DECISION
X.AI, LLC v. Jason Miller / json chao / jack meng / andy zhang / tengda / sun sun / Yu Robin / hua shisan / Curry Sarkory
Claim Number: FA2512002196880
PARTIES
Complainant is X.AI, LLC ("Complainant"), represented by Jonathan Uffelman of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, District of Columbia, USA. Respondent is Jason Miller / json chao / jack meng / andy zhang / tengda / sun sun / Yu Robin / hua shisan / Curry Sarkory ("Respondent"), Multiple Locations.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <grokimagine.ai>, <grokimagine.net>, <grokimagine.pro>, <grokimagine.one>, <grok-imagine.ai>, <grok-imagine.net>, <grok-imagine.pro> and <grok-imagine.org> (the "Domain Names"), registered with Spaceship, Inc.
PANEL
The undersigned certify 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.
Ho-Hyun Nahm and Charles Kuechenmeister as Panelists and Alan L. Limbury as Chair.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on December 29, 2025. Forum received payment on December 29, 2025.
On December 30, 2025, Spaceship, Inc. confirmed by e-mail to Forum that the Domain Names are registered with Spaceship, Inc. and that Respondent is the current registrant of the names. Spaceship, Inc. has verified that Respondent is bound by the Spaceship, 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 December 30, 2025, 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 registrations as technical, administrative, and billing contacts, and to postmaster@grokimagine.ai, postmaster@grokimagine.net, postmaster@grokimagine.pro, postmaster@grokimagine.one, postmaster@grok-imagine.ai, postmaster@grok-imagine.net, postmaster@grok-imagine.pro, and postmaster@grok-imagine.org. Also on December 30, 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 registrations as technical, administrative and billing contacts.
A timely Response from Jason Miller was received and determined to be complete on February 10, 2026.
On February 18, 2026, pursuant to Respondent's request to have the dispute decided by a three-member Panel, Forum appointed Ho-Hyun Nahm and Charles Kuechenmeister as Panelists and Alan L. Limbury as Chair.
On February 19, 2026, Complainant filed an Additional Submission in response to Respondent Jason Miller's February 10, 2026 Response.
RELIEF SOUGHT
Complainant requests that the Domain Names be transferred from Respondent to Complainant.
PRELIMINARY ISSUE: MULTIPLE RESPONDENTS
Paragraph 3(c) of the Rules provides that a "complaint may relate to more than one domain name, provided that the domain names are registered by the same domain name holder". Paragraph 1(d) of Forum's Supplemental Rules defines "The Holder of a domain name Registration" as "the single person or entity listed in the registration information, as verified by the Registrar, at the time of commencement" and sub-paragraph 1(d)(i) provides that a Complainant wishing to make an argument for a single Respondent having multiple aliases must comply with Supplemental Rules 4(c) and 17(a)(i).
Respondent Jason Miller respectfully submits that this consolidated proceeding is improper and requests that the Panel sever the dispute concerning <grokimagine.ai> from this proceeding, or alternatively, dismiss the Complaint in its entirety for improper consolidation. His arguments are as follows: He is the registrant of the domain name <grokimagine.ai> only, and has no affiliation, connection, or relationship of any kind with the registrants of the other seven domain names. Complainant's own exhibits confirm that the eight domain names are registered by different individuals with different names, different email addresses, different physical addresses and different registration dates. Jason Miller has never had any contact or communication with any of the other named registrants. Complainant has failed to establish that the eight domain names at issue are registered by the same domain-name holder, as required by UDRP Rule 3(c). The consolidation test under WIPO Overview 3.1, Section 4.11.2 is not met, and requiring Respondent to participate in a consolidated proceeding is procedurally unfair.
Respondent respectfully requests that the Panel sever the dispute concerning <grokimagine.ai> from this consolidated proceeding and require Complainant to file a separate complaint; or dismiss the Complaint in its entirety for failure to comply with Rule 3(c). In the alternative, if the Panel proceeds with this matter, Respondent requests that the Panel evaluate the dispute concerning <grokimagine.ai> strictly on its own merits, without reference to the conduct or circumstances of any other registrant or domain name.
