DECISION

 

ORCID, Inc. v. Mira Holdings

Claim Number: FA2512002196448

 

PARTIES

Complainant is ORCID, Inc. ("Complainant"), represented by Paula K. Upson of MontaguLaw, P.C., New York, USA. Respondent is Mira Holdings ("Respondent"), Minnesota, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <orcid.com> ("Domain Name"), registered with TurnCommerce, Inc. DBA NameBright.com.

 

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.

 

Nicholas J.T. Smith as Panelist.

 

PROCEDURAL HISTORY

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

 

On December 30, 2025, TurnCommerce, Inc. DBA NameBright.com confirmed by e-mail to Forum that the <orcid.com> domain name is registered with TurnCommerce, Inc. DBA NameBright.com and that Respondent is the current registrant of the name. TurnCommerce, Inc. DBA NameBright.com has verified that Respondent is bound by the TurnCommerce, Inc. DBA NameBright.com 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 January 2, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 13, 2026 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@orcid.com. Also on January 2, 2026, 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 February 13, 2026.

 

On February 16, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Nicholas J.T. Smith as Panelist.  The Panel notes that the Response contains a request that the proceeding be heard by a three-member Panel however the Respondent failed to pay the required fee by the deadline set by the Forum (and there is no provision allowing Forum to extend the deadline) so in the circumstances, while the Panel has sympathy for the Respondent, the Panel is satisfied that it is properly appointed under the Policy and Rules.

 

On February 19, 2026, Complainant filed two unsolicited additional submissions in this matter with Forum. The first one simply correct an obvious error in the Exhibits to the Complaint. The second submission responded to certain matters raised in the Response.  As there were matters in the Response that could not have been reasonably anticipated or dealt with in the Complaint, the Panel has exercised its discretion to have regard to the Additional Submissions.  On that day the Panel issued a Panel Order under Rule 12 of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") providing Respondent with the opportunity (by February 26, 2026) to respond to Complainant's additional submission.  On February 26, 2026, Respondent provided a response to Complainant's additional submission. 

 

On February 27, 2026, Complainant filed a third additional submission with Forum. This submission consisted of a settlement offer from Respondent to the Complainant, offering sell the Domain Name to the Complainant for a significant sum. While noting the existence of Supplemental Rule 7, the Panel retains the discretion to decide whether to accept additional submissions.  See generally Bar Products.com, Inc. v. RegisterFly.com, FA 829161 (Forum Jan. 9, 2007) (declining to consider Complainant's reply because it adds nothing of substance to the record, and does not address any arguments of Respondent that could not have been anticipated by the Complainant). In the present case the Panel declines to have regard to this particular submission as it adds nothing to the record; the Respondent has at all times been open about its desire to sell the Domain Name for a sum greater than its out-of-pocket costs; the fact that it has made a similar settlement offer in the context of the proceeding does not change the issues the Panel must consider.  It is not necessary for the Panel to consider this additional submission to decide the proceeding. 

 

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 is a non-profit organization that provides a set of unique ID numbers for researchers, known as ORCID IDs, the term deriving from the concept "Open Researcher Contributor Identification". The Complainant was established (and commenced issuing ORCID IDs) in 2009, and by 2022 had issued 14 million ORCID IDs. It advertises its services through its website at www.orcid.org. Complainant has rights in the ORCID mark through Complainant's registration of the mark in numerous jurisdictions including with the United States Patent and Trademark Office ("USPTO") (e.g. Reg. No. 4,163,194, registered on June 26, 2012). Respondent's <orcid.com> domain name is identical to Complainant's ORCID mark as it incorporates Complainant's mark in its entirety and merely adds the ".com" generic top-level-domain ("gTLD").

 

Respondent lacks rights or legitimate interests in the <orcid.com> domain name. Respondent is not commonly known by the Domain Name, nor has Respondent been authorized by Complainant to use the ORCID mark. Respondent has not used the Domain Name in connection with a bona fide offering of goods or services as the Domain Name resolves to a website ("Respondent's Website") that prompts offers from the public to purchase the Domain Name.

