DECISION

 

Razor Trade Corporation v. FlokiNET Ltd WhoisProtection FlokiNET Ltd WhoisProtection / FlokiNET Ltd / Alexander Fisunov / Bernard Fleury / Eleni Nikolaidis / Anna Maria Klimecka / Ruslan Marushchenko / Sofia Ramirez

Claim Number: FA2601002200798

 

PARTIES

Complainant is Razor Trade Corporation ("Complainant"), represented by Kamal Tserakhau of REVERA Polska sp. z o.o., Poland. Respondent is FlokiNET Ltd WhoisProtection FlokiNET Ltd WhoisProtection / FlokiNET Ltd / Alexander Fisunov / Bernard Fleury / Eleni Nikolaidis / Anna Maria Klimecka / Ruslan Marushchenko / Sofia Ramirez ("Respondent"), Multiple Locations.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <play-lukki.com>, <lukki.top>, <lukki-online.net>, <playlukkicasino.com>, <casinolukki.net>, <lukki-aus.com>, <au-lukkicasino.com> and <lukkicasinonorge.com> (the "Domain Names"), registered with Namecheap, Inc., Gransy, S.R.O., Tucows Domains Inc., Porkbun Llc and Key-Systems, 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.

 

Alan L. Limbury, as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 21, 2026. Forum received payment on January 21, 2026.

 

On January 21 and 22, 2026, Namecheap, Inc., Gransy, S.R.O., Tucows Domains Inc., Porkbun Llc and Key-Systems, Llc confirmed by e-mail to Forum that the Domain Names are registered with Namecheap, Inc., Gransy, S.R.O., Tucows Domains Inc., Porkbun Llc and Key-Systems, Llc and that Respondent is the current registrant of the names. Namecheap, Inc., Gransy, S.R.O., Tucows Domains Inc., Porkbun Llc and Key-Systems, Llc have verified that Respondent is bound by the Namecheap, Inc., Gransy, S.R.O., Tucows Domains Inc., Porkbun Llc and Key-Systems, Llc registration agreements 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 28, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 17, 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@play-lukki.com, postmaster@lukki.top, postmaster@lukki-online.net, postmaster@playlukkicasino.com, postmaster@casinolukki.net, postmaster@lukki-aus.com, postmaster@au-lukkicasino.com, postmaster@lukkicasinonorge.com. Also on January 28, 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 registrations as technical, administrative and billing contacts.

 

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

 

On February 18, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Alan L. Limbury 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 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).

 

Complainant has shown that the Domain Names are effectively controlled by the same person and/or entity, which is operating under several aliases.

 

Hence this decision refers to FlokiNET Ltd WhoisProtection FlokiNET Ltd WhoisProtection / FlokiNET Ltd / Alexander Fisunov / Bernard Fleury / Eleni Nikolaidis / Anna Maria Klimecka / Ruslan Marushchenko / Sofia Ramirez as "Respondent". 

 

PARTIES' CONTENTIONS

A. Complainant

In 2023, Complainant founded an online casino targeting EU markets, operating under the brand name LUKKI, through the website at  "www.lukki.com".  Complainant registered its LUKKI brand name and logo as an EU trademark on 16 January 2025.

 

All the Domain Names are confusingly similar to Complainant's <lukki.com> domain name and LUKKI trademark. Respondent has no legitimate interest in the Domain Names as it does not operate any online casinos, nor does it provide any other services through any of the Domain Names. The only purpose of registering the Domain Names was to lure traffic from Complainant's website to several websites of its competitors.

 

Respondent has no rights or legitimate interests in the Domain Names. Respondent's use is nowhere near "bona fide". Respondent registered the Domain Names with the only purpose to copy Complainant's domain name and associated website, making users searching for Complainant's website find one of the Domain Names. Respondent's websites are either complete copies of Complainant's "www.lukki.com" website or closely similar to it, falsely suggesting that users have reached Complainant's website. However, Respondent provides no casino services at all contrary to the content of its websites.

 

All Respondent's websites simply feature links to a number of other online casino sites owned by Complainant's competitors and providing  similar online gambling and betting services.

 

Respondent could not possibly contend that it is commonly known by or identified with any of the Domain Names.

 

When Respondent registered the Domain Names, at and shortly after the peak of popularity of Complainant's domain name and LUKKI brand, Respondent was well-aware of Complainant's LUKKI mark. Respondent is using the Domain Names in bad faith to intentionally attract players and users to its websites by exploiting the reputation of Complainant's trademark and then redirecting users to another website for commercial gain. Further, Respondent plainly purports to disrupt and damage Complainant's business. Since Respondent has no connection to the trademark, there can be no dispute, given the fame of the mark, that Respondent is intentionally using it in bad faith to generate traffic to the websites of Complainant's competitors, most likely receiving remuneration for such unlawful and unfair conduct.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

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.

 

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

Complainant has shown that it has rights in the mark LUKKI, namely EUTM Registration No. 018951229, registered on January 16, 2025 for inter alia "Computer games programs downloaded via the internet [software]", in International Class 9.

 

It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the complainant's trademark and the disputed domain name. WIPO Overview 3.0, ¶ 1.7.

 

The Panel finds Respondent's <lukki.top> domain name to be identical to Complainant's LUKKI mark and its <play-lukki.com>, <lukki-online.net>, <playlukkicasino.com>, <casinolukki.net>, <lukki-aus.com>, <au-lukkicasino.com> and <lukkicasinonorge.com> domain names to be confusingly similar to Complainant's LUKKI mark, only differing by the addition of hyphens, the descriptive words "play", "online" and "casino", and the geographic abbreviations or words "aus", "au" and "norge", which differences are insufficient to distinguish those domain names from Complainant's mark. The inconsequential ".top", "net" and ".com" generic top-level domains ("gTLDs") may be ignored under this element. See, for example, Rollerblade, Inc. v. Chris McCrady, D2000-0429 (WIPO June 25, 2000).

 

Complainant has established this element.

 

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 between February 19 and November 4, 2025, several months after the registration of Complainant's LUKKI mark. The <au-lukkicasino.com> domain name resolves to a Registrar parking page with pay-per-click links including: "888 Games" and "Free Spins no Wagering". The other domain names all resolve to websites purporting to offer gambling services, most of which display Complainant's LUKKI mark and all of which redirect users to the websites of competitors of Complainant.

 

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). Respondent has made no attempt to do so.

 

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 LUKKI mark and "www.lukki.com" website 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).

 

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 <play-lukki.com>, <lukki.top>, <lukki-online.net>, <playlukkicasino.com>, <casinolukki.net>, <lukki-aus.com>, <au-lukkicasino.com> and <lukkicasinonorge.com> Domain Names be TRANSFERRED from Respondent to Complainant.

 

 

 

Alan L. Limbury, Panelist

Dated: February 20, 2026