DECISION

 

Google LLC v. Lambert YANG

Claim Number: FA2507002167380

 

PARTIES

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

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <veo-3.ai> ("Disputed Domain Name"), 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.

 

Claire Kowarsky as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on July 24, 2025; Forum received payment on July 24, 2025.

 

On July 25, 2025, NameCheap, Inc. confirmed by e-mail to Forum that the <veo-3.ai> Disputed 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 28, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of September 11, 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@veo-3.ai. Also on July 28, 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.

 

On August 17, 2025, Respondent requested, and was granted a four calendar-day extension to file their response.

 

On August 20, 2025, Respondent requested that, due to exceptional circumstances, it be allowed additional time to respond to the Complaint. Forum granted the request and provided an extension for the Respondent to submit the Response until September 11, 2025.

 

A timely Response was received and determined to be complete on September 10, 2025.

 

On September 11, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Claire Kowarsky 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 Disputed Domain Name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant, Google LLC, asserts that it owns rights in the VEO trademark, used in connection with its AI-powered video generation offerings, initially launched on May 14, 2024. Complainant's most recent iteration, Veo 3, was announced and launched on May 20, 2025. Google contends that the VEO mark is well-known, benefits from extensive marketing and unsolicited media coverage, and has registered trademark rights and pending trademark applications in multiple jurisdictions.

Complainant alleges that the Disputed Domain Name <veo-3.ai> is confusingly similar to its VEO mark because it fully incorporates the mark, with the only addition being a hyphen, the number 3 (corresponding to the third iteration of Google's product) and the ".ai" generic top-level domain. According to Complainant, the Disputed Domain Name resolves to a website that created the impression of being affiliated with Google and promotes a competing AI-powered video generation service under the same name, thereby trading on the reputation and goodwill of the VEO mark.

Complainant further contends that Respondent has no rights or legitimate interests in the Disputed Domain Name, as they are not licensed nor otherwise authorized to use the VEO mark, are not commonly known by that name and are using the Disputed Domain Name solely to attract consumers to Respondent's competing offer. Complainant argues that Respondent's use does not constitute a bona fide offering of goods and services or a legitimate non-commercial or fair use.

Lastly, the Complainant asserts that respondent registered and is using the Disputed Domain Name in bad faith. The registration occurred on May 25, 2025, just five days after the launch of Veo 3, following the widespread recognition of the VEO mark. Complainant contends the Respondent willfully intended to violate Google's intellectual property rights due to the registration and use of a domain name that fully incorporates the identical VEO mark, while using the opportunistically-registered Disputed Domain Name to promote Respondent's own identical and/or competing commercial offerings for Respondent's own commercial gain. Complainant further points to Respondent's use of the Disputed Domain Name to mislead consumers, including a <support@veo-3.ai> email address, and the use of a privacy/proxy service to conceal ownership, as further evidence of bad faith.

Complainant requests that the Disputed Domain Name be transferred to it pursuant to the Policy.

 

B. Respondent

The Respondent, Lambert Yang, in their brief response, acknowledges Complainant's rights in the VEO trademark and recognizes that the Disputed Domain Name <veo-3.ai> may cause confusion. Respondent asserts that the website associated with the Disputed Domain Name was created as a technology demonstration platform to showcase AI video generation capabilities and that any reference to "Google Veo 3" was intended only as a technical attribution.

 

Respondent asserts there was no bad faith intent on their part because the mention of "Google" alongside "Veo3" was meant to properly credit Google as the technology provider and further, there has been no attempt to sell the Disputed Domain Name to the Complainant or its competitors nor any intent to prevent the Complainant from using it.

 

Lastly, Respondent "accepts the likely outcome of this proceeding" and that said outcome is "inevitable" but requests an extended period of 30-days post decision to effectively wind down commercial operations connected with the Disputed Domain Name.

 

FINDINGS

Complainant holds prior trademark rights in the VEO mark. The Disputed Domain Name is confusingly similar to Complainant's VEO mark. Respondent is not affiliated with Complainant and has not been authorized to use Complainant's trademark in any capacity. Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent registered and has used the Disputed Domain Name in bad faith.

