DECISION

 

Chai Research Corp. v. Ahmad Awais / Langbase

Claim Number: FA2507002163671

 

PARTIES

Complainant is Chai Research Corp. ("Complainant"), represented by Kim Boyle of Richard Law Group, Inc., Texas, USA. Respondent is Ahmad Awais / Langbase ("Respondent"), represented by Omar Imtiaz, California, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <chai.new>, registered with Cloudflare, Inc.

 

PANEL

The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding.

 

Eduardo Magalhães Machado as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on July 1, 2025; Forum received payment on July 1, 2025.

 

On July 2, 2025, Cloudflare, Inc. confirmed by e-mail to Forum that the <chai.new> domain name is registered with Cloudflare, Inc. and that Respondent is the current registrant of the name. Cloudflare, Inc. has verified that Respondent is bound by the Cloudflare, 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 July 3, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 23, 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@chai.new. Also on July 3, 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 July 22, 2025.

 

On July 23, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Eduardo Magalhães Machado 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

 

The Complainant affirms that it is a leading artificial intelligence platform, performing research in conversational generative artificial intelligence and it offers its CHAI app on Apple's App Store and via Google Play. It claims that it invests significant amounts in developing and marketing its CHAI app and platform and has had substantial success with its app with the consumers in the relevant market.

 

It claims that it is the owner of the CHAI trademark, which it would be registered or the subject of pending trademark applications in many countries around the world for downloadable software using artificial intelligence for chatting and communications, and providing temporary use of online non-downloadable software and mobile applications using artificial intelligence for chatting and communications. It claims it also owns the domains <chai-research.com> and <chai.ai>, and that it has been using the CHAI mark since at least as early as March 31, 2021.

 

Regarding its pending U.S.'s trademark application for CHAI, Serial No. 98297278, filed on December 4, 2023, Complainant explains that it is currently suspended in view of the now-abandoned application for the "Chaibot" trademark, which Complainant would have successfully opposed before the Trademark Trial and Appeal Board.

 

Further, Complainant affirms that the CHAI mark has become favorably known and recognized by the relevant consumer as identifying Complainant's services and distinguishing them from the goods and services of others, and it would have established valuable goodwill in the CHAI mark.

 

In addition, it affirms that, by virtue of Complainant's use and success of its CHAI platform over the past 4 years, it has established its common law rights.

 

In this sense, Complainant alleges that the domain name in dispute is confusingly similar to its CHAI trademark, as it includes the "CHAI" element in its entirety and the TLD "new", which would not be sufficient to distinguish the disputed domain name.

 

It further claims that the Respondent has no rights or legitimate interests in the disputed domain name, as it is not commonly known by Complainant's CHAI mark, nor does Respondent own any trademark application or registration for the marks "chai" or "chai.new". It is also not affiliated with or licensed by Complainant to use the CHAI mark, and it is not an authorized vendor, supplier, or distributor of Complainant's goods and services.

 

The Complainant affirms that the disputed domain name resolves to a site <chai.new>, which describes artificial intelligence chat product and service offerings similar to Complainant's web-based product, and which is visually similar to Complainant's in its black and white colorway, logo iconography and the word CHAI in the upper left corner, in addition to the word CHAI with other words in the center of the page.

 

Finally, it claims that the Respondent has registered the domain name in bad faith, as the Complainant's CHAI trademark was already well-known and distinctive at the time of the registration of the domain name. In addition, the fact that the Respondent would be displaying the Complainant's CHAI trademark at the landing page of the domain for use in connection with artificial intelligence chat products and services, similar to those offered by the Complainant's, it would be clear that the Respondent registered the disputed domain name with knowledge of Complainant's rights and intended to create an association with its products and services.

 

In addition, Complainant claims that, by incorporating its CHAI mark and utilizing a colorway, arrangement of elements including a similar logo placement and overall look and feel similar to Complainant's at the landing page for the disputed domain, Respondent would have created the false impression that its website originates with or is associated with Complainant. It also claims that the fact that the Respondent used a privacy shield on the domain registration information would indicate bad faith.

B. Respondent

 

The Respondent affirms that it is a U.S. company that supplies advanced cloud infrastructure and developer tooling for artificial intelligence agents. Among its offerings is a tool formerly branded CHAI – which would be an acronym for Computer Human AI – which assists software developers in generating code and deploying AI agents on Langbase's proprietary platform, and it was accessible via the disputed domain name, now rebranded to <command.new>.

