NATIONAL ARBITRATION FORUM

DECISION

Chime Financial, Inc. v. Dmitry Orlov

Claim Number: FA2511002189343

PARTIES

Complainant is Chime Financial, Inc. ("Complainant"), represented by AJ Schumacher of Kelly IP, LLP, District of Columbia, USA. Respondent is Dmitry Orlov ("Respondent"), Germany.

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <chimeapp.com>, registered with NameSilo, LLC.

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.

Paul M. DeCicco, as Panelist.

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on November 17, 2025; Forum received payment on November 17, 2025.

On November 18, 2025, NameSilo, LLC confirmed by e-mail to Forum that the <chimeapp.com> domain name is registered with NameSilo, LLC and that Respondent is the current registrant of the name. NameSilo, LLC has verified that Respondent is bound by the NameSilo, LLC 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 November 25, 2025, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of December 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@chimeapp.com. Also on November 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.

Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.

On December 16, 2025, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Paul M. DeCicco 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. Therefore, the Panel may issue its decision based on the documents submitted and in accordance with the ICANN Policy, ICANN Rules, Forum's Supplemental Rules and any rules and principles of law that the Panel deems applicable, without the benefit of any response from Respondent.

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

PARTIES' CONTENTIONS

A. Complainant

Complainant contends in part as follows:

Complainant is a financial technology company founded on the simple idea that basic banking services should be helpful, easy, and free. Since its founding in 2012, Chime has been partnering with national banks to design member-first financial solutions that provide better and lower-cost options for everyday people, such as providing early access to paychecks, checking and savings accounts with no monthly fees, debit account services, fee-free overdrafts up to $200 through its SPOTME® product, and secured credit cards that enable users to safely build credit. Complainant's various financial solutions are also promoted and offered via its highly popular downloadable CHIME mobile application.

Complainant has successfully obtained numerous trademark registrations in various countries, including the U.S., for its CHIME marks. Complainant's U.S. registrations for its CHIME marks are currently valid, subsisting, and in some instances, incontestable.

Respondent registered or otherwise acquired the domain in bad faith on April 30, 2025, which is long after Complainant began using and registering the CHIME marks and after Complainant's CHIME marks became well known.

Respondent registered and is using the domain in bad faith with actual knowledge of Complainant's prior rights in its CHIME marks and for the express purpose of trading on the goodwill of Complainant's marks for commercial gain. In this regard, among other things, the domain prominently starts with and features Complainant's identical CHIME mark in combination with the generic or descriptive wording "app," which relates to Complainant and its CHIME mobile "app" through which its financial technology solutions are available, and the domain extension ".com."

Given the evidence and totality of the circumstances, it is clear that Respondent registered the domain primarily for the purpose of selling, renting, or otherwise transferring and profiting from the domain, including to Complainant—who is owner of a well-known CHIME trademark and brand that just so happens to provide its financial technology solutions through a mobile "app"—and that Respondent is attempting to conceal the true nature of Respondent's conduct.

The domain currently resolves to a webpage displaying the same or similar content associated with a previous owner of the domain name.

The domain is confusingly similar to Complainant's CHIME marks. Complainant's common law rights and trademark registrations for its CHIME marks establish Complainant's rights to the marks, including because "the registration of a mark with a legitimate governmental authority is sufficient under the Policy to allow a rebuttable presumption of rights in the mark." The at-issue domain name is confusingly similar to Complainant's well-known and registered CHIME marks, including because the domain name prominently starts with and features Complainant's identical CHIME mark in its entirety in combination with the generic or descriptive term "app," which clearly relates to Complainant and its CHIME mobile "app" through which its financial technology solutions are provided, and the domain extension ".com." These additions are inadequate to distinguish the domain from Complainant's CHIME marks. Panels have consistently held that a domain name containing a Complainant's mark in its entirety is confusingly similar to the mark at issue. In addition, it is well-settled that adding generic, descriptive, or other terms, particularly those terms related to complainants' businesses, such as the term "app" here, to complainants' marks does not obviate the risk of confusion. Panels have consistently held that domain extensions are irrelevant to the confusing similarity analysis.

