DECISION

 

Razor Trade Corporation v. Eugene Gonzales / Mikhail Haraldson / Matthias Walter Plomer / Iraidis Morales Romero / Serhiienko Maksym / Alexandr Fisunov / Sofia Ramirez / Evgeniya Tolstova

Claim Number: FA2601002202629

 

PARTIES

Complainant is Razor Trade Corporation ("Complainant"), represented by Kamal Tserakhau of REVERA Polska sp. z o.o., Poland. Respondent is Eugene Gonzales / Mikhail Haraldson / Matthias Walter Plomer / Iraidis Morales Romero / Serhiienko Maksym / Alexandr Fisunov / Sofia Ramirez / Evgeniya Tolstova ("Respondent"), Various Locations.

 

REGISTRAR AND DISPUTED DOMAIN NAMES 

The domain names at issue are <casino-luckyones.org>, <luckyones-deutschland.com>, <the-lucky-ones-casino.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <oneslucky.com>, <luckyones-australia.com>, <luckyoneskasino.com>, and <luckyonescasinonorge.com>, registered with Namecheap, Inc.; Devexpanse Ltd; Realtime Register B.V.; Hosting Concepts B.V. D/B/A Registrar.Eu; and Url Solutions, Inc.

 

For the reasons given below, the Panel finds that the only relevant domain name for this case are <casino-luckyones.org>, <luckyones-deutschland.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <luckyones-australia.com>, <luckyoneskasino.com>, and <luckyonescasinonorge.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.

 

Richard Hill as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 30, 2026; Forum received payment on January 30, 2026.

 

On Jan 31, 2026; Feb 02, 2026, Namecheap, Inc.; Devexpanse Ltd; Realtime Register B.V.; Hosting Concepts B.V. D/B/A Registrar.Eu; and Url Solutions, Inc. confirmed by e-mail to Forum that the <casino-luckyones.org>, <luckyones-deutschland.com>, <the-lucky-ones-casino.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <oneslucky.com>, <luckyones-australia.com>, and <luckyoneskasino.com>, <luckyonescasinonorge.com> domain names are registered with Namecheap, Inc.; Devexpanse Ltd; Realtime Register B.V.; Hosting Concepts B.V. D/B/A Registrar.Eu; and Url Solutions, Inc. and that Respondent is the current registrant of the names. Namecheap, Inc.; Devexpanse Ltd; Realtime Register B.V.; Hosting Concepts B.V. D/B/A Registrar.Eu; and Url Solutions, Inc. have verified that Respondent is bound by the Namecheap, Inc.; Devexpanse Ltd; Realtime Register B.V.; Hosting Concepts B.V. D/B/A Registrar.Eu; and Url Solutions, Inc. 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 February 10, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 2, 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@casino-luckyones.org, postmaster@luckyones-deutschland.com, postmaster@the-lucky-ones-casino.com, postmaster@luckyones-norway.com, postmaster@luckyoneslogin.com, postmaster@oneslucky.com, postmaster@luckyones-australia.com, postmaster@luckyoneskasino.com, and postmaster@luckyonescasinonorge.com. Also on February 10, 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 March 3, 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. In support of this allegation it states:

a)       Each and every domain name includes Complainant's LUCKY ONES trademark in its entirety.

b)       Each and every domain name is being used solely to host phishing websites that mimic Complainant's original website and to redirect users to the competitors' websites.

c)       Each and every domain name is being registered within a narrow timeframe immediately following the surge in Lucky Ones popularity in 2024.

d)       All websites behind the domain names utilize identical design elements, including the Complainant's original creative images, logo implementations, and color palette.

e)       The domain names demonstrate a coordinated geographical expansion strategy.

f)       Despite presenting themselves as operational casinos, none of the domain names actually provide any casino services. All are mere redirect vehicles. 

g)       In the Complainant's previous Forum proceedings which involved multiple respondents on the Lucky Ones and LuckyWins trademarks, which is another Complainant's brands, some of the same identities were used by the Respondents.

h)       The consistent use of a limited number of registrars, combined with identical privacy protection patterns, demonstrates centralized control.

i)       Multiple domains redirect to the same competing casino or other websites.

j)       Analysis of the contact information for the eight respondents reveals multiple anomalies that irrefutably prove these are not independent individuals but rather fabricated personas created by a single entity to obscure common ownership of the domain names.

 

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 allegations and (a), (c), (e) and (g)-(j) above do not necessarily indicate that the domain names are under common control. The Panel does not agree with allegations (b), (d), and (f): the evidence presented by Complainant indicates that two of the resolving websites are different from the others and don't mimic Complainant's website, whereas the others seven do indeed mimic Complainant's website, displaying Complainant's mark.

 

Thus the Panel finds that Complainant has not presented sufficient evidence to find that all the disputed domain names were registered by the same person or entity.