In its Additional Submission, Complainant submits that Respondent argues that "Complainant has failed to establish that the eight domain names at issue are registered by the same domain-name holder," pointing only to the fact that the Domain Names' WHOIS records list five different registrants. No other named Respondent has rebutted Complainant's prima facie showing that consolidation is proper here. Nor does Respondent dispute or offer any explanation for the facts that the Domain Names are all identical except for the use of a hyphen and different gTLDs; were registered within one week of one another; were registered within days after Complainant announced the release of "Grok Imagine"; were registered with the same registrar; and are all used for similar AI-related websites, except for the <grokimagine.pro> domain.
The Panel considers that Mr. Miller's assertions of independence are contradicted by the facts that all eight Domain Names were registered using the same privacy service in Reykjavik and all were registered between July 30 and August 5, 2025, only a few days after Complainant's July 28, 2025 announcement that video generation was coming to the Grok platform via its "Imagine" feature. These circumstances present too great a coincidence and indicate that all eight Domain Names are effectively controlled by the same person and/or entity, which is operating under several aliases.
Hence this decision refers to Jason Miller / json chao / jack meng / andy zhang / tengda / sun sun / Yu Robin / hua shisan / Curry Sarkory as "Respondent". The Panel will nevertheless consider the merits of this case regarding the <grokimagine.ai> domain name, having regard to the parties' submissions.
PARTIES' CONTENTIONS
A. Complainant
Led by its CEO and world-renowned entrepreneur Elon Musk, Complainant, xAI LLC, is focused on building artificial intelligence products and services to accelerate human scientific discovery. On November 3, 2023, Complainant announced the early release of Grok, a conversational AI model. The Grok platform has millions of users around the world. On July 28, 2025, Complainant announced that video generation was coming to the Grok platform via its "Imagine" feature, which allows users to create both images and videos on a page titled "Grok Imagine."
Complainant's rights in the inherently distinctive GROK IMAGINE mark are based on its common law rights acquired through the substantial and continuous use of the GROK IMAGINE mark by Complainant and its affiliated companies since July 28, 2025. Complainant's rights in the inherently distinctive GROK mark are based on its common law rights acquired through the substantial and continuous use of the GROK mark by Complainant and its affiliated companies since November 3, 2023, and on Complainant's trademark registrations in countries all over the world.
The Domain Names are identical to Complainant's GROK marks.
Respondent has no rights or legitimate interest in the Domain Names. Respondent is not and has not been commonly known by the Domain Names. Respondent currently uses seven of the Domain Names to pass itself off as Complainant, diverting consumers away from the official <grok.com> website to its own websites offering competing AI services under the GROK mark. Respondent uses the <grokimagine.pro> domain for a parked website. Such use of the Domain Names does not constitute a bona fide offering of goods or services nor a legitimate non-commercial or fair use of the Domain Names. Respondent has attempted to conceal its identity using a privacy-protection service, interfering with Complainant's efforts to investigate Respondent and the extent of its infringing activities. Finally, Respondent has registered at least two of the Domain Names using false WHOIS contact information.
Respondent's registration and use of the Domain Names constitute bad faith under Policy ¶¶ 4(b)(iii) and (iv) because Respondent uses seven of the Domain Names to pass itself off as Complainant, diverting consumers away from the official <grok.com> website to its own websites offering competing services under the GROK mark. Respondent's use of the <grokimagine.pro> domain name constitutes bad faith under Policy ¶4(a)(iii) because Respondent uses it for a parked website.
