Decision for dispute CAC-UDRP-108328

The Panel is not aware of any other legal proceedings which are pending or decided and which relate to the disputed domain name.

The Complainant owns multiple trademark registrations for WAN and WANX in jurisdictions including, inter alia, China, the European Union, and Hong Kong. Among the trademark portfolio of the Complainant, the "WAN" mark is protected in various jurisdictions including, among others, the following:

• United Kingdom TM No. UK00004164944, WAN, Nice Cl. 9, 42, registered on July 25, 2025; and
• Indonesia TM No. IDM001380513, WAN, Nice Cl. 42, 9, registered on September 18, 2025.

The Complainant is Alibaba Innovation Private Limited, a company affiliated with the Alibaba Group, a leading Chinese multinational conglomerate founded in 1999. The Group operates globally across sectors including, inter alia, e-commerce, cloud computing, and artificial intelligence. It is recognized as one of the world’s largest retail and AI enterprises, operating major platforms such as ALIBABA.COM, TAOBAO, and TMALL.

As part of its AI strategy, the Complainant developed WAN, a family of open-source multimodal video‑generation models. The brand evolved from the TONGYI WANXIANG model to WANX, and ultimately rebranded as WAN in February 2025. Recent iterations, specifically WAN 2.5 and WAN 2.6, have significantly advanced the Complainant's capabilities in high-quality video content creation.

The Complainant registered domain names such as <wanxai.com> and <wan.video>, which resolve to its official website https://wan.video/. Accordingly, the name WAN has become associated with the Complainant’s goods. The Complainant has made extensive use of the WAN mark on its website and on platforms such as GitHub and Hugging Face.

The disputed domain name was registered on November 30, 2025. The disputed domain name initially resolved to the website, which promoted the Complainant’s products, namely “WAN 2.5” and “WAN 2.6,” described as leading AI video generation models. The website used the Complainant’s trademarks within its content, falsely implying a connection or origin. Once the disputed domain name redirected to a third-party website where the Complainant’s products are displayed. Currently the disputed domain name resolves to an error page.

COMPLAINANT:

The Complainant contends that the requirements of the Policy have been met and that the disputed domain name should be transferred to it.

(i) The Complainant holds rights in the trademark WAN, as set forth in the "Identification of Rights" section above. The disputed domain name is confusingly similar to the Complainant’s trademark WAN, as it incorporates the mark in its entirety, followed only by the minus/dash symbol “-” and the numbers “2” and “6”, which directly correspond to the name of Alibaba’s AI video generation model “Wan 2.6” and the “.com” gTLD.

(ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is neither licensed to use the Complainant’s trademarks nor commonly known by the disputed domain name. Furthermore, the Respondent is not engaged in any bona fide offering of goods or services or any legitimate noncommercial or fair use. Instead, the Respondent uses the disputed domain name to unauthorizedly promote and sell the Complainant’s WAN AI video generation services, explicitly referencing the Complainant’s products. The Respondent’s website mimics the Complainant’s visual identity without any disclaimer, thereby misleading Internet users regarding the source of the website. The disputed domain name, registered on November 30, 2025, incorporates the Complainant’s "WAN" mark with the numbers "2" and "6", targeting the Complainant's WAN 2.6 product. This registration postdates the Complainant's rights, confirming the Respondent’s knowledge. Such impersonation and unauthorized commercial use cannot confer rights or legitimate interests under the Policy.

(iii) The disputed domain name was registered and is being used in bad faith. Given the Complainant’s established reputation in China, where the Respondent is located, the Respondent was undoubtedly aware of the Complainant's trademarks, including WAN and TONGYI WANXIANG. The domain name incorporates the WAN mark with the numbers "2" and "6", creating a confusing similarity to the Complainant’s specific product. Furthermore, the Respondent uses the website to display the Complainant’s content and unauthorizedly sell services for commercial gain, creating a likelihood of confusion regarding the source or affiliation of the website. Finally, the Respondent has established a pattern of bad faith conduct, evidenced by other infringing registrations and a previous adverse decision in International Business Machines Corporation v. Jian Liu. 

