DECISION

 

Aderant North America, Inc. v. Sasan Aghdasi

Claim Number: FA2605002222727

 

PARTIES

Complainant is Aderant North America, Inc. ("Complainant"), represented by Nicole K. McLaughlin of Duane Morris, LLP, Pennsylvania, USA. Respondent is Sasan Aghdasi ("Respondent"), represented by John Berryhill, Pennsylvania, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <maddi.ai>, registered with Dynadot 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.

 

Nick J. Gardner, Professor David E. Sorkin and Eugene I. Low as Panelists, with Eugene I. Low as Chair.

 

PROCEDURAL HISTORY

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

 

On May 23, 2026, Dynadot Inc confirmed by e-mail to Forum that the <maddi.ai> domain name is registered with Dynadot Inc and that Respondent is the current registrant of the name. Dynadot Inc has verified that Respondent is bound by the Dynadot 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 May 26, 2026, Forum served a Deficiency Letter on Complainant, requesting it to amend the Complaint to properly identify Respondent and its contact information in accordance with the Registrar's email verification. On May 27, 2026, Complainant filed an amended Complaint accordingly.

 

On May 27, 2026, Forum served the Complaint (as amended) and all Annexes, including a Written Notice of the Complaint, setting a deadline of June 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@maddi.ai. Also on May 27, 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 June 26, 2026.

 

On July 7, 2026, pursuant to Respondent's request to have the dispute decided by a three-member Panel, Forum appointed Nick J. Gardner, Professor David E. Sorkin and Eugene I. Low as Panelists, with Eugene I. Low as Chair.

 

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

The parties' key contentions are summarized and extracted below. For simplicity, the Panel has not reproduced here all citations of cases, decisions and rules referred to by the parties in their respective submissions, but for the avoidance of doubt the Panel has considered the parties' submissions in full.

 

A. Complainant

Aderant North America, Inc. ("Aderant") is the owner of the MADDI trademark and trade name has continuously used the MADDI mark and name in commerce since at least as early as June 21, 2023. Aderant is the owner of U.S. Trademark Office Registration No. 7380655 for the mark MADDI which registered on May 7, 2024. Complainant also has a registration in Canada for the mark MADDI (TMA1379911) and in the U.K. for the mark MADDI (Reg 3915482) (collectively Aderant's registrations are referred to as the "MADDI Mark"). The MADDI Mark is registered and used in connection with an AI platform for supporting law firm activities including billing compliance, bill delivery, docketing, financial management, outside counsel guideline compliance, people management, and time entry.

 

A1. The Domain Name Is Confusingly Similar to Complainant's MADDI Mark 

The Domain Name is identical to, and thus confusingly similar to Complainant's MADDI Mark. The Domain Name incorporates Complainant's MADDI Mark in its entirety and differs from the MADDI Mark only in that it adds the generic top-level domain (gTLD), ".ai" to the end of the mark. The addition of the ".ai" gTLD is irrelevant under the Policy and has no effect for the purposes of determining whether the domain name is identical or confusingly similar to Complainant's trademark. Respondent's addition of the "ai" top-level domain adds to confusing similarity in this case, because Complainant's services utilize artificial intelligence. As such, appending the gTLD ".ai" to Complainant's MADDI Mark cannot overcome the confusing similarity between the Domain Name and the mark.

 

Respondent's domain name is likely to cause confusion for the purposes of Policy ¶ 4(a)(i), and is therefore, infringing upon Complainant's registered MADDI Mark.

 

A2. Respondent Has No Rights or Legitimate Interests in the Domain Name

Respondent has no legitimate right or interest in the Domain Name. Respondent is not connected or affiliated with Complainant and has not received a license or consent, express or implied, to use the MADDI Mark in the Domain Name or in any other manner. Respondent reserved and registered <maddi.ai> without Complainant's permission. Complainant does not sponsor or endorse the Respondent in any manner. Under Policy ¶ 4(a)(ii), the mere statement that the Respondent is not licensed or otherwise authorized to use the Domain Name constitutes prima facie proof for the Complainant that Respondent has no legitimate rights

or interests in the Domain Name. 

