Decision for dispute CAC-UDRP-108482

The Panel is not aware of any other legal proceedings that are pending or decided and that relate to the Disputed Domain Name.

Complainant states that it “has exclusive rights to Chinese trademarks such as MINIMAX, MiniMax and Minimax Intelligence in multiple categories, and also has exclusive rights to New Zealand, Singapore and Peru trademarks such as MINIMAX in multiple categories.” In support thereof, Complainant provides documentation showing its ownership of Madrid Reg. No. 842282A for the mark MINIMAX (registered February 5, 2004) for use in connection with, inter alia, “telecommunications”; New Zealand Reg. No. 1270412 for MINIMAX (registered August 2, 2024) for use in connection with, inter alia, “computer chatbot software for simulating conversations”; and Singapore Reg. No. 40202417422S for MINIMAX (registered March 18, 2025) for use in connection with, inter alia, “chaperoning.” These registrations are referred to herein as the “MINIMAX Trademark.”

The Complaint was filed on behalf of Shanghai Xiyu Jizhi Technology Co., Ltd. and Nanonoble PTE. LTD.  In response to a procedural order, Complainants state that each of these entities is “a 100% indirectly owned subsidiary of MiniMax Group Inc.”; that “both Complainants are under the ultimate common control of the same parent entity, MiniMax Group Inc., thereby constituting a single commercial entity for the purpose of this proceeding”; and that “[c]onsequently, their consolidation is procedurally appropriate and necessary to reflect the commercial reality of the MINIMAX brand ownership.”

While Shanghai Xiyu Jizhi Technology Co., Ltd. is the owner of the MINIMAX Trademark, it is unclear why the Complaint includes Nanonoble PTE. LTD as a party and, further, why the Complaint does not include MiniMax Group Inc. as a party.  See WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.4: “A trademark owner’s affiliate such as a subsidiary of a parent or of a holding company, or an exclusive trademark licensee, is considered to have rights in a trademark under the UDRP for purposes of standing to file a complaint. The same holds true for a parent company filing a UDRP case on the basis of rights held in the name of one of the companies or brands under its corporate umbrella.” Accordingly, the term “Complainant” as used herein shall refer to Shanghai Xiyu Jizhi Technology Co., Ltd.

Complainant states that it was founded in December 2021 and that it “launched the MINIMAX brand, which is widely used in connection with its artificial intelligence services and products and is commonly referred to in the market as MiniMax.” Complainant further states that “the MiniMax-M2 was officially released on October 27, 2025, as a native multimodal foundation model.” Complainant further states that “MiniMax” – presumably, MiniMax Group Inc. – “completed a round of financing of more than US$250 million in June 2023, with a value of more than US$1.2 billion” and that “[i]n 2024, Alibaba led a new round of financing for MiniMax, with an investment of up to US$600 million, making the company's valuation exceed US$2.5 billion.”

The Disputed Domain Name was created on October 28, 2025, and, according to the Complaint, “the content of the website associated with the Disputed Domain Name corresponds precisely to the Complainant's trading area and its M2 series technology.” An annex of a screenshot of the website refers to MiniMax M2” as “An Efficient Model for the Agentic Era.”

Complainant contends, in relevant part, as follows:

Paragraph 4(a)(i): Complainant states that the Disputed Domain Name is confusingly similar to the MINIMAX Trademark because “[t]he MINIMAX trademark is the dominant and most distinctive element within the Disputed Domain Name”; “the addition of the suffix ‘m2’ is far from coincidental and serves as a direct reference to the Complainant’s flagship technology”; and “the content of the website associated with the Disputed Domain Name corresponds precisely to the Complainant's trading area and its M2 series technology.”

Paragraph 4(a)(ii): Complainant states that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because, inter alia, “[t]he Respondent is not a distributor, partner, or licensee of the Complainant”; “[t]he Complainant has never directly or indirectly authorized the Respondent to use the MINIMAX trademark, the MiniMax brand, or any corresponding domain names in any form”; and “[t]he Complainant also conducted searches in various national and regional trademark databases under the Respondent's name and found no evidence that the Respondent holds any trademark rights in MINIMAX or MiniMax.”

