panelist.
Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2.
RELIEF SOUGHT
Complainant requests that the domain name be transferred from Respondent to Complainant.
PARTIES' CONTENTIONS
A. Complainant
Complainant, CONTRACTPOD TECHNOLOGIES LTD., based in the United Kingdom, is the owner of several trademark registrations for the LEAH mark including United Kingdom Reg. No. 00801390487 registered on July 24, 2018, European Union Reg. No. 018923616 registered on February 20, 2024 and United States Reg. No. 7416978 registered on June 18, 2024.
The LEAH mark was first used on January 31, 2017 in connection with a software in the medical field by Complainant's predecessor-in-interest, Embecta Corp., from whom Complainant purchased the rights in the LEAH mark on August 1, 2023. Since the assignment of the LEAH mark, Complainant has used the mark in connection with an online software platform in the legal field that includes artificial intelligence, also referred to as "AI".
Respondemt's <leah.ai> domain name is identical to the LEAH trademark in which Complainant has rights.
Respondent has no legitimate rights or interests in respect to the <leah.ai> domain name. Respondent, Fred Ju, is not commonly known by the domain name. Respondent's website located at the domain name has not been in use until around June 10, 2025 (in the last week before the filing of this complaint) and only after Complainant sought to purchase the domain name from Respondent.
In contrast, Complainant has legitimate rights in the LEAH mark and has used the LEAH mark in the U.S. since January 31, 2017 (as the predecessor in interest of Complainant started using the LEAH mark as early as January 31, 2017 in connection with software, as shown in the online records from the U.S. Patent and Trademark Office for the LEAH mark). In 2017, Complainant acquired the rights in the LEAH mark from Embecta Corp. and continued using the LEAH mark in connection with software. Moreover, Complainant is the owner of several registered marks for the LEAH mark including UK Reg. No. 00801390487 which was filed on August 14, 2017, a year and a half prior to Respondent's purchase of the domain name on January 31, 2019.
The <leah.ai> domain name was registered and is used in bad faith by Respondent. By registering the domain name, Respondent clearly intended to confuse the public with Complainant's LEAH mark which is used in connection with an online software with AI. Further, Respondent has no legitimate rights or interests in respect to the domain name as Respondent, Fred Ju, is not commonly known by the domain name. The WHOIS record reflects no mention of the term LEAH. The domain name was registered by Respondent on or about January 31, 2019, subsequent to when Complainant started using the LEAH mark (2017) and subsequent to when the application for the LEAH mark in the United Kingdom was filed.
The domain name consists of a website that lacked any content until very recently. Thus, Respondent's recent adding of content to Respondent's website demonstrates Respondent's bad faith effort to divert customers from Complainant's website and possibly trying to give an incentive to Complainant to accept Respondent's unreasonable sale offer of the domain name for over a million dollars. Indeed, Complainant sought to purchase the domain name from Respondent for a fair price. The negotiations failed due to Respondent's unreasonable counteroffer asking Complainant to pay over a million dollars to purchase the domain name. Based on the above, the domain name was registered in bad faith by Respondent in an effort to extort Complainant. Respondent also registered the domain name in order to prevent Complainant from reflecting the mark and in order to seek unreasonable fees from Complainant to purchase the domain name from Respondent. Accordingly, Respondent fails to actively use the disputed domain name and thus fails to use the domain name in connection with a bona fide offering of goods or services under Policy ¶ 4(c)(i), or a legitimate noncommercial or fair use per Policy ¶ 4(c)(iii). Based on the foregoing, Respondent has no legitimate rights or interests in respect to the domain name, and the domain name was registered and is used in bad faith by Respondent.
B. Respondent
Respondent says his daughter's name is Leah Ju and that, as an Internet enthusiast, Respondent registered the domain name with the intention of developing AI-related services in her field of interest as she grows older.
On June 25, 2025, Respondent requested that the Panel make a finding of Reverse Domain Name Hijacking (RDNH) under Rule 15(e) of the UDRP, submitting that the domain <leah.ai> was lawfully registered by Respondent in January 2019, nearly four and a half years before Complainant's trademark registration for LEAH in July 2023. At the time of registration, Complainant's mark did not exist and the domain name was acquired in good faith for personal, non-commercial use, specifically tied to the Respondent's daughter, whose given name is Leah.
