DECISION

 

Google LLC v. Qiao Yinhang / LinkingCloud

Claim Number: FA2507002164135

 

PARTIES

Complainant is Google LLC ("Complainant"), represented by Griffin Barnett of Morgan, Lewis & Bockius LLP, District of Columbia, USA. Respondent is Qiao Yinhang / LinkingCloud ("Respondent"), China.

 

REGISTRAR AND DISPUTED DOMAIN NAME 

The domain name at issue is <veo3.ai>, registered with NameCheap, 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.

 

Richard W. Hill and Bart Van Besien as Panelists, and Paul M. DeCicco as Chair.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on July 3, 2025; Forum received payment on July 3, 2025.

 

On July 4, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <veo3.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 July 10, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of August 4, 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@veo3.ai. Also on July 10, 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 August 4, 2025.

 

Complainant's Additional Submission dated August 5, 2025 was received by Forum.

 

On August 19, 2025, pursuant to Respondent's request to have the dispute decided by a three-member Panel, Forum appointed Richard W. Hill and Bart Van Besien as Panelists and Paul M. DeCicco as Chair.

 

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 contends in its Complaint in part as follows:

 

Complainant Google LLC is a Delaware Limited Liability Company located in Mountain View, California with offices throughout North America, Europe, Latin America, Asia Pacific, Africa, and the Middle East.

 

The GOOGLE name and company were created in 1998 by Stanford Ph.D. candidates Larry Page and Sergey Brin. Since that time, the Google search engine has become one of the most highly recognized internet search services in the world. In 2020, Forbes ranked GOOGLE the second most-valuable brand globally, and in 2025 Brand Finance ranked Google as the third most-valuable brand in its Global 500 ranking. Google's website has been recognized as one of the most popular destinations on the Internet

 

On May 14, 2024, Complainant announced its artificial intelligence ("AI") powered video generation offering under the name and trademark VEO. On December 16, 2024, Complainant announced and launched Veo 2, the second iteration of Google's AI-powered video generation offering. On May 20, 2025, Google announced and launched Veo 3, the third iteration of Google's AI-powered video generation offering. There has been extensive unsolicited media coverage relating to Complainant's VEO products.

 

The VEO mark has already become well-known and consumers associate the mark with Google and its AI related goods and services.

 

Complainant has trademark registrations and pending applications for VEO with multiple national trademark registrars worldwide.

 

Likelihood of Confusion. The at-issue domain name is confusingly similar to Complainant's VEO mark, as it wholly incorporates the mark. The at-issue domain name fully incorporates the VEO mark, followed by the number "3" (a reference to the third iteration of Complainant's VEO offering Veo 3), and the ".ai" top-level domain ("TLD"). Such differences do not prevent a finding of confusing similarity between the disputed domain and Complainant's mark.

 

No Rights or Legitimate Interests. Respondent is not licensed or otherwise authorized to use the VEO trademark, nor any other trademark owned by Complainant. Unlicensed, unauthorized use of a third-party trademark in a domain is strong evidence that Respondent has no rights or legitimate interest in the domain name.

 

WHOIS records do not suggest that Respondent is known as Veo 3, Veo, or any variation of Veo. A UDRP respondent may be found to lack any right or legitimate interest in a domain name where there is no indication it is known by that name.

 

Respondent has not used and is not using the at-issue domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use. On the contrary, Respondent is using the domain name in connection with a website that is clearly intended to pass itself off as Complainant or to create the impression that the website is operated by or is affiliated with, sponsored or endorsed by, or otherwise authorized by Complainant in relation to its VEO offerings to attract consumers to Respondent's competing AI offering.

 

Finally, previous panels have held that there can be no rights or legitimate interests under Policy ¶ 4(c)(i) when respondent was on notice that a complainant possesses strong trademark rights in a mark identical or similar to the disputed domain name.