Given that the Domain Names were all registered within days of Complainant's announcement regarding the introduction of "Grok Imagine," Respondent's registration and use of the Domain Names constitute opportunistic bad faith under Policy ¶ 4(a)(iii). Respondent's registration and use of the Domain Names constitute bad faith under Policy ¶¶ 4(b)(ii) because Respondent has displayed a pattern of abusive conduct, registering at least eight domain names incorporating Complainant's trademarks. Respondent has attempted to conceal its identity using a privacy-protection service, interfering with Complainant's efforts to investigate Respondent and the extent of its infringing activities. Respondent registered at least two of the Domain Names using false contact information. Finally, given Complainant's registrations of its GROK mark, the fame of Complainant's Grok AI service, and the fact that the Domain Names incorporate Complainant's GROK marks in their entirety and resolve to websites offering nearly identical AI services, Respondent undoubtedly knew of Complainant's rights in the GROK marks prior to registering the Domain Names and did so in bad faith.
B. Respondent
Respondent Jason Miller limits his Response to the domain name <grokimagine.ai> only. Respondent does not dispute that the domain name <grokimagine.ai> contains the term "grok imagine" which is similar to Complainant's asserted marks. However, the term "GROK" has a well-established meaning in common usage that predates Complainant's trademark rights. The word "grok" was coined by Robert A. Heinlein in the 1961 novel "Stranger in a Strange Land" and has been widely used in the technology community for decades to mean "to understand deeply and intuitively." The term is not exclusively associated with Complainant.
The word "imagine" is a common English dictionary word that cannot be monopolized by any single entity. The combination of a widely used tech community term with a common dictionary word does not create an inherently distinctive phrase belonging exclusively to Complainant.
With respect to the GROK IMAGINE mark specifically, Complainant asserts only common law rights dating from July 28, 2025. Complainant does not hold a registered trademark for the combined phrase "GROK IMAGINE". Common law trademark rights are inherently limited in scope and do not confer the same breadth of protection as a registered mark.
While Respondent acknowledges there is some degree of similarity between the domain name and Complainant's asserted marks, the question of confusing similarity under Policy 4(a)(i) should be evaluated in the context of the Respondent's own independent use of descriptive terms that were not exclusively associated with Complainant at the time of registration.
Respondent submits that it has rights and legitimate interests in the domain name <grokimagine.ai>. Prior to notice of this dispute, Respondent was using the domain name <grokimagine.ai> in connection with a bona fide offering of services. The website at <grokimagine.ai> provided AI-powered image generation tools and information to users. This was a genuine, operational website offering real services, not a passive holding page, parked domain, or redirect to Complainant's website.
The domain name <grokimagine.ai> is composed of two common terms: "grok," a word widely used in the technology community since 1961 meaning "to understand intuitively," and "imagine," a common English word describing the creative process. The combination of these descriptive terms in the context of AI services reflects the nature of the services offered — tools related to AI understanding and image creation. Respondent selected the domain name for its descriptive value in relation to the services offered, not to target Complainant's trademarks.
Complainant asserts common law trademark rights in the combined phrase "GROK IMAGINE" dating from July 28, 2025. Respondent's registration and use of the domain <grokimagine.ai> to provide AI-related services predates or is contemporaneous with any alleged trademark rights in the combined phrase "GROK IMAGINE." The timeline supports a finding of legitimate interest rather than targeting of Complainant's marks.
Respondent did not register the domain to target Complainant. At the time of registration, Respondent selected the domain name based on its descriptive meaning in the AI technology space. The term "grok" has widespread independent usage in the technology community, and "imagine" is a generic English word. Respondent had no intent to create confusion with Complainant or to trade on Complainant's goodwill.
Respondent denies that the domain name <grokimagine.ai> was registered and is being used in bad faith. Respondent did not register <grokimagine.ai> for the purpose of selling, renting, or transferring it to Complainant or any competitor. Respondent has never offered to sell the domain name to Complainant or to any third party. There have been no communications between Respondent and Complainant regarding any sale or transfer of the domain name. Respondent has not engaged in a pattern of registering domain names to prevent trademark holders from reflecting their marks in corresponding domain names. This proceeding involves the only domain name registered by Respondent that is at issue. Respondent did not register the domain name primarily for the purpose of disrupting Complainant's business. Respondent operates in the AI image generation space and selected the domain name for its descriptive qualities. Respondent is not a competitor of Complainant's core AI model business.
