Another AI-assisted UDRP complaint?

Complainant cited cases that didn’t back up his claims or didn’t exist.

A UDRP panelist has admonished a Complainant for citing cases that didn’t back up the Complainant’s claims. At least one of the cases didn’t even exist.

Quincy Hall / Advice Only filed the dispute against the domain AdviceOnly.com.

There were many problems with Hall’s case, but the panelist found against him on the very first prong: whether the domain was identical or confusingly similar to a mark in which the Complainant has rights.

Under UDRP, having a registration on the U.S. Supplemental Register is not enough to show trademark rights. The Complainant provided a couple of other pieces of evidence of use, but none were enough to prove to the panelist that there were common law trademark rights.

Panelist Eugene I Low found this was a case of reverse domain name hijacking.

Low noted:

Complainant should have been aware of the inherent indistinctiveness of the mark and that the evidence adduced falls far short of meeting the evidential threshold of proving acquired distinctiveness. In other words, Complainant should have known that this Complaint could not have reasonably succeeded based on the submitted evidence.

Low also said he was “extremely troubled” by the case citations in the Complaint. They referred to cases that didn’t support Hall’s claims or that simply didn’t exist.

In some cases involving pro se Complainants, it seems they may have used AI tools to develop some of their arguments and citations. It’s not clear if that was the case here, but that excuse would be the best case for the Complainant.

Low wrote:

Whether or not Complainant did this deliberately, the Panel finds these “case citations” misleading. The Panel shares the observations in a recent decision (WIPO Case No. D2025-4174), in which the learned panelist found RDNH for, inter alia, the   mistakes/misquotations, the extent of mistakes/misquotations by Complainant as demonstrated above is unacceptable. Complainant has breached its certification as to the completeness and accuracy of the Complaint.