DECISION

 

X.AI, LLC v. Jason Bloomer

Claim Number: FA2602002203441

 

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 Bloomer ("Respondent"), Arizona, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <grok-pedia.com>, registered with DreamHost, LLC.

 

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.

 

Beatrice Onica Jarka as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on February 3, 2026; Forum received payment on February 3, 2026.

 

On February 4, 2026, DreamHost, LLC confirmed by e-mail to Forum that the <grok-pedia.com> domain name is registered with DreamHost, LLC and that Respondent is the current registrant of the name. DreamHost, LLC has verified that Respondent is bound by the DreamHost, 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 February 5, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 25, 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@grok-pedia.com. Also on February 5, 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 19, 2026.

 

Additional Submissions were received from the Complainant on February 21, 2026, followed on February 25, 2026 by Additional Submissions from the Respondent.

 

Both Additional Submissions do comply with Supplemental Rule 7.

 

On February 20, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Dr. Beatrice Onica Jarka 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

By the Complaint the Complainant contends that:

-       It holds common-law rights in the inherently distinctive GROK mark 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 word wide registrations , which includes Int'l Reg. No. 1799269 for the mark GROK, filed Apr. 22, 2024, registered Apr. 22, 2024 and Israel Reg. No. 375496 for the mark GROK, filed Apr. 22, 2024, registered Jan. 2, 2025.

-       The Disputed Domain Name is confusingly similar to Complainant's GROK marks because it incorporates Complainant's GROK mark in its entirety, only adding a hyphen, the descriptive term "pedia," and the non-distinguishing ".com" gTLD.

-       Respondent uses the Disputed Domain Name to pass itself off as Complainant, purporting to offer competing AI services under the GROK mark, while promoting his own commercial website, <jasonbloomer.com>.

-       Respondent's inclusion of a disclaimer at the bottom of his website—added only after receiving Complainant's takedown request—further confirms that Respondent has no rights or legitimate interests in the Disputed Domain Name, and moreover is insufficient to avoid consumer confusion as to Respondent's affiliation with Complainant.

-       Respondent's offer to sell the Disputed Domain Name to Complainant is further evidence he has no rights or legitimate interests in it.

-       Respondent's use of the Disputed Domain Name to attempt to leverage a business opportunity from Complainant is also evidence that he has no rights or legitimate interests in it.

-       Respondent's use of the Disputed Domain Name to pass himself off as Complainant while promoting his own commercial website, <jasonbloomer.com> meet the grounds for bad faith outlined in the UDRP.

-       The offering to sell the Disputed Domain Name for out-of-pocket costs and the usage of the Disputed Domain Name to leverage a business opportunity from Complainant, offering to transfer the Disputed Domain Name in exchange for a footnote on Complainant's Grokipedia website which would credit the Respondent as the first to implement the AI encyclopedia concept represents further evidence of bad faith.

 

B. Respondent

By its elaborate Response, the Respondent claims bona fide in registration and use of the Disputed Domain Name and mainly asserts that:

-       Complainant has provided no evidence of any trademark registration with the United States Patent and Trademark Office but Complainant rather has attempted unsuccessfully to register the mark with USPTO.

-       The Complainant has provided some international registrations which do not confer rights within the United States where both parties and the registrar are located. 

-       "Grok" is a real English word with an established dictionary definition and a public domain literary term which has been used extensively in computer programming and hacker culture since the 1960s to mean "to understand deeply or completely." predating Complainant's use.

-       Even if Complainant had acquired some common law rights through use, these rights would be narrow and limited, particularly where a  respondent is using the term in its ordinary descriptive sense rather than as a trademark.

-       The combination "grok-pedia" is naturally descriptive: it combines "grok" meaning "to understand deeply" with "pedia" from encyclopedia, creating a term that literally means "encyclopedia of deep understanding" or "repository of knowledge to be deeply understood."

-       Respondent registered <grok-pedia.com> on April 21, 2025, seven days before Complainant registered <grokipedia.com> on April 28, 2025

-       Respondent selected the term "grok-pedia" because it accurately described the website's function: a site dedicated to helping users deeply understand topics through AI-generated encyclopedic content.

-       Respondent's website went live in April 2025 and operated as a free, noncommercial educational resource with no advertising, no products for sale, no subscription fees, no donation mechanisms, and no revenue generation of any kind.