 

Furthermore, Respondent is not commonly known by the disputed Domain Name, nor could it be. The WHOIS listing does not identify Respondent's identity. The Panel has previously found that the combination of WHOIS information, along with the absence of other affirmative evidence indicating a connection between Respondent and the Domain Name, reveals that Respondent is not commonly known by the Domain Name and consequently has no rights and legitimate interests pursuant to Policy ¶ 4(c)(ii).

 

Respondent does not hold any legitimate interest in the Domain Name, which was registered with notice of the Complainant's registered MADDI Mark. Complainant's MADDI Mark had acquired a positive reputation and goodwill as a result of nearly three (3) years of use, and advertisements and promotion of its AI platform for supporting law firm activities and related services. Complainant's federal registration for the MADDI Mark puts Respondent on constructive notice of the existence of the MADDI Mark. One who has constructive knowledge of the trademark, acquires a confusingly similar domain name, has no rights or legitimate interests in the domain name.

 

Additionally, Respondent is not using the Domain Name in connection with a bona fide offering of goods or services. The Domain Name does not currently host any content or an active website.

 

A3. The Domain Name Was Registered and Used in Bad Faith 

It is unlikely that Respondent can provide any explanation for the selection or intended use of the Domain Name. Under the circumstances, it is reasonable to infer that the Domain Name was registered and is being used to create and exploit confusion with Complainant's MADDI Mark for commercial gain, perhaps in an attempt to sell the Domain Name to Complainant or a competitor.

 

The Respondent's intent is illustrated precisely by the Domain Name being offered for sale for the price of nearly $35,000.

 

(i) Respondent inactively holds a confusingly similar Domain Name

 

Respondent's Domain Name does not display any content or an active website. Inactively holding a domain name is generally considered evidence of bad faith under Policy ¶ 4(a)(iii). From the inception of the UDRP, panelists have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. The factors that are typically considered when determining bad faith under the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant's mark; (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use; (iii) the respondent's concealment of its identity or its use of false contact details; and (iv) the implausibility of any good faith use to which the domain name may be put.

 

Respondent was registered in bad faith because Respondent intended to use it to create and exploit confusion with Complainant's well-known mark, most likely either by attempting to force a sale of the Domain Name to Complainant or by using it to attract Internet users seeking Complainant. Here, Complainant's MADDI Mark has a high degree of reputation in the AI assistant platform community. At the time Respondent registered the Domain Name on January 15, 2026, Complainant was enjoying widespread unsolicited media coverage regarding its AI platform. Complainant's nearly three years of use of its MADDI Mark in connection with the highest quality services, means that the MADDI Mark has achieved a high degree of reputation. Additionally, as discussed further below, Respondent is concealing its identity by way of a proxy service. Further, it is implausible that the Domain Name <maddi.ai> could be used in any way that would constitute good faith. Given the high degree of reputation of the MADDI Mark, lack of legitimate use of the Domain Name, Respondent concealing its identity by way of a proxy service, and the implausibility of any good faith use of the Domain Name, it may be assumed that the use and registration of this domain name could only be for the purposes of selling it for profit to Complainant or to Complainant's competitors.

 

2. Respondent's primary purpose is to sell the Doman Name to the

trademark owner or a competitor

 

The evidence suggests that the Respondent has acted in bad faith, where its primary intent was to sell the Domain Name to the trademark owner or one of its competitors for a price in excess of out-of-pocket expenses related to the name. Here, the Domain Name is currently parked, courtesy of godaddy.com with an offer to sell: "The domain name maddi.ai is for sale," accompanied by a listing price of $34,888.