 

Bad Faith. Respondent opportunistically registered and is using the <veo3.ai> in bad faith. The notoriety and distinctive qualities of the VEO trademark, the timing of the registration of the at-issue domain name, and the content displayed on the associated website render it wholly implausible that Respondent independently and innocently registered the at-issue domain name.

 

The use of an infringing domain name through an associated email address may constitute bad faith. Respondent refers to themselves as Complainant on the <veo3.ai> website and invites internet users to contact Respondent by emailing the support@veo3.ai email address associated with the at-issue domain name.

 

Respondent registered the at-issue domain name nine months after Complainant launched Veo, and two months after Complainant launched Veo 2. Complainant's use of the VEO mark, the widespread, unsolicited media coverage associated with Complainant's offerings under the VEO mark. Respondent's registration of the domain name well after Complainant began offering services under its VEO mark clearly demonstrate that Respondent registered the domain name in bad faith to target Complainant and its VEO brand.

 

In this context, Respondent's use of a proxy service to hide its actual registration information is further evidence of bad faith.

 

B. Respondent

Respondent contends in its Response as follows:

 

The domain name <veo3.ai> is not confusingly similar to a trademark in a manner that violates the Policy because Respondent has legitimate interests in the name. While the Complainant asserts rights in the "VEO" mark, the term "veo" is a common word. Specifically, "veo" is the Spanish word for "I see," a term highly descriptive of services related to video and visual content generation. The selection of the domain name was based on this descriptive meaning, which is directly relevant to the nature of the services offered. The addition of the number "3" refers to the third version of the Respondent's own independent project and is not a reference to any of the Complainant's products. The top-level domain ".ai" is similarly descriptive of the Artificial Intelligence technology used to provide the service. Therefore, the domain name was chosen for its descriptive qualities, not to target the Complainant.

 

Respondent has rights and legitimate interests in the domain name. Pursuant to Paragraph 4(c)(i) of the Policy, the Respondent has a legitimate interest in the domain name. The Respondent has been using <veo3.ai> in connection with a bona fide offering of services prior to any notice of this dispute. Respondent developed an AI video generation service and selected a descriptive name for it. The business was established and has been operating under the <veo3.ai> domain, offering a legitimate service to its users. This constitutes a bona fide offering of services under the Policy. The Respondent is not using the domain name to misleadingly divert consumers or to tarnish the Complainant's trademark.

 

The domain name was not registered and is not being used in bad faith. Respondent categorically denies that the domain name was registered and used in bad faith. The registration of <veo3.ai> was based on the descriptive and generic value of the term "veo" as explained above, not made with the intention of targeting the Complainant or its trademark. At the time of registration, Respondent was not aware of Complainant's trademark rights in a manner that would preclude the registration of a descriptive term for a related service. Any temporal proximity to Complainant's product announcements is coincidental. The <veo3.ai> website's design, layout, and color scheme are based on common, contemporary design trends prevalent in the technology and SaaS industries and were not intended to mimic or create an association with the Complainant's properties. Respondent's intent is to offer a competitive service under a descriptive name, not to create a likelihood of confusion for commercial gain.

 

Procedural Request. Without prejudice to the foregoing arguments, should the Panel find in favor of the Complainant, Respondent respectfully requests that the implementation of the decision be stayed for a period of 21 days. This temporary stay is requested to allow for an orderly and smooth transition of the Respondent's existing paid subscribers and users to an alternative platform. This is critical to prevent undue disruption to their services and to ensure business continuity for valued customers who rely on the service.

