DECISION

 

X.AI, LLC v. Muhammad Umar Farooq

Claim Number: FA2602002203490

 

PARTIES

Complainant is X.AI, LLC ("Complainant"), represented by Jonathan Uffelman of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, District of Columbia, USA. Respondent is Muhammad Umar Farooq ("Respondent"), Pakistan.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <grokipedias.com>, registered with Spaceship, Inc.

 

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 February 4, 2026; Forum received payment on February 4, 2026.

 

On February 5, 2026, Spaceship, Inc. confirmed by e-mail to Forum that the <grokipedias.com> domain name is registered with Spaceship, Inc. and that Respondent is the current registrant of the name. Spaceship, Inc. has verified that Respondent is bound by the Spaceship, Inc. 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 6, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 26, 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@grokipedias.com. Also on February 6, 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 formal response from Respondent, Forum transmitted to the parties a Notification of Respondent Default. Respondent did however sent an email to Forum, see below.

 

On February 27, 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 name be transferred from Respondent to Complainant.

 

PARTIES' CONTENTIONS

A. Complainant

Complainant states that, led by its CEO and world-renowned entrepreneur Elon Musk, it is focused on building artificial intelligence products and services to accelerate human scientific discovery. On November 3, 2023, Complainant announced the early release of Grok, a conversational AI model with a bit of wit and humor. Complainant's announcement gained immediate and widespread media attention. Third-party coverage of Grok's release included articles by the Financial Times, Fox Business, WIRED, and The Guardian. By December 2023, when Complainant made the Grok system available to users subscribed to X Premium+, Complainant had already raised nearly $135 million from investors. With its access to, and promotion on, the X (formerly Twitter) platform, the Grok system instantly reached countless users around the world. Following the overwhelming success of the Grok system, on August 13, 2024, Complainant announced the beta release of its Grok 2 system. Following the release of Grok 3 in February 2025, traffic to the Grok platform surged by 436%, with Complainant's platform recording 25.82 million unique monthly visits. Since then, the Grok platform receives over 21 million visits every month, including another surge to 29.6 million monthly visits following the release of Grok 4. The Grok platform has millions of active monthly users in the United States, India, Brazil, and Germany alone, as well as millions of other users all around the world. On September 30, 2025, Elon Musk announced that Complainant was creating "Grokipedia," an AI-generated online encyclopedia, to compete against Wikipedia. The <grokipedia.com> domain name was registered on April 28, 2025 and has been used for Complainant's official Grokipedia website since at least as early as October 27, 2025. Complainant asserts rights in the mark GROK through its international registration in 2024.

 

Complainant alleges that the disputed domain name is confusingly similar to its GROK trademark because it incorporates the mark in its entirety and merely adds the term "ipedias", together with the ".com" generic top-level domain ("gTLD") ".com". Complainant cites UDRP precedents to support its position.

 

According to Complainant, Respondent lacks rights or legitimate interests in the disputed domain name as Respondent is not commonly known by the disputed domain name, nor did Complainant authorize it to use its mark in any way. Respondent fails to make a bona fide offering of goods or services or legitimate noncommercial or fair use in connection with the disputed domain name. Instead, Respondent uses the disputed domain name to install malicious malware on users' computers by redirecting them to a variety of websites that result in a security warning coupled with an offer to perform a security scan of the uses' computers. Users who visit the resolving website are initially greeted by a webpage that passes itself off as Complainant's, displaying "Grokipedia The Encyclopedia for Curious Minds" prominently in the center of the page. The website almost immediately redirects users to a new webpage at <credovian.co.in> or <monatrix.co.in> (among others), that asks users to confirm they are not a robot. If users click the buttons, the website redirects them to yet another webpage at <datafortifier.com> or <echonetfusion.com> that displays a McAfee safety warning and offers a button for the user to click that purports to run a "quick scan." The disputed domain name is on sale for $110,000.00. Complainant cites UDRP precedents to support its position.

 

Further, says Complainant, Respondent registered and uses the disputed domain name in bad faith as Respondent attempts to impersonate Complainant. The resolving website attempts to install malware. Respondent offered the disputed domain name for sale for a price in excess of out-of-pocket costs. Respondent had actual knowledge of Complainant's mark. Respondent has engaged in opportunistic registration. Respondent engaged in typosquatting. Respondent used a privacy service. Complainant cites UDRP precedents to support its position.

