DECISION

 

MAJA Holdings, LLC v. Ram Shanmugam

Claim Number: FA2602002206245

 

PARTIES

Complainant is MAJA Holdings, LLC ("Complainant"), represented by Cade Carmichael of MAJA Holdings, LLC, California, USA. Respondent is Ram Shanmugam ("Respondent"), represented by Igor Motsnyi of Motsnyi IP (dba Motsnyi Legal), Serbia.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <armoriq.ai>, registered with GoDaddy.com, 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.

 

Jeffrey J. Neuman as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on February 19, 2026; Forum received payment on February 19, 2026.

 

On February 19, 2026, GoDaddy.com, LLC confirmed by e-mail to Forum that the <armoriq.ai> domain name is registered with GoDaddy.com, LLC and that Respondent is the current registrant of the name. GoDaddy.com, LLC has verified that Respondent is bound by the GoDaddy.com, 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 23, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of March 16, 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@armoriq.ai. Also on February 23, 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 March 10, 2026.

 

On March 11, 2026, pursuant to the Parties' requests to have the dispute decided by a single-member Panel, Forum appointed Jeffrey J. Neuman 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

Complainant contends that it has established rights in the ARMORIQ mark through its registrations with the United Kingdom Intellectual Property Office (UKIPO) and the European Union Intellectual Property Office, as well as through a pending application with the United States Patent and Trademark Office (USPTO). Complainant asserts that it has used the ARMORIQ name in commerce since October 2023 in connection with the sale of personal protective equipment and related products, and that it has further reinforced its rights through its ownership and use of the domain name <armoriq.com>.

Complainant argues that the disputed domain name <armoriq.ai> is identical or confusingly similar to its mark because it incorporates the ARMORIQ mark in its entirety without alteration, differing only by the top level domain. According to Complainant, such use is likely to cause confusion among Internet users, particularly given that both parties operate in what Complainant characterizes broadly as the security sector.

With respect to rights or legitimate interests, Complainant asserts that Respondent has no rights or legitimate interests in the disputed domain name because Respondent was never authorized to use the ARMORIQ mark and is not commonly known by the name. Complainant further contends that Respondent adopted the name after Complainant had already begun using it in commerce and after Complainant had established its online presence. Complainant also argues that Respondent's use of the domain name in connection with a commercial website does not constitute a bona fide offering of goods or services because such use trades on Complainant's mark and creates a likelihood of confusion.

As to bad faith, Complainant contends that Respondent registered the disputed domain name with knowledge of Complainant's prior use and domain name, and that Respondent's use of the identical term in a commercial context demonstrates an intent to capitalize on Complainant's goodwill. Complainant further points to Respondent's alleged failure to respond to multiple attempts at contact, including cease and desist communications, as additional evidence of bad faith. Complainant asserts that Respondent's use of the domain name disrupts its business and creates confusion in the marketplace, particularly given Complainant's stated intention to expand into AI-related security offerings.

B. Respondent

Respondent does not dispute that the disputed domain name is confusingly similar to Complainant's mark for purposes of the first element. However, Respondent contends that Complainant cannot satisfy the second and third elements of the Policy.

Respondent argues that Complainant did not possess any enforceable trademark rights at the time the disputed domain name was registered on August 21, 2024, noting that all of Complainant's trademark filings and registrations occurred in 2025, nearly one year after the domain name registration. Respondent further contends that Complainant has failed to establish any common law rights predating the domain name registration, emphasizing that Complainant has provided no evidence of actual use in commerce sufficient to give rise to such rights.

Respondent asserts that it has rights and legitimate interests in the disputed domain name based on its use in connection with a bona fide offering of services. Respondent explains that it is involved in an AI-related business operating under the name "ArmorIQ AI," which focuses on developing systems for trust, security, and governance in artificial intelligence environments. Respondent states that the name "ArmorIQ" was independently selected as a combination of the concepts of protection and intelligence, and that the domain name was registered for use in connection with this business. Respondent further contends that it has actively developed and operated a website at the disputed domain name, along with related business activities, which demonstrates a bona fide offering of services.