 

C. Additional Submissions

Complainant contends in its Additional Submission (Complainant's Further Statement) in part as follows:

 

VEO is not descriptive in relation to the relevant goods and services, as demonstrated by the numerous registrations that have been granted to Complainant around the world for this mark in connection with the Complainant's associated AI offerings. While Respondent claims that its inclusion of the number "3" in the domain name refers to the third iteration of their own independent project, Respondent provides no evidence of this. The only evidence in the record relating to Respondent's use of the number "3" in the at-issue domain name is the opportunistic domain name registration date - which occurred after Complainant's launch of Veo 2 but before Complainant launched Veo 3, Respondent's extensive on-site references to Complainant and Complainant's Veo 3 offering, and Respondent's identical commercial offering under the identical "Veo 3" name. While TLDs are generally irrelevant under the first UDRP factor, Respondent's use of the ".ai" TLD in this context further demonstrates Respondent's intent to trade off Complainant and its AI-related services offered under its VEO mark. Notwithstanding the above, a simple side-by-side comparison between the domain name and the VEO mark in which Complainant has demonstrated its established prior rights clearly illustrates that the at-issue domain name is confusingly similar to Complainant's VEO trademark. 

 

Respondent fails to address the timing of the domain name registration, which as noted above, occurred between the launch of Google's Veo 2 and Veo 3 offerings and after Complainant had filed for and secured registrations for its VEO mark. Respondent also fails to address the fact that many of the supposed testimonials on Respondent's site specifically refer to Complainant and Complainant's Veo 3 offering, as does the "pricing" section of the site which explicitly refers to "Google 3 Veo Support." Respondent clearly selected an identical name for identical offerings to those provided by Complainant with prior knowledge of Complainant and its VEO Mark. Thus, notwithstanding the fact that Respondent's offerings are imitative of Complainant's offerings, Respondent engages in trademark infringement, rendering Respondent's use non-bona fide within the meaning of the UDRP.

 

Respondent has provided no evidence supporting a claim that its adoption and use of the identical mark, VEO, for its identical and directly competing AI offering, was coincidental or somehow superior to Complainant's rights. Therefore, the evidence demonstrates that Respondent has no rights or legitimate interests in the at-issue domain name. Respondent's assertion that the timing of the domain name registration and Google's Veo product announcements was merely coincidental, and that Respondent was not aware of Complainant's rights in Complainant's VEO Mark, is clearly undercut by Respondent's own admission that Respondent's intent is "to offer a competitive service." See, e.g., Google LLC v. Elke Qin, FA2503002144832 (Forum April 8, 2025) ("Respondent registered [veo-2.net]...five days after Google publicly announced the launch of the second iteration of its VEO offering, Veo 2…and approximately seven months after the initial launch of Veo…These facts support the conclusion that Respondent registered the domain name in bad faith with the intention of targeting Complainant and its VEO brand"). Respondent's assertions are further undermined by the fact that the <veo3.ai> website is replete with references to Complainant and supposed consumer testimonials that clearly demonstrate confusion.

 

RESPONSE TO RESPONDENT'S REQUEST FOR POST-DECISION STAY PERIOD. Complainant is not aware of any UDRP rule that would allow for Respondent to request a stay of the Panel's decision for 21 days. Respondent will enjoy a ten (10) business days appeal period. This is the only post-decision pre-transfer period contemplated under the Policy. As a result, Complainant respectfully requests that in the event the Panel decides in Complainant's favor that Respondent's request for a separate temporary stay be denied.

 

Respondent titles as an "Additional Submission" its list of three candidates to serve on the three-member Administrative Panel.

 

FINDINGS

Complainant has rights in the VEO trademark.

 

Respondent is not affiliated with Complainant and had not been authorized to use Complainant's trademark in any capacity.

 

Respondent registered the at-issue domain name after Complainant acquired rights in VEO.

 

Respondent uses the at-issue domain name to direct internet users to a website that offers services that are competitive with Complainant's offering.

 

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

The at-issue domain name is confusingly similar to a trademark in which Complainant has rights.

 

Any of Complainant's multiple worldwide trademark registrations for VEO is sufficient to demonstrate Complainant's rights in a mark under Policy ¶ 4(a)(i). See Thermo Electron Corp. v. Xu, FA 713851 (Forum July 12, 2006) (finding that the complainants had established rights in marks where the marks were registered with a national trademark authority).