 

3. Respondent has attempted to hide its true identity

 

Respondent used a privacy registration service to register the Domain Name incorporating Complainant's registered MADDI Mark. Respondent's attempt to hide its true identity further demonstrates bad faith. When a person or entity uses false contact information while registering a domain name, such deception constitutes bad faith under the Policy. Respondent does not provide its true contact information, instead masking this information by providing the proxy service's information.

 

Respondent has not made any bona fide use of the domain name and instead has sought to sell it for nearly $35,000, an amount that bears no relationship to registration or maintenance costs and reflects an attempt to capitalize on the trademark value of Complainant's MADDI Mark. Panels routinely find bad faith where a respondent's sole or primary use of a disputed domain name is to offer it for sale at an exorbitant price. Respondent's demand for nearly $35,000 confirms that the disputed domain name is being offered for its trademark value rather than any descriptive or independent meaning. Prior panels have consistently rejected the arguments that transparency or the mere act of listing a domain name for sale negates bad faith.

 

Accordingly, Respondent's conduct squarely falls within Policy ¶ 4(b)(i) and supports a finding that the disputed Domain Name was registered and is being used in bad faith.

 

4. Respondent had actual or constructive knowledge of Complainant's mark at the time of registering the Domain Name

 

Respondent's bad faith is evidenced by Complainant's prior use and registration of the MADDI Mark. Complainant has used the MADDI Mark in commerce in connection with its services since at least as early as June 21, 2023. The trademark registration for MADDI (Reg. No. 7380655) was filed in May of 2023 and issued in May of 2024. As such, Complainant is entitled to the presumption of ownership, validity and the exclusive right to use its mark in connection with the services identified in its trademark registration.

 

Respondent's registration of the Domain Name displays a finding of bad faith, where the federal registration of the MADDI Mark predates the Respondent's adoption of the "MADDI" term. As a matter of the United States trademark law, it must therefore be presumed that Respondent was on notice of Complainant's rights in the MADDI Mark prior to registering the Domain Name. The Panel has consistently recognized that bad faith registration exists where the Respondent knew of Complainant's mark because the Respondent was a competitor of the Complainant. Further, if a complainant's mark has achieved notoriety, actual notice may be imputed. Respondent's awareness of Complainant's services and the MADDI Mark is evident from Respondent's intentional use of the MADDI Mark in its entirety in the Domain Name. Thus, Respondent is charged with actual and constructive knowledge of Complainant's rights in the MADDI Mark by virtue of Complainant's offerings, trademark registrations in multiple jurisdictions, and Complainant's notoriety. The Respondent's actions of registering a Domain Name that includes the entirety of the Complainant's trademark,

while charged with constructive notice of the Complainant rights in the MADDI Mark, can only support a finding of bad faith.

 

B. Respondent

I. Introduction

This Proceeding involves a feminine personal name, and surname, which is non-distinctively and concurrently used by many persons as a personal name and by various companies as a trademark or domain name for a range of goods and services, including digital services. The domain name is consistent with a pattern of registrations undertaken by the Respondent involving personal names, given the popularity of such names for AI chatbots and assistants in various fields. Nowhere does the Complainant show that the Respondent has used the domain name in any manner suggesting an association with or targeting of the Complainant's goods or services associated with the asserted mark, nor does the Complainant allege a pattern suggestive of such targeting. The Respondent does submit there is a relevant pattern of domain name registrations which strongly suggest an obvious rationale for the Respondent's registration and use of the domain name.

 

II. Trade or Service Mark Rights

The first criterion is a low-threshold standing test which is easily satisfied here. The Complainant owns US TM Reg. No. 7,380,655, and several junior non-US registrations in "MADDI" for: AI platform for supporting law firm activities. The Complainant does not allege to have any reputation among consumers generally, or outside of its specialized niche. The Complainant does not allege to have any significant volume of customers. The Complainant does not allege to spend anything on advertising. The Complainant does not allege to earn any substantial revenue. While the Complainant provides no hint of a reputation directly under the first criterion, the Panel is requested to specifically and carefully note the Complainant's allegation, at page 7 of the Complaint: "At the time Respondent registered the Domain Name on January 15, 2026, Complainant was enjoying widespread unsolicited media coverage regarding its AI platform. See Annex 8." and to compare, unsupported puffery aside, the actual contents of Complainant's Annex 8 to counsel's claim that they demonstrate "widespread unsolicited media coverage" as of January 15, 2026. The Complainant's Annex 8 contains, in its entirety:

 

- A May 12, 2026 article from Lawnext.com, falsely characterized by counsel as of "January 15, 2026"

- A May 12, 2026 Press Release written by the Complainant, falsely characterized by counsel as "unsolicited media" 

- A May 12, 2026 copy of Complainant's press release published at Investing.com

- A May 20, 2026 copy of Complainant's press releases published at LegalTechnology.com

- A May 20, 2025 copy of one of Complainant's previous press releases published at LegalTechnology.com, on the occasion of a conference presentation by Complainant

 

None of this is "unsolicited media" and only one item in Complainant's Annex 8 actually existed prior to January 2026. That one item is from a website that likely no one on this Panel has ever heard of, and does not appear to be unsolicited given the apparent editorial policy. The Complainant's bizarrely inappropriate mischaracterization of material based on its own recent press releases suggests there may be a lack of actual evidence of any significant market or reputation, even in what is admittedly a niche market.

 

To be clear, the Complainant's marks easily satisfy the first criterion. It is nonetheless useful background to consider the relative distinctiveness and scope of the Complainant's mark, along with the Complainant's mischaracterization of reputational evidence mentioned elsewhere in the Complaint, concerning the Complainant's allegations of fame and distinctiveness. Merely owning a US trademark registrations for specialized services marketed to professional law practice administrators does not establish a monopoly or notorious connection between the Complainant and the name Maddi. For example, simply looking at registered marks from the EUIPO TMVIEW database, the Complainant's registrations exist among a field of 13 other registered MADDI marks in various jurisdictions. Accordingly, the Complainant has satisfied the first element by showing that it has limited rights in a specialized and sophisticated market, and the Complainant is one of many parties who owns registered marks in the word "MADDI". The Complainant does not provide any evidence of a substantial market or reputation prior to registration of the domain name, and the recency of the "unsolicited media" consisting mostly of Complainant's news releases from May 2026 appear to suggest an answer to the question of the Complainant's recent interest in the disputed domain name relative to the Complainant's brief existence thus far.

 

III. Legitimate Rights Or Interests

The second criterion of the Policy requires the Complainant to show that the Respondent has no rights or legitimate interests in the domain name. Such "rights and legitimate interests" are not limited to trade or service mark rights, but include equitable rights such as by use of the domain name for a bona fide purpose prior to notice of a dispute. The Respondent is a registrant of a substantial portfolio of personal name domain names. As is apparent from the burgeoning market in AI "chatbots", companions and assistants, there is a distinct tendency for them to be assigned personal names. While such companions as Siri, Alexa, or the grandmother of the genre, Eliza, have long been with us, it does not take much reflection on systems like Claude, there is a substantial market in AI products having personal first names. These include systems as exemplified in Exhibit B such as: - Kimi.ai, the official home of Moonshot AI's popular assistant known for pioneering work in autonomous research agents - Alice, a highly-regarded AI security platform - Connie, an IBM/Hilton joint venture AI concierge - Connie AI, an AI content manager, which demonstrates the co-existence of similarly named AI agents in different fields, along with: - Maddie, an AI medical billing system at trymaddie.com - Maddy, an AI powered shipping logistics system 3 - Madeline, an AI strategy and execution platform at Madeline.one - Madhi, an AI production platform at Madhi.ai - Maddie, an AI agent for additive manufacturing - Maddie, an AI movie-watching assistant at getmaddie.com - Madison AI, an AI system for accessing government information - Maddy, an AI business automation system at maddy-ai.com - Maddie, an AI-powered scientific data analysis system Of course, there is a much wider variety of personal-named AI agents, chatbots and assistants, but the bulk of the selections shown in Exhibit B demonstrate that nickname variations of the personal name Madeleine, Madison, etc., as a class of personal-named AI systems, are relatively common. The Panel is likely to know of many more personal-name AI agents, including the recently denied UDRP Complainant, Clio, which has quite an outstanding reputation in the legal field, and in relation to which the UDRP Panel noted:

 

·       Respondent replies that "common, non-exclusive personal names have independent commercial value, apart from their incidental use as trademarks" and claims that the "disputed domain name here is a four-letter personal name, being one of the nine Greek muses." It further notes that it has demonstrated a pattern of registering dictionary words and first names, many from Greek mythology, as domain names in the ".ai" TLD and it submits WHOIS records showing its ownership of such names as , , , , , and , amongst a list of approximately thirty domains. [...]

·       Upon reviewing the entirety of the parties' submissions, the Panel finds that Complainant's case is circumstantial, speculative, and can be distilled down to two key elements. It argues that Respondent's use is not bona fide and it must have targeted Complainant because 1) the sale price of the disputed domain name was set at a level that only a small number of companies could afford; and 2) Respondent must have been aware of Complainant's planned entrance into the AI space. However, the Panel finds neither ground convincing. The purchasing and sale of generic or descriptive domain names is a bona fide offering under the Policy so long as infringing or cybersquatting intent is not evident. Under such circumstances, an investor is entitled to set whatever price it likes for its offerings. Here, there is significant evidence that the word "Clio" has numerous meanings and uses beyond Complainant's mark and there is nothing on the auction website that refers or relates to Complainant.

 

The desirability of personal-name domain names, including in the .ai ccTLD, is not limited to artificially intelligent systems themselves, but are also desirable among persons who may be occupied or have a connection to the field. For example, the domain name <maddie.ai> is registered to a Maddie Simmons, who is an AI professional with OpenAI.

 

Of course, it is trivially easy to find many persons having "Maddi" as a first name or even a surname in a directory such as LinkedIn. However, even if one limits a LinkedIn search having the first or surname "Maddi", and some connection to the field of artificial intelligence, there is no shortage of such persons, as shown in Exhibit C, which is a sample of several pages of them. Of course, removing the "ai" search restriction generates an impressively large number of professionals named "Maddi" in general, without a specific reference to AI in their profiles. Any of these persons may be interested in obtaining the domain name for personal or commercial use for an eponymous company.

 

As a domain name, "maddi" finds widespread commercial and personal use, including in fields relevant to AI technology, as shown in Exhibit D, which includes: - <Maddi.dev>, the home of software developer Madeleine Milasas - <Maddi.com.mx>, a Mexican advertising system which matches advertisers and their products to a digital map of billboards in Mexico - <Maddi.it>, an Italian agricultural promotion board of some kind - <Maddi.is>, the personal website of a person nicknamed "Maddi" - <Maddi.ca>, a Canadian digital and graphic services firm, which is a field being revolutionized by AI - <Maddi.es> / <Maddi.eus>, the personal page of a Basque citizen - <Maddi.de>, an automated retail sales bargain consolidation system - <Maddi.com>, a Nordic mystery of some kind So, this is not a case where there is not an apparent widespread, concurrent and diverse universe of persons and entities who use "Maddi" as a domain name, including in fields in which the application of AI technology has become commonplace.

