DECISION
Jeff Hamilton Holdings, Inc. v. Registrant Street: 942 W Patapsco Avenue
Claim Number: FA2606002226609
PARTIES
Complainant is Jeff Hamilton Holdings, Inc. ("Complainant"), represented by Neil Peluchette of Taft Stettinius & Hollister LLP, Indiana, USA. Respondent is Registrant Street: 942 W Patapsco Avenue ("Respondent"), Maryland, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <jeffhamilton.com>, registered with NameCheap, 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.
Adam Taylor as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on June 10, 2026; Forum received payment on June 10, 2026.
On June 12, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <jeffhamilton.com> domain name is registered with NameCheap, Inc. and that Respondent is the current registrant of the name. NameCheap, Inc. has verified that Respondent is bound by the NameCheap, 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 June 19, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of July 13, 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@jeffhamilton.com. Also on June 19, 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 July 13, 2026.
Respondent and Complainant filed Additional Submissions on July 13 and 14, 2026, respectively. Paragraph 10(d) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") gives the panel authority to determine the admissibility, relevance, materiality and weight of the evidence. The Panel has decided to admit Respondent's Additional Submission, which is an amended version of the Response, filed on the same day as the Response, and to which Complainant has raised no objection. References to "the Response" below include Respondent's Additional Submission. The Panel admits Complainant's Additional Submission insofar as it addresses matters raised in the Response that Complainant could not reasonably have anticipated when filing its Complaint.
On July 14, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Adam Taylor 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 "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.
On July 20, 2026, the Panel issued a Panel Order inviting Additional Submissions. Respondent and Complainant duly filed Additional Submissions on July 24 and 26, respectively.
RELIEF SOUGHT
Complainant requests that the domain name be transferred from Respondent to Complainant.
PARTIES' CONTENTIONS
A. Complainant
Complainant contends that it has rights in the JEFF HAMILTON JH mark based upon registration of its mark with the United States Patent and Trademark Office ("USPTO") and upon common law rights in the mark JEFF HAMILTON arising from long-standing continuous business use. The disputed domain name is identical to Complainant's common law mark and personal name, and confusingly similar to Complainant's registered mark.
Respondent has no rights or legitimate interests in the disputed domain name. Complainant has never authorized Respondent to use Complainant's mark. Respondent has not used the disputed domain name in connection with a bona fide offering of goods or services; on the contrary, Respondent has used the disputed domain name for a fraudulent phishing scheme against consumers seeking Complainant.
Respondent is not commonly known by the disputed domain name. The WHOIS information does not identify Respondent as "Jeff Hamilton". Respondent cannot claim to be commonly known by a name that includes Complainant's prior and longstanding mark, or when Respondent advertises at least 10 other domain names, including <josefhamilton.com>. Respondent has used fake WHOIS information. The WHOIS record for the related domain name <jfhamilton.us> identifies the registrant as Sylvia Chan, which differs from the WHOIS information for the disputed domain name.
Respondent has not made legitimate noncommercial or fair use of the disputed domain name.
Respondent registered and used the disputed domain name in bad faith. Respondent's actual knowledge of Complainant's mark is evidenced by its fame and use for over 30 years before Respondent acquired the disputed domain name. Respondent has used the disputed domain name to create a likelihood of confusion with Complainant's mark for commercial gain. Respondent uses Complainant's exact trademark, to attract consumers to its website to induce consumers to click on the bitcoin QR code, for the purposes of fraudulent phishing. The fact that the website is in Arabic, one of two official languages of Morocco, where Complainant was born, is likely to cause confusion. Respondent's bad faith is further demonstrated by the totality of the circumstances. Respondent likely acquired the disputed domain name when the WHOIS information was "updated" in 2025, using fake WHOIS information.