 

Under Forum's Supplemental Rule 4(c), the Panel must determine which domain names are commonly owned and elect which Respondent to proceed against, as a UDRP decision can proceed against only one Respondent. The Panel is then required to dismiss the Complaint in relation to the domain names not commonly owned by the chosen Respondent. 

 

Accordingly, the Panel will rule only on the <casino-luckyones.org>, <luckyones-deutschland.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <luckyones-australia.com>, <luckyoneskasino.com>, and <luckyonescasinonorge.com> domain names, and it will dismiss, without prejudice, the complaint regarding the domain names <the-lucky-ones-casino.com>, and <oneslucky.com >. See Brian Renner v. Contactprivacy.com, FA 1335211 (Forum Aug. 26, 2010); see also Amazon Technologies, Inc. v. M M / shanwang chen / feifei lin / HUA ZHANG / L H / Eddie Nash / Heather Brooker, FA 1973471 (Forum Dec. 17, 2021).

 

PARTIES' CONTENTIONS

A. Complainant

Complainant states that, in 2024, it, with Just Entertainment B.V. has released its online casino platform under the brand name "Lucky Ones" operating on the domain name <luckyones.com>. Complainant's partner, Just Entertainment B.V., is incorporated under the laws of Curacao and owns the necessary international Curacao E-gaming license. Therefore, Complainant's operations of Lucky Ones is completely legit 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's casino manages its own loyalty and jackpot programs, and marketing putting significant efforts in promoting the LUCKY ONES brand, which is now associated by the public with an enjoyable online gaming experience. Following the increased popularity of the LUCKY ONES brand among the EU players, Complainant decided to protect its brand name and logo by registering it as EU trademark. The LUCKY ONES trademark was registered in the EU on 28 January 2025 in relation to a wide range of goods and services connected with the Complainant's online casino and entertainment business activities. Almost immediately after gaining public attention in the industry, Complainant observed a great number of sites infringing on its trademark rights, exploiting the trust and goodwill built up with players and partners. An unknown party, i.e. Respondent, has registered confusingly similar domain names to create clear-cut copies of Complainant's domain name. The main aim of such clones is to lure traffic from Complainant by confusing players to thinking that they reached Complainant's website. However, after users attempt to register an account with such unauthorized website, they are transferred to the website of one of the Complainant's competitors. The domain names listed in the Complainant are just most notable examples of numerous similar unauthorized copies of Complainant's website. According to WhoIs information, domain names were registered right after the "boom" in Complainant's Lucky Ones popularity, which started in March 2024, which is a self-evident confirmation of the actual knowledge of the Respondent of the Trademark in the process of the registering the Domain names. Complainant asserts rights in the mark LUCK ONES through its registration in the European Union on January 28, 2025, filing date October 11, 2024.

 

Complainant alleges that the disputed domain names are confusingly similar to its LUCKY ONES mark because they incorporate the mark in its entirety, merely adding a hyphen, and/or reversing the terms of the mark, adding geographic terms, and/or generic/descriptive terms, together with a generic top-level domain ("gTLD").

 

According to Complainant, Respondent has no rights or legitimate interests in the disputed domain names. Respondent is not commonly known by the disputed domain names and Complainant has not authorized or licensed to Respondent any rights in its mark. 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 mimic Complainant's legitimate website, displaying Complainant's mark, and purport to offer services that compete with those of Complainant.

 

Further, says Complainant, Respondent registered and uses the disputed domain names in bad faith. The resolving websites purport to offer services that compete with those of Complainant. Respondent registered the disputed domain names with actual/constructive knowledge of Complainant's rights in the LUCKY ONES mark.

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant owns the mark LUCKY ONES and uses it to provide gambling services. The associated services were launched in March 2024.

 

Complainant registered the mark on January 28, 2025, with the filing date of October 11, 2024.

 

The <luckyones-australia.com> domain name was registered on August 7, 2024. The other registrations postdate the date on which Complainant established rights in its trademark.

 

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

 

The resolving websites purport to offer services that compete with those of Complainant; they display Complainant's mark and mimic Complainant's legitimate website.

 

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 the Complainant's mark is the filing date, 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").

 

The disputed domain names incorporate Complainant's LUCKY ONES mark in its entirety, merely adding a hyphen, and/or reversing the terms of the mark, adding geographic terms, and/or generic/descriptive terms, together with a generic top-level domain ("gTLD"). Under Policy ¶ 4(a)(i), such changes are not sufficient to differentiate 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 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 Mrs. World Pageants, Inc. v. Crown Promotions, FA 94321 (Forum Apr. 24, 2000) (finding that punctuation is not significant in determining the similarity of a domain name and mark); see also Morgan Stanley v. Francis Mccarthy / Baltec Marine Llc, FA 1785347 (Forum June 8, 2018) ("The [<morganstonley.com> and <morganstainley.com>] Domain Names are confusingly similar to Complainant's marks, as they fully incorporate the MORGAN STANLEY mark, varying it only by subtle misspellings, omitting a space between the words, and adding the generic top-level domain ("gTLD") '.com.'"). Therefore, the Panel finds that the disputed domain names are confusingly similar to Complainant's mark under Policy ¶ 4(a)(i).

