DECISION

 

Ubiquity Global Services, Inc. v. Anthony Eggleston

Claim Number: FA2601002199452

 

PARTIES

Complainant is Ubiquity Global Services, Inc. ("Complainant"), represented by Julie M. Latsko of Royer Cooper Cohen Braunfeld LLC, Pennsylvania, USA. Respondent is Anthony Eggleston ("Respondent"), represented by Igor Motsnyi of Motsnyi IP (dba Motsnyi Legal), Serbia.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <aigenthelp.com> ("Disputed Domain Name"), registered with GoDaddy.com, 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.

 

David L. Kreider, Chartered Arbitrator (UK), as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 13, 2026; Forum received payment on January 13, 2026.

 

On January 13, 2026, GoDaddy.com, LLC confirmed by e-mail to Forum that the <aigenthelp.com> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, 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 January 15, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 4, 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@aigenthelp.com. Also on January 15, 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 3, 2026.

 

On February 3, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed David L. Kreider 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 domain name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant, Ubiquity Global Services, Inc., is a global business process outsourcing company that provides technology-driven services, including AI-driven software tools under the AIGENT trademark. Since 2018, Ubiquity and its predecessor have consistently promoted and provided software products and services to clients under the trademark AIGENT. Specifically, Ubiquity's AIGENT software is a suite of AI-driven tools that help human agents perform their jobs by providing live call transcription, call summaries, next best activity, keyword-based threat detection, and AI-assisted quality assurance.

 

Complainant is the owner of registered and common-law rights in the trademark AIGENT in connection with a suite of AI-driven tools that provide live call transcription, call summaries, next best activity, keyword-based threat detection, and AI-assisted quality assurance. Complainant avers that Ubiquity and its predecessor have consistently used the trademark AIGENT in connection with its software products and services, in interstate commerce in the United States, since 2018.

 

Complainant alleges that Respondent, without Complainant's authorization, is utilizing the Disputed Domain Name to offer software services which compete directly with Complainant's services, under an identical "AIgent" trademark. Complainant avers that Respondent's use of the AIGENT mark for software services will cause the average Internet user to assume that Respondent, its domain name, and the website to which the domain name is pointed are affiliated with, sponsored by, or otherwise related to Complainant, which they are not. See Swedish Match UK Ltd. v. Admin, Domain, FA 0873137 (Forum Feb. 13, 2007) (finding confusing similarity "bolstered" where Respondent's use of the disputed domain name was the same as Complainant's use of its marks).

 

B. Respondent

Respondent describes himself as a Texas-based entrepreneur operating his own company registered in the state of Texas under the name "AIgent, LLC". Respondent submits in evidence his signed, written declaration "under penalty of perjury and any other applicable laws for making false statements", stating: "I am the owner and principal of 'Aigent, LLC', a company registered in Texas, filing date - June 04, 2024. Main business activities of "Aigent, LLC" are building AI solutions specifically for customers' business requirements, custom AI Agent development and AI integration consulting. I was not aware of the Complainant in UDRP proceeding No. FA2601002199452, "Ubiquity Global Services" and its trademarks. I only became aware of the Complainant after I received this UDRP complaint. I registered the Disputed Domain Name because it corresponds to the name of my business, reflects my experience in the AI field and my experience as the author of books on AI. I did not target any other business. I never received any cease-and-desist letters from the Complainant".

Respondent asserts his rights and legitimate interest under Policy Paragraph 4(c)(i), since before any notice of the dispute he has been using the disputed domain name in connection with a bona fide offering of services and under Policy Paragraph 4(c)(ii), as he has been commonly known by the Disputed Domain Name since the Disputed Domain Name corresponds to Respondent's company name and to Respondent's book title "AIgents". Respondent submits that he had every right to register the Disputed Domain Name that corresponds to a name of his registered business in Texas, his own experience in the field of AI and includes the descriptive term "help". Respondent never claimed any affiliation with Complainant and was unaware of Complainant when he registered the Disputed Domain Name. He explains, the term "aigent" is a combination of the two dictionary words: "AI" (a short form of "Artificial Intelligence") and "agent". It is also used by numerous third parties unrelated to Complainant, including businesses offering software products and related services. Respondent proffers that it is not surprising that the term "aigent", a combination of "AI" and "agent", is popular and used by various unrelated businesses. For instance, one of the businesses using "aigent" is another Texas based company <aigent.energy>. Respondent avers he did not target Complainant and did not intend to take unfair advantage of the complainant's mark, and that the Respondent's website "is clearly different" from the Complainant's website.

FINDINGS

1. Complainant's Trademark Rights

Complainant holds United States federal trademark registration number 6,158,504, registered on September 22, 2020, for the standard character mark AIGENT (the "Mark"), in connection with software for analyzing, processing, performing, communicating, controlling, and/or managing transactions for customer service interactions, in International Class 9. Complainant alleged but did not provide any evidence of its common law trademark rights.

