Company filed cybersquatting complaint against domain registered well before it had trademark rights in the term Hudson’s Detroit.
UDRP panel finds reverse domain name hijacking in HudsonsDetroit.com dispute
Bedrock Management Services, LLC has been found to have attempted reverse domain name hijacking in its dispute over the domain HudsonsDetroit.com. The decision by a Uniform Domain Name Dispute Resolution Policy (UDRP) panel concluded the company pursued the complaint in bad faith after it relied on an incorrect chronology that undermined its case.
Background: Hudson’s Detroit project and competing domains
Bedrock developed Hudson’s Detroit, a mixed-use project located on the former J.L. Hudson Department Store site, and operates the property website at Hudsons-Detroit.com. That hyphenated domain is in active commercial use by Bedrock, which explains why the company wanted the unhyphenated HudsonsDetroit.com.
However, the registrant of HudsonsDetroit.com, Hassan Kadouh, registered the domain in February 2015. Kadouh explained the name reflected multiple personal connections: an homage to the J.L. Hudson department store where his grandmother worked, a studio located in a former Hudson Motor Car Company service facility, and his son Hudson, with whom he lives in Detroit. Historical records support Kadouh’s account of the domain’s creation date.
Key factual error in Bedrock’s complaint
In its complaint, Bedrock asserted the domain registration occurred in February 2026. That assertion was central to its allegation that Kadouh had registered the domain in bad faith to target Bedrock’s trademark. The mistake appears to have come from relying on the date the Whois record was last updated, rather than the domain creation date.
Despite receiving a registrar verification and an opportunity to amend its filing, Bedrock did not correct the registration date in its amended complaint. The panel noted that the very documents Bedrock filed contained the correct creation date directly beneath the update date that Bedrock misinterpreted.
Panelist findings and reasons for RDNH ruling
Panelist David L. Kreider concluded the complaint amounted to Reverse Domain Name Hijacking (RDNH) for three principal reasons:
- The complaint’s central factual assertion (that the domain was registered in 2026) was contradicted by evidence already in Bedrock’s possession, which showed the creation date as February 5, 2015.
- Bedrock persisted in the incorrect assertion even after receiving the registrar’s verification that supplied the creation date, and the amended complaint left the erroneous registration date unchanged.
- Bedrock was represented by trademark counsel throughout. A represented complainant is expected to establish and address the domain’s registration date, especially when that date predates any asserted rights. The complaint failed to provide any basis for a finding of bad faith given the earlier registration.
The panel emphasized it made no finding on the underlying trademark dispute about concurrent use of similar names. That issue lies within trademark law and was outside the scope of the UDRP proceeding. The panel’s decision focused strictly on the availability of the administrative route given the uncontested chronology and the complainant’s conduct.
Outcome and implications for domain disputes
Because the domain was created years before Bedrock had enforceable rights in the term “Hudson’s Detroit,” the panel found Bedrock could not show bad-faith registration by the respondent. The panel therefore determined the complaint was brought in bad faith and constituted Reverse Domain Name Hijacking under the UDRP rules, an abuse of the administrative process.
This decision underscores the importance of accurately verifying domain registration dates and other Whois information before filing a UDRP complaint. It also highlights the professional responsibility of trademark representatives to investigate foundational facts thoroughly. Filing a UDRP claim without confirming chronology risks not only losing the case but also being sanctioned by a finding of reverse domain name hijacking.
For trademark owners and domain registrants alike, this case is a reminder that domain disputes must be grounded in verified facts. Administrative proceedings like UDRP are designed to address clear-cut cases of bad-faith registration and use; they are not an appropriate mechanism when the contested domain predates asserted rights.