 

The Respondent, whose public "definitely not hiding from anyone" LinkedIn profile is attached as Exhibit E, is a native of Victoria, British Columbia, and studied economics at the University of Victoria. He is a serial entrepreneur who in 2006 launched Schoolr.com, an academic research website that helped students find information, create citations, and access educational resources from one place. Upon winding up that business, he found that there is a market for domain names, and Schoolr.com was his first domain name sold. He then co-founded Milktape, a consumer electronics company that produced USB cassette tapes; and then co-founded TruckPlease, a venture-backed startup that connected customers with moving companies. Both of these businesses were successfully sold after their start-up phases. In parallel with these businesses, Mr. Aghdasi provides consulting services to businesses seeking to grow their reputations online. Currently, the Respondent is the publisher of Ungrabbed.com, a daily domain name newsletter subscribed by domain investors, developers, entrepreneurs, and others interested in online business. The Respondent has no background or experience in the field of law firm management. The Respondent's personal history has made him keenly aware of the value of such personal name domain names, and in addition to the disputed domain name, is likewise the registrant of: beadie.ai, charlotte.so, erno.ai, jem.ai, joaquin.ai, kerri.ai, ottilie.ai, pinkie.ai, pythias.ai, silvie.ai, wynnie.ai, elinor.app, jill.app, rupert.app, harriet.co, billy.so, emily.so, isaac.so, miro.so, marjory.xyz, as seen in the Respondent's view of the respective registrars across which the Respondent maintains his domain portfolio, shown in Exhibit F.

 

As noted in the Clio.ai decision quoted above, and as is established as a well-known principle by now, trade in short words and common names as domain names is a legitimate business, provided that it is not the sort of situation where there is (a) evidence of targeting of a particular trademark claimant, or (b) a case of no substantial or realistic possibility of non-infringing use, such as with famous or inherently distinctive marks. Neither of those circumstances is present here.

 

The name "Maddi" is not an exceptional or unusual first name or surname, as shown in relation to AI professionals, nor are variations of Maddie, Maddy, etc. unusual among vendors of AI products generally. Given that first names for such services manage to co-exist, the Complainant's specialized field in which it claims, without much evidence, to have a substantial reputation, simply does not extend a presumptive right to any and all desirable or productive uses for which a prospective buyer may want to acquire and use a personal name domain such as <maddi.ai>. For decades now, UDRP panels have recognized that common, non-exclusive personal names have independent commercial value, apart from their incidental use as trademarks. Certainly, some marks are famous or have no conceivable legitimate purpose apart from brands with which they are strongly associated. Likewise, whether a respondent's use suggests evidence of an illegitimate predatory purpose would be an important consideration. But those are simply not the facts here. There is no reason to believe that the Respondent, a reseller with a portfolio of domain names comprised of thematically similar names, has had any purpose in mind other than registering and using a widely used name for resale for purposes having nothing to do with the Complainant's services provided to a specialized niche market. The Complainant does not allege that the Respondent has, for one millisecond of the domain name's existence, used it for any illegitimate purpose. The Complainant does not allege the Respondent has passed itself off as the Complainant, confused a single consumer, infringed the mark, or used the domain name for any purpose remotely related to the Complainant's mark. Accordingly, the Respondent submits that the Complainant has failed to carry its burden by a preponderance of evidence that the Respondent lacks rights or interests in the domain name.

 

IV. Bad Faith

The final criterion of the Policy requires the Complainant to show that the domain name has been registered and is used in "bad faith" - in which the enumerated examples all derive from an intentional targeting of the asserted trade or service mark. It is worth dispensing with the Complainant's most offensive, insulting and false allegation first - namely the ridiculous idea that "Respondent has attempted to hide its identity."

 

As the Panel, or anyone remotely cognizant of domain name policy is aware the "WHOIS privacy as bad faith" argument is desperately in need of retirement from these Proceedings. Since the advent of GDPR privacy regulations in the EU and similar provisions elsewhere, the ICANN Temporary Specification for gTLD Registration Data has become the governing ICANN policy for registrar data collection and publication. WHOIS itself is no longer an ICANN required registrar service. By default, gTLD registrars do not publish registration data, and the UDRP was amended several years ago to provide an initial phase during which the registrant data is provided to a UDRP complainant and the provider after initial filing of a UDRP complaint. The Complainant was provided the Respondent's actual name and contact data prior to filing the Amended Complaint. The Respondent's contact data is consistent with the Respondent's public LinkedIn profile, and indeed the Respondent's reputation in the domain industry as the publisher of a relevant newsletter at Ungrabbed.com. The Respondent is hiding nothing.