 

Respondent's <veo3.ai> domain name contains Complainant's entire VEO trademark, followed by the numeral "3", with all followed by the ".ai" country code top-level domain name. The differences between Complainant's VEO trademark and Respondent's at-issue domain name fail to distinguish the domain name from Complainant's mark under Policy ¶ 4(a)(i). Therefore, the Panel finds that Respondent's <veo3.ai> domain name is confusingly similar to Complainant's VEO trademark.  See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognizable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element.");  see also, Pandora Media, Inc. v. MASATAMI KITA, FA 1622614 (Forum July 20, 2015) (holding the <pandora1.com> domain name confusingly similar to the PANDORA trademark because the only difference between the two was the addition of the numeral "1" and the gTLD ".com"). see also, Bloomberg Finance L.P. v. Igor Gabrielan, FA2311002072420 (Forum Jan. 8, 2024) (Stating: "Under Policy ¶ 4(a)(i), adding the ".ai" gTLD to a mark does not differentiate the domain name from the mark it incorporates…" and finding the subject domain name confusingly similar to the BLOOMBERG mark).

 

Respondent argues that Complainant's mark is not confusingly similar to its domain name since Complainant's mark is made up of a common word "veo" which is Spanish for "I see" and that VEO is thus used in the at-issue domain name to suggest or describe the subject of Respondent's commercial business. Respondent continues that adding the numeral "3" simply refers to the third version of Respondent's own independent project and that the top-level domain name, "AI", only suggests the technology used by Respondent to provide its services. However, Respondent's claims do not negate Complainant's established trademark rights in its registered VEO mark and even if credible, Respondent's rational for including additional terms along with VEO in Respondent's <veo3.ai> domain name, is not relevant to the Panel's confusingly similarity analysis finding that the inclusion of additional terms and a top-level in Respondent's trademark laden domain name do not distinguish the domain name from Complainant's mark.

 

Rights or Legitimate Interests

Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006).

 

Complainant avers that it has not authorized Respondent to use Complainant's trademark in any capacity and shows that its trademark rights in VEO predate Respondent's registration of the <veo3.ai> domain name. The Panel finds that Complainant has made out a prima facie case in support of Respondent lacking rights and lacking legitimate interests in <veo3.ai>. See Starwood Hotels & Resorts Worldwide, Inc. v. Samjo CellTech.Ltd, FA 406512 (Forum Mar. 9, 2005) (holding: "The threshold for making such a showing is quite low, since it is difficult to produce evidence to support a negative statement. Here, Complainant has alleged that Respondent does not own any rights in the terms STARWOOD or STARWOODS, and that Respondent's use of the Domain Name is not a fair one. These unsupported assertions, though sparse, are sufficient to make a prima facie showing in regard to the legitimacy element.")

 

Respondent fails to substantiate that it is in fact commonly known by <veo3.ai>, rather Respondent claims that the domain name is used to simply describe the subject of Respondent's business. Additionally, the WHOIS information for the at-issue domain name identifies the domain name's registrant as "Qiao Yinhang / LinkingCloud" and the record before the Panel contains no evidence tending to prove that Respondent is commonly known as <veo3.ai> or any relevant variation thereof. The Panel therefore concludes that Respondent is not commonly known by the <veo3.ai> domain name for the purposes of Policy ¶ 4(c)(ii). See Braun Corp. v. Loney, FA 699652 (Forum July 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where the WHOIS information, as well as all other information in the record, gave no indication that the respondent was commonly known by the domain names, and the complainant had not authorized the respondent to register a domain name containing its registered mark).