There is no evidence — nor has any been provided — to suggest that Respondent registered the domain name with any intent to sell, mislead, or interfere with Complainant's business. The domain name has never been advertised for sale, used commercially, or configured in any way to capitalize on Complainant's brand. The only mention of a potential sale occurred in response to an unsolicited offer from a third party via a domain inquiry platform, which Respondent met with an intentionally inflated figure to discourage negotiation — not to seek profit.
Despite this, Complainant has initiated a UDRP complaint without disclosing the timing of its trademark rights relative to the domain name's registration and without a legitimate basis under the UDRP criteria. This suggests an effort to misuse the UDRP process to pressure or dispossess Respondent of a lawfully acquired domain name — a classic case of Reverse Domain Name Hijacking.
On June 26, 2025, Respondent submitted that he did not initiate any attempt to sell the domain name. He received an unsolicited inquiry from an unknown individual. Believing it to be a random request from the general public, Respondent replied with an intentionally high and unrealistic counteroffer simply to discourage further communication. The domain name was registered in good faith and was never intended for resale or commercial exploitation of any trademark. Respondent's original and continuing purpose remains personal, tied to his 15-year-old daughter's name and her future interests in AI-related projects.
Complainant's LEAH trademark registration was filed under their corporate entity (Contractpod) after July 2023, well after Respondent registered the domain name in July, 2019. It clearly indicates that the domain name was not registered with knowledge of or intent to target Complainant's mark, which did not exist at the time of registration. The claim of bad faith registration lacks factual and legal basis under the UDRP framework.
It is disappointing to see that Complainant, despite registering/acquiring the trademark LEAH well after Respondent lawfully registered the domain name <leah.ai>, has chosen to pursue this Complaint. This action not only lacks legal merit but also raises concerns about the ethics of attempting to reverse hijack a domain name that was registered in good faith for personal use.
In summary, Complainant replied to the above submissions as follows.
While it may be correct that the domain name was registered nearly four and a half years before Complainant's registration for LEAH in July 2023, it is irrelevant. The registration date of the LEAH mark is not of importance here. Instead, what matters and what Complainant alleged in the Complaint is that the LEAH mark was used since January 31, 2017 in connection with software by Complainant's predecessor-in-interest, Embecta Corp. Thus, in 2019, when Respondent purchased the domain name, the LEAH mark had been in use in commerce in connection with software for over two years already. In contrast, since its purchase by Respondent in 2019, the domain name has not been in use by Respondent in any concrete manner. As a result, Complainant did allege in the Complaint that the domain name was acquired in bad faith by Respondent.
Respondent's further allegation that Complainant initiated a UDRP complaint without disclosing the timing of its trademark rights relative to the domain's registration, and without legitimate basis is incorrect. Complainant did explain the timing of the use of the LEAH mark. In the Complaint, Complainant explained that its predecessor-in-interest, Embecta Corp., had used the LEAH mark in connection with software since 2017. Then, on August 1, 2023, the LEAH mark was purchased and assigned to Complainant. Since that assignment, Complainant has used the LEAH mark in connection with a software. Complainant's current use of the LEAH mark is in connection with a software platform as explained on Complainant's website located at https://contractpodai.com/product/leah-legal/. A more detailed explanation of this use is found in the Complaint. Therefore, contrary to Respondent's allegations, Complainant did not file the proceeding to misuse the UDRP process, but to regain ownership of a domain name that is crucial to its business and operations.
With respect to the bad faith use of the domain name and Complainant's offer to purchase the domain name at a reasonable price, Respondent claims that its counteroffer for an "inflated figure" (of over a million dollars) was meant to "discourage negotiation – not to seek profit." Complainant strongly disagrees with this allegation. If Respondent was in fact not interested in selling the domain name at all, Respondent could have clearly stated that the domain name was not for sale when first contacted by Complainant, and that it was purchased for future use by his daughter Leah. Instead, in its counteroffer asking for over a million dollars to buy the domain name, Respondent stated "I'm already making best offer this domain is for serious buyers with VC backed companies". Based on this comment, Respondent clearly was looking to use the domain name and sell it for profit and had no interest in using it for personal use.
