DECISION

 

Razor Trade Corporation v. Dara Bulatova / princ effqo / Serhiienko Maksym / Alexandr Fisunov / Sergei Bodrov / Geoffrey CUVELIER / Vinicius Bongaertz / Alexander Fisunov

Claim Number: FA2601002201110

 

PARTIES

Complainant is Razor Trade Corporation ("Complainant"), represented by Kamal Tserakhau of REVERA Polska sp. z o.o., Poland. Respondent is Dara Bulatova / princ effqo / Serhiienko Maksym / Alexandr Fisunov / Sergei Bodrov / Geoffrey CUVELIER / Vinicius Bongaertz / Alexander Fisunov ("Respondent"), Various Locations.

 

REGISTRAR AND DISPUTED DOMAIN NAMES

The domain names at issue are <de-miraxcasino.org>, <miraxcasino-login.com>, <mirax-us.com>, <miraxcasinoaus.com>, <miraxcasino-au.com>, <miraxcasino-australia.com>, <mirax-casino-au.com>, <mirax-casino1.com>, <mirax.bet>, and <miraxcasino.win>, registered with Hosting Concepts B.V. d/b/a Registrar.eu; NameCheap, Inc.; Spaceship, Inc.; and Internet Domain Service BS Corp.

 

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.

 

Richard Hill as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 22, 2026; Forum received payment on January 22, 2026.

 

On Jan 22, 2026; Jan 28, 2026, Hosting Concepts B.V. d/b/a Registrar.eu; NameCheap, Inc.; Spaceship, Inc.; and Internet Domain Service BS Corp confirmed by e-mail to Forum that the <de-miraxcasino.org>, <miraxcasino-login.com>, <mirax-us.com>, <miraxcasinoaus.com>, <miraxcasino-au.com>, <miraxcasino-australia.com>, <mirax-casino-au.com>, <mirax-casino1.com>, <mirax.bet>, and <miraxcasino.win> domain names are registered with Hosting Concepts B.V. d/b/a Registrar.eu; NameCheap, Inc.; Spaceship, Inc.; and Internet Domain Service BS Corp and that Respondent is the current registrant of the names. Hosting Concepts B.V. d/b/a Registrar.eu; NameCheap, Inc.; Spaceship, Inc.; and Internet Domain Service BS Corp have verified that Respondent is bound by the Hosting Concepts B.V. d/b/a Registrar.eu; NameCheap, Inc.; Spaceship, Inc.; and Internet Domain Service BS Corp 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 30, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 19, 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@de-miraxcasino.org, postmaster@miraxcasino-login.com, postmaster@mirax-us.com, postmaster@miraxcasinoaus.com, postmaster@miraxcasino-au.com, postmaster@miraxcasino-australia.com, postmaster@mirax-casino-au.com, postmaster@mirax-casino1.com, postmaster@mirax.bet, and postmaster@miraxcasino.win. Also on January 30, 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.

 

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

 

On February 20, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Richard Hill 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

In the instant proceedings, Complainant has alleged that the entities which control the domain names at issue are effectively controlled by the same person and/or entity, which is operating under several aliases. Paragraph 3(c) of the Rules for Uniform Domain Name Dispute Resolution Policy (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."

 

The Panel finds that the domain names are under common control as the websites displayed at these domains are similar and display Complainant's mark (or its dominant portion) and distinctive logo; they are phishing websites that redirect users to services that compete with those of Complainant. This is sufficient to find that the domain names were registered by the same domain name holder. See The Valspar Corporation v. Zhou Zhiliang / zhouzhiliang / Zhiliang Zhou / Eric Chow / Visspa Ltd., FA 133934 (Forum Sept. 28, 2010); see also BBY Solutions, Inc. v. White Apple / Dev Kumar, FA 1787251 (Forum June 20, 2018).

 

Consequently, the Panel will rule on all the contested domain names, and the registrants are collectively referred to as "Respondent".