-       Given that Respondent's site initially utilized Complainant's API to generate content, Complainant's systems necessarily had technical visibility into the existence and operation of Respondent's <grok-pedia.com> website through API calls and server requests.

-       On October 2, 2025, two days after Complainant's public announcement, Respondent posted a comment on Elon Musk's announcement offering to collaborate and share the source code for the existing <grok-pedia.com> implementation, stating that the concept had already been built and was operational.

-       Following the cease-and-desist letter sent by Complainant on October 16, 2025, Respondent immediately took steps to address any potential concerns and modified the website language to remove any potentially ambiguous phrasing and added a clear disclaimer stating the site is not affiliated with or endorsed by X.AI LLC.

-       Respondent also offered two reasonable settlement options to resolve the dispute amicably transfer the domain name to Complainant either: (a) at no cost in exchange for a brief historical footnote crediting Respondent as having implemented the AI encyclopedia concept first in April 2025, or (b) for $3,000 to compensate Respondent for development time and costs incurred.

-       The website includes a link to Respondent's professional portfolio at <jasonbloomer.com>, which is standard practice for independent software developers and open-source project creators, which serves multiple legitimate purposes.

-       Complainant has failed to meet the burden of bad faith registration and use as Respondent immediately acted in good faith following receiving Complainant's cease-and-desist letter, as already mentioned above. 

-       Complainant provides no evidence that Respondent has engaged in a pattern of registering domain names incorporating others' trademarks.

-       The timing and circumstances of this dispute raise serious concerns about whether Complainant is using the UDRP process appropriately or is instead attempting to strong-arm a small independent developer out of a legitimately registered domain name.

-       Respondent suggests that Complainant could be found to have committed reverse domain name hijacking, but refrains from formally requesting it.

 

C. Additional Submissions

C1. Complainant's Additional Submissions

 

By its Additional Submissions the Complainant further contends, reiterating its initial arguments that:

-       Complainant provided evidence that it owns common-law rights and international registrations in the GROK mark, which represents prima facie evidence of its exclusive right to use GROK in association with AI-related products.

-       Respondent brazenly targeted Complainant and its GROK-branded AI services specifically from its conception. As early as August 11, 2025, the very first line of Respondent's website read: "I'm Grok, created by xAI, and this is GrokPedia—a living, breathing encyclopedia designed to unleash truth and knowledge across the cosmos. Unlike static wikis, GrokPedia is a dynamic, ever growing repository of factual summaries on any subject, person, place, or thing, all generated by me [i.e.,Grok] and indexed for the world to discover."

-       Respondent's website crosses the line from mere attribution to active promotion for his commercial services at <jasonbloomer.com> which cannot be considered commercial use. At the top of the Domain Name's website in the first line under the second heading, Respondent states: "GrokPedia is the brainchild of Jason A. Bloomer, a software developer dedicated to making knowledge accessible and truthful (check out his work at Jasonbloomer.com)

-       Respondent's offer further shows that he registered the Disputed Domain Name intending to gain Complainant's attention and develop a business relationship.

-       Respondent altered his website only after Complainant sent a demand letter asserting its rights in the GROK trademark. Respondent's claim that his alterations evidence good-faith registration and use are therefore unavailing.

-       In relationship to the Respondent's release of the Disputed Domain Name website before Complainant's "Grokipedia" services were announced, Respondent misreads the cases he cites to support his assertion.

-       Respondent suggests that Complainant could be found to have committed reverse domain name hijacking, but does not meet requirements for such finding.  

 

By its Additional Submissions, the Respondent replies and also reiterates its arguments in the Response that:

-       Respondent could not have targeted in bad faith a specific service that did not yet exist and had never been announced. The TOBAM principle applies: bad faith cannot be imposed retroactively on registration that was not malicious at the time.

-       Respondent did not target the Complainant and its GROK-branded AI services specifically from its conception.

-       The Complainant has no exclusive rights in the term "grok."

-       Respondent's use of "grok-pedia" is inherently descriptive of the website's function as a knowledge repository.

-       Respondent operates a free, non-commercial educational resource using a descriptive public domain term.