B. Respondent
The following is a summary of Respondent's contentions in the Response:
- Respondent acquired the disputed domain name in January 2011, and the 2025 WHOIS "Updated" date reflects only a registrar account change rather than any transfer of ownership;
- Respondent is commonly known by the disputed domain name because Respondent's legal name includes "Jeffrey" and "Hamilton" and Respondent has been known as "Jeff Hamilton" by friends and family for decades;
- Respondent is one of many individuals whose name is "Jeffrey Hamilton", "Jeff Hamilton", or a permutation thereof, and Complainant cannot exclude any of those individuals from registering a domain name such as the disputed domain name unless the registrant is using the disputed domain name to violate Complainant's trademark rights;
- Respondent has changed the printed form of its name to "Jf Hamilton" out of respect towards a well-known American jazz drummer called "Jeff Hamilton", but retains "Jeff" as the pronounced version;
- since 2018, the disputed domain name has been held in a Namecheap account in the name of Sylvia Chan, who manages "several intellectual properties" on behalf of the Respondent;
- Respondent is using, or preparing to use, the disputed domain name in connection with a bona fide offering of goods and services;
- Respondent is engaged in the business of music production and music engraving, and has used the disputed domain name as a landing page for an as-yet incomplete music project;
- there are prominent links on the Respondent's website as a courtesy to three musicians who share the name "Jeff Hamilton";
- it is undisputed that the parties are not competitors;
- Respondent has never used the disputed domain name or any of its many other domain names to sell jackets or other apparel;
- Complainant gives the false impression that Respondent is a mystery figure whereas the parties started communicating some 14 years ago, when Respondent sent an email to Complainant signed "Jeff Hamilton";
- Respondent has not engaged in phishing or other fraudulent conduct and the bitcoin link is merely a visible and publicly available vanity wallet address, "1JfXam…", denoting Respondent's website at www.jfx.am, located in the website footer;
- the absence of the disputed domain name from the "Wayback Machine" does not denote fraud, but simply arises because Respondent requested removal because the archive versions of the website included files covered by restricted distribution licenses;
- the fact that the site has been "under construction" for years does not denote fraud as the majority of domain names worldwide would be voided on that basis;
- the presence of the Arabic on the website is irrelevant as this language is spoken by 300 million people and there is no evidence of Complainant marketing activity in Arabic-speaking markets; and
- Respondent has accordingly neither registered nor used the disputed domain name in bad faith.
C. Additional Submissions
The following is a summary of Complainant's Additional Submissions dated July 14, 2026:
- Respondent's account of the parties' earlier communications is irrelevant because Complainant believed it was corresponding with a previous registrant before the disputed domain name changed hands in 2025;
- Complainant relied in good faith on the 2025 WHOIS changes and the subsequent use of the disputed domain name in believing that ownership had changed;
- neither Sylvia Chan nor the alleged Jeffrey Hamilton is identified as the registrant in the WHOIS information;
- the listed registrant and named Respondent in this proceeding is "Registrant/Street: 942 W. Patapsco Avenue" and therefore Respondent cannot be commonly known by the disputed domain name;
- Respondent has produced no evidence that Respondent is genuinely named Jeffrey Hamilton or is the famous jazz drummer whose identity Respondent appears to be adopting;
- Respondent's concealed identity prevents Complainant from investigating Respondent's domain name portfolio or any history of abusive registrations, and Forum panels have generally found in favor of complainants in cases involving misleading or false WHOIS information; and
- Respondent has failed to provide any explanation for use of the bitcoin QR code, and Respondent's reliance on the alleged connection with the domain name <jfx.am> casts further doubt on the legitimacy of such use.
The following is a summary of Respondent's Additional Submissions in response to the Panel Order dated July 20, 2026:
- Respondent has supplied a District of Columbia driver's licence (expired 2018) that was valid at the time of the 2011 auction and a New York State identification card (expired June 25, 2026);
- despite contacting numerous New York law firms, Respondent was unable to obtain the attorney certification requested by the Panel because of the cost involved and legal concerns expressed by attorneys regarding certification of identity documents;
- Complainant has known Respondent's identity for over fourteen years through the parties' previous communications;
- Respondent has nevertheless complied substantially with the Panel's request by providing an unsworn declaration;
- Respondent is willing to present both documents in person if required; and
- Respondent has provided the Namejet 2011 confirmation email.