 

PARTIES' CONTENTIONS

A. Complainant

Complainant states that it is a company incorporated under the laws of Seychelles and having its registered office in the Seychelles. In 2022, Complainant together with Dama N.V. (DAMA Group) has released its online casino platform under the brand name MIRAX CASINO operating at <miraxcasino.com>. Complainant's partner, DAMA Group, is incorporated under the laws of Curacao and owns the necessary international Curacao E-gaming license. Therefore, Complainant's operations of Mirax Casino under the Dama's Curacao license is completely legitimate and compliant with all applicable regulatory requirements. Complainant's website provides players from the EU with a wide diversity of online entertainment experience, including numerous slot games from world top providers and live casino games. Complainant manages its own loyalty program, which is designed to reward players as they engage more with the platform, offers attractive welcome bonuses, organizes tournaments and marketing campaigns putting significant efforts in the promotion of the MIRAX CASINO, which is now associated by the public with a fair and enjoyable online gaming experience. As a result of Complainant's successful operations, the brand name MIRAX CASINO received massive attention and substantial growth in popularity, in particular as of in July 2023. Complainant asserts rights in the mark MIRAX CASINO through its registration in the European Union on February 11, 2025, filing date October 29, 2024. Complainant also claims common law rights in the mark dating back to at least July 2023.

 

Complainant alleges that the disputed domain names are confusingly similar to its MIRAX CASINO mark as they include the entire mark, or the dominant portion MIRAX of the mark, and merely add hyphens, and/or geographical terms, and/or generic/descriptive terms, and/or digits, together with a generic top-level domain ("gTLD").

 

According to Complainant, Respondent lacks rights or legitimate interests in the disputed domain names. Respondent is not licensed or authorized to use Complainant's mark and is not commonly known by the disputed domain names. Respondent does not use the disputed domain names for a bona fide offering of goods or services or a legitimate noncommercial or fair use. Instead, the resolving websites display Complainant's mark (or its dominant portion) and distinctive logo and redirect users to services that compete with those of Complainant.

 

Further, says Complainant, Respondent registered and uses the disputed domain names in bad faith by offering competing products and services. Respondent has engaged in a pattern of bad faith registration and use of domain names.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant owns the mark MIRAX CASINO and uses it to provide online gambling services.

 

Complainant's rights in its mark date back to at least July 2023.

 

The disputed domain names were registered between January 2024 and December 2025.

 

Complainant has not licensed or otherwise authorized Respondent to use its mark.

 

The resolving websites display Complainant's mark (or its dominant portion) and distinctive logo and redirect users to services that compete with those of Complainant.

 

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 relevant date for Complainant's registered mark MIRAX CASINO is the filing date (October 29, 2024), see Lenovo (Beijing) Limited Corporation China v. jeonggon seo, FA 1591638 (Forum Jan. 16, 2015) (finding Complainant has rights in the LENOVO mark dating back to the February 20, 2003 filing date with the USPTO as the trademark application was ultimately successful); see also Hershey Co. v. Reaves, FA 967818 (Forum June 8, 2007) (finding that the complainant's rights in the KISSES trademark through registration of the mark with the USPTO "date back to the filing date of the trademark application and predate [the] respondent's registration").

 

In addition to its registered trademark rights, Complainant asserts common law rights in its MIRAX CASINO mark. Common law rights are sufficient to establish rights in a mark under Policy ¶ 4(a)(i). See Artistic Pursuit LLC v. calcuttawebdevelopers.com, FA 894477 (Forum Mar. 8, 2007) (finding that Policy ¶ 4(a)(i) does not require a trademark registration if a complainant can establish common law rights in its mark). Common law rights may be established through evidence of secondary meaning in the mark such as longstanding use, evidence of use of an identical domain name, media recognition, and promotional material and advertising. See Marquette Golf Club v. Al Perkins, 1738263 (Forum July, 27, 2017) (finding that Complainant had established its common law rights in the MARQUETTE GOLF CLUB mark with evidence of secondary meaning, including "longstanding use; evidence of holding an identical domain name; media recognition; and promotional material/advertising"). Here, Complainant registered the domain name <miraxcasino.com> in 2021, and used it to market and sell its services well before the registration of the disputed domain names. Further, Complainant extensively used its MIRAX CASINO mark in various promotional and advertising materials. Therefore, the Panel finds that Complainant established common law rights in its MIRAX CASINO mark, with rights predating the first registration of the disputed domain names.