In light of the above, Complainant alleges that the Complaint was not filed in an effort to deprive Respondent of the domain name nor to harass Respondent, but only to allow Complainant to regain ownership of a domain name which is critical to the use of its trademark LEAH.
In summary, Respondent responded to Complainant's Reply that it is evident that Complainant's true objective is not to protect a trademark, but rather to acquire the domain name <leah.ai> at all costs after entering the AI space in 2023. The Complaint reflects a clear desire to obtain a highly desirable and brand-relevant domain name that Complainant failed to secure earlier — not to remedy actual abuse. This underscores the abusive nature of the filing and further supports a finding of Reverse Domain Name Hijacking.
Complainant asserts trademark rights in LEAH via its predecessor, Embecta Corp., dating back to 2017. However, the mark in question is not famous, widely recognized, nor associated in any way with artificial intelligence, either then or now. It is a relatively obscure mark, used exclusively in connection with medical software, with no public visibility or commercial overlap with the AI field, .ai domains, or the broader technology ecosystem.
Crucially, Complainant — including its predecessor — did not begin offering any AI-related services until 2023, more than four years after Respondent registered <leah.ai> in January 2019. There is no record or evidence that, at the time of registration, Complainant had any product, branding, or public association involving artificial intelligence.
Under Paragraphs 4(a)(i) and 4(b) of the UDRP, it is Complainant's burden to prove that the domain name is confusingly similar and that it was registered and used in bad faith. When the asserted mark is relatively unknown, used in a completely unrelated industry like healthcare, and the domain name is a common first name registered for a personal and legitimate purpose, that burden is not met.
Respondent had no knowledge of Embecta's trademark, nor any reason to believe that the term LEAH was protected or associated with any brand, particularly not one engaged in medical software solutions. The domain name was registered in good faith, based on Respondent's daughter's name and a forward-looking idea to explore AI-related development.
Complainant's attempt to extend "software" use from 2017 into the AI domain namespace is both overreaching and unsupported — particularly considering that Complainant itself did not enter the AI field until years later.
Complainant argues that the domain <leah.ai> has not been used "in any concrete manner" since its registration in 2019. However, passive holding alone does not constitute bad faith under the UDRP. Panels have repeatedly held that non-use is not misuse, especially when the domain name is a common personal name and was not registered with any intent to exploit a trademark. Complainant offers no evidence of targeting, and the absence of a live site does not meet the standard for bad faith under Paragraph 4(a)(iii). See WIPO Case No. D2000-0003 (Telstra Corporation Ltd. v. Nuclear Marshmallows).
Complainant argues that Respondent's counteroffer of over one million dollars constitutes evidence of bad faith under Paragraph 4(b)(i) of the UDRP Policy. This is incorrect, both factually and legally. Respondent did not solicit any interest in selling the domain name. The inquiry came through a third-party platform (DomainAgents) and was completely unsolicited. Respondent has never advertised, listed, or otherwise offered the domain for sale. Respondent replied to the inquiry with a single, one-time counteroffer in a deliberately inflated amount, not as a genuine sales negotiation.
Respondent's brief and vague comment — "I'm already making best offer this domain is for serious buyers with VC-backed companies" — is a general expression of the domain name's aspirational future value and in no way suggests an attempt to sell it to Complainant or anyone associated with its mark.
Under UDRP Paragraph 4(b)(i), bad faith requires clear evidence that the domain name was registered primarily for the purpose of selling it to Complainant (or a competitor). In this case, the domain name was registered in January 2019, long before Complainant engaged in any AI-related activity or adopted LEAH in that context. There is no evidence — nor could there be — that Respondent anticipated Complainant's future use of the mark.
