Panel Rules No-Code Company Glide Acted in Bad Faith in Failed UDRP Case
No-code app development company Typeguard, Inc., which does business as Glide and operates its website on the domain GlideApps.com, was found by a dispute panel to have attempted reverse domain name hijacking in a complaint over the domain glide.ai. The decision concluded that Glide pursued the UDRP complaint in bad faith after a failed purchase attempt and without adequate justification for claiming rights to the domain.
Earlier this year, Glide sought to acquire glide.ai through a brokered negotiation and made a formal offer of $103,750. According to the record, Glide stated at the time that it hoped the domain owner would respond with a counteroffer to begin negotiations. The domain owner, Narendra Ghimire, did not submit a counteroffer, and the transaction did not proceed.
A month after the failed negotiation, Glide filed a UDRP complaint with the World Intellectual Property Organization (WIPO) against the registrant of glide.ai. The panel reviewing the case determined that the complaint amounted to reverse domain name hijacking — a practice where a complainant uses the UDRP process to try to wrest control of a domain without a legitimate claim to trademark rights or evidence of bad faith on the part of the registrant.
The panel found several problems with Glide’s filing. First, the complaint failed to demonstrate that Glide had established a well-known trademark in the relevant market at the time the domain was registered. Under UDRP standards, a complainant must show they hold rights in a trademark that predate the domain registration or otherwise establish legitimate claim to the name. The panel concluded Glide did not meet this burden.
Second, the panel criticized omissions and misleading statements in the complaint. Glide cited multiple prior disputes involving the respondent but neglected to disclose that the respondent had prevailed in many of those matters. Transparency in presenting past decisions is important for panels to accurately assess patterns of conduct; omitting such outcomes undermines the credibility of a complainant’s case. The panel noted that these omissions suggested a lack of candor and reinforced the finding of bad faith.
Third, the panel observed aspects of how Glide presented its case that suggested the company treated the UDRP as a fallback option after a failed purchase attempt. The panel emphasized that the UDRP is not intended to serve as a substitution for negotiation leverage. The proceeding requires a demonstration of the registrant’s probable bad faith use or registration of the domain name, supported by evidence. A complainant’s subjective belief that it has a stronger commercial use for a name is not, by itself, sufficient to prove the registrant acted improperly.
The panel also highlighted that the complainant nominated two WIPO panelists who had previously ruled in the registrant’s favor in other proceedings. While parties may name preferred panelists, doing so without acknowledging prior adverse findings against them, when paired with selective case citations, further eroded the complainant’s presentation in this case.
In its decision, the panel wrote that Glide had “initiated the proceeding because it believed it had a more compelling use for the disputed domain name than Respondent” and that the UDRP requires a more robust showing — namely, a reasoned assessment of the registrant’s likely bad faith given the known facts. In short, the panel found the complaint lacked the necessary evidence to establish the registrant’s bad faith and, instead, reflected an attempt to obtain the domain through the UDRP after direct purchase efforts failed.
As a result of these findings, the panel concluded that the complaint constituted reverse domain name hijacking. That determination is notable because panels reserve the label of reverse domain name hijacking for clear instances where a complainant has brought a complaint in bad faith, either through intentional misrepresentations or by pursuing a claim that lacks substantive merit.
The domain owner, Narendra Ghimire, was represented in the proceedings by attorney John Berryhill. The case underscores several lessons for companies seeking domain names: document clear trademark rights predating any contested registration, avoid relying on negotiation failures as a basis for filing a UDRP, and present a complete and transparent record to the panel. When those steps are not followed, panels may view a filing as an improper attempt to deprive a registrant of a legitimately held domain.