Respondent did not register the domain name to create a likelihood of confusion with Complainant's marks as to source, sponsorship, or affiliation. The website at <grokimagine.ai> does not impersonate Complainant, does not use Complainant's logos or trade dress, and does not claim any association with Complainant or its products.
The word "grok" has been used in the technology community since 1961 and carries an independent meaning apart from Complainant's AI product. Respondent's selection of a domain name containing this widely used term does not, by itself, constitute evidence of bad faith. Many parties across the technology industry use the term "grok" independently of Complainant.
Complainant bears the burden of proving bad faith registration AND use. Both elements must be established. Complainant has not presented sufficient evidence to meet this burden with respect to <grokimagine.ai> specifically, as distinct from the other domain names in this consolidated proceeding.
C. Additional Submissions
Complainant says Respondent registered the <grokimagine.ai> domain name on July 31, 2025, three days after Complainant publicly announced, on July 28, 2025, that video generation was coming to its Grok platform via its "Imagine" feature. Complainant's announcement, and Respondent's subsequent use of it for a website that displays the GROK trademark and offers services identical to those Complainant described in its public announcement, shows that his registration was not coincidental, but targeted opportunistically at Complainant's nascent, and valid, GROK IMAGINE trademark rights. Even if the Panelists find that Respondent registered the <grokimagine.ai> domain name before Complainant's common law rights in GROK IMAGINE had accrued, his registration does not predate Complainant's rights in the GROK trademark. Respondent fails to explain how the purported definition—or the terms "grok" or "grok imagine"—describe his particular services, namely, an Internet website that offers AI image-generation services. Respondent's failure to explain the connection is unsurprising, because he actually uses the <grokimagine.ai> domain to impersonate Complainant.
Respondent argues that his website "does not impersonate Complainant, does not use Complainant's logos or trade dress, and does not claim any association with Complainant or its products." He further claims he "is not a competitor of Complainant's core AI model business." Respondent's arguments are flatly contradicted by the undeniable fact that he uses the <grokimagine.ai> domain name for a website that displays Complainant's GROK trademark in the upper left corner of the website and offers the identical AI-related services as Complainant's Grok Imagine platform.
FINDINGS
Complainant has established all the elements entitling it to relief.
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 shown that it has rights in the registered mark GROK, including International Registration No. 1799269, registered on April 22, 2024 for inter alia "downloadable computer programs and downloadable computer software for the artificial production of human speech and text", in International Class 9.
The Panel finds Respondent's <grokimagine.ai>, <grokimagine.net>, <grokimagine.pro>, <grokimagine.one>, <grok-imagine.ai>, <grok-imagine.net>, <grok-imagine.pro> and <grok-imagine.org> Domain Names to be confusingly similar to Complainant's GROK mark, only differing by the addition of the descriptive word "imagine" and, in some cases, a hyphen. These differences are insufficient to distinguish the Domain Names from Complainant's mark. The inconsequential ".ai", ".net", "pro", ".one", and ".org" generic top-level domains ("gTLDs") may be ignored under this element. See Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognisable 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 Vanguard Group Inc. v. Proven Fin. Solutions, FA 572937 (Forum Nov. 18, 2005) (holding that the addition of both the word "advisors" and the gTLD ".com" did not sufficiently alter the disputed domain name to negate a finding of confusing similarity under Policy ¶ 4(a)(i)); see also Rollerblade, Inc. v. Chris McCrady, D2000-0429 (WIPO June 25, 2000).
Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate Respondent's rights or legitimate interests to a domain name for purposes of Paragraph 4(a)(ii):
(i) before any notice to Respondent of the dispute, the use by Respondent of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or
(ii) Respondent (as an individual, business or other organization) has been commonly known by the domain name, even if Respondent has acquired no trademark or service mark rights; or
(iii) Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert customers or to tarnish the trademark or service mark at issue.