Respondent also emphasizes that the parties operate in entirely different fields. According to Respondent, Complainant is engaged in the manufacture and sale of physical protective equipment, whereas Respondent provides software and technology services related to artificial intelligence. Respondent contends that there is no overlap between the parties' goods and services and no plausible basis for confusion.

With respect to bad faith, Respondent argues that it did not and could not have registered the domain name in bad faith because Complainant had no trademark rights at the time of registration. Respondent further contends that there is no evidence that it targeted Complainant or sought to take advantage of Complainant's alleged mark. Respondent asserts that its conduct falls outside the scope of the Policy, which is intended to address clear cases of abusive domain name registration and not disputes between parties with competing or unrelated business interests.

Respondent further argues that to the extent Complainant is asserting trademark infringement or likelihood of confusion, such claims exceed the limited scope of the UDRP. As prior panels have held, the UDRP is not designed to adjudicate complex trademark disputes or resolve competing rights between parties, and such matters are more appropriately addressed in courts of competent jurisdiction.

Finally, Respondent requests a finding of Reverse Domain Name Hijacking, asserting that Complainant knew or should have known that it could not succeed under the Policy given the timing of the domain name registration, the absence of prior trademark rights, and the clear evidence of Respondent's bona fide use. Respondent contends that the Complaint is based largely on conclusory allegations without supporting evidence and represents an improper attempt to obtain the domain name through the UDRP rather than through appropriate legal channels.

FINDINGS

The Panel finds that:

 

1.       Complainant has established rights in the ARMORIQ mark through its trademark registrations.

2.       The disputed domain name <armoriq.ai> was registered on August 21, 2024.

3.       Complainant's trademark applications and registrations post-date the registration of the disputed domain name, and Complainant has not established earlier common law rights.

4.       The disputed domain name resolves to a website offering AI-related services distinct from Complainant's goods.

5.       Respondent has demonstrated use of the domain name in connection with a bona fide offering of services.

6.       The parties operate in different fields, with no clear competitive overlap.

7.       The Panel finds no evidence that Respondent registered the domain name in bad faith or targeted Complainant.

8.       Complainant failed to meaningfully address the timing of the domain name registration or Respondent's asserted legitimate 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.

 

Identical and/or Confusingly Similar

The first element under the Policy is essentially a standing requirement. Where the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case. See WIPO Overview of WIPO Panel View on Select UDRP Questions ("WIPO Overview 3.1"), Section 1.2.1.

Complainant claims rights in the ARMORIQ mark through its registrations with the United Kingdom Intellectual Property Office (No. UK00004226567; effective as of 30 June 2025) and the European Union Intellectual Property Office (No. 019210090, registered on November 6, 2025). Registration of a mark with a recognized trademark authority is generally sufficient to establish rights in a mark under Policy ¶ 4(a)(i). See DIRECTV, LLC v. The Pearline Group, FA 1818749 (Forum Dec. 30, 2018); see also (finding that registration with a national trademark authority is sufficient to establish rights under the Policy).

Complainant also contends that the disputed domain name <armoriq.ai> is identical or confusingly similar to its mark. The Panel agrees. The disputed domain name incorporates the ARMORIQ mark in its entirety. The only difference between the domain name and the mark is the addition of the ".ai" generic top-level domain.

Panels have consistently held that the addition of a generic top-level domain is insufficient to distinguish a domain name from a complainant's mark. See The Toronto-Dominion Bank v. George Whitehead, FA 1784412 (Forum June 11, 2018); see also (finding that the addition of a top level domain does not distinguish a domain name from the mark incorporated therein).

Accordingly, the Panel finds that the disputed domain name is identical or confusingly similar to a mark in which Complainant has rights under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Under Policy ¶ 4(a)(ii), Complainant must first make a prima facie showing that Respondent lacks rights or legitimate interests in the disputed domain name. Once such a showing is made, the burden shifts to Respondent to demonstrate rights or legitimate interests. See Advanced International Marketing Corp. v. AA-1 Corp., FA 780200 (Forum Nov. 2, 2011); see also Neal & Massey Holdings Ltd. v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014).

The Panel finds that even if Complainant has made a prima facie case, Respondent has rebutted that showing.