 

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 demonstrated rights in the VEO mark through its trademark registrations in multiple jurisdictions, including its earliest registration with the Austrian Patent Office (Reg. No. 328,856, Nov. 13, 2024). This registration alone is sufficient to establish rights in a mark under Policy 4(a)(i). See Thermo Electron Corp. v. Xu, FA 713851 (Forum  Jul. 12, 2006) (finding that a national trademark registration satisfies the standing requirement under the Policy). Complainant has further shown that the VEO mark has been extensively used in commerce and widely publicized since its initial launch. The Panel therefore finds that Complainant has established rights in the VEO mark for purposes of the Policy.

 

The Disputed Domain Name <veo-3.ai> is confusingly similar to Complainant's VEO mark. It incorporates the mark in its entirety, adding only a hyphen and the numeral "3," which directly references Complainant's most recent product iteration, as well as the ".ai" top-level domain. Such minor additions do not avoid a finding of confusing similarity. See Skechers U.S.A., Inc. and Skechers U.S.A., Inc. II v. Svensson Viljae, FA 1784650 (Forum Jun. 1, 2018) (finding confusing similarity where "[t]he disputed domain name <skechers-outlet.com> adds a hyphen and the generic term 'outlet' to Complainant's registered SKECHERS mark, and appends the '.com' top-level domain"). See also Pandora Media, Inc. v. MASATAMI KITA, FA 1622614 (Forum Jul. 20, 2015) (holding <pandora1.com> confusingly similar to PANDORA where the only difference was the addition of a numeral and the gTLD).  

Although .ai is formally the country-code TLD for Anguilla, it functions as a de facto gTLD closely associated with artificial intelligence or AI, which strengthens the likelihood of association with Complainant's AI-powered VEO technology. Nonetheless, top-level domains are generally disregarded when evaluating confusing similarity. See Bloomberg Finance L.P. v. Igor Gabrielan, FA2072420 (Forum Jan. 8, 2024) ("Under Policy 4(a)(i), adding the '.ai' gTLD to a mark does not differentiate the domain name from the mark it incorporates.").

Accordingly, the Panel concludes that Complainant has satisfied the requirement under Policy 4(a)(i), and that the Disputed Domain Name is identical or confusingly similar to Complainant's VEO mark.

 

Rights or Legitimate Interests

To satisfy this second element, Complainant must make a prima facie showing that Respondent has no rights or legitimate interests in the Disputed Domain Name within the meaning of paragraph 4(a)(ii) of the Policy. The burden then shifts to Respondent to present evidence of such rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006) ("Before shifting the burden to Respondent, Complainant must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy 4(a)(ii).") Complainant asserts - and Respondent does not dispute - that Respondent is not authorized to use the VEO mark in any capacity. Complainant further claims the Respondent makes no bona fide offering of goods or services or a legitimate non-commercial or fair use. These claims and the evidence submitted in support thereof is sufficient to satisfy Complainant's prima facie burden. 

 

Paragraph 4(c) of the Policy sets out a list of circumstances through which a respondent may rebut a complainant's claims to demonstrate that it does have such rights or interests.

 

Paragraph 4(c)(i) allows a respondent to demonstrate rights or legitimate interests where, "before any notice to you 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". Here, the Disputed Domain Name resolves to a website branded as "Veo 3", referencing Complainant's AI video generation technology and offering paid subscriptions to users. The use of Complainant's VEO mark as the dominant element of the Disputed Domain Name and website content creates a false impression of endorsement or affiliation with Complainant. Such use cannot be considered bona fide under the Policy. See Google LLC v. jiaming tang FA2165873 (Forum Aug. 11, 2025) ("The use of a confusingly similar domain name to resolve to a webpage that passes off as a complainant does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use; indeed it provides a false impression that the Respondent is affiliated with or authorized by Complainant.") 

 

Moreover, the Respondent does not disclaim being aware of Complainant's VEO mark at the time of acquiring the Disputed Domain Name, but rather, Respondent expressly acknowledges Complainant's rights in the VEO trademark and concedes that the Disputed Domain Name "may cause confusion." While Respondent states that the website was created as a "technology demonstration platform showcasing various AI video generation capabilities" and that the reference to "Google Veo3" was intended only to attribute the technology source, this admission of likely confusion, combined with the commercial nature of the use, undercuts any claim of legitimacy. Instead, it confirms that Respondent knowingly adopted Complainant's mark in a way that trades on its goodwill in a way that could mislead Internet users as to source or affiliation.