 

According to 1.7 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition ("WIPO Jurisprudential Overview 3.0"): "In specific limited instances, while not a replacement as such for the typical side-by-side comparison, where a panel would benefit from affirmation as to confusing similarity with the complainant's mark, the broader case context such as website content trading off the complainant's reputation, … may support a finding of confusing similarity."

 

Here, Complainant presents evidence showing that the resolving websites contain elements likely intended to make consumers believe that Respondent's sites are somehow affiliated with Complainant. This supports the side-by-side comparison above.

 

Rights or Legitimate Interests

Respondent has not been licensed or authorized by Complainant to use its mark. Respondent is not commonly known by the disputed domain names: under Policy ¶ 4(c)(ii), relevant WHOIS information can be used as evidence to show a respondent is or is not commonly known by the disputed domain name. See Chevron Intellectual Property LLC v. Fred Wallace, FA 1626022 (Forum July 27, 2015) (finding that the respondent was not commonly known by the <chevron-europe.com> domain name under Policy ¶ 4(c)(ii), as the WHOIS information named "Fred Wallace" as registrant of the disputed domain name). Here, the WHOIS information of record identifies the registrants of the domain names as "Eugene Gonzales / Mikhail Haraldson / Serhiienko Maksym / Alexandr Fisunov / Sofia Ramirez / Evgeniya Tolstova". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain names under Policy ¶ 4(c)(ii).

 

The resolving websites purport to 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 name 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

The domain name <luckyones-australia.com> was registered on August 7, 2024, before Complainant acquired rights in its mark.

 

The WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition ("WIPO Jurisprudential Overview 3.1") states under 3.8.2:

 

As an exception to the general proposition described above in 3.8.1 [where a respondent registers a domain name before the complainant's trademark rights accrue, panels will not normally find bad faith on the part of the respondent], in certain limited circumstances where the facts of the case establish that the respondent's intent in registering the domain name was to unfairly capitalize on the complainant's nascent (typically as yet unregistered) trademark rights, panels have been prepared to find that the respondent has acted in bad faith.

 

Such scenarios include registration of a domain name: (i) shortly before or after announcement of a corporate merger, (ii) further to the respondent's insider knowledge (e.g., a former employee), (iii) further to significant media attention (e.g., in connection with a product launch or prominent event), or (iv) following the complainant's filing of a trademark application.

 

Complainant provides evidence showing that that all the disputed domain names, including the <luckyones-australia.com> domain name, were registered further to significant media attention in connection with the launch of Complainant's Lucky Ones services. See the discussion of opportunistic bad faith below.

 

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 purport to 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 and mimic Complainant's legitimate website. 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 the mark prior to Respondent's registration of the disputed domain name and that this constitutes bad faith under Policy ¶ 4(a)(iii).

 

In addition, Respondent displays a pattern of bad faith registration of disputed domain names containing Complainant's LUCKY ONES 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).

 

Finally, on the balance of the evidence before it, the Panel finds that Respondent registered the disputed domain names opportunistically, because it registered them shortly after the public announcement of Complainant's Lucky Ones services. This constitutes bad faith registration and use. See GridPoint, Inc. v. Matt Giovanini, FA 1909399 (Forum Oct. 5, 2020) ("Under Policy ¶ 4(a)(iii), opportunistic bad faith may be demonstrated by a Respondent registering a disputed domain name that integrates a distinct or famous mark, around the time of a certain event that creates interest or value in the disputed domain name."); see also Amazon Technologies, Inc. v. harshit dhingaun, FA 1619696 (Forum June 10, 2015) ("Respondent registered the contested domain names within days after the announcement of Complainant's sponsorship of India Fashion Week, thus demonstrating opportunistic bad faith in the registration and subsequent use of the domains."). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii) on this ground also. 

 

DECISION

The Panel dismisses, without prejudice, the Complaint against the <the-lucky-ones-casino.com>, and <oneslucky.com> domain names.

 

Having established all three elements required under the ICANN Policy for the <casino-luckyones.org>, <luckyones-deutschland.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <luckyones-australia.com>, <luckyoneskasino.com>, and <luckyonescasinonorge.com> domain names, the Panel concludes that relief shall be GRANTED for those domain names.

 

Accordingly, it is Ordered that the <casino-luckyones.org>, <luckyones-deutschland.com>, <luckyones-norway.com>, <luckyoneslogin.com>, <luckyones-australia.com>, <luckyoneskasino.com>, and <luckyonescasinonorge.com> domain names be TRANSFERRED from Respondent to Complainant and that the <the-lucky-ones-casino.com>, and <oneslucky.com> domain names REMAIN WITH Respondent.

 

 

 

Richard Hill, Panelist

Dated: March 3, 2026