The Domain Names were registered as follows: <grokimagine.net> on July 30, 2025; <grokimagine.ai> on July 31, 2025; <grokimagine.pro> on August 2, 2025; <grok-imagine.net> and <grok-imagine.org> on August 3, 2025; <grok-imagine.ai> and <grok-imagine.pro> on August 4, 2025; and <grokimagine.one> on August 5, 2025.
Each of the Domain Names was registered more than a year after the registration of Complainant's International GROK mark and only a few days after Complainant's announcement on July 28, 2025 that video generation was coming to the Grok platform via its "Imagine" feature.
The domain name <grokimagine.ai>, registered in the name of Jason Miller, resolved, as of the date of the filing of the Complaint, to a website offering services similar to those of Complainant, headed "Grok Imagine" and "Grok Imagine AI Platform', with statements including: "Turn wild ideas into viral content with Grok Imagine"; "Choose Your Grok Imagine Plan"; and "Start creating professional AI videos and images for free, then upgrade to unlock advanced features and unlimited generations with our flexible credit system". All of the other Domain Names except <grokimagine.pro> resolve to similar websites, and all seven of these websites are similar in general appearance to Complainant's <grok.com> website in that they all display white lettering in the same font against a black background. The photo images are different in subject matter but the sites as a whole are very similar in look and feel. The <grokimagine.pro> domain name resolves to a Registrar-sponsored parked webpage.
These circumstances, together with Complainant's assertions, are sufficient to constitute a prima facie showing of absence of rights or legitimate interests in respect of the Domain Names on the part of Respondent. The evidentiary burden therefore shifts to Respondent to show that it does have rights or legitimate interests in the Domain Names. See JUUL Labs, Inc. v. Dryx Emerson / KMF Events LTD, FA 1849706 (Forum July 17, 2019).
The Panel finds that the timing of the registration of the <grokimagine.ai> domain name and the inclusion of the word "imagine", instead of "image" or "images", negates any finding that Jason Miller, who admits that he operates in the AI image generation space, selected that domain name for its descriptive qualities and therefore has a legitimate interest in the domain name. This finding applies to all of the other Domain Names except <grokimagine.pro>, which is passively held.
The Panel finds that Respondent has no rights or legitimate interests in respect of the Domain Names.
Complainant has established this element.
Registration and Use in Bad Faith
Paragraph 4(a)(iii) of the Policy is expressed in the conjunctive: "the domain name has been registered and is being used in bad faith" and Paragraph 4(b) sets out four illustrative circumstances, which, though not exclusive, shall be evidence of the registration and use of a domain name in bad faith for purposes of paragraph 4(a)(iii), including:
(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.
The circumstances set out above in relation to the second element satisfy the Panel that Respondent was fully aware of Complainant, its GROK mark and its announcement of July 28, 2025 when Respondent registered the Domain Names and that Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent's websites, by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent's websites and of the services promoted on those websites. This demonstrates registration and use in bad faith to attract users for commercial gain under Policy ¶ 4(b)(iv).
Although the <grokimagine.pro> domain name does not resolve to an active website, as in the leading case of Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003, there is no conceivable active use that could be made of that domain name that would not amount to an infringement of Complainant's rights in its GROK mark. Accordingly, the Panel finds that Respondent's hitherto passive use of the <grokimagine.pro> domain name demonstrates registration and use in bad faith.
Complainant has established this element.
DECISION
Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.
Accordingly, it is Ordered that the <grokimagine.ai>, <grokimagine.net>, <grokimagine.pro>, <grokimagine.one>, <grok-imagine.ai>, <grok-imagine.net>, <grok-imagine.pro> and <grok-imagine.org> Domain Names be TRANSFERRED from Respondent to Complainant.
Alan L. Limbury, Chair
Ho-Hyun Nahm, Panelist
Charles Kuechenmeister , Panelist
Dated: February 23, 2026
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