 

The Complainant then manages to mis-apply every factor of the Telstra passive holding doctrine, even though this is a "for sale" lander which inherently facilitates contact with the Respondent by filling out the form and hitting "submit", and thus is not a "passive holding" situation. As noted in WIPO Overview 3.1: Factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant's mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent's taking active steps to conceal its identity or (iv) the use of false or inaccurate contact details (noted to be in breach of the respondent's registration agreement). Applying these factors here: (i) - The Complainant's mark consists of a common first name and surname, which is also concurrently the subject of widespread trademark claims, domain names and personal names, and variants of which are commonly used in relation to AI systems. It is not inherently distinctive and the Complainant is a relatively recent start-up whose Annex 8 evidence of reputation is mostly material which is two months old. (ii) The Respondent has filed a Response and shown a pattern of domain name registrations consistent with a good faith legitimate interest in first name domain names. (iii) The Respondent has taken no active steps to conceal his identity. (iv) The Respondent's contact details are correct. The Complaint fails every single one of the "passive holding" doctrine criteria stated in WIPO Overview 3.1. Of course, that failure would be premised on the notion that an active contact page, such as used for this domain name, qualifies as the sort of "non-use" around with the passive holding doctrine was built. A "for sale" page through which the Respondent can be contacted is an active web page, and not the sort of entire non-use which was the essence of the Telstra decision and its progeny.

 

The Complainant alleges, without any factual basis whatsoever, that the Respondent's public offer for sale necessarily implies that the Respondent's purpose was to sell the domain name to the Complainant in particular. That claim is transparently ridiculous against the background of Respondent's general interest in first name domain names, and the demonstrable concurrent use of "maddi" by a wide variety of personal and commercial users, including in fields relevant to AI technology.

 

Much of the remaining arguments under "bad faith" are premised on such factually unsupported puffery as the Complainant's "fame" and "notoriety" which are buttressed in the Complaint by several copies of a May 2026 press release. It is worth noting in relation to "constructive notice", even if it were applied, that the Complainant's Canadian trademark registration is junior to the date on which the Respondent, a Canadian, registered the domain name. In any event, the Respondent had never heard of the Complainant, who does not operate any of the comparable "maddi" domain names used as a measure of popularity as a potential acquisition, prior to this Proceeding. While the Complainant would of course urge the Panel to proceed on inferences premised on unsupported claims of a widespread reputation generally, such inferences are a poor substitute for actual facts such as (a) the Respondent's relevant personal history and background in serial entrepreneurship involving the sale of businesses and domain names, (b) the Respondent's lack of familiarity with the field of law firm management, and (c) the Respondent's relevant portfolio of personal domain names of which the disputed domain name is simply one of a class. Inferences are useful, but they do not outweigh facts.

 

No amount of supplemental evidence will change the fact that the Complainant's mark is simply not inherently distinctive - it is a common name - and the Complainant's mark is simply not famous, as it is subject to widespread concurrent use. Indeed, it is the very popularity of such names which is the driver of their commercial value to parties such as the Respondent. There is simply no point, for a professional domain investor such as the Respondent, to waste time on what are "one customer" domain names, as such names may never sell. The goal, as demonstrated by the selection of names in the Respondent's portfolio, is to obtain a portfolio of domains that can be obtained within a reasonable budget, but have the widest possible potential market. The Respondent is not the most well-funded domain investor, and his names may be in secondary TLDs and not the most common of names, but domain investing is a cost/value proposition.

 

FINDINGS

Complainant has established the first element, but has failed to establish the second and third elements. The Complaint is accordingly dismissed.

 

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 is not really in dispute. The Panel is satisfied that Complainant has established the first element.

 

Complainant has, among others, a trademark registration for MADDI in the US in the Principal Register. This is sufficient to establish Complainant's standing under this element. 