 

2. Respondent's Business and Domain Name Registration

Respondent incorporated AIgent, LLC, a domestic limited liability company, in Texas, USA, on June 4, 2024. Respondent acknowledges in a signed declaration that he registered the Disputed Domain Name <aigenthelp.com> on May 22, 2024, and only became aware of the complainant after receiving the UDRP complaint in the present action.

3. Communications Between Parties

On September 23, 2025, and October 2, 2025, Complainant's legal counsel sent cease and desist letters to Respondent demanding that Respondent cease all use of the AIGENT Intellectual Property. The Respondent claims he did not receive the letters, which Complainant's lawyers had sent by email to contact@aigenthelp.com – the email address specified for communications in the Respondent's own website.

4. Website Comparison

Respondent concedes in its Response that the Disputed Domain Name is confusingly similar to Complainant's registered trademarks for the purpose of the Policy. The Panel notes that the website at URL: <aigent.com> redirects Internet users to Complainant's official website at www.ubiquity.com. Complainant's Complaint makes no mention of the <aigent.com> domain name, which appears material to the question whether Respondent had actual knowledge of Complainant's AIGENT Mark when Respondent registered the Disputed Domain Name <aigenthelp.com>. The Panel finds the content of Respondent's website indistinguishable from that of Complainant's official website, except that Complainant's website references UBIQUITY in addition to the Complainant's registered AIGENT Mark.

5. Bad Faith Registration and Use

Respondent was on notice of the Complainant's AIGENT Mark. Accordingly, Respondent's registration and use of the Disputed Domain Name incorporating Complainant's registered "AIGENT" Mark in connection with the promotion of competing software services is compelling evidence of Respondent's 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

Respondent concedes in its Response that the Disputed Domain Name is confusingly similar to Complainant's registered Mark for the purpose of the Policy. Accordingly, the Panel finds that the first element at Policy Paragraph 4(a)(i) is admitted by Respondent and satisfied.

 

Rights or Legitimate Interests

The Panel finds that Respondent is not making a bona fide offering of goods and services and has no rights or legitimate interests in the Disputed Domain Name. Respondent is utilizing the domain, without Complainant's authorization, to offer software services which compete directly with Complainant's services under the "AIGENT" trademark.  Complainant's rights to the AIGENT Mark significantly predate Respondent's first use of "AIgent."  See, e.g., JES Publ'g Corp. v. Brand Wellard, FA 01036201 (Forum Sept. 11, 2007) ("Given the near identity of the mark and the domain name and the use of the domain name in connection with services related to those provided by Complainant, . . . Respondent is not using the domain name in connection with a bona fide offering of goods or services.").

 

Respondent's website contains no disclaimers or clarifications whatsoever that the site is operated by Respondent, and not Complainant, nor does Respondent's website identify Respondent or Respondent's Texas limited liability corporation in any way. Further, the inclusion of the word "HELP" in the Disputed Domain Name falsely suggests that the Disputed Domain Name and website are affiliated with Complainant, the owner of the registered AIGENT Mark. The Panel considers that a reasonable visitor to the Disputed Domain Name and website might incorrectly believe it to be an adjunct "help" portal incidental or affiliated with Complainant's official website.  See WIPO Overview 3.0, at paragraph 2.5, et seq.  

 

The Panel considers that the Disputed Domain Name and Respondent's website carry a high risk of implied affiliation and correlation with the Complainant and Complainant's registered Mark, and that Respondent intentionally and unfairly benefitted commercially from such correlation.  The Panel finds that Respondent is not using the Disputed Domain Name in connection with a bona fide offering of goods or services, and that the second element at Policy Paragraph 4(a)(ii) is satisfied.

 

Registration and Use in Bad Faith

The Disputed Domain Name differs from Complainant's registered AIGENT Mark only by the addition of the word "HELP". The Panel considers that the inclusion of "HELP" increases the likelihood of confusion by visitors that the Disputed Domain Name and website are complementary to or affiliated with Complainant.  Moreover, although Respondent alleges in conclusory terms that the Respondent's website "is clearly different" from the Complainant's website, the Panel finds the substantive content of the respective websites indistinguishable.

 

The Respondent's website identifies neither the Respondent, who purports to be an author and figure of some prominence in the AI field, nor the Respondent's company.  The Panel finds by a preponderance of the evidence that the Disputed Domain Name and Respondent's website are misleading as to source or sponsorship and were registered and used by Respondent in bad faith as a pretext to unfairly benefit from the Complainant's goodwill for Respondent's own commercial gain. The third element at Policy Paragraph 4(a)(iii) is satisfied.

 

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

 

 

 

 

David L. Kreider, Panelist

Dated: February 6, 2026