Entrepreneur files claim against domain registered before his trademarks
An Indian entrepreneur and fund manager has been found to have attempted reverse domain name hijacking in a dispute over the domain CEOAthlete.com. The World Intellectual Property Organization (WIPO) panel concluded that the complaint lacked a reasonable prospect of success because the domain predated the complainant’s asserted rights.
Anshul Singhal, who runs a leadership development platform styled as CEO Athlete, filed the UDRP claim against the domain registrant. Singhal relied on a series of trademark applications in India; however, all of those applications were still pending at the time of filing except for a figurative mark that only registered in December 2025.
The key factual point in the panel’s decision is timing: the disputed domain was registered on March 23, 2016—years before the complainant’s trademark registration and long before the bulk of his applications. The complaint did not put forward evidence of earlier rights, registered or unregistered, that would explain how a domain registered in 2016 could have targeted a brand that only emerged later.
The domain owner did not file a response to the complaint. In light of the registration date and the lack of earlier trademark rights, WIPO panelist David Taylor found the complaint to be an attempt at reverse domain name hijacking. The panel’s written decision emphasized that the determinative issue under the third element of the UDRP—whether the respondent registered and used the domain name in bad faith—should have been obvious from the record and from established UDRP principles.
“As noted above, the disputed domain name was registered on March 23, 2016, whereas the Complainant has sought to rely upon Indian trademark applications for CEO ATHLETE, one of which matured to registration only in 2025, nearly nine years after the Respondent registered the disputed domain name. No evidence of any earlier relevant rights, registered or unregistered, has been produced. On a plain reading of the Policy and well-established UDRP principles, the Complaint as filed lacked a reasonable prospect of success. The Complainant was represented by counsel and referred in its submissions to views as expressed in WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition and prior decisions, which underscores that the determinative timing issue under the third element of the Policy should have been apparent.”
The complainant was represented by Luthra & Luthra Law Offices. The panel’s finding serves as a reminder that UDRP complainants must have rights that predate a domain’s registration—or clear evidence of bad faith—to sustain a claim, and that bringing a complaint without such a foundation can lead to a reverse domain name hijacking determination.