RESPONDENT:

The Respondent’s contentions can be summarized as follows:

(i) Regarding the consent to transfer and the Complainant's refusal to settle, the Respondent unequivocally consents to the transfer of the disputed domain name. The Respondent asserts that it provided full cooperation by previously submitting a formal consent to transfer and by signing and returning the Complainant's unilateral declaration on January 23, 2026. Despite this, the Complainant's representative refused to finalize the settlement because the Respondent could not immediately provide the transfer authorization code. The Respondent argues that providing an authorization code is technically impossible while the domain name is locked by the administrative proceedings, a fact confirmed by the Case Administrator. Additionally, regarding the request for identification, the Respondent's identity was already verified by the Registrar, and sending a personal identification document via email poses privacy risks. Therefore, the Respondent claims to have done everything in its power to resolve the dispute and asserts that the Complainant's insistence on continuing the proceeding is abusive. Consequently, the Respondent requests the Panel to simply order the transfer.

(ii) While the Respondent accepts the transfer due to trademark confusion, it firmly rejects the Complainant's allegations that it engaged in "malicious cybercrime," or "phishing." The Respondent submits a security scan report showing a clean score, arguing that the disputed domain name was technically safe and never used to distribute malware.

(iii) Regarding the allegation of mistaken identity, the Respondent contends that the Complainant improperly cited International Business Machines Corporation v. Jian Liu, WIPO Case No. D2021-0248, to allege a pattern of bad faith. The Respondent notes that "Jian Liu" is an extremely common name in China and explicitly denies being the respondent in the cited case. The Respondent argues that the Complainant failed to verify the Respondent's identity before making this accusation and requests the Panel to disregard this unfounded allegation.

The Complainant has, to the satisfaction of the Panel, shown the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights (within the meaning of paragraph 4(a)(i) of the Policy).

The Complainant has, to the satisfaction of the Panel, shown the Respondent to have no rights or legitimate interests in respect of the disputed domain name (within the meaning of paragraph 4(a)(ii) of the Policy).

The Complainant has, to the satisfaction of the Panel, shown the disputed domain name has been registered and is being used in bad faith (within the meaning of paragraph 4(a)(iii) of the Policy).

       A. Language of the Proceedings

The Panel notes that the Registration Agreement is in English, thereby making English the default language of the administrative proceeding. However, the Respondent submitted its Response in Chinese. On February 10, 2026, the Panel issued a Procedural Order directing the Respondent to submit a full English translation of the Response, by a specified deadline. On February 11, 2026, the Respondent timely submitted the full English translation of the Response. 

       B. Consent to Transfer

The Panel notes the following procedural history regarding the Respondent's consent to transfer the disputed domain name:

On January 22, 2026, the Respondent submitted a communication to the CAC expressing its unconditional consent to transfer the disputed domain name to the Complainant without contest. The Respondent indicated that it had removed all associated content and DNS records, thereby rendering the domain inactive. Furthermore, the Respondent stated its intention to waive its right to submit a formal response and requested that the Panel order an immediate transfer to efficiently terminate the proceeding.

On the same day, the CAC forwarded the Respondent's consent to the parties, advising that the parties could execute a standard settlement form to suspend the proceeding. In reply, the Complainant stipulated that it would only consider the settlement proposal and request a suspension if the Respondent first provided the domain’s transfer authorization code, a signed declaration, and a copy of its identification document.

On January 23, 2026, the Complainant informed the CAC of its decision not to execute the settlement form and its clear intention to proceed with the UDRP proceeding. Consequently, the CAC notified the parties that the proceeding would continue and confirmed that the Respondent had until February 9, 2026, to submit a formal response.

Finally, on February 9, 2026, the Respondent filed its Response, which formally reiterated its consent to transfer the disputed domain name containing a denial of the Complainant's allegations in the Complaint.

      C. The Panel’s Determination on the Issue of Consent to Transfer

Notwithstanding the Respondent’s unconditional consent to the transfer of the disputed domain name to the Complainant, given that the Complainant has requested to proceed with the UDRP proceeding, the Panel has determined to proceed to a decision on the merits of the case.

The Panel is satisfied that all procedural requirements under UDRP were met and there is no other reason why it would be inappropriate to provide a decision.