 

Respondent registered and uses the <orcid.com> domain name in bad faith. While the Domain Name was initially registered in 2001, predating the establishment of the Complainant, Respondent acquired the Domain Name on or around June 28, 2022. Respondent registered the Domain Name with awareness of Complainant's well-known ORCID mark as it immediately redirected the Domain Name to a website offering it for sale for a sum significantly greater than any likely out-of-pocket costs and on August 27, 2022 sent an e-mail to the Complainant asking if the Complainant was interested in acquiring the Domain Name.  Respondent registered the Domain Name with the intent to sell the Domain Name to the Complainant or a competitor of the Complainant which is bad faith under the Policy.

 

B. Respondent

The <orcid.com> domain name is a five-letter word that is a variant spelling of the dictionary word "orchid" and has inherent value as a 5-letter acronym. The Respondent is a professional domain name investor with more than 10,000 generic domain names under ownership and offered for sale and has sold similar domain names as <minder.com>, <WYKYK.com> and <screeny.com>.

 

The Domain Name's previous registered owner let it expire on September 3, 2022 and at that time the Respondent chose to participate in a public auction for the Domain Name held by namejet.com. The Respondent succeeded and acquired the Domain Name for the sum of US$6,312. The Domain Name, as a memorable 5-letter word, has been appraised by reputable third parties in the market at variously $20,500 and $48,000.

 

The Respondent has subsequently offered the Domain Name for sale for a sum of $48,500 by reference to the third-party appraisal prices. The Respondent notes that the Complainant is one of a number of entities that uses the term ORCID in commerce and one of a number of companies that owns ORCID as a trade mark; and is by no means particularly well known. The Respondent has not used the Domain Name to take advantage of any confusion with the Complainant, nor was it aware of the Complainant until the filing of the proceeding; in particular it was not aware of the Complainant at the time it acquired the Domain Name.

 

The Respondent denies being associated with the e-mail sent on August 27, 2022. The message in the email said "Hello, I'm working on a deal for ORCID.com domain name. Would you be interested in acquiring it?. The Respondent states that this e-mail predated its acquisition of the Domain Name and denies being associated with the individual who sent it. The Respondent requests a finding of Reverse Domain Name Hijacking.

 

C. Complainant's Additional Submission

The Complainant notes that the Complainant's trademark is a coined term with no generic meaning; Respondent's submission that because the domain name consists of a 5-letter term and has value it is generic and can be traded without bad faith is contrary to the express purpose of the Policy and would in effect create a carve-out for such Domain Names.

 

Furthermore, Respondent's submissions that the term ORCID is used by multiple organizations is misleading as disingenuous; the Complainant's use of the ORCID mark is well-known with a reputation built up over 15 years of use; indeed a Google search for "orcid" brings up only references to the Complainant in the first four pages of results.

 

Respondent has acknowledged that a search of US trade mark registrations would have revealed the identity of the Complainant and its rights in the ORCID mark, and it had such an obligation before acquiring the Domain Name; it cannot simply point to its status as a domain name investor as a reason why it has rights or legitimate interests; Indeed, in recent UDRP cases involving this same Respondent, the Panels rejected the same line of argument advanced by Respondent here. See SRL BOWTEX v. Mira Holdings, WIPO Case No. D2024-1632 (July 22, 2024) ("Bowtex Case") ("the Complainant's mark was registered and in force in the jurisdiction where the Respondent is based at the point when it decided to acquire the disputed domain name. The Respondent either knew about this, or it deliberately chose to look the other way in an act of wilful blindness. In that context, it should be borne in mind that the Respondent warranted to its Registrar in terms of paragraph 2 of the Policy that to its knowledge the registration of the disputed domain name would not infringe upon or otherwise violate the rights of any third party"); and Temco Industrial v. Mira Holdings, WIPO Case No. D2025-3913 (Dec 30, 2025) ("Respondent has submitted a number of exhibits in this case which demonstrate that Respondent is capable of conducting sophisticated research using different domain name and trademark databases, as well as Google searches, to identify TEMCO trademark owners and/or companies using the Temco name... A trademark search, such as those submitted by Respondent in evidence in this case for the U.S. trademark registry, would have revealed Complainant's TEMCO mark as well as the TEMCO marks held by other companies.").

