DECISION

 

Ninja Holdco, LLC v. li jiang

Claim Number: FA2604002217147

 

PARTIES

Complainant is Ninja Holdco, LLC ("Complainant"), represented by Kelley S. Gordon of Marshall, Gerstein & Borun LLP, Illinois, USA. Respondent is Li Jiang ("Respondent"), China.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <creditninja.co>, registered with Spaceship, Inc.

 

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge has no known conflict in serving as Panelist in this proceeding.

 

Alan L. Limbury, as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on April 21, 2026. Forum received payment on April 21, 2026.

 

On April 22, 2026, Spaceship, Inc. confirmed by email to Forum that the <creditninja.co> 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 April 27, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of May 18, 2026 by which Respondent could file a Response to the Complaint, via email to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@creditninja.co. Also on April 27, 2026, the Written Notice of the Complaint, notifying Respondent of the email 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 May 19, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Alan L. Limbury 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 is a Chicago-based financial services provider which began using its CREDITNINJA service mark in 2018, covering consumer lending services, installment loans, personal loans and lines of credit, and credit counseling services. It owns the domain name <creditninja.com> since December 2017.

 

Respondent's <creditninja.co> domain name is identical or confusingly similar to Complainant's marks.

 

Respondent has no rights or legitimate interests in the <creditninja.co> domain name. Complainant did not authorize Respondent to use Complainant's marks. To date, Respondent has not used the domain name in connection with a bona fide offering of goods or services or any legitimate noncommercial or fair use. Respondent uses the domain name to divert users away from Complainant's legitimate website "www.creditninja.com". The domain name redirects consumers to a parking page where they are confronted with a link farm designed to generate click-through advertising revenue. Respondent is not commonly known by the domain name. Respondent failed to discharge its duty under Policy ¶ 2(b) to select, register, and use a domain name that does not infringe the rights of a third party.

 

The <creditninja.co> domain name was registered and is being used in bad faith. Respondent intentionally attempts to disrupt and compete with Complainant's business. Respondent's adoption of a domain name that wholly incorporates the CREDITNINJA mark to create a likelihood of confusion and divert Internet users to Respondent's pay-per-click website evinces Respondent's registration and use of the <creditninja.co> domain name in bad faith. 

 

B. Respondent

Respondent failed to submit a Response in this proceeding.

 

FINDINGS

Complainant has established all the elements entitling it to relief.

 

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 3.1 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

Complainant has shown that it has rights in the service mark CREDITNINJA, including USPTO Registration No. 5,846,273, registered on August 27, 2019 for "Consumer lending services; Installment loans; Providing personal loans and lines of credit", in International Class 36.

 

The Panel finds Respondent's <creditninja.co> domain name to be identical to Complainant's CREDITNINJA mark, since the inconsequential ".co" country code top-level domain ("ccTLD") may be ignored under this element. See Rollerblade, Inc. v. Chris McCrady, D2000-0429 (WIPO June 25, 2000).

 

Complainant has established this element.

 

Rights or Legitimate Interests

Paragraph 4(c) of the Policy provides that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate Respondent's rights or legitimate interests to a domain name for purposes of Paragraph 4(a)(ii):

 

(i)                      before any notice to Respondent of the dispute, the use by Respondent of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or

 

(ii)                      Respondent (as an individual, business or other organization) has been commonly known by the domain name, even if Respondent has acquired no trademark or service mark rights; or

 

(iii)        Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert customers or to tarnish the trademark or service mark at issue.

 

The <creditninja.co> domain name was registered on April 22, 2023, over three years after the registration of Complainant's CREDITNINJA mark. It resolves to a website displaying pay-per-click links related to applying for and finding personal loans.

 

It is well established that the domain name registrant is responsible for PPC links, whether or not the registrant was aware of them. See Nutramax Laboratories, Inc. v. GRUPO SA Ltd Co / Grupo S.A. Ltd Co., FA 1985605 (Forum March 30, 2022) ("Panels have found that respondents are ultimately responsible for the content of their resolving webpages.").

 

These circumstances, together with Complainant's assertions, are sufficient to constitute a prima facie showing of absence of rights or legitimate interests in respect of the domain name on the part of Respondent. The evidentiary burden therefore shifts to Respondent to show that it does have rights or legitimate interests in the <creditninja.co> domain name. See JUUL Labs, Inc. v. Dryx Emerson / KMF Events LTD, FA 1849706 (Forum July 17, 2019). Respondent has made no attempt to do so.

 

The Panel finds that Respondent has no rights or legitimate interests in respect of the domain name.

 

Complainant has established this element.

 

Registration and Use in Bad Faith

Paragraph 4(a)(iii) of the Policy is expressed in the conjunctive: "the domain name has been registered and is being used in bad faith" and Paragraph 4(b) sets out four illustrative circumstances, which, though not exclusive, shall be evidence of the registration and use of a domain name in bad faith for purposes of paragraph 4(a)(iii), including:

 

(iv)                      by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.

The circumstances set out above in relation to the second element satisfy the Panel that Respondent was fully aware of Complainant, its CREDITNINJA mark and its "www.creditninja.com" website when Respondent registered the <creditninja.co> domain name and that Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent's website, by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent's website and of the services promoted on that website. This demonstrates registration and use in bad faith to attract users for commercial gain under Policy ¶ 4(b)(iv).

 

Complainant has established this element.

 

DECISION

Complainant having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <creditninja.co> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Alan L. Limbury, Panelist

Dated: May 20, 2026.