UDRP panels have repeatedly confirmed that responding to a third-party approach with a high asking price does not, by itself, constitute bad faith. As stated in WIPO Case D2009-1661 (Goldline International, Inc. v. Gold Line): "The mere fact that a registrant responds to an unsolicited inquiry about a domain name with a high asking price does not, of itself, constitute bad faith."
Respondent registered <leah.ai> in good faith — based on his daughter's
name and an interest in future AI development. The domain name was never intended to interfere with or profit from Complainant's mark. It was registered years prior to Complainant's AI activity, for reasons wholly unrelated to Complainant's business or branding. Complainant's assertion of bad faith is unsupported by the facts and appears instead to be an attempt retroactively to obtain a domain name Complainant failed to secure itself.
In light of the complete absence of evidence that Respondent targeted Complainant's mark and given that Complainant's claims rely on speculative interpretations of an unsolicited, one-time counteroffer and passive domain name ownership, Respondent respectfully requests that the Panel issue a finding of Reverse Domain Name Hijacking pursuant to Rule 15(e) of the UDRP.
This Complaint lacks factual or legal merit and constitutes an abuse of the administrative process — a retroactive attempt to seize a domain name registered in good faith, years before Complainant entered the AI field or developed any relevant brand presence.
FINDINGS
Complainant has failed to establish all the elements entitling it to relief and has engaged in Reverse Domain Name Hijacking.
DISCUSSION
Paragraph 15(a) of the Rules instructs this Panel to "decide a 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."
Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:
(1) the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and
(2) Respondent has no rights or legitimate interests in respect of the domain name; and
(3) the domain name has been registered and is being used in bad faith.
Identical and/or Confusingly Similar
Complainant has shown that, by assignment from Embecta Corp. dated January 8, 2023, it acquired rights in the trademark LEAH, registered in the United Kingdom on July 24, 2018 (Reg. No. 00801390487); in the United States on March 6, 2018 (USPTO Reg. No. 5417035); and International Registration No. 1390487, registered on August 14, 2017.
Complainant also registered the trademark LEAH in the United States on June 18, 2024 (USPTO Reg. No. 7,416,978) and in the European Union on February 20, 2024 (Reg. No. 018923616).
The Panel finds Respondent's <leah.ai> domain name to be identical to Complainant's LEAH marks, since the ".ai" generic top-level domain ("gTLD"), although possibly relevant under the other elements, may be ignored under this element. See, for example, Rollerblade, Inc. v. Chris McCrady, D2000-0429 (WIPO June 25, 2000).
Complainant has established this element.
Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate Respondent's rights or legitimate interests to the domain name for purposes of Paragraph 4(a)(ii):
(i) before any notice to Respondent of the dispute, the use by Respondent 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) Respondent (as an individual, business or other organization) has been commonly known by the domain name, even if Respondent has acquired no trademark or service mark rights; or
(iii) Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert customers or to tarnish the trademark or service mark at issue.
The expression "in particular but without limitation" makes clear that these circumstances are illustrative and not exhaustive.
The <leah.ai> domain name was registered by Respondent, a resident of the United States, on January 31, 2019, prior to the assignment by Embecta Corp. to Complainant of its United States, United Kingdom and International LEAH registrations and prior to the 2024 registrations by Complainant of its LEAH mark in the United States and the European Union.
Hence there is no evidence that, at the time of the registration of the domain name, Complainant had rights in any LEAH marks.
Respondent himself is not commonly known by the domain name. However, it is well known that LEAH is a common female given name. Respondent has exhibited a photograph of his 15-year-old daughter's passport, showing that her first name is Leah. Respondent says he registered the <leah.ai> domain name with the intention of developing AI-related services in her field of interest as she grows older.
The Panel finds that the passport photograph proves that Leah is the name of Respondent's daughter. Accordingly, the Panel finds that Respondent has shown that he has a legitimate interest in the domain name because his daughter is commonly known by the domain name.
Complainant has failed to establish this element.
Registration and Use in Bad Faith
Paragraph 4(a)(iii) of the Policy is expressed in the conjunctive: "the domain name has been registered and is being used in bad faith" and Paragraph 4(b) sets out four illustrative circumstances, which, though not exclusive, shall be evidence of the registration and use of the domain name in bad faith for purposes of paragraph 4(a)(iii), namely:
(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.