 

C. Respondent's Additional Submission

Respondent argues that Complainant is incorrect in its usage or description of ORCID as a 'coined term', noting several examples of usage prior to any usage by the Complainant; rather the term is simply an abbreviation of Open Researcher and Contributor ID. There are numerous examples where domain names that amount to multi-letter acronyms and abbreviations have been found to be good faith registrations that do not exploit trade marks.

 

The Respondent notes that it has prevailed in numerous UDRP proceedings in past years and to the extent that it has been unsuccessful, such as in the cases identified in the Complainant's Additional Submission, it has filed appeals in the United States District Court.

 

FINDINGS

Complainant holds trademark rights for the ORCID mark.  The Domain Name is identical to Complainant's ORCID mark.  Complainant has established that Respondent lacks rights or legitimate interests in the Domain Name and that Respondent registered and has used the 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.

 

Prior to commencing consideration of the elements; there are certain factual conclusions that I consider appropriate to set out as they inform the conclusions that I reach in the rest of this decision. They are as follows:

 

a)       The Respondent is a Domain Name trader who has acquired the Domain Name for resale purposes. There is no dispute that the Domain Name was acquired for the purposes of resale for a profit and has solely been used for that purpose (the Domain Name being redirected to a webpage advertising it for sale and the Respondent indicating that the Domain Name has been offered for sale for a considerable sum).

 

b)       The Panel accepts the Respondent acquired the Domain Name on or after September 3, 2022 and accepts Respondent's characterization of the August 28, 2022 e-mail to the Complainant as being unconnected to the Respondent as it was sent by an entity unconnected to the Respondent and sent before the Respondent acquired the Domain Name.

 

c)       The Panel accepts the Complainant's characterization of ORCID as a coined term with no generic meaning. The word 'orcid' has no meaning in the English language nor is it an obvious acronym/abbreviation. The mere fact that entities other than the Complainant have used that 5 letter combination for their own purposes (or that it could be a misspelling of the word "orchid") does not result in this particular term being a generic/descriptive under the Policy; were that to be the case, essentially all combinations of letters and numbers could be deemed to be generic merely because it would be possible to identify uses as acronyms or abbreviations or similar.  

 

Identical and/or Confusingly Similar

Complainant asserts rights in the ORCID mark through its registration of the mark with the USPTO (e.g., Reg. No. 4,163,194, registered on June 26, 2012). Registration of a mark with the USPTO is generally sufficient to establish rights in the mark per Policy ¶ 4(a)(i). See DIRECTV, LLC v. The Pearline Group, FA 1818749 (Forum Dec. 30, 2018) ("Complainant's ownership of a USPTO registration for DIRECTV demonstrate its rights in such mark for the purposes of Policy ¶ 4(a)(i).").

 

The Panel finds that the <orcid.com> domain name identical to Complainant's ORCID mark as it wholly incorporates the mark along with the ".com" gTLD.  Under Policy ¶ 4(a)(i), the addition of a TLD is irrelevant in determining whether a domain name and mark are identical. See Blue Cross and Blue Shield Association v. Shi Lei aka Shilei, FA 1784643 (Forum June 18, 2018) ("A TLD (whether a gTLD, sTLD or ccTLD) is disregarded under a Policy ¶4(a)(i) analysis because domain name syntax requires TLDs.") 