 

It claims that Langbase, Inc., owner of the disputed domain name, operates at a massive scale, as in June 2025, it was triggered 706 million times to run hundreds of thousands of AI agents powered by its infrastructure, processing billions of AI tokens. It also publishes its research followed by a huge community of developers under the <stateofaiagents.com> research report, and it invests significant amounts in developing new tools and products to help builders and developers make use of intelligent AI agents.

 

In this sense, <chai.new> was built as a "Computer Human AI" product, with the sole purpose to help developers to build AI agents using proprietary AI primitives developed by Langbase, and deploy these agents on Langbase. Thus, it claims that <chai.new> is not a chat bot and it is not meant for AI chat, being meant to help builders and developers to build AI apps and agents.

 

It further claims that "Chai" is a common word meaning "tea" in Urdu, Turkish, Hindi, Russian, and numerous other languages, and its widespread use in commerce across multiple industries would preclude any claim to exclusive rights.

 

Respondent affirms that its use of CHAI as an acronym for "Computer Human AI" would create an entirely different commercial impression and the services would be entirely different. It also claims that its branding actively prevents any possibility of confusion, as "by Langbase" is prominently displayed in the logo, it has a professional developer-focused design language, it uses a technical documentation and terminology, and it has no visual or functional similarity to consumer chat applications. It affirms that the selection of black and white colors and top-left logo placement represents standard web design conventions, and not evidence of copying.

 

Respondent claims that the Complainant lacks registered trademark rights, as it holds no registered trademark for "CHAI" in the United States or any relevant jurisdiction. It claims that the USPTO Application Serial No. 98297278 remains suspended due to prior conflicting marks, and the USPTO database would reveal numerous conflicting "CHAI" marks, which would confirm the term's generic nature.

 

It affirms that is has established legitimate rights though the development and operation of the disputed domain name as a commercial developer platform before receiving any notice from Complainant. It alleges that the domain name directly reflected the service's purpose, which would be Computer-Human AI tools for developers who want to build AI agents and applications. This acronymic use would have created a descriptive mark for Respondent's specialized developer infrastructure, which would be fundamentally distinct from Complainant's consumer chat application.

 

Thus, Respondent affirms that its legitimate interests would be demonstrated through substantial commercial activity, and such extensive usage would have occurred organically through Langbase's pre-existing developer community, without any attempt to trade on Complainant's alleged goodwill.

 

Further, it claims that it has become known for the <chai.new> platform within the AI developer community as a legitimate tool for agent creation, operating with complete transparency regarding the platform's ownership and purpose.

 

Respondent alleges that the registration of the disputed domain name was made without any knowledge of Complainant's service, which would operate in an entirely different market segment. It affirms that the domain was never registered for resale, to prevent Complainant's use, or to divert consumers.

 

Further, it affirms that its actions following Complainant's initial contact disprove any bad faith, as it has immediately proposed a voluntary rebranding plan, providing regular updates on rebranding progress. In addition, it affirms that the rebranding was completed as promised before the complaint was filed. Respondent explains that it has already fully migrated from <chai.new> to <command.new>, pursuant to the pre-existing agreement with the Complainant and not in response to the Complaint, and that the domain now merely redirects to preserve existing user bookmarks and marketing materials, which would be a reasonable transition practice.

 

Regarding the WHOIS privacy protection, Respondent claims that it is an industry-standard security measure recommended by all major registrars to prevent spam, hacking attempts, and identity theft.

 

Finally, it claims that the Complainant has made an improper use of the UDRP process, given that, despite knowing of and acknowledging the voluntary rebranding, Complainant filed this proceeding precisely when Respondent was completing the agreed migration, which would suggest and opportunistic attempt to acquire a premium .new domain without compensation, abusing the UDRP process to circumvent the parties' good faith agreement.

 

Thus, it requested a finding of Reverse Domain Name Hijacking, given that, according to the Respondent: (i) Complainant would be attempting to use the UDRP process to seize traffic from a generic domain and filed the Complaint despite knowing Respondent was voluntarily rebranding; (ii) attempted to pressure a sale after agreeing to the rebrand timeline and lacks any registered trademark rights in the relevant jurisdiction; (iii) the Complainant knew the Respondent was already migrating away and nonetheless filed the Complaint to harass or gain leverage at the exact time when Respondent changed domains, so that respondent wouldn't have ample evidence and all the traffic from <chai.new> domain could be hijacked by the Complainant; and (iv) Complainant filing of the Complaint despite prior good-faith communication constitutes abuse of process.