Respondent has no rights or legitimate interests in the domain. Respondent has no rights or legitimate interests in the at-issue domain name under UDRP ¶ 4(c)(ii) for at least the following reasons: The WHOIS record for the at-issue domain name was initially privacy protected, but the disclosed registration information received from the registrar lists the registrant as "Dmitry Orlov." This WHOIS and registration information, and the lack of information and evidence in the record to the contrary, is evidence that Respondent is not commonly known as the domain name or any derivation of the domain name. Furthermore, the disclosed registration information confirms that Respondent is not connected with the prior business that held the domain name, including because Respondent is apparently located in Germany while the prior business was based in Toronto, and because Respondent's apparent LinkedIn profile does not mention the prior business. This confirms that the current use of the domain is purely pretextual. In addition, Complainant has not authorized Respondent, or any associated person or entity, to use or register the CHIME marks in any manner, nor is Respondent or any other associated person or entity a current or former licensee of Complainant and its CHIME marks. Complainant also has no knowledge that Respondent, or any other person or entity associated therewith, are, or have ever been, commonly known by the domain. Additionally, Respondent has no rights or legitimate interests in the domain under UDRP ¶¶ 4(c)(i) or 4(c)(iii) for at least the following reasons: Complainant received email from an unidentifiable individual purportedly named "Lisa Root" advising Complainant of an "exclusive opportunity" to acquire—or purchase—the domain name, and that Complainant could respond directly to discuss additional details, presumably including an excessive purchase price. While Respondent has attempted to disguise and legitimize Respondent's registration and use of the domain, including currently utilizing website content previously associated with a previous owner, this evidences that Respondent is intending to sell, rent, or otherwise transfer the domain for valuable, excessive consideration, and Panels have held that this conduct does not constitute a bona fide offering of goods or services nor a non-commercial or fair use of domains such that Respondent can claim any legitimate rights or interests in the at-issue domain name. Moreover, the domain currently displays the same or similar content associated with a prior owner of the domain name from 2012-2018 despite the prior owner ceasing operations sometime around 2013 and the domain resolving to webpages indicating the domain was for sale from around September 2018 – to at least February 2025. Given this evidence and the totality of circumstances, including Complainant's receipt of the email indicating the domain was available for purchase on the same day Respondent registered the domain, Complainant submits that Respondent's current use of the domain in this manner is pretextual attempt to hide the true nature of Respondent's cybersquatting and to pursue a payment, including from Complainant, for the domain for valuable, excessive consideration. Put simply, this current use of the domain is an unsuccessful pretextual attempt to legitimize Respondent's conduct, including to circumvent the UDRP, and cannot confer Respondent with any legitimate rights or interests in the domain. Lastly, to the extent that Respondent does not reply in this case, the Panel may presume that Respondent lacks rights and legitimate interests in the domain based on no response.

Respondent's bad faith registration and use of the domain under UDRP ¶¶ 4(a)(iii) and 4(b). First, the evidence shows that Respondent "intentionally attempted to attract, for commercial gain, Internet users" to the domain "by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of" the domain. In this regard, the domain is confusingly similar to Complainant's CHIME marks, including because the domain prominently starts with and features Complainant's identical CHIME mark in its entirety in combination with the generic or descriptive term "app," which clearly relates to Complainant and its business, and the domain extension ".com." While Respondent has made pretextual attempts to disguise Respondent's motive and the true nature of Respondent's registration and use of the domain, the evidence and totality of circumstances show that Respondent registered the domain primarily for the purpose of selling, renting, or otherwise transferring and profiting from the domain, including to Complainant, for valuable, excessive consideration. Second, the evidence shows that Respondent has a pattern of registering domains that are identical or confusingly similar to third-party marks as evidenced by the prior UDRP decision naming "Dmitry Orlov" and "InterPromo" (which is utilized in Respondent's email address) as the respondent and transferring the domain to the mark owner under the UDRP Policy, which is further evidence of Respondent's bad faith. Panels have consistently held "there is a legal presumption of bad faith when Respondent reasonably should have been aware of Complainant's trademarks, actually or constructively." Respondent had constructive knowledge of Complainant's rights in its CHIME marks by virtue of Complainant's U.S. registrations for the same. Additionally, the evidence and totality of circumstances surrounding the at-issue domain name establish that Respondent had actual knowledge of Complainant and its CHIME marks prior to registering and using the Domain.

B. Respondent

Respondent failed to submit a Response in this proceeding.

FINDINGS

Complainant has rights in the CHIME trademark.

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

Respondent registered the at‑issue domain name after Complainant acquired rights in CHIME.

Respondent uses the at-issue domain name to offer it for sale.

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.

In view of Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of Complainant's undisputed representations pursuant to paragraphs 5(f), 14(a) and 15(a) of the Rules and draw such inferences it considers appropriate pursuant to paragraph 14(b) of the Rules. The Panel is entitled to accept all reasonable allegations set forth in a complaint; however, the Panel may deny relief where a complaint contains mere conclusory or unsubstantiated arguments. See WIPO Jurisprudential Overview 3.0 at ¶ 4.3; see also eGalaxy Multimedia Inc. v. ON HOLD By Owner Ready To Expire, FA 157287 (Forum June 26, 2003) ("Because Complainant did not produce clear evidence to support its subjective allegations [. . .] the Panel finds it appropriate to dismiss the Complaint").