 

Furthermore, given that Complainant's trademark registration is for "AI platform for supporting law firm activities", the ".ai" part of the disputed domain name is not an effective differentiator.

 

It follows that the Panel is satisfied that the disputed domain name as a whole is identical or confusingly similar to Complainant's registered trademark.

 

However, it is worth pointing out that the Panel finds force in Respondent's submissions that Complainant has failed to substantiate the claimed "widespread unsolicited media coverage" or "nearly three years of use" of its MADDI Mark/AI platform. Complainant only produced a few website articles referencing its MADDI Mark, but those articles were all dated fairly recently (one article was dated May 2025, and the others were dated May 2026). Furthermore, those articles only referenced the MADDI Mark in passing. While this insufficiency of evidence does not negate Complainant's standing under the first element, it does impact on the Panel's assessment of the second element and the third element, as discussed below.

 

Rights or Legitimate Interests

Complainant has failed to establish the second element.

 

It is not in dispute that Respondent is not connected or affiliated with Complainant and has not received a license or consent, express or implied, to use the MADDI Mark in the disputed domain name; Respondent is also not commonly known by the disputed domain name.

 

However, it is well established that those factors are not conclusive, and that the circumstances to demonstrate a respondent's rights and legitimate interests are not exhaustive. The Panel is obliged to take into account all the relevant circumstances when assessing this second element. Here, the Panel has considered and applied the following principles:

 

(i)       The more descriptive or generic the term is, the more likely the Panel will find rights or legitimate interests. Here, the Panel accepts Respondent's submissions that Maddi can be a personal name and is not an exceptional or unusual one, and that it is quite a popular practice in the AI field to have personal-named domains/products/services. Thus, the Panel is satisfied that absent evidence of targeting, Respondent can have rights and legitimate interests in the disputed domain name.

 

(ii)       Investing and trading in domain names can constitute rights and legitimate interests, when done without taking unfair advantage of the trademark owner's rights.

 

(iii)       Use of the domain name for a website with substantive contents is not a pre-requisite to proving rights and legitimate interests under the Policy. Therefore, the fact that the disputed domain name resolves to a "for sale" webpage by itself is not conclusive of the matter.

 

(iv)        Respondent's personal history and pattern of registering personal name domain names supports his contention that he has a legitimate interest in investing in personal name domain names.

 

All things considered, the Panel is satisfied that Respondent has demonstrated his rights and legitimate interests in the disputed domain name.

 

Registration and Use in Bad Faith

Given the Panel's findings under the second element, it naturally follows that the Panel considers that the registration and use of the disputed domain name is not in bad faith. To supplement:

 

(i)       Complainant's attack on Respondent's use of privacy registration service is perhaps overstated. Given the prevalence of use of privacy and proxy registrations services (as pointed out by Respondent, Complainant and Complainant's counsel also seem to be using privacy registration services for their own domain names), increasingly the use of the such services by itself would be considered a neutral point and not an indicator of bad faith, absent any evidence of false or misleading information or attempts to hide or conceal the transaction history of the domain name.

 

(ii)       To quote UDRP Perspective Paragraph 3.3: "The onus is on the Complainant to prove its case and this includes providing evidence of the Respondent's intention to target a specific Complainant rather than anyone who may have a trademark for the corresponding or similar term". Here, Complainant falls short of proving that Respondent's registration and use of the disputed domain name are targeting Complainant. As discussed above under the first element, Complainant has provided fairly limited evidence to demonstrate the use and reputation of its MADDI Mark; coupled with the fact that Maddi is not an exceptional or unusual personal name, the Panel is not satisfied Respondent must have targeted Complainant or must have Complainant in mind when registering and using the disputed domain name.    

 

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 <maddi.ai> domain name REMAIN WITH Respondent.

 

 

 

 

Eugene I. Low, Chair

Nick J. Gardner, Panelist

Professor David E. Sorkin, Panelist

 

Dated: July 14, 2026