 

FINDINGS

Complainant is the owner of the WIPO International Registration No. 1770831 for the CHAI word mark, recorded on December 6, 2023, under the Madrid Protocol, designating several jurisdictions, in classes 9 and 42, to cover "downloadable software using artificial intelligence for chatting and communications" and "providing temporary use of online non-downloadable software and mobile applications using artificial intelligence for chatting and communications", respectively.

 

This Panel performed an independent research (See Société des Produits Nestlé SA v. Telmex Management Services WIPO D2002-0070) in the WIPO Global Brand Database and found that the Complainant obtained the following registrations for the CHAI mark in the following jurisdictions on the following dates, through the mentioned International Registration:

 

·       Russian Federation – No. 1770831 – May 8th, 2024

·       European Union – No. 1770831 – May 31th, 2024

·       United Kingdom – No. 1770831 – June 13th, 2024

·       Australia - No. 2419457 – July 16th, 2024

·       Switzerland – No. 1770831 – October 21st, 2024

·       Japan – No. 1770831 – April 3rd, 2025

·       Mexico – No. 1770831 – May 13th, 2025

 

Complainant's is also the owner of the trademark application No. 98297278, for the CHAI mark, filed on December 4th, 2023, with the USPTO, still pending analysis.

 

According to the Complainant's own website (Exhibit B), CHAI means CHAT + AI.

 

The domain name in dispute was registered on February 20th, 2025.

 

The Respondent has not demonstrated that it has any trademark registration for the "CHAI" mark. No trademark registrations or applications were found in the name of the Respondent. However, an article on a third-party blog explaining how its "CHAI" platform works has been published.

 

Currently, the domain name redirects to another domain <command.new>, which displays the COMMAND BY LANGBASE brand and offers a technical platform for building AI agents for developers. 

 

According to Exhibit F brought by the Respondent and not contested by the Complainant, previously to the filing of this Complaint, Complainant contacted the Respondent on June 4, 2025, about the disputed domain name, and there was an exchange of emails until July 5, 2025, after the filing of this Complaint. In this email exchange, the Respondent demonstrated complete willingness to cease use of the trademark, requesting a reasonable period of time to transition to another, and when it did so, it was surprised by this Complaint.

 

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

Initially, the Panel finds that Complainant has not provided sufficient evidence in this Complaint to support its assertion that it has common law trademark rights over the CHAI mark, although this Panel acknowledges that, in previous cases decided by ICANN panelists, these rights have been recognized.

 

In accordance with WIPO Jurisprudential Overview 3.0, item 1.3, "relevant evidence demonstrating such acquired distinctiveness (also referred to as secondary meaning) includes a range of factors such as (i) the duration and nature of use of the mark, (ii) the amount of sales under the mark, (iii) the nature and extent of advertising using the mark, (iv) the degree of actual public (e.g., consumer, industry, media) recognition, and (v) consumer surveys. (…) Specific evidence supporting assertions of acquired distinctiveness should be included in the complaint; conclusory allegations of unregistered or common law rights, even if undisputed in the particular UDRP case, would not normally suffice to show secondary meaning." (emphasis added).

 

While the Complainant claims to have been using the trademark since March 31, 2021, to have millions of daily active users, a good rating on Google Play and Apple Store apps, and to generate millions in revenue, in addition to investing those millions in development and marketing, for example, the only evidence of use of the trademark is a screenshot of its website and the registration of the domain name <chai-research.com>.

 

Nevertheless, noting the global nature of the Internet and Domain Name System, this Panel finds that Complainant has satisfied Policy 4(a)(i), given that it is the owner of the CHAI trademark registration in the Russian Federation, European Union, United Kingdom, Australia and Switzerland, prior to the registration of the domain name in dispute, which contains the "CHAI" sign.

 

Rights or Legitimate Interests

According to Paragraph 4(c) of the Policy, a Respondent may establish its rights or legitimate interests in the disputed domain name 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."

 

In the present case, the Respondent asserts that it had used the disputed domain name to identify its "CHAI" developer platform, where "CHAI" stood for "Computer Human AI", a tool intended exclusively for software developers to build and deploy AI agents, and not as a consumer-facing chat application competing with Complainant's services. According to the unrefuted evidence submitted by the Respondent, prior to any notice of this dispute, the disputed domain name resolved to a legitimate website describing Respondent's technical infrastructure targeted to a community of developers.