Paragraph 4(a)(iii): Complainant states that the Disputed Domain Name was registered and is being used in bad faith because, inter alia, “[b]efore the disputed domain name was registered, MINIMAX had been widely reported in multiple media outlets worldwide, particularly following the high-profile launch of the MiniMax-M2 model on October 27, 2025”; “[t]he fact that the disputed domain name incorporates both the MINIMAX trademark and the specific ‘M2’ model identifier precludes any possibility that the Respondent’s registration was accidental”; “the Respondent created a website featuring content substantially similar to the Complainant’s official website,” which “demonstrates that the registration was a calculated move to capitalize on the specific commercial momentum of the Complainant's latest technology”; and “the website content associated with the disputed domain… features the Complainant’s stylized MiniMax logo, product videos, and specific imagery related to the M2 model, while also including multiple advertising pages.”

No administratively compliant response has been filed.

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 UDRP).

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 UDRP).

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 UDRP).

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.

Identical or Confusingly Similar: Paragraph 4(a)(i)

The documentation provided by Complainant is sufficient to establish that Complainant has rights in the MINIMAX Trademark.

As to whether the Disputed Domain Name is identical or confusingly similar to these trademarks, the relevant comparison to be made is with the second-level portion of the Disputed Domain Name only (i.e., “minimaxm2”) because “[t]he applicable Top Level Domain (‘TLD’) in a domain name (e.g., ‘.com’, ‘.club’, ‘.nyc’) is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test.”  WIPO Overview 3.1, section 1.11.1.

Here, the Disputed Domain Name contains the MINIMAX Trademark in its entirety. As set forth in section 1.7 of WIPO Overview 3.1: “[I]n cases where a domain name incorporates the entirety of a trademark…, the domain name will normally be considered confusingly similar to that mark.”

As to the addition of the “m2”, section 1.8 of WIPO Overview 3.1 says: “Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element.”

Accordingly, the Panel finds that Complainant has proven the first element of the Policy. 

Rights or Legitimate Interests: Paragraph 4(a)(ii)

Complainant states that Respondent has no rights or legitimate interests in respect of the Disputed Domain Name because, inter alia, “[t]he Respondent is not a distributor, partner, or licensee of the Complainant”; “[t]he Complainant has never directly or indirectly authorized the Respondent to use the MINIMAX trademark, the MiniMax brand, or any corresponding domain names in any form”; and “[t]he Complainant also conducted searches in various national and regional trademark databases under the Respondent's name and found no evidence that the Respondent holds any trademark rights in MINIMAX or MiniMax.”

WIPO Overview 3.1, section 2.1, states: “Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the often impossible task of ‘proving a negative’, requiring information that is often primarily within the knowledge or control of the respondent. As such, 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.”

The Panel finds that Complainant has established its prima facie case and, without any evidence from Respondent to the contrary, the Panel is satisfied that Complainant has satisfied the second element of the UDRP.

Registered and Used in Bad Faith: Paragraph 4(a)(iii)

Whether a domain name is registered and used in bad faith for purposes of the UDRP may be determined by evaluating four (non-exhaustive) factors set forth in paragraph 4(b) of the UDRP: (i) circumstances indicating that the registrant has registered or the registrant has 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 complainant, for valuable consideration in excess of the registrant’s documented out-of-pocket costs directly related to the domain name; or (ii) the registrant 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 registrant has engaged in a pattern of such conduct; or (iii) the registrant has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, the registrant has intentionally attempted to attract, for commercial gain, Internet users to the registrant’s 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 registrant’s website or location or of a product or service on the registrant’s website or location.

Creating a website using a domain name containing Complainant’s trademark to offer the same or similar services identified by the MINIMAX Trademark may create a likelihood of confusion and, therefore, constitutes bad faith.  See, e.g., Arla Foods amba v. Jucco Holdings, WIPO Case No. D2006-0409 (“the practice of registering a domain name and using it to redirect a user to a website which is used for the sale of competing services constitutes evidence of registering and using a trademark in bad faith”); Six Continents Hotels, Inc. v. NA InterMos, WIPO Case No. D2006-1313 (Respondent “intentionally uses the domain name… aiming to profit from Complainant’s renowned trademark by attracting Internet users. The confusion created by the domain name makes potential customers to choose