-       Respondent's settlement offer came only after Complainant announced competing services and sent legal threats, which is normal dispute resolution, not evidence of registration for purpose of sale.

and requests that the Panel exercise its discretion under Forum Supplemental Rule 7 to disregard both parties' additional submissions.

 

FINDINGS

The Panel finds that the Complainant holds rights in the GROK trademark and the circumstances surrounding the registration and use of the Disputed Domain Name and the Respondent's own submissions rebut his claim of bona fide use and rather support a finding of bad faith registration and use.

 

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.

 

PRELIMINARY ISSUE: ADDITIONAL SUBMISSIONS

Noting that the Additional Submissions from both Complainant and Respondent do not contain relevant supplementary arguments but only reiteration of the arguments already submitted in the Complaint and Response, the Panel chose in its discretion to not consider the Additional Submissions of both parties in its findings.

 

Identical and/or Confusingly Similar

Preliminary, under Policy ¶ 4(a)(i), the Panel notes that, given the global nature of the Internet, Panels do not consider the jurisdiction where a trademark is valid relevant to the analysis of the first element (existence of rights). In this respect, the Respondent's contentions as to existence or non-existence of a valid trademark registration or common law rights in the US jurisdiction stand no relevance under the first element of the Policy, as long as the Complainant has documented its rights by international registrations in the GROK trademark.

 

Moreover, for the purpose of the Policy, the Panel is satisfied that under Policy ¶ 4(a)(i) the analysis of the Disputed Domain Name is performed in connection with Complainant's GROK trademark and not in connection to the Complainant's domain name Grokipedia, as Respondent suggests.

 

Consequently, the Panel finds that the Complainant holds rights in the mark GROK in relationship with AI conversational models and uses it to provide various services.

 

Several Forum UDRP decisions, see X.AI, LLC v. Jason Miller / json chao / jack meng / andy zhang / tengda / sun sun / Yu Robin / hua shisan / Curry Sarkory, FA 2196880; X.AI, LLC v. Muhammad Umar Farooq; FA 2203490 X.AI Corporation and X.AI LLC v. Marlon Omandam, FA 2132914, confirmed the Complainant's trademark rights in GROK. 

 

The Panel considers that the existence of the Complainant's trademark rights in GROK term is an objective matter under UDRP and cannot be rebutted by subjective allegations and interpretations.

 

It is undisputed, that the Disputed Domain Name incorporates the term GROK in its entirety, only adding a hyphen, the descriptive term "pedia," and the non-distinguishing ".com" gTLD.

 

Under Policy ¶ 4(a)(i), adding a gTLD and/or generic terms and/or hyphens is considered insufficient in differentiating a disputed domain name from the mark it incorporates. 

 

Therefore, the Panel finds that the Disputed Domain Name is confusingly similar to Complainant's mark under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests.  See Hanna-Barbera Prods., Inc. v. Entm't Commentaries, FA 741828 (Forum Aug. 18, 2006), see Advanced International Marketing Corporation v. AA-1 Corp, FA 780200 (Forum Nov. 2, 2011) (finding that a complainant must offer some evidence to make its prima facie case and satisfy Policy ¶ 4(a)(ii)); see also Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014).

 

The Complainant asserts that the Respondent uses the Disputed Domain Name to pass itself off as Complainant, purporting to offer competing AI services under the GROK mark, while promoting his own commercial website, <jasonbloomer.com>. The Respondent replies, that following the cease-and-desist letter sent by Complainant on October 16, 2025, it  immediately took steps to address any potential concerns and modified the website language to remove any potentially ambiguous phrasing and added a clear disclaimer stating the site is not affiliated with or endorsed by X.AI LLC, but maintaining the link to Respondent's professional portfolio at <jasonbloomer.com>. Further, Respondent considers that maintaining the link to Respondent's professional portfolio at <jasonbloomer.com> is standard practice for independent software developers and open-source project creators.

 

The Panel notes that the Respondent's inclusion of a disclaimer at the bottom of his website to which the Disputed Domain Name resolves has been accompanied by two settlement options to resolve the dispute amicably transfer the domain name to Complainant either: (a) at no cost in exchange for a brief historical footnote crediting Respondent as having implemented the AI encyclopedia concept first in April 2025, or (b) for $3,000 to compensate Respondent for development time and costs incurred. 