 

According to WIPO Jurisprudential Overview 3.0, item 2.2 - "What qualifies as prior use, or demonstrable preparations to use the domain name, in connection with a bona fide offering of goods or services? – non-exhaustive examples of prior use in connection with a bona fide offering of goods or services may include proof of a genuine (i.e., not pretextual) business plan utilizing the domain name, and credible signs of pursuit of the business plan, as well as other evidence generally pointing to a lack of indicia of cybersquatting intent.

 

In independent research conducted by this Panel, which accessed both the Complainant's website and its "CHAI" chat, as well as the old content of the Respondent's domain through the Internet Archive, although both clearly use artificial intelligence to offer their services — which justifies the use of the acronym 'AI' in the "CHAI" sign in both cases —, their market focus and target audience are notably different. While Complainant's CHAI platform is aimed at consumers seeking interactive chat experiences with AI characters, Respondent's platform focused on providing infrastructure-level tools enabling developers to create and deploy their own AI agents.

 

The record further shows that Respondent's CHAI platform was independently covered in a third-party technology article ("How to Build Custom AI Agents in Minutes Using Chai (Vibe Code) by a developer Blogger", dated May 12, 2025, Exhibit E), describing how developers could use Respondent's tools to create custom AI agents. The existence of such independent coverage by an unaffiliated source corroborates Respondent's claim that its use of the disputed domain name corresponded to a genuine developer‑focused product, rather than a pretext to target Complainant's consumer-facing chatbot services.

 

In light of the foregoing, the Panel finds that the Respondent has demonstrated legitimate interests in relation to the disputed domain name, having used it in connection with a bona fide offering of services prior to any notice of this complaint or contact made by the Complainant, pursuant to paragraph 4(c)(i) of the Policy.

 

Registration and Use in Bad Faith

According to Paragraph 4(b) of the Policy, the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:

 

"(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."

 

First, it is important to note that, despite being a registered trademark in some jurisdictions, this does not mean that CHAI is a strong brand in the artificial intelligence sector in general. As acknowledged by the Complainant itself on its website, "CHAI" is an abbreviation derived from "CHAT + AI", and it does not take much creative work to arrive at this combination. This does not mean that anyone can copy the trademark at will, but rather that terms which are descriptive or composed of generic elements receive a narrower scope of protection. Therefore, the context in which the Respondent registered and used the domain name is extremely relevant in assessing whether there was bad faith.

 

In this case, the Respondent has credibly demonstrated that it adopted the term "CHAI" as an acronym for "Computer Human AI", which aligns with the nature of its services, namely developer‑focused infrastructure for creating and deploying AI agents. The Respondent's platform was not aimed at consumer end‑users seeking AI chat experiences, but rather at software developers building their own applications. This distinction in purpose and target audience significantly reduces the likelihood of confusion and undermines an inference of bad faith intent.

 

Furthermore, according to an independent investigation made by this Panel through the Internet Archive, on June 1, 2025 – prior to any contact from Complainant and before the filing of this Complaint – the Respondent's website under the disputed domain name displayed a "CHAI" logo accompanied by the indication "By Langbase," along with an explanatory video explicitly identifying the program as a product of the Respondent itself, as well as comments from its users explicitly referring to Langbase. There was no indication whatsoever that Respondent attempted to suggest any association with Complainant or its CHAI chatbot platform. This independent evidence strongly corroborates Respondent's narrative of bona fide use and transparency regarding the origin of its offering.

 

Moreover, the record contains no evidence that the Respondent sought to sell, rent, or otherwise transfer the disputed domain name to the Complainant or a competitor for valuable consideration, nor that it engaged in a pattern of registering domain names corresponding to others' trademarks. Similarly, there is no evidence of an intention to block Complainant from registering its mark in a domain name, nor to disrupt Complainant's business.

 

On the contrary, the Respondent's behavior when first contacted by the Complainant, by a representative, weighs against a finding of bad faith. The Respondent promptly expressed willingness to adopt a new name and requested only a reasonable transition period to ensure service continuity for its existing developer community. This voluntary rebranding process demonstrates good‑faith cooperation rather than cybersquatting intent. The record also shows that, by July 5, 2025, the Complainant itself, by its representative, acknowledged in email correspondence that the Respondent had already shifted its branding to "COMMAND by Langbase". When this case came before the Panel, the disputed domain name was already redirecting to <command.new>, confirming that a rebranding process was in progress.