 

Further, Respondent uses the at-issue domain name to address a website purportedly offering AI video generation services developed by Respondent. The Panel disagrees with Respondent's conclusion that such use indicates the domain name is being used in connection with a bona fide offering of services under the Policy. Respondent's <veo3.ai> website is made to appear as if it is sponsored or endorsed by Complainant. However, Respondent's services are overtly in competition with services related to Complainant's VEO mark. Indeed, Respondent's intent in registering and using the <veo3.ai> domain name was to compete with Complainant under a descriptive name, i.e. <veo3.ai>.  Respondent's use the of the <veo3.ai> domain name in this manner is neither a bona fide offering of goods or services under Policy ¶ 4(c)(i), nor a non-commercial or fair use pursuant to Policy ¶ 4(c)(iii). See Insomniac Holdings, LLC v. Mark Daniels, FA 1735969 (Forum July 15, 2017) (refusing to find rights and legitimate interests in a domain name on the part of a respondent when the disputed domain name "resolves to a website that Respondent has designed to mimic Complainant's own in an attempt to pass itself off as Complainant"); see also Citadel LLC and its related entity, KCG IP Holdings, LLC v. Joel Lespinasse / Radius Group, FA 1409001579141 (Forum Oct. 15, 2014) ("Here, the Panel finds evidence of Policy ¶ 4(b)(iv) bad faith as Respondent has used the confusingly similar domain name to promote its own financial management and consulting services in competition with Complainant.")

 

Given the forgoing, Respondent fails to overcome Complainant's prima facie case and so the Panel therefore finds that Respondent lacks rights and lacks legitimate interests in respect of <veo3.ai>.

 

Registration and Use in Bad Faith

As discussed below without limitation, Respondent acted in bad faith.

 

Respondent uses the confusingly similar <veo3.ai> domain name to address a website that pretends to be sponsored or endorsed by Complainant. The website is purportedly employed by Respondent to facilitate Respondent's AI related business, which competes with services offered by Complainant, under its VEO trademarks. Respondent's domain name and associated website deceives internet users into falsely believing that the <veo3.ai> domain name and its website are affiliated with Complainant. Respondent's use of <veo3.ai> is disruptive to Complainant's business and designed to attract internet users so that Respondent may capitalize on the confusion Respondent created between its <veo3.ai> domain name and Complainant's VEO trademark. Respondent thus registered and used the at-issue domain name in bad faith pursuant to Policy ¶ 4(b)(iii) and Policy ¶ 4(b)(iv). See Fitness International, LLC v. ALISTAIR SWODECK / VICTOR AND MURRAY, FA1506001623644 (Forum July 9, 2015) (finding that use of the subject domain to operate a website purporting to offer the exact services offered by the complainant causes customer confusion, disrupts complainant's business, and demonstrates bad faith); see also, Allianz of Am. Corp. v. Bond, FA 680624 (Forum June 2, 2006) (finding bad faith registration and use under Policy ¶ 4(b)(iv) where the respondent was diverting internet users searching for the complainant to its own website and likely profiting).

 

Next, Respondent engaged in opportunistic bad faith. Respondent's registration of <veo3.ai> occurred between the launch of Google's Veo 2 and Veo 3 offerings and after Complainant had secured trademark registrations for its VEO mark. Respondent insists that the temporal proximity of Complainant's introduction and promotion of its VEO products to Respondent's registration and use of its <veo3.ai> domain name was purely coincidental. Such assertion is dubious at best. The Panel finds it more likely that Respondent was very much aware of Complainant's well publicized VEO related accomplishments. Significantly, Respondent claims to operate in the same narrow area of commerce – AI powered video generation- as Complainant occupies and admittedly was aware of Complainant's VEO products. Thus, in registering <veo3.ai>, when it did Respondent seized the opportunity to exploit the anticipated surging goodwill in Complainant's VEO mark.  See Google LLC v. Elke Qin, FA2503002144832 (Forum April 8, 2025) ("Respondent registered [veo-2.net]...five days after Google publicly announced the launch of the second iteration of its VEO offering, Veo 2…and approximately seven months after the initial launch of Veo…These facts support the conclusion that Respondent registered the domain name in bad faith with the intention of targeting Complainant and its VEO brand.")