 

The disputed domain names incorporate Complainant's MIRAX CASINO mark in its entirety, or the dominant portion MIRAX of the mark, and merely add hyphens, and/or geographical terms, and/or generic/descriptive terms, and/or digits, together with a generic top-level domain ("gTLD"). Under Policy ¶ 4(a)(i), such changes are generally insufficient in differentiating a disputed domain name from the mark it incorporates. 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 ADP, LLC. v. Ella Magal, FA 1773958 (Forum Aug. 2, 2017) ("Respondent's <workforce-now.com> domain name appropriates the dominant portion of Complainant's ADP WORKFORCE NOW mark and adds a hyphen and the gTLD ".com." These changes do not sufficiently distinguish the disputed domain name from the ADP WORKFORCE NOW mark."); 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 Home Depot Product Authority, LLC v. Angelo Kioussis, FA 1784554 (Forum June 4, 2018) ("The domain name contains the mark in its entirety, with only the addition of the generic letters 'sb' and the digits '2018,' plus the generic Top Level Domain ("gTLD") '.com.'  These alterations of the mark, made in forming the domain name, do not save it from the realm of confusing similarity under the standards of the Policy."); see also American Farm Bureau Fed'n and Texas Farm Bureau v. Michael Yeates, FA 1432672 (Forum Apr. 12, 2012) ("Complainant asserts that Respondent's <texasfarmbureau.net> domain name is confusingly similar to its FARM BUREAU mark. The Panel finds that Respondent's addition of the geographic term 'texas' fails to distinguish the disputed domain name from Complainant's mark."); see also Health Devices Corp. v. Aspen S T C, FA 158254 (Forum July 1, 2003) ("[T]he addition of punctuation marks such as hyphens is irrelevant in the determination of confusing similarity pursuant to Policy ¶ 4(a)(i)."). Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant's mark under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Complainant has not licensed or otherwise authorized Respondent to use its mark. Respondent is not commonly known by the disputed domain names: under Policy ¶ 4(c)(ii), WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name. See Tercent Inc. v. Lee Yi, FA 139720 (Forum Feb. 10, 2003) (stating "nothing in [the respondent's] WHOIS information implies that [the respondent] is 'commonly known by' the disputed domain name" as one factor in determining that Policy ¶ 4(c)(ii) does not apply); see also Alaska Air Group, Inc. and its subsidiary, Alaska Airlines v. Song Bin, FA 1574905 (Forum Sept. 17, 2014) (holding that the respondent was not commonly known by the disputed domain name as demonstrated by the WHOIS information and based on the fact that the complainant had not licensed or authorized the respondent to use its ALASKA AIRLINES mark). Here, the WHOIS information for the disputed domain names lists the registrants as "Dara Bulatova / princ effqo / Serhiienko Maksym / Alexandr Fisunov / Sergei Bodrov / Geoffrey CUVELIER / Vinicius Bongaertz / Alexander Fisunov". Therefore the Panel finds that Respondent is not commonly known by the disputed domain names per Policy ¶ 4(c)(ii).

 

The resolving websites offer services that compete with those of Complainant. Previous panels have found that use of a disputed domain name to offer goods or services in competition with those of a complainant does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. See Vanguard Trademark Holdings USA LLC v. Dan Stanley Saturne, FA 1785085 (Forum June 8, 2018) ("Respondent's use of the disputed domain name does not amount to a bona fide offering of goods or services or a legitimate noncommercial or fair use" where "Respondent is apparently using the disputed domain name to offer for sale competing services."). Thus the Panel finds that Respondent fails to use the disputed domain names to make a bona fide offering of goods or services or a legitimate noncommercial or fair use under Policy ¶¶ 4(c)(i) or (iii). And the Panel finds that Respondent does not have rights or legitimate interests in the disputed domain names.

 

Registration and Use in Bad Faith

Respondent (who did not reply to Complainant's contentions) has not presented any plausible explanation for its use of Complainant's mark. In accordance with paragraph 14(b) of the Rules, the Panel shall draw such inferences from Respondent's failure to reply as it considers appropriate. Accordingly, the Panel finds that Respondent did not have a legitimate use in mind when registering the disputed domain names.