 

The Panel also notes Complainant's argument that Respondent's earlier website allegedly used a similar color scheme and logo placement. However, these elements are common design conventions and are insufficient, absent stronger evidence, to support a conclusion that Respondent intentionally sought to imitate Complainant's branding or to mislead Internet users.

 

Regarding Complainant's allegation that the Respondent acted in bad faith by using a privacy protection service to hide its WHOIS registration data, as noted in WIPO Overview 3.0, item 3.6, "there are recognized legitimate uses of privacy and proxy registration services", and the circumstances in which such services are used can however impact a panel's assessment of bad faith. As is widely known, the use of a privacy or proxy registration service is a common practice adopted by many legitimate businesses and individuals to protect against spam, identity theft, and other security risks — even the Complainant, as can be seen in Exhibit B. Absent additional evidence showing that such privacy was employed specifically to conceal wrongful conduct or to prevent a trademark owner from identifying the registrant, the mere use of a privacy service does not in itself support a finding of bad faith.

 

Given all of the above, the Panel finds that Complainant has failed to provide evidence to support the requirement of Paragraph 4(a)(iii) of the Policy.  

 

REVERSE DOMAIN NAME HIJACKING

The Respondent requested for a finding of reverse domain name hijacking, stating that: (i) Complainant would be attempting to use the UDRP process to seize traffic from a generic domain and filed the Complaint despite knowing Respondent was voluntarily rebranding; (ii) attempted to pressure a sale after agreeing to the rebrand timeline and lacks any registered trademark rights in the relevant jurisdiction; (iii) the Complainant knew the Respondent was already migrating away and nonetheless filed the Complaint to harass or gain leverage at the exact time when Respondent changed domains, so that respondent wouldn't have ample evidence and all the traffic from <chai.new> domain could be hijacked by the Complainant; and (iv) Complainant filing of the Complaint despite prior good-faith communication constitutes abuse of process.

 

Under Paragraph 1 of the Rules, "Reverse Domain Name Hijacking" (RDNH) is defined as "using the Policy in bad faith to attempt to deprive a registered domain-name holder of a domain name." Paragraph 15(e) of the Rules provides that if "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."

 

In reaching this conclusion, the Panel notes several key circumstances. On the same day that the Complaint was filed — that is, less than a month after the Complainant's first contact — after several email exchanges — in which the Respondent showed clear signs of good faith, requesting a reasonable period of 30 to 45 days to change the brand name — the Respondent emailed the Complainant updating that it had already selected a new name and was actively migrating from "CHAI" to that new branding. By July 5, 2025, the rebranding had already been implemented, as expressly acknowledged by the Complainant itself in email correspondence. Rather than pursuing or concluding the cooperative resolution that was already underway, Complainant opted to initiate this administrative proceeding.

 

In addition, Complainant failed to provide evidence to support two of the three required elements under the Policy, namely, proof of Respondent's lack of legitimate interests and proof of bad faith registration and use. This is particularly notable given that Complainant was aware of the identity of the Respondent from the outset, yet still chose to rely primarily on conclusory allegations rather than presenting concrete documentary evidence of confusion, commercial targeting, or any other actual indicia of cybersquatting intent. The Complaint also asserted that Complainant's mark was "well‑known", but did not include supporting evidence sufficient to substantiate that assertion.

 

Third, the filing of this Complaint despite the ongoing direct dialogue and Respondent's active rebranding efforts, already acknowledged by Complainant shortly thereafter, reflects a disregard for the cooperative path that was available. Instead of pursuing a resolution already in progress, Complainant chose to initiate an administrative proceeding lacking supporting evidence for two of the three required Policy elements.

 

Taking into account these factors, the Panel concludes that Complainant used the UDRP process as a tactical mechanism to pressure the Respondent into transferring the disputed domain name, notwithstanding Respondent's good faith conduct and willingness to resolve the matter amicably. This constitutes a classic case of Reverse Domain Name Hijacking under Paragraph 1 and Paragraph 15(e) of the Rules. Accordingly, the Panel declares that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding.

 

DECISION

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 <chai.new> domain name REMAIN WITH Respondent.

 

 

 

 

Eduardo Magalhães Machado, Panelist

Dated: August 7, 2025