 

The Panel finds Complainant has satisfied Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Complainant alleges that Respondent holds no rights or legitimate interests in the Domain Name. In order for Complainant to succeed under this element, it must first make a prima facie case that Respondent lacks rights and legitimate interests in the Domain Name under Policy ¶ 4(a)(ii), and then the burden shifts to Respondent to show it does have rights or legitimate interests. See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006) and AOL LLC v. Gerberg, FA 780200 (Forum Sept. 25, 2006) ("Complainant must first make a prima facie showing that Respondent does not have rights or legitimate interest in the subject domain names, which burden is light. If Complainant satisfies its burden, then the burden shifts to Respondent to show that it does have rights or legitimate interests in the subject domain names."). The Panel holds that Complainant has made out a prima facie case.

 

Complainant asserts that Respondent has no rights or legitimate interests in the Domain Name as Respondent is not commonly known by the Domain Name, nor has Complainant authorized Respondent to use the ORCID mark. Respondent has no relationship, affiliation, connection, endorsement or association with Complainant and both based on the WHOIS information and as effectively acknowledged by the Respondent, the Respondent is not commonly known by the Domain Name in accordance with Policy ¶ 4(c)(ii).

 

The Respondent submits that it is a Domain Name trader engaged in the legitimate business practice of acquiring generic domain names for resale, and that it acquired the Domain Name without reference to or awareness of the Complainant's trademark because of its inherent value as a five-letter domain name that would be suitable for resale. The Panel accepts the principles set out in 2.10 of the WIPO Overview 3.1 that, as a general rule, a person such as the respondent has the right to acquire a domain name containing a dictionary word or phrase based upon its dictionary meaning and to offer this for sale at a price of its choosing, provided that in so doing it does not target the trademark value of the term.

 

However, the Domain Name does not consist of a dictionary or generic term and as such the principles above are inapplicable. Furthermore, for the reasons set out in greater detail under the "Registration and Use in Bad Faith" heading the Panel considers this term to have the appearance of a trademark or coined term. In such a case, there is a requirement to do a basic level of due diligence to determine if the inherent value of the Domain Name derived from its inherent nature or from its similarity to the Complainant's mark; this due diligence could have been a simple Google or trade mark search in the Respondent's jurisdiction. The Respondent's apparent failure to perform such a search amounts in this case to willful blindness that does not provide Respondent with rights or legitimate interests in a Domain Name.

 

The Respondent has registered a Domain Name that has no generic meaning and is identical to the Complainant's ORCID mark which was well-established (in that it was registered as a trademark in the Respondent's jurisdiction, there were 14 million ORCID IDs issued and it was the leading result on a Google search) at the time the Domain Name was registered. The Respondent was either aware of or willfully blind to this fact. The Respondent now seeks to sell the Domain Name for a sum considerably greater than its out-of-pocket costs. These facts do not provide a basis to find Rights or Legitimate interests under the principles set out of under the Policy, and particularly under the case law set out in 2.10 of the WIPO Overview 3.1.

 

The Panel finds Complainant has satisfied Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

The key issue in this case is whether the Respondent, a domain name trader, has registered and used the Domain Name in bad faith. Part 3.1.1. of the WIPO Overview 3.1 set out below provides a detailed summary of when Panels will find, under the Policy, that a respondent has registered or acquired a domain name primarily to sell the domain name to the complainant (or its competitor) for valuable consideration in excess of the respondent's costs related to the domain name.

 

"Generally speaking, panels have found that the practice as such of registering a domain name for subsequent resale (including for a profit) would not by itself support a claim that the respondent registered the domain name in bad faith with the primary purpose of selling it to a trademark owner (or its competitor).

Circumstances indicating that a domain name was registered for the bad-faith purpose of selling it to a trademark owner can be highly fact-specific; the nature of the domain name (e.g., whether a typo of a famous mark, a domain name wholly incorporating the relevant mark plus a geographic term or one related to the complainant's area of commercial activity, or a pure dictionary term) and the distinctiveness of trademark at issue, among other factors, are relevant to this inquiry.