 

Under Paragraph 4(c)(ii), a respondent can establish rights if commonly known by the disputed domain name. Here, the Registrar's verification identifies Respondent as "Lambert Yang," which bears no resemblance to the Disputed Domain Name and there is no evidence of any trade name or other identifier corresponding to "veo-3." See LELABO HOLDINGS, LLC v. Tiến Vũ Dương / Khổng Louis / Pham Quang Tai / Nguyen Viet Tuan / Tran Thi Tuyet Nhung, FA2169427 (Forum Sep. 15, 2025) (finding that Respondent is not commonly known by, and lacks rights or legitimate interests in, the disputed domain name per Policy 4(c)(ii).)

 

Policy 4(c)(iii) establishes rights or legitimate interest where there is non-commercial or fair use of a domain name without intent for commercial gain, to misleadingly divert consumers, or to tarnish the complainant's mark. Here, respondent admits to operating a subscription-based service, confirming that the use is commercial, thus negating any claim of non-commercial use. See General Motors LLC v. MIKE LEE, FA 1659965 (Forum Mar. 10, 2016) (finding that "use of a domain to sell products and/or services that compete directly with a complainant's business does not constitute a bona fide offering of goods or services pursuant to Policy 4(c)(i) or a legitimate noncommercial or fair use pursuant to Policy 4(c)(iii).") Even if the reference to "Veo3" was intended as attribution, the overall impression is one of affiliation with Complainant, which is precisely the type of confusion the Policy aims to prevent.

 

For these reasons, the Panel finds that Complainant has sufficiently made out its prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent's explanations do not establish any of the circumstances under Policy 4(c), and therefore do not rebut Complainant's prima facie case.

 

Accordingly, the Panel concludes that Complainant prevails under Policy 4(a)(ii) and the Respondent is not shown to have rights or legitimate interests in the Disputed Domain Name.

 

Registration and Use in Bad Faith

Paragraph 4(b) of the Policy provides a non-exhaustive list of circumstances, any one of which may be evidence of the registration and use of a domain name in bad faith. Relevant here is Paragraph 4(b)(iv), which applies where a respondent, by using the domain name, has intentionally attempted to attract, for commercial gain, Internet users to the respondent's website 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 the respondent's website or location or of a product or service on the site or location.

 

Based on the evidence discussed under the second element, the Panel is satisfied that Respondent was aware of Complainant and its VEO mark when registering the <veo-3.ai> Disputed Domain Name. Respondent selected a domain name that fully incorporates Complainant's most recent product iteration and registered it just five days after its launch, facts that make independent, good-faith registration implausible. See Google LLC v. Feng Deng / ZingFront HongKong Limited, FA2155500 (Forum Jun. 7, 2025) ("The notoriety and distinctive qualities of the VEO trademark, the timing of the registration of the domain name, and the content displayed on the associated website render it wholly implausible that Respondent independently and innocently registered the domain name.").

 

Respondent then used the Disputed Domain Name to operate a subscription-based platform that referenced Complainant's "Veo 3," thereby capitalizing on user confusion for commercial gain.

 

This conduct falls squarely within the scope of Policy 4(b)(iv), which provides that bad faith exists where a respondent, by using the domain name, has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with complainant's mark as to the source, sponsorship, affiliation, or endorsement of the website. Respondent's acknowledgment that the Disputed Domain Name "may cause confusion" further supports a finding of bad faith. The claim that the site merely demonstrated technology does not cure the unauthorized and confusing use of Complainant's mark or eliminate the risk of consumer confusion. Panels have consistently found that using Complainant's mark prominently, without authorization, and to attract Internet users constitutes an attempt to trade on the goodwill of the complainant's mark rather than a legitimate offering of goods or services. See Xylem Inc. and Xylem IP Holdings LLC v. YinSi BaoHu YiKaiQi, FA 1612750 (Forum May 13, 2015) ("The Panel agrees that Respondent's use of the website to display products similar to Complainant's, imputes intent to attract Internet users for commercial gain, and finds bad faith per Policy ¶ 4(b)(iv).").

 

As a final point, the Panel notes the Respondent's request for a 30-day post-decision transition period. However, the Policy and the Rules do not provide for such relief. Accordingly, the Panel denies the Respondent's request.

 

The Panel concludes that the Complainant has made out its case that the Domain Name was registered and is being used in bad faith and thus has satisfied the requirements under Policy 4(a)(iii).

 

DECISION

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

 

Accordingly, it is Ordered that the <veo-3.ai> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Claire R. Kowarsky, Panelist

Dated: September 19, 2025