 

Moreover, Respondent had actual knowledge of Complainant's rights in the VEO mark when it registered <veo3.ai> as a domain name. Respondent's prior knowledge is evident from the worldwide notoriety of Complainant's VEO trademark and from Respondent's registration and use of the <veo3.ai> domain name to directly compete with Complainant as discussed elsewhere herein. Respondent's registration and use of <veo3.ai> with knowledge of Complainant's rights in VEO further shows Respondent's bad faith. See Lemon Inc. v. Sumer Singh, FA 2110519 (Forum September 5, 2024 ("registration of a disputed domain name with actual knowledge of another's trademark rights is sufficient to establish bad faith, and can be shown by the notoriety of the mark and the use the Respondent makes of the disputed domain name"); see also, Minicards Vennootschap Onder FIrma Amsterdam v. Moscow Studios, FA 1031703 (Forum Sept. 5, 2007) (holding that respondent registered a domain name in bad faith under Policy ¶ 4(a)(iii) after concluding that respondent had actual knowledge of Complainant's mark when registering the disputed domain name); see also, Univision Comm'cns Inc. v. Norte, FA 1000079 (Forum Aug. 16, 2007) (rejecting the respondent's contention that it did not register the disputed domain name in bad faith since the panel found that the respondent had knowledge of the complainant's rights in the UNIVISION mark when registering the disputed domain name).

On the website accessible through the disputed domain name, there are multiple references to Google's VEO trademark, demonstrating that Respondent had actual knowledge of Complainant's mark when using – and likely when registering – the domain name. Some references appear to be users' comments (e.g., "I did more tests with Google's #Veo3." and "Less than 24 hours since Google dropped Veo3 and people are already creating wild stuff."). However, other references are clearly made by Respondent itself (e.g., "What's the difference between Veo3.ai and Google Flow? We both use the official Google VEO3 model, but Google Flow has daily limits while we don't."; see also Respondent's pricing, which includes "Google Veo 3 Support").

Furthermore, while Respondent claims that the addition of the number "3" in the domain name merely refers to the third version of its own project, no evidence has been submitted to support this assertion.

Accordingly, Respondent's arguments that it was unaware of Complainant's trademarks, and that any proximity to Complainant's product announcement is merely coincidental, lack credibility.

Request for a stay of enforcement

Respondent requests that the Panel stay the enforcement of its decision to allow for an orderly and smooth transition of the Respondent's existing paid subscribers and users to an alternative platform; this is critical to prevent undue disruption to their services and to ensure business continuity for valued customers who rely on the service.

 

According to Complainant, there are no provisions in the Policy that would enable a panel to stay enforcement of its decision.

 

Policy 4.i states: "Remedies. The remedies available to a complainant pursuant to any proceeding before an Administrative Panel shall be limited to requiring the cancellation of your domain name or the transfer of your domain name registration to the complainant."

 

Rule 10(c): states (emphasis added): "The Panel shall ensure that the administrative proceeding takes place with due expedition. It may, at the request of a Party or on its own motion, extend, in exceptional cases, a period of time fixed by these Rules or by the Panel."

 

For the reasons given below, the Panel need not determine whether Rule 10(c) could be broadly interpreted to effectively delay enforcement if there is an "exceptional case" warranting delayed enforcement.

 

The reasons set forth by Respondent for a stay are not exceptional: confusingly similar domain names that resolve to competing websites are routinely transferred. As Complainant correctly points out, Respondent will enjoy a ten business days appeal period before the domain name is actually transferred. This will allow it to notify its customers of a forthcoming transfer to a new domain name.

 

Consequently, the Panel will deny Respondent's request for a stay of enforcement of its decision. 

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Respondent's request to temporarily stay enforcement of the Panel's decision is denied.

 

Accordingly, it is Ordered that the <veo3.ai> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Paul M. DeCicco, Chair
Richard W. Hill and Bart Van Besien, Panelists

Dated: August 27, 2025