…

If, on the other hand, circumstances indicate that the respondent's intent in registering the disputed domain name was in fact to profit in some fashion from or otherwise exploit the complainant's trademark, panels will find bad faith on the part of the respondent. Although panel assessment remains fact-specific, generally speaking such circumstances, alone or together, include: (i) the respondent's likely knowledge of the complainant's rights, (ii) the distinctiveness of the complainant's mark, (iii) a pattern of abusive registrations by the respondent, (iv) website content targeting the complainant's trademark, e.g., through links to the complainant's competitors, (v) threats to point or actually pointing the domain name to trademark-abusive content, (vi) threats to "sell to the highest bidder" or otherwise transfer the domain name to a third party, (vii) failure of a respondent to present a credible evidence-backed rationale for registering the domain name, (viii) a respondent's request for goods or services in exchange for the domain name, (ix) a respondent's attempt to force the complainant into an unwanted business arrangement, (x) a respondent's past conduct or business dealings, or (xi) a respondent's registration of additional domain names corresponding to the complainant's mark subsequent to being put on notice of its potentially abusive activity.

Particularly where the domain name at issue is identical or confusingly similar to a highly distinctive or famous mark, panels have tended to view with a degree of skepticism a respondent defense that the domain name was merely registered for legitimate speculation (based for example on any claimed dictionary meaning) as opposed to targeting a specific brand owner.

Offers to sell: taking the above scenarios into account, panels have generally found that where a registrant has an independent right to or legitimate interest in a domain name, an offer to sell that domain name would not by itself be evidence of bad faith for purposes of the UDRP, irrespective of which party solicits the prospective sale. This also includes "generalized" offers to sell, including those on a third-party platform. Panels have noted in respect of UDRP paragraph 4(b)(i) that offers to sell which exceed the respondent's documented out-of-pocket costs must target a trademark owner; assessment of such targeting will take account of all relevant facts and circumstances, and often includes matters such as the strength of the mark at issue (including whether there may be third parties also using the term as a mark for other goods/services including in other jurisdictions and whether it may also be descriptive or a dictionary term capable of non-infringing uses), the extent or reach of the complainant's online presence, and the location of the parties. Mere offers to sell for a profit, where this does not target a trademark owner would not be considered to violate paragraph 4(b)(i). Panels moreover rely on the parties to provide evidence of such costs."

 

The Response provides clear details of the Respondent's business model and the Panel notes that the Respondent is a frequent participant in proceedings under the Policy, with considerable success. The Panel has reviewed each of the previous cases in which the Respondent was a party under the Policy, seeing to ensure consistency with prior decisions, noting that a considerable number of previous cases are factually quite distinct, such as cases where the Respondent did not file a Response, where the Domain Name was acquired before the Complainant acquired trademark rights/any reputation and where the Domain Name consists of an obviously generic term/terms.

 

The decision in Nalli's Silks Sari Centre v. Mira Holdings WIPO Case No. D2024-5168 (March 10, 2025) is perhaps the most helpful case in characterizing when the Respondent's business model will result in a finding that the particular domain name in question was registered and used in bad faith (the Panel accepts that there are numerous decisions where the then panel has found that the Respondent has not acted in bad faith).  At page 7 the decisions summarises the relevant principles set out in the Bowtex Case before explaining why the Nalli's case is factually distinct from those two cases. I extract the summary below:

 

"The Panel further notes that, unlike here, the domain names at issue in those cases reflected highly distinctive made-up words and that the respective complainants had each demonstrated a reputation in the sense that their marks featured prominently in Google searches for the relevant terms, whereas there is no such evidence in this case (as further discussed below).