Complainant contends that Respondent lacks rights or legitimate interests in the disputed domain name because Respondent was not authorized to use the ARMORIQ mark, is not commonly known by the domain name, and is using the domain name in a manner that allegedly creates confusion with Complainant's mark. Complainant further argues that Respondent adopted the domain name after Complainant began using the ARMORIQ name and that Respondent's use is therefore not bona fide.

The Panel finds that Complainant's arguments are not persuasive.

While lack of authorization and the absence of evidence that a respondent is commonly known by a domain name may support a prima facie showing, those factors are not dispositive where the record demonstrates that Respondent is using the domain name in connection with a bona fide offering of goods or services.

Here, Respondent has provided evidence that it is using the disputed domain name in connection with an active business focused on artificial intelligence systems designed to enhance security, trust, and governance of AI agents. The record reflects that Respondent operates a website at the disputed domain name that describes its services, identifies individuals involved in the business, and presents a developed business concept.  This is further supported by Respondent's active online presence, including social media accounts associated with the disputed domain name.

The Panel finds that this constitutes a bona fide offering of services under Policy ¶ 4(c)(i). There is no evidence that Respondent's use is pretextual or that it is attempting to pass itself off as Complainant. Rather, the content of Respondent's website is directed toward a distinct field of activity.

The Panel also finds persuasive Respondent's explanation for its selection of the term "ArmorIQ," which combines concepts of protection and intelligence in the context of artificial intelligence. The Panel further notes that the term "ArmorIQ" is composed of common elements suggestive of protection and intelligence, and its adoption by Respondent is consistent with its stated AI-focused services rather than indicative of targeting Complainant.

Importantly, the Panel notes that the disputed domain name was registered on August 21, 2024, prior to Complainant's trademark filings and registrations. While Complainant asserts earlier use, it has failed to provide sufficient evidence to establish common law rights predating Respondent's registration. The only evidence provided is a fictitious business name filing, which, standing alone, is insufficient to establish trademark rights.

As reflected in the WIPO Overview 3.0, Section 1.3, a complainant must provide evidence demonstrating that a mark has become a distinctive identifier associated with its goods or services, such as evidence of use, sales, advertising, and consumer recognition. Complainant has provided none of this evidence. Accordingly, the Panel cannot conclude that Complainant possessed common law rights in the ARMORIQ mark prior to Respondent's registration of the disputed domain name.

Panels have consistently held that where a domain name is registered prior to the accrual of trademark rights, such timing weighs heavily in favor of a finding of rights or legitimate interests.

The Panel further finds that the parties operate in different fields. Complainant is engaged in the manufacture and sale of physical protective equipment, while Respondent provides technology services related to artificial intelligence. Complainant's speculative assertions regarding possible future expansion into AI-related services are insufficient to negate Respondent's present legitimate use.

To the extent Complainant's arguments sound in trademark infringement or likelihood of confusion, those claims exceed the limited scope of the Policy. As this Panel has previously recognized, including in Swisher International, Inc. v. Hempire State Smoke Shop, FA 1952939 (Forum July 27, 2021), the Policy is not designed to adjudicate disputes between parties who may each have a legitimate interest in a term.

As in that case, the present dispute raises issues that go beyond the narrow confines of the Policy and instead implicate more complex trademark questions better suited for courts of competent jurisdiction. As noted in that decision, "the Policy's purpose is to combat abusive domain name registrations and not provide a prescriptive code for resolving more complex trademark disputes," quoting Luvilon Industries NV v. Top Serve Tennis Pty Ltd, DAU2005-0004 (WIPO Sept. 6, 2005). See also Courtney Love v. Brooke Barnett, FA 944826 (Forum May 14, 2007) (stating that the Policy is not intended to resolve disputes between parties who might each have legitimate rights in a domain name, but rather to address a narrow category of abusive registrations).

Moreover, as recognized in Hempire State, the limited evidentiary framework of the UDRP makes it ill-suited to resolve disputes involving competing factual narratives or nuanced trademark issues. Such matters are more appropriately addressed through judicial proceedings where the parties have access to discovery and other procedural safeguards.

Accordingly, the Panel finds that Respondent has demonstrated rights or legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii).