 

In this respect, the Panel considers that it is more likely that the Respondent intentionally registered the Disputed Domain Name which replicates the Complainant's trademark GROK and further associated himself and his business with the Complainant and Complainant's services, by promoting his own commercial website, <jasonbloomer.com>, with the clear target to attract the attention of the Complainant so he can come with a proposal for amicable settlement in which he can capitalise on the Complainant's notoriety and the  Complainant's mark GROK.

 

It is the opinion of the Panel, that despite the fact the Respondent insists to appear completely uninterested in the association with the Complainant and Complainant's trademark, claiming public domain rights for his registration of the Disputed Domain Name, his behaviour at the registration of the Disputed Domain Name and post cease and desist letter sent by the Complainant demonstrates exactly the opposite.

 

By its own submissions the Respondent indicated that the Disputed Domain Name includes the Complainant trademark GROK, and populated the opening of the website resolving to the Disputed Domain Name with specific statements of association with the Complainant and Complainant's Services: "I'm Grok, created by xAI, and this is GrokPedia—a living, breathing encyclopedia designed to unleash truth and knowledge across the cosmos. Unlike static wikis, GrokPedia is a dynamic, ever growing repository of factual summaries on any subject, person, place, or thing, all generated by me [i.e.,Grok] and indexed for the world to discover." 

 

The Panel notes that in a post announcing the Complainant Grokipedia, the Respondent posted a comment on Elon Musk's announcement offering to collaborate and share the source code for the existing <grok-pedia.com> implementation, stating that the concept had already been built and was operational.

 

Moreover the Panel notes that post cease and desist letter the Respondent contacted Joe North, the chief executive of Complainant's operations for Australia and New Zealand, seeking an in-person meeting with him to discuss a possible business relationship between Complainant and himself.

 

Further, the Respondent offered two settlement options to resolve the dispute amicably transfer the domain name to Complainant either: (a) at no cost in exchange for a brief historical footnote crediting Respondent as having implemented the AI encyclopedia concept first in April 2025, or (b) for $3,000 to compensate Respondent for development time and costs incurred.

 

Both options of amicable settlement appear to document the intent of the Respondent to capitalise on the Complainant's notoriety and the Complainant's trademark.  

 

In the opinion of the Panel, all the actions of the Respondent from the registration use and post cease and desist letter received from the Complainant coupled with the promotion of his own commercial website, <jasonbloomer.com> on the website under the Disputed Domain Name replicating the Complainant's trademark GROK cannot constitute a bona fide offering of goods or services or a legitimate non-commercial or fair use of the Domain Name under the UDRP.

 

The Panel considers that the Respondent's inclusion of a disclaimer at the bottom of his website—added only after receiving Complainant's takedown request— corroborated with his multiple actions as indicated above, appears to be more of a business plan to approach a complainant and offer a joint business agreement and denies the very essence of the Respondent's allegations on the non- commercial nature of the website.  See Bayerische Motoren Werke AG v. Stressfree Driving School Pty Ltd / James Vergis, Case No. DAU2017-0002 (WIPO Mar. 13, 2017).

 

Consequently, the Panel is not persuaded by the Respondent's loud claims of bona fide and finds that registering and using a domain name which incorporates the trademak of a notorius Complainant to leverage a business opportunity from Complainant does not legitimise rights and interests in the Disputed Domain Name.

 

Therefore, the Panel finds that the Respondent does not hold rights or legitimate interest in the Disputed Domain Name under Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

Each and all circumstances and actions of the Respondent from registration to the use of the Disputed Domain Name analyzed under Policy ¶ 4(a)(ii), above and found not to support a bona fide claim of the Respondent in respect of the Disputed Domain Name represent as many circumstances and actions supporting bad faith registration and use of the Disputed Domain Name under the Policy ¶ 4(a)(iii). 

 

The Panel does not consider necessary to analyze these circumstances and actions again under this element and finds that the Respondent registered and used the Disputed Domain Name, targeting the Complainant and Complainant's trademark and its notoriety in order to capitalise on them either by getting out of pocket money for the Disputed Domain Name offered to public sale and/or to gain commercial recognition and/or leverage a business opportunity from Complainant.

 

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 <grok-pedia.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Dr. Beatrice Onica Jarka Panelist

Dated: March 5, 2026