The circumstances set out above in relation to the second element satisfy the Panel that, even if Respondent was aware of Complainant's predecessor's United Kingdom, International and United States LEAH trademark rights when registering the domain name, his purpose in doing so was not to take advantage of any of those rights but rather to provide to his then 10 year old daughter the opportunity to pursue AI interests under her own name when she became older.
This purpose is consistent with Complainant's evidence that the domain name did not resolve to an active website until shortly before the filing of the Complaint and that even now, the domain name resolves to an "Under construction" website and remains inactive. The Panel finds that Respondent's passive holding of the domain name comprising the well-known given female name of his daughter is not evidence of the registration and use of the domain name in bad faith.
Further, the evidence provided with the Complaint shows that, over several hours on June 5, 2025, Complainant, through domainagents.com, anonymously offered to buy the domain name for $2,000. Respondent made a counteroffer of $1,010,000, commenting "for serious buyers only $...". Complainant made a counteroffer of $3,500, commenting "Make a real counteroffer,…" and Respondent declined, commenting "I'm already making best offer. this domain is for serious buyers with VC backed companies."
The Panel finds that, contrary to the circumstances set out in Paragraph 4(b)(i) of the Policy, this exchange in 2025, some 6 years after the registration of the domain name and initiated anonymously by Complainant, does not establish that Respondent registered the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to Complainant or its predecessor nor to a competitor of Complainant, for valuable consideration in excess of Respondent's documented out-of-pocket costs directly related to the domain name.
Complainant has failed to establish this element.
REVERSE DOMAIN NAME HIJACKING
Reverse Domain Name Hijacking ("RDNH") is defined in Rule 1 as "using the Policy in bad faith to attempt to deprive a registered domain-name holder of a domain name". Rule 15(e) provides, in part:
"If after considering the submissions the Panel finds that the complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or was brought primarily to harass the domain-name holder, the Panel shall declare in its decision that the complaint was brought in bad faith and constitutes an abuse of the administrative proceeding."
As noted, the <leah.ai> domain name was registered on January 31, 2019, almost 4 years before Complainant acquired any rights in the LEAH mark, which it did by assignment from Embecta Corp. in 2023, and prior to the registration by Complainant of its LEAH mark in the United States and the European Union. On January 5, 2025, Complainant anonymously offered to buy the domain name from Respondent for 2,000 USD. The offer was declined. Complainant increased the offer to 3,500 USD. That offer was declined. The Complaint was filed on June 23, 2025.
In the Panel's view, this is a classic "Plan B" case, i.e., using the Policy after failing in the marketplace to acquire a domain name. This stratagem has been described in several UDRP cases as "a highly improper purpose" and has contributed to findings of RDNH. See, e.g., Patricks Universal Export Pty Ltd. v. David Greenblatt, WIPO Case No. D2016-0653 and BERNINA International AG v. Domain Administrator, Name Administration Inc. (BVI), WIPO Case No. D2016-1811.
Further, Complainant falsely represented that it had rights in the LEAH mark before Respondent registered the <leah.ai> domain name by stating that, in 2017, Complainant acquired the rights in the LEAH mark from Embecta Corp. Complainant also stated that the domain name was registered by Respondent subsequent to when Complainant started using the LEAH mark (2017) and subsequent to when the application for the LEAH mark in the United Kingdom was filed. The evidence shows that it was Embecta Corp. that used the mark and filed the application to register the LEAH mark in the United Kingdom prior to the registration of the domain name. Complainant did not acquire rights in the LEAH mark before the assignment from Embecta Corp. in 2023 and there is no evidence that Complainant used the LEAH mark before the assignment.
In light of the circumstances set out above, the Panel finds this to be a case of Reverse Domain Name Hijacking because it was brought in bad faith and constitutes an abuse of this administrative proceeding.
DECISION
Complainant having not established all three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.
Accordingly, it is Ordered that the <leah.ai> domain name REMAIN WITH Respondent.
Alan L. Limbury, Panelist
Dated: June 30, 2025
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