 

B. Respondent

Respondent failed to submit a formal Response in this proceeding.  It its email to Forum Respondent states, in pertinent part:

 

In the interest of resolving this matter efficiently and avoiding further proceedings, I am willing to voluntarily transfer the disputed domain name to X.AI, LLC upon receipt of a good-faith settlement payment of USD 20,000.

 

If this proposal is acceptable to the Complainant, I am prepared to cooperate fully and complete the transfer promptly through the registrar.

 

FINDINGS

Complainant owns the mark GROK and uses it to provide various services, including the online encyclopedia Grokipedia, announced on 30 September 2025.

 

Complainant's rights in its mark date back to 2024.

 

The disputed domain name was registered on October 1, 2025.

 

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

 

The resolving website attempts to impersonate Complainant, displaying Complainant's mark and prominently displaying the text: "Grokipedia The Encyclopedia for Curious Minds". The resolving website attempts to download malware on users' computers. Respondent offered the disputed domain name for sale for a price in excess of out-of-pocket costs. 

 

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 disputed domain name incorporates Complainant's GROK mark in its entirety, merely adding the term "ipedias", together with the ".com" generic top-level domain ("gTLDs"). Under Policy ¶ 4(a)(i), adding a gTLD and/or generic terms is 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 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."). 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

Complainant has not licensed or otherwise authorized Respondent to use its mark. Respondent is not commonly known by the disputed domain name: under Policy ¶ 4(c)(ii), WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name. See Amazon Technologies, Inc. v. LY Ta, FA 1789106 (Forum June 21, 2018) (concluding a respondent has no rights or legitimate interests in a disputed domain name where the complainant asserted it did not authorize the respondent to use the mark, and the relevant WHOIS information indicated the respondent is not commonly known by the domain name). Here, the WHOIS information for the disputed domain name lists the registrant as "Robert Jake". Therefore, the Panel finds that Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii).

 

Respondent attempts to confuse internet users into thinking that Respondent is associated with Complainant: the resolving website displays Complainant's mark and images of Complainant's products. Use of a disputed domain name to create a false impression that a respondent is associated or affiliated with a complainant is not a bona fide offering of goods or services or legitimate noncommercial or fair use per Policy ¶ 4(c)(i) or (iii). Indeed, according to paragraph 2.5 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (WIPO Jurisprudential Overview 3.1): "Fundamentally, a respondent's use of a domain name will not be considered 'fair' if it falsely suggests affiliation with the trademark owner …". See 201 Folsom Option JV, L.P. and 201 Folsom Acquisition, L.P. v. John Kirkpatrick, D2014-1359 (WIPO Oct. 28, 2014); see also Ripple Labs Inc. v. Jessie McKoy / Ripple Reserve Fund, FA 1790949 (Forum July 9, 2018) (finding the respondent did not use the domain name to make a bona fide offering of goods or services per Policy ¶ 4(c)(i) or for a legitimate noncommercial or fair use per Policy ¶ 4(c)(iii) where the website resolving from the disputed domain name featured the complainant's mark and various photographs related to the complainant's business). Therefore, the Panel finds that Respondent has failed to use the disputed domain name to make a bona fide offering of goods or services or legitimate noncommercial or fair use per Policy ¶ 4(c)(i) or (iii).

 

Further, Complainant provides evidence showing that the resolving website is used to attempt to install malware on users' computers. Under Policy ¶¶ 4(c)(i) and (iii), using a disputed domain name to install malware on users' devices is not a bona fide offering of goods or services, nor a legitimate noncommercial or fair use. See Coachella Music Festival, LLC v. Carolina Rodrigues / Fundacion Comercio Electronico, FA 1785199 (Forum June 5, 2018) ("Respondent uses the <coechella.com> domain name to direct internet users to a website which is used to attempt to install malware on visiting devices. Using the domain name in this manner is neither a bona fide offering of goods or services under Policy ¶4(c)(i), nor a non-commercial or fair use under Policy ¶4(c)(iii)."). Thus the Panel finds, on this ground also, 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).