Registration and Use in Bad Faith

Given that Complainant has failed to establish the second element of the Policy, there is no need to evaluate the third element, namely, whether the domain name was registered and used in bad faith. However, because Respondent has alleged that Complainant has engaged in Reverse Domain Name Hijacking ("RDNH"), the Panel will address the issue of bad faith in that context. The Panel finds that Complainant has failed to establish that the disputed domain name was registered and is being used in bad faith.

A fundamental issue in this case is timing. The disputed domain name was registered prior to Complainant's trademark filings and registrations. Panels have consistently held that where a domain name is registered before a complainant acquires trademark rights, a finding of bad faith is generally not appropriate absent evidence that the respondent was targeting nascent rights or otherwise acting with knowledge of and intent to exploit the complainant's mark.

Here, Complainant has failed to provide sufficient evidence of common law rights that predate the registration of the disputed domain name. Nor has Complainant provided evidence that Respondent had knowledge of Complainant or its alleged mark at the time of registration.  Archived evidence of Complainant's website provided by the Respondent indicates that it was in a limited or pre-launch state in 2024, further undermining any claim of established common law rights at the time of Respondent's registration.

The record instead supports Respondent's position that the domain name was selected for its own independent business purposes related to artificial intelligence. The Panel finds no evidence that Respondent has attempted to sell the domain name to Complainant, disrupt Complainant's business, or otherwise engage in conduct falling within Policy ¶ 4(b).

Moreover, the Panel finds that Respondent's use of the domain name in connection with a bona fide business offering is inconsistent with a finding of bad faith. The content of the website associated with the domain name reflects a legitimate business that is distinct from Complainant's activities.

To the extent Complainant asserts that Respondent's conduct constitutes trademark infringement or creates confusion, such claims are beyond the limited scope of the Policy. As prior Forum panels have recognized, the Policy is not designed to resolve disputes where both parties may have legitimate rights or where the dispute turns on questions of trademark infringement better suited for judicial determination.

Accordingly, the Panel finds that Complainant has failed to establish bad faith registration and use under Policy ¶ 4(a)(iii).

 

REVERSE DOMAIN NAME HIJACKING

Reverse Domain Name Hijacking is defined under the Rules as using the Policy in bad faith to attempt to deprive a registered domain name holder of a domain name.

The Panel has carefully considered whether such circumstances are present in this case.

As this Panel has previously held, including in Electrosoft Services, Inc. v. TechOps / Domain Admin, FA 1969515 (Forum Dec. 9, 2021), a finding of Reverse Domain Name Hijacking may be appropriate where a complainant knew or should have known that it could not succeed under any fair interpretation of the facts.

Here, the record reflects that the disputed domain name was registered prior to Complainant's trademark filings and registrations. This timing issue presents a significant weakness in Complainant's case and one that Complainant either knew or should have known at the time it filed the Complaint. Complainant has also failed to provide evidence of common law rights predating the domain name registration.

In addition, the evidence demonstrates that Respondent is using the disputed domain name in connection with a bona fide business offering that is distinct from Complainant's goods and services. This is not a case involving passive holding, impersonation, or other indicia typically associated with cybersquatting. Rather, it is a dispute between parties operating in different fields who each assert some interest in a similar term.

Despite these circumstances, Complainant proceeded with a Complaint that does not meaningfully address the timing issue or Respondent's asserted legitimate use.

As panels have repeatedly held, including in Swisher International, Inc. v. Hempire State Smoke Shop, FA 1952939 (Forum July 27, 2021), the Policy is not a substitute for trademark litigation and should not be invoked where the dispute falls outside its limited scope.

Under these circumstances, the Panel finds that Complainant should have recognized that this dispute, involving competing claims and a plausible good faith use, was not well suited for resolution under the Policy.

On balance, the Panel concludes that Complainant's use of the Policy in this instance supports a finding of Reverse Domain Name Hijacking.

DECISION

Having not established all three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.

 

Accordingly, it is Ordered that the <armoriq.ai> domain name REMAIN WITH Respondent.

 

 

 

Jeffrey J. Neuman, Panelist

Dated: March 25, 2026