 

In the Bowtex Case, the panel set out the principles that it considered applicable where a registrant acquired a domain name in an expiring domain name auction. There, as here, the Respondent had claimed that it acquired the domain name without reference to, or awareness of, the complainant's trade mark. The panel found that:

-       as a general rule, a person such as the Respondent had the right to acquire a domain name containing a dictionary word or phrase based upon its dictionary meaning and to offer this for sale at a price of its choosing, provided that in so doing it did not target the trade mark value of the term;

-       however, given that the domain name had the appearance of a trade mark or coined word rather than a dictionary term, and which it knew to have a history,

-       the Respondent, as a domain name investor, should have shown a basic level of due diligence when acquiring it in a drop catching auction;

-       the Respondent need have looked no further than a brief trade mark search in its own jurisdiction, and/or a basic search of the history of the disputed domain name, and/or a Google search for the trade mark owner's official website;

-       the Respondent either knew about the complainant's trade mark in the Respondent's jurisdiction (i.e., United States) or deliberately looked the other way in an act of willful blindness;

-       the Respondent was on notice that the domain name had a history but appeared not to have researched it, whereas an Internet Archive search would have shown that it was in use by the complainant around 16 months before the Respondent registered it;

-       while there was no hard evidence in support of the complainant's submission that its mark was well known, its website appeared at the top of a current Google search;

-       any one of those searches would probably have disclosed the complainant's interest; and

-       it was implausible that the Respondent performed no such investigations but, if it did not, it should have done so and its willful blindness to the complainant's rights did not absolve it from the consequences of the Policy.

 

Applying those principles to the disputed domain name, is it likely that the Respondent thought that the disputed domain name derived from a trade mark, rather than purely a surname, when it opted to bid for the disputed domain name in the expiring domain names auction?"

 

The factual matrix in the Bowtex Case are uncannily similar to the facts in the present case and as such it is appropriate to reach a similar outcome, namely that the Respondent has registered and used the Domain Name in bad faith per Policy ¶ 4(b)(i). Specifically:

-       Like Bowtex, the Domain Name involves a coined word with no generic meaning that, on its face has the appearance of a trade mark, as such the principles that allow a registrant to acquire a domain name containing a generic word, name or phrase and resell it (provided it did not target a mark-owner) do not apply.

-       Given the above and noting that the Respondent acquired the Domain Name through an expired domain name auction, the Respondent, as a domain name investor, should have shown a basic level of due diligence when acquiring the Domain Name. ¹

-       Like Bowtex the Complainant has demonstrated a reputation in the ORCID mark. Respondent need have looked no further than a brief trade mark search in its own jurisdiction, and/or a Google search for the trademark owner's official website; indeed the Complainant provides evidence that a Google search for "Orcid" results in references to it for the first 4 pages of the results; hence a Google search would have made it apparent that the value of the Domain Name at least partially derived from the Complainant's corresponding trademark.

-       Thus, the Respondent either knew about the complainant's trademark in the Respondent's jurisdiction (i.e., United States) or deliberately looked the other way in an act of willful blindness and to the extent it engaged in an act of willful blindness this does not absolve it from the consequences of the Policy.

 

The Panel in Temco Industrial v. Mira Holdings, WIPO Case No. D2025-3913 (Dec 30, 2025) also reached a similar conclusion on set of similar facts (though that case also involved evidence of specific negotiations with a broker, which are not part of the factual matrix in this case).

 

In sum, the Panel determines on the balance of probabilities, that at the time of registration of the Domain Name, September 3, 2022, whether it was aware of the Complainant (through a trademark or Google search) or had deliberately taken steps to avoid such awareness, Respondent was aware that much of the value of the Domain Name arose from its value to a trademark owner in existence. As such the Panel finds that that Respondent acquired the Domain Name primarily for the purpose of selling, renting, or otherwise transferring it to Complainant (or a competitor of Complainant) for valuable consideration in excess of documented out-of-pocket costs directly related to the Domain Name. Policy, paragraph 4(b)(i).

 

The Panel finds Complainant has satisfied Policy ¶ 4(a)(iii).

 

REVERSE DOMAIN NAME HIJACKING

Because Complainant has satisfied the three elements required under the Policy, the Panel finds no support for Respondent's allegation of Reverse Domain Name Hijacking.

 

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

 

 

 

Nicholas J.T. Smith, Panelist

Dated: February 28, 2026