 

In addition, Respondent has offered to sell the disputed domain name for an amount in excess of out of pocket costs. This does not constitute a bona fide offering of goods or services pursuant to Policy ¶ 4(c)(i) and it is not a legitimate noncommercial or fair use of the domain name pursuant to Policy ¶ 4(c)(iii). See Hewlett-Packard Co. v. High Performance Networks, Inc., FA 95083 (Forum July 31, 2000) (finding no rights or legitimate interests where the respondent registered the domain name with the intention of selling its rights); see also Reese v. Morgan, FA 917029 (Forum Apr. 5, 2007) (finding that the respondent's willingness to sell a contested domain name for more than its out-of-pocket costs provided additional evidence that Respondent had no rights or legitimate interests in the contested domain name). Thus the Panel finds, on this ground also, 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).

 

For all the above reasons, the Panel finds that Respondent does not have rights or legitimate interests in the disputed domain name.

 

Registration and Use in Bad Faith

Respondent has not presented any plausible explanation for its use of Complainant's mark. The Panel finds that Respondent did not have a legitimate use in mind when registering the disputed domain name.

 

Indeed, as already noted, consumers visiting the resolving website are likely to be confused as to whether Respondent and/or its website are affiliated in some way with Complainant; and/or the disputed domain name or the associated website is endorsed, authorized, or sponsored by Complainant, none of which are true. This is a form of bad faith use of the disputed domain name. See Bank of America Corp. v. Out Island Props., Inc., FA 154531 (Forum June 3, 2003) (bad faith established "[s]ince the disputed domain names contain entire versions of Complainant's marks and are used for something completely unrelated to their descriptive quality, a consumer searching for Complainant would become confused as to Complainant's affiliation with the resulting search engine website."). Thus the Panel finds bad faith registration and use under Policy ¶ 4(a)(iii).

 

Further, also as already noted, Respondent is attempting to pass itself off as Complainant in order to install malware. This behavior is evidence of bad faith registration and use under Policy ¶ 4(b)(iii). See Capital One Fin. Corp. v. Roben Houspian Singerdi, FA 1668125 (Forum Apr. 26, 2016) (finding bad faith where [r]espondent's confusingly similar domain name directs internet visitors to a website which attempts to infect such visitors with a ransomware variant of malware); see also eNom, Incorporated v. Muhammad Enoms General delivery / Enoms.com has been registered just few days after Enom.com, therefore could not have been regstere, FA 1621663 (Forum July 2, 2015) ("In addition, Respondent has used the disputed domain name to install malware on Internet users' devices.  The Panel finds that this is bad faith under Policy ¶ 4(a)(iii)."). Therefore the Panel finds that Respondent registered and uses the disputed domain name in bad faith under Policy ¶ 4(a)(iii) on this ground also.

 

In addition, Respondent offers to sell the disputed domain name at a price in excess of out-of-pocket costs. This can evince bad faith registration and use under Policy ¶ 4(b)(i). See Staples, Inc. v. lin yanxiao, FA 1617686 (Forum June 4, 2015) ("Respondent's offering to sell the disputed domain name to a third party (in this case, the general public) supports a finding of bad faith registration and use."); see also Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Forum Sept. 30, 2003) ("Respondent's general offer of the disputed domain name registration for sale establishes that the domain name was registered in bad faith under Policy ¶ 4(b)(i)."); see also Am. Anti-Vivisection Soc'y v. "Infa dot Net" Web Serv., FA 95685 (Forum Nov. 6, 2000) (finding that "general offers to sell the domain name, even if no certain price is demanded, are evidence of bad faith"); see also George Weston Bakeries Inc. v. McBroom, FA 933276 (Forum Apr. 25, 2007) (concluding that the respondent registered and was using the< gwbakeries.mobi> domain name in bad faith according to Policy ¶ 4(b)(i) where it offered it for sale for far more than its estimated out-of-pocket costs it incurred in initially registering the disputed domain name). Thus the Panel finds that Respondent registered and uses the disputed domain name in bad faith under Policy ¶ 4(b)(i).

 

In addition, the Panel finds that Respondent registered the disputed domain name opportunistically, because it registered the disputed domain name shortly after the public announcement of Complainant's Grokipedia. 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. 

 

Finally, Respondent registered the disputed domain name with actual knowledge of Complainant's mark: the resolving website displays Complainant's mark and prominently displaying the text: "Grokipedia The Encyclopedia for Curious Minds". 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 registration and use under Policy ¶ 4(a)(iii).

 

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

 

 

 

Richard Hill, Panelist

Dated: February 27, 2026