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 national registrations for CHIME is sufficient to established Complainant's rights in such mark under Policy 4(a)(i). See Red Hat, Inc. v. Muhammad Shahzad, FA 1787738 (Forum June 19, 2018) ("Registration of a mark with multiple trademark agencies is sufficient to demonstrate rights to a mark per Policy ¶ 4(a)(i)."); see also, Google LLC v. Bhawana Chandel / Admission Virus, FA 1799694 (Forum Sep. 4, 2018) ("Complainant has rights in the GMAIL mark based upon its registration of the mark with numerous trademark agencies around the world."); see also, Liberty Global Logistics, LLC v. damilola emmanuel / tovary services limited, FA 1738536 (Forum Aug. 4, 2017) (stating, "Registration of a mark with the USPTO sufficiently establishes the required rights in the mark for purposes of the Policy.").

The at-issue domain name contains Complainant's CHIME trademark followed by the suggestive term "app," with all followed by the ".com" top-level domain name. The differences between the <chimeapp.com> domain name and Complainant's CHIME trademark are insufficient to distinguish the domain name from Complainant's trademark under Policy ¶ 4(a)(i). Therefore, the Panel finds that Respondent's <chimeapp.com> domain name is confusingly similar to Complainant's CHIME mark. 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.")

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). Since Respondent failed to respond, Complainant's prima facie showing acts conclusively.

Respondent is not authorized to use Complainant's trademarks in any capacity and, as discussed below, there are no Policy ¶ 4(c) circumstances from which the Panel might find that Respondent has rights or legitimate interests in respect of the at-issue domain name. See Emerson Electric Co. v. golden humble / golden globals, FA 1787128 (Forum June 11, 2018) ("lack of evidence in the record to indicate a respondent is authorized to use [the] complainant's mark may support a finding that [the] respondent does not have rights or legitimate interests in the disputed domain name per Policy ¶ 4(c)(ii)").

The WHOIS information for the at-issue domain name ultimately leads to identifying the domain name's registrant as Dmitry Orlov"and the record before the Panel contains no evidence tending to prove that Respondent is commonly known by <chimeapp.com>. The Panel therefore concludes that Respondent is not commonly known by the <chimeapp.com> 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).

Respondent has used the confusingly similar domain name in a manner allowing the domain name to be offered for-sale. Respondent's use of the confusingly similar domain name to offer the domain name for-sale, presumably for an amount more than its out of pocket costs, indicates 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).

Given the foregoing, Respondent's lack of rights and lack of legitimate interests in respect of <chimeapp.com>.

Registration and Use in Bad Faith

As discussed below without being exhaustive, Respondent acted in bad faith.

Respondent's <chimeapp.com> domain name was offered for sale to Complainant via an email from a nominal third-party intermediary. The Panel presumes that the domain name was being offered for an amount more than Respondent's reasonable out-of-pocket costs concerning the domain name thus indicating Respondent's bad faith registration and use of <chimeapp.com> per Policy ¶ 4(b)(i). See Educ. Testing Serv. v. TOEFL, D2000-0044 (WIPO Mar. 16, 2000) (finding that a general offer of sale combined with no legitimate use of the domain name constitutes registration and use in bad faith).

Next, Respondent has suffered at-least one prior adverse UDRP decision as a respondent, i.e., Google LLC v. Dmitry Orlov / InterPromo UG, FA 2087687 (Forum April 5, 2024). Respondent's history including the present dispute reveals a pattern of domain name abuse suggesting Respondent's bad faith regarding the at-issue domain name pursuant to Policy ¶ 4(b)(ii). See Hackensack Meridian Health, Inc. v. Candie Deloach / Excella, FA 2085056 (Forum Mar. 20, 2024) (finding that Respondent's repeated improper and illegitimate registration and use of domain names is evidence of bad faith).

Moreover, Respondent had actual knowledge of Complainant's rights in CHIME when it registered <chimeapp.com> as a domain name. Respondent's prior knowledge of Complainant's mark is evident from the notoriety of Complainant's CHIME trademark as well as from Respondent's inclusion of the descriptive term "app" in <chimeapp.com>. Respondent's registration and use of the confusingly similar <chimeapp.com> domain name with knowledge of Complainant's trademark rights in CHIME shows Respondent's bad faith pursuant to Policy ¶ 4(a)(iii). See 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).

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 <chimeapp.com> domain name be TRANSFERRED from Respondent to Complainant.

Paul M. DeCicco, Panelist

Dated: December 19, 2025