The following is a summary of Complainant's Additional Submissions in response to the Panel Order dated July 20, 2026:
- the documents submitted by Respondent fail to establish either Respondent's identity or Respondent's acquisition of the disputed domain name in 2011;
- the authenticity of the identification documents is questionable as neither is current, and Respondent's accompanying declaration is unsworn;
- Respondent failed to comply with the Panel's requirement for certification by a United States attorney, Respondent's explanations are unconvincing, and the documents submitted by Respondent therefore remain questionable;
- the Namejet email indicates an international presence because of its printout date format and it therefore casts doubt on Respondent's claim to be located in the United States;
- even if the identity documents are genuine, without attorney certification, they do not establish that the person communicating with Forum is the individual identified in those documents;
- the New York addresses appearing in Respondent's submissions are inconsistent with the Maryland addresses associated with the disputed domain name and website, further calling Respondent's identity into question;
- the identity documents reveal for the first time that the alleged Respondent's full name is "Russell Jeffrey Hamilton", never before used by Respondent to identify itself and giving rise to further questions concerning Respondent's identity;
- the NameJet confirmation email does not establish that Respondent registered the disputed domain name in 2011 because it refers to a different email address and instead supports Complainant's case that there was a subsequent change of registrant; and
- Respondent has produced no evidence as to when the registrant email address changed, or that Sylvia Chan was the registrant in 2018, or that the disputed domain name was transferred to her Namecheap account at that time, in which case Sylvia Chan must be the current registrant, must own/operate the current registrant email address and must be the individual communicating with Forum in this proceeding, all of which is inconsistent with Respondent's contention that Jeffrey Hamilton is the registrant of the disputed domain name.
FINDINGS
Complainant's personal Instagram account has some 8.5 million followers.
Complainant has operated a website at www.jeffhamiltonshop.com since 2022.
By email dated January 9, 2011, NameJet sent an email to Respondent stating that Respondent had won the disputed domain name for USD 510 in a domain name auction.
There were various communications between the parties between 2012 and 2020, which have not been produced to the Panel. The following summary is based on Respondent's account of the correspondence, which Complainant has not disputed.
In June 2012, Complainant emailed Respondent concerning the disputed domain name. Respondent replied that it had legitimately purchased the disputed domain name at a NameJet auction in 2011, that it was unaffiliated with the Complainant, and it invited Complainant to contact it by telephone with any further questions. Respondent signed the email: "Jeff Hamilton".
On or about January 18, 2019, Complainant complained to the Registrar that Respondent was cybersquatting and requested transfer of the disputed domain name. The Registrar forwarded the complaint to Respondent. Respondent replied that it had legitimately purchased the disputed domain name at auction in 2011, that Respondent's name was "Jeffrey Hamilton", that Respondent had been known as "Jeff Hamilton" by friends and family for decades, that there was no "cybersquatting", that there were prominent links on the page which had been there for years as a courtesy to three musicians who share the name "Jeff Hamilton", and that Respondent was not willing to sell the disputed domain name.
On or about February 17, 2020, Complainant contacted Respondent via a contact form on Respondent's website at www.jfhamilton.com, following which the parties spoke by telephone. Respondent stated that it identified itself as a musician named Jeffrey Hamilton, explained that it was adopting the written form "Jf Hamilton" to distinguish itself from another musician of the same name, and again stated that it was unwilling to sell the disputed domain name.
On or about April 1, 2020, a person claiming to be a domain name specialist acting on behalf of an interested party twice approached the Respondent seeking to purchase the disputed domain name, first for USD 500 and then for USD 2,000. Respondent declined both offers.
As of June 4, 2026, the disputed domain name resolved to a webpage that was headed with some text in Arabic, followed by the image of a stave with musical notes plus the text: "Jf Hamilton is a musician who lives in Annapolis, Maryland. The English-language site is under construction." The footer included what the Panel understands is a Quranic in Arabic above a long bitcoin address starting "1JfXam…", which generated a QR code plus the term "bitcoin URL link".
The footer also contained links to Terms and Conditions and a Privacy Policy ("the Legal Pages"), each of which contained blocks of text in numerous languages including Arabic. The Terms and Conditions comprised licensing terms relating to "digital and physical products sold by Jf Hamilton or Pyftn Records", while the privacy policy referred to use of personal information in online purchases, and to participation by the website in the Amazon affiliate program.
The Legal Pages each included the following list of domain names followed by the phrase (in Arabic) "The J.F. Hamilton network of websites":
· josefvs.hamiltonvs.com
· hajiefu.com
· e16q82c0.com
· jfhamilton.co.uk
· jfhamilton.com
· jeffhamilton.com
· jfhamilton.in
· jfhamilton.id
· jfhnation.fr
· jfhamilton.de
· jfhamilton.pt
· jfhamilton.pl
· jfhamilton.pk
· jfhamilton.net
· jfxamilton.com
· jfx.am/ilton
· jfhamilton.us
· jfhamilton.red
· lowercaseitalicf.com
· josefhamilton.com
· jfxamilton.ru
· cdn.pyftn.net/jfxamilton
According to the WHOIS information for the disputed domain name, it was "Updated" on August 9, 2025.
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
Where a domain name incorporates the entirety of a trademark, or at least a dominant feature of the relevant mark is recognizable in the disputed domain name, it will normally be considered confusingly similar to that mark for purposes of UDRP standing. See WIPO Jurisprudential Overview 3.1 at ¶ 1.7.
In this case, the disputed domain name comprises a dominant feature of the mark, namely the term "jeff hamilton".
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 must first make a prima facie case that Respondent lacks rights and legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii); then the burden shifts to Respondent to show it does have rights or legitimate interests. See Neal & Massey Holdings Limited v. Gregory Ricks, FA 1549327 (Forum Apr. 12, 2014) ("Under Policy ¶ 4(a)(ii), Complainant must first make out a prima facie case showing that Respondent lacks rights and legitimate interests in respect of an at-issue domain name and then the burden, in effect, shifts to Respondent to come forward with evidence of its rights or legitimate interests").
Complainant contends that Respondent lacks rights or legitimate interests in the disputed domain name since Respondent is not commonly known by the disputed domain name. Respondent strongly contends otherwise.
In response to the Panel Order of July 20, 2026, Respondent produced copies of two identification documents indicating that Respondent's legal name is "Russell Jeffrey Hamilton".
Complainant has questioned the authenticity of the documents including on the basis that: neither document is current; Respondent has given a questionable explanation for the lack of attorney certification; they are accompanied only by an unsworn declaration; and the New York address in the New York document, as well as other New York addresses in Respondent's submissions, are inconsistent with the Maryland registrant address for the disputed domain name and the Maryland location mentioned on the Respondent's website.
However, while Respondent has not taken up the Panel's invitation to have the copies certified by a licensed United States attorney, on the face of it, the documents appear genuine. Each contains a photograph of what seems to be the same person. And the Panel has no reason to doubt that they belong to the person who is corresponding with Forum as Respondent.
The Panel has not been provided with any evidence that the discrepancy in addresses is an indicator of illegitimacy, rather than simply arising from a change of address or some other innocent reason. Furthermore, although the Panel Order requested production of a current identity document, the Panel does not consider that anything turns on the fact that both documents have expired (the New York one only recently). They nonetheless support Respondent's assertion that its legal name includes the terms "Jeffrey" and "Hamilton", and that it is commonly known by a variation of such name, namely "Jeff Hamilton".
Overall, the Panel has not been provided with convincing evidence that the identity documents presented by Respondent are likely inauthentic. The Panel would add that this is a limited proceeding without the benefit of the tools available in litigation such as discovery and cross-examination and the Panel must rest its findings on the evidence submitted by the parties. This decision does not prevent Complainant from pursuing the matter further in court should Complainant consider that it has grounds to do so.
Furthermore, it is not in dispute that Respondent owns many other domain names that reflect variations of "Jeff Hamilton", especially "jfhamilton", which Respondent claims to have adopted as the written (not spoken) version of its name to avoid conflict with a well-known jazz drummer named "Jeff Hamilton", as well as other versions such as "jfxamilton" and "josef…hamilton". This does not seem to be the type of behaviour that one might expect from someone who is purely out to impersonate a person called "Jeff Hamilton".
Complainant relies on the fact that the registrant of the disputed domain name is not "Jeff Hamilton". However, while WHOIS information may be used to determine whether a respondent is commonly known by the disputed domain name under Policy ¶ 4(c)(ii), a respondent may be able to establish its name by other means. See Braun Corp. v. Loney, FA 699652 (Forum July 7, 2006) (concluding that the respondent was not commonly known by the disputed domain names where, not only the WHOIS information, but also all other information in the record, gave no indication that the respondent was commonly known by the domain names). Whereas, here, other information on record, namely identity documents, indicate that Respondent is indeed commonly known by a name corresponding to the disputed domain name.
Complainant criticizes the WHOIS information for the disputed domain name as "fake", because the registrant name is shown as "Registrant / Street: 942 W Patapsco Avenue". However, registrant names often consist of terms other than the name of the ultimate controller of the domain name, whether due to registration by an agent, privacy protection, errors or otherwise. The Panel is not prepared to conclude that the mere appearance of a street address in the registrant name field is anything other than an inadvertent pasting error - in the absence of any indication of deliberate falsification by Respondent, or that the address itself is fictitious.
Complainant also alights on the fact that another of Respondent's domain names is registered to a Sylvia Chan, who Respondent says manages certain of Respondent's domain names. Complainant appears to invoke Respondent's statement that the disputed domain name was transferred to Sylvia Chan's account with the Registrar in 2018, as well as a change of registrant email address since the Namejet 2011 confirmation email, as indicating that Sylvia Chan, not Jeffrey Hamilton, is the controller of the disputed domain name. However, all of the evidence points towards the same person as having controlled the disputed domain name since 2011, including the fact that the 2011 email address and the current registrant email address have the same username, which is a variation of "Jeff Hamilton", and that the current registrant is in possession of correspondence with the Complainant, which goes back to 2012. In these circumstances, the Panel considers that the 2025 "Updated" date in the WHOIS information is unlikely to signify a change of control of the disputed domain name.
Complainant further contends that the disputed domain name is not being used for a bona fide offering of goods or services but, rather, for a fraudulent phishing scheme that seeks to misleadingly divert consumers seeking Complainant. For its part, Respondent asserts that the website at the disputed domain name constitutes demonstrable preparations to use the disputed domain name for a legitimate, but as-yet incomplete, music project. Respondent strongly denies fraud.
Respondent has only provided a limited explanation for its use of a bitcoin QR code/link, simply pointing out that the bitcoin address displayed on the website comprises a vanity address starting "1JfXam", corresponding to Respondent's website at www.jfx.am.
However, the bitcoin address appears only in the footer of the website, beneath a phrase in Arabic that the Panel understands is derived from the Quran, i.e., the bitcoin address does not appear to be accompanied by any messaging relating to bitcoins, payments, clothing or Complainant.
The Panel also notes that the homepage presents as a skeletal and obscure page, labelled "under construction", with a mix of English and Arabic, and dominated by the image of a stave with music notes. The Legal Pages contain blocks of text in multiple languages that relate to unspecified music products "sold by Jf Hamilton or Pyftn Records". Accordingly, while the exact purpose of the site is difficult to discern, it is clearly focused on some sort of music project; certainly, the website makes no mention of apparel, let alone jackets, the products for which Complainant is famous.
Overall, this seems very far removed from the kind of website one might expect if Respondent was out to defraud Complainant's customers or otherwise create a likelihood of confusion with Complainant's mark. On the contrary, the Panel's impression is that, as contended by Respondent, this is an embryonic website being developed for an unspecified music project by a person called Jeff Hamilton, who happens to bear the same name as Complainant, a famous jacket designer, but which name is also shared by many others, including at least one well-known musician. The Panel considers that, on the balance of probabilities, Respondent registered and used the disputed domain name, along with many others, because it reflected Respondent's own name and with no intention of targeting Complainant or Complainant's customers.
This conclusion is not affected by Respondent's intermittent use of Arabic on the website, notwithstanding that this happens to be a language spoken in Complainant's country of birth. As Respondent observes, Arabic is spoken by a vast number of people worldwide and Complainant has provided no evidence of activity/reputation in Arabic-speaking markets.
For all of the above reasons, the Panel finds that Respondent has used, or made demonstrable preparations to use, the disputed domain name for a bona fide offering of goods or services per Policy ¶ 4(c)(i) and that Respondent is commonly known by a name corresponding to the disputed domain name per Policy ¶ 4(c)(ii).
Therefore, the Panel concludes that Respondent possesses rights or legitimate interests in the disputed domain name under Policy ¶ 4(a)(ii).
Registration and Use in Bad Faith
It is unnecessary for the Panel to consider the third element in light of the Panel's conclusion under the second element. The Panel would just add that Complainant would likewise have failed under the third element for substantially the same reasons discussed above.
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 <jeffhamilton.com> domain name REMAIN WITH Respondent.
Adam Taylor, Panelist
Dated: August 1, 2026
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