 

Indeed, as already noted, the resolving websites offer services that compete with those of Complainant. Panels have held that registration and use of a disputed domain name to divert Internet traffic to a competing website offering the same or similar goods or services demonstrates bad faith registration and use under Policy ¶¶ 4(b)(iii) and/or (iv). See ZIH Corp. v. ou yang lin q, FA 1761403 (Forum Dec. 29, 2017) (finding bad faith where Respondent used the infringing domain name to disrupt Complainant's business by diverting Internet users from Complainant's website to Respondent's website where it offered competing printer products); see also Citadel LLC and its related entity, KCG IP Holdings, LLC v. Joel Lespinasse / Radius Group, FA 1579141 (Forum Oct. 15, 2014) ("Here, the Panel finds evidence of Policy ¶ 4(b)(iv) bad faith as Respondent has used the confusingly similar domain name to promote its own financial management and consulting services in competition with Complainant."). Thus the Panel finds that Respondent registered and uses the disputed domain names in bad faith under Policy ¶ 4(b)(iii) and/or Policy ¶ 4(b)(iv).

 

Further, Respondent registered the disputed domain names with actual knowledge of Complainant's mark: the resolving websites display Complainant's mark (or its dominant portion) and distinctive logo. While constructive notice is insufficient to demonstrate bad faith, actual knowledge of a complainant's rights in a mark prior to registration may be evidence of bad faith per Policy ¶ 4(a)(iii). See Custom Modular Direct LLC v. Custom Modular Homes Inc., FA 1140580 (Forum Apr. 8, 2008) ("There is no place for constructive notice under the Policy."); see also Orbitz Worldwide, LLC v. Domain Librarian, FA 1535826 (Forum Feb. 6, 2014) ("The Panel notes that although the UDRP does not recognize 'constructive notice' as sufficient grounds for finding Policy ¶ 4(a)(iii) bad faith, the Panel here finds actual knowledge through the name used for the domain and the use made of it."); 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). The Panel finds that Respondent had actual knowledge of Complainant's rights in its mark prior to Respondent's registration of the disputed domain names and that this constitutes bad faith registration and use under Policy ¶ 4(a)(iii).

 

Finally, Respondent displays a pattern of bad faith registration of disputed domain names containing Complainant's mark. Registration of multiple domain names containing a complainant's mark can substantiate an argument that a respondent registered and uses a disputed domain name in bad faith per Policy ¶ 4(b)(ii). See NIKE, Inc., and Nike Innovate, C.V. v. Emile Boulanger, FA 1732458 (Forum July 3, 2017) (finding that registration of several infringing domain names in a case satisfies the burden imposed by the Policy ¶ 4(b)(ii)); see also Caterpillar Inc. v. Angie Arendt / DIAHOST .CO / keith mosley, FA 1789701 (Forum July 2, 2018) (finding that Respondent engaged in a pattern of bad faith and registration by registering multiple domain names that contain Complainant's famous CATERPILLAR mark); see also Radisson Hotels Internation, Inc. v. Yue Mei Wang / Wang Yue Mei aka Pei Jun Gan / Gan Pei Jun / Jun Yu He / He Jun Yu / Denliyan, FA 1615349 (Forum June 1, 2015) ("The Panel agrees that Respondent's registration of the <radissonbluplazachongqing.com>, <radissonbluchongqingshapingba.com>, <radissonplazahoteltianjin.com>, and <radissonbluhotelshanghai.com> domain names, which all infringe on Complainant's mark, constitutes bad faith under Policy ¶ 4(b)(ii)."). Thus the Panel finds that Respondent registered the disputed domain names in bad faith per Policy ¶ 4(b)(ii).

 

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 <de-miraxcasino.org>, <miraxcasino-login.com>, <mirax-us.com>, <miraxcasinoaus.com>, <miraxcasino-au.com>, <miraxcasino-australia.com>, <mirax-casino-au.com>, <mirax-casino1.com>, <mirax.bet>, and <miraxcasino.win> domain names be TRANSFERRED from Respondent to Complainant.

 

 

 

Richard Hill, Panelist

Dated: February 20, 2026