Paragraph 15(a) of the Rules for the UDRP ('the Policy') instructs this Panel to "decide a complaint on the basis of the statements and documents submitted 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 the 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 the Respondent's failure to submit a response, the Panel shall decide this administrative proceeding on the basis of the 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 and inferences set forth in the Complaint as true unless the evidence is clearly contradictory. See Vertical Solutions Mgmt., Inc. v. webnetmarketing, inc., FA 95095 (FORUM July 31, 2000) (holding that the respondent’s failure to respond allows all reasonable inferences of fact in the allegations of the complaint to be deemed true); see also Talk City, Inc. v. Robertson, D2000-0009 (WIPO Feb. 29, 2000) (“In the absence of a response, it is appropriate to accept as true all allegations of the Complaint.”). 

Rights

The Complainant asserts ownership of the registered trademark WAN, as identified in the “Identification of Rights,” section above. The Panel recognizes that an international or national trademark registration is sufficient to establish rights in a mark. Accordingly, the Panel finds that the Complainant has established its rights in the WAN trademark.

The Complainant further contends that the disputed domain name <wan2-6.com> is confusingly similar to its WAN mark, as it fully incorporates the WAN mark in its entirety, followed only by the minus/dash symbol “-” and the numbers “2” and “6”, which directly correspond to the name of Alibaba’s AI video generation model “Wan 2.6” and the “.com” gTLD. The Panel notes that the Respondent accepts the confusing similarity between the disputed domain name and the Complainant’s mark. Furthermore, the addition of a generic or descriptive term, together with a gTLD, does not suffice to distinguish a disputed domain name from a trademark. See SportScheck GmbH v. wu han yu chong shang mao you xian gong si, CAC-UDRP-107391 (CAC April 14, 2025) (“The addition of a generic or descriptive term and a gTLD does not sufficiently distinguish a disputed domain name from a trademark.”). Accordingly, the Panel finds that the disputed domain name is confusingly similar to the Complainant’s WAN mark. 

No rights or legitimate interests

A complainant must first make a prima facie case that a respondent lacks rights and legitimate interests in the disputed domain name under Policy paragraph 4(a)(ii), after which the burden shifts to the Respondent to demonstrate it does have rights or legitimate interests. See Section 2.1, WIPO Jurisprudential Overview 3.0 ("Where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element."). 

Relevant information, such as WHOIS data, can serve as evidence to demonstrate whether a respondent is or is not commonly known by the disputed domain name under Policy paragraph 4(c)(ii). The Panel notes that the WHOIS data lists "Jian Liu" as the registrant, and there is no evidence in the record indicating that the Respondent was authorized to use the mark. Therefore, the Panel finds that the Respondent is not commonly known by the disputed domain name under Policy paragraph 4(c)(ii). 

The Complainant asserts that the Respondent uses the disputed domain name to promote and sell the Complainant’s WAN AI video generation services without authorization, explicitly referencing the Complainant’s products. The Respondent’s website mimics the Complainant’s visual identity without any disclaimer, thereby misleading Internet users regarding the source of the website. The disputed domain name, registered on November 30, 2025, incorporates the Complainant’s "WAN" mark with the numbers "2" and "6," targeting the Complainant's WAN 2.6 product.

The Panel observes that the Respondent did not accurately and prominently disclose its lack of affiliation with the Complainant. Previously, the disputed domain name redirected to a third-party website where the Complainant’s products were displayed. Currently, the disputed domain name resolves to an error page. Although the disputed domain name no longer resolves to an active website, the foregoing facts demonstrate that the Respondent engaged in passing off by falsely presenting the disputed site as affiliated with the Complainant’s legitimate business. The Complainant has submitted screenshots of the website to which the disputed domain name resolved, alongside a screenshot of the Complainant’s original products.

