DECISION
Keeta, Inc. v. chu jiajun / keeta
Claim Number: FA2609002244708
PARTIES
Complainant is Keeta, Inc. ("Complainant"), represented by Maulin V. Shah of Envision IP LLC, North Carolina, USA. Respondent is chu jiajun / keeta ("Respondent"), Hong Kong.
REGISTRAR AND DISPUTED DOMAIN NAMES
The domain names at issue are <keetaai.info> and <keetafund.com> registered with Hello Internet Corp and Web Commerce Communications Limited dba WebNic.cc.
PANEL
Alan L. Limbury, as Panelist.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on September 10, 2026. Forum received payment on September 10, 2026.
On September 11, 2026, Hello Internet Corp and Web Commerce Communications Limited dba WebNic.cc confirmed by e-mail to Forum that the <keetaai.info> and <keetafund.com> domain names are registered with Hello Internet Corp and Web Commerce Communications Limited dba WebNic.cc and that Respondent is the current registrant of the names. Hello Internet Corp and Web Commerce Communications Limited dba WebNic.cc have verified that Respondent is bound by the Hello Internet Corp and Web Commerce Communications Limited dba WebNic.cc registration agreements and have thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").
On September 15, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of October 5, 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@keetaai.info, postmaster@keetafund.com. Also on September 15, 2026, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.
Having received no response from Respondent, Forum transmitted to the parties a Notification of Respondent Default.
On October 6, 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 names be transferred from Respondent to Complainant.
PARTIES' CONTENTIONS
A. Complainant
Complainant Keeta, Inc. is a financial technology company operating under the registered KEETA mark. Through its official website at <keeta.com>, Complainant promotes technology and financial services relating to global payments, digital wallets, cryptocurrency and digital assets, investments and yield, treasury products, tokenization, and on-chain financial infrastructure.
Both <keetaai.info> and <keetafund.com> are confusingly similar to Complainant's KEETA trademark.
Respondent has no rights or legitimate interests in <keetaai.info> or <keetafund.com>. Respondent is not affiliated with Complainant, has not been authorized, licensed, or otherwise permitted to use the KEETA mark, and is not commonly known by either domain name. There is no bona fide offering of goods or services and no legitimate noncommercial or fair use related to the domain names. Instead, Respondent uses them to impersonate Complainant and to present Internet users with an unauthorized KEETA-branded financial and cryptocurrency website. Both resolving websites are the same or substantially identical in appearance and operation. They reproduce KEETA branding and display purported DeFi, staking, lending, yield, investment, and/or wallet functionality in a manner designed to appear officially endorsed or offered by Complainant.
The <keetaai.info> and <keetafund.com> domain names were registered and are being used in bad faith. Respondent specifically targeted Complainant and the KEETA mark. Both domain names were registered years after Complainant established trademark rights, each reproduces KEETA in full, and each is used for an unauthorized site that presents itself as Complainant and purports to offer financial, cryptocurrency, investment, and/or wallet services. There is no plausible explanation for this combination other than actual knowledge of Complainant and an intent to exploit the KEETA mark.
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 mark KEETA, including International Registration No. 1738181, registered on June 7, 2023, for inter alia ATM banking services, in International Class 36.
The Panel finds Respondent's <keetaai.info> and <keetafund.com> domain names to be confusingly similar to Complainant's KEETA mark, only differing by the addition of the abbreviation "ai" or the word "fund", which differences are insufficient to distinguish either domain name from Complainant's mark. The inconsequential ".info" and ".com" generic top-level domains ("gTLDs") 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 <keetaai.info> and <keetafund.com> domain names were registered on July 24 and August 25, 2026, three years after the registration of Complainant's KEETA mark. The resolve to almost identical websites headed: "Safeguard your asset transactions" and "Welcome to Keeta – your secure global investment platform", and stating:
"About Us
Keeta is a comprehensive trading platform focused on decentralized finance (DeFi), dedicated to providing users with a secure, transparent, and efficient digital asset trading experience."
The websites appear to offer the same services as Complainant.
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 names on the part of Respondent. The evidentiary burden therefore shifts to Respondent to show that it does have rights or legitimate interests in the <keetaai.info> and <keetafund.com> domain names. 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 names.
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 KEETA mark and its website at <keeta.com> when Respondent registered the <keetaai.info> and <keetafund.com> domain names and that Respondent has intentionally attempted to attract, for commercial gain, Internet users to Respondent's websites, by creating a likelihood of confusion with Complainant's mark as to the source, sponsorship, affiliation, or endorsement of Respondent's websites and of the services promoted on those websites. 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 <keetaai.info> and <keetafund.com> domain names be TRANSFERRED from Respondent to Complainant.
Alan L. Limbury, Panelist
Dated: October 7, 2026
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