The Panel finds that the Respondent’s website did not disclose its relationship, or lack thereof, with the Complainant. Accordingly, even if the Respondent was offering only the Complainant’s genuine goods, such use does not constitute a bona fide offering of goods or services under paragraph 4(c)(i), nor a legitimate noncommercial or fair use under paragraph 4(c)(iii) of the Policy. Furthermore, when the Respondent uses the disputed domain name to impersonate the Complainant, such conduct does not qualify as a bona fide offering or a legitimate noncommercial or fair use. See Würth International AG v. Mandy Mohr, CAC-UDRP-107275 (CAC March 17, 2025) (holding that the use of a domain name to feature the complainant’s mark and related content did not qualify as a bona fide offering or a legitimate noncommercial use under Policy paragraph 4(c)(i) or (iii)).

Based on the foregoing, the Panel finds that the Complainant has established a prima facie case against the Respondent. While the Panel notes the Respondent’s rejection of the Complainant's allegations regarding "malicious cybercrime," or "phishing," and its submission of a security scan report showing a clean score to argue that the disputed domain name was technically safe and never used to distribute malware, the Panel finds that this is insufficient to rebut the Complainant’s allegations of the Respondent’s passing off activities, and thus the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain name under paragraph 4(a)(ii) of the Policy. 

Bad faith

Paragraph 4(b) of the Policy provides a non-exclusive list of circumstances that evidence registration and use of a domain name in bad faith. Any one of the following is sufficient to support a finding of bad faith: 

(i) circumstances indicating that the respondent has registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that the complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or

(ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or

(iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the respondent’s website or location. 

The Complainant asserts that the Respondent registered and used the disputed domain name in bad faith by intentionally disrupting the Complainant’s business and seeking to attract Internet users to a competing website for commercial gain. The Panel notes that when a respondent impersonates a complainant through a disputed domain name, such conduct constitutes bad faith disruption of the complainant’s business under paragraph 4(b)(iii) of the Policy and reflects an intent to commercially benefit by creating confusion under paragraph 4(b)(iv) of the Policy. See Xiaomi Inc. v. Nguyễn Đức Đạt (N/A), CAC-UDRP-107237 (CAC Feb. 12, 2025) (finding that the respondent’s use of a disputed domain name to offer competing products disrupted the complainant’s business and misled Internet users by falsely suggesting affiliation with the complainant, thereby supporting a finding of bad faith registration and use under Policy paragraph 4(b)(iv)).

The Panel accepts the Respondent’s submission that (i) it rejects the Complainant's allegations that it engaged in "malicious cybercrime," or "phishing." The Respondent submits a security scan report showing a clean score, arguing that the disputed domain name was technically safe and never used to distribute malware, and (ii) the Complainant improperly cited International Business Machines Corporation v. Jian Liu, WIPO Case No. D2021-0248, to allege a pattern of bad faith. The Respondent notes that "Jian Liu" is an extremely common name in China and explicitly denies being the respondent in the cited case. The Respondent argues that the Complainant failed to verify the Respondent's identity before making this accusation and requests the Panel to disregard this unfounded allegation.

However, as previously noted, the Respondent’s website displayed the Complainant’s trademarks, thereby imitating the Complainant and misleading Internet users into believing that the website was affiliated with or endorsed by the Complainant. Following the Complainant’s cease-and-desist notice, the Respondent continued to exploit the Complainant’s trademarks by redirecting users to a third-party website that contains the same content. Currently, the disputed domain name resolves to an error page.

The Panel finds that the Respondent’s conduct was designed to impersonate the Complainant and mislead Internet users into believing they were interacting with the Complainant or with an authorized outlet. Such behavior not only creates a likelihood of confusion but also intentionally diverts consumers away from the Complainant’s official website, thereby interfering with the Complainant’s business operations and exploiting the goodwill associated with its mark for commercial gain. Accordingly, the Panel concludes that the Respondent’s conduct satisfies the criteria for bad faith registration and use under paragraphs 4(b)(iii) and 4(b)(iv) of the Policy.

Next, the Complainant contends that, given the Complainant’s established reputation in China, where the Respondent is located, the Respondent was undoubtedly aware of the Complainant's trademarks, including WAN and TONGYI WANXIANG. The Panel infers, due to the reputation of the Complainant’s WAN mark and the manner of use of the disputed domain name, in which the Respondent mimics the content of the Complainant’s website, that the Respondent registered the disputed domain name with actual knowledge of the Complainant’s rights in the WAN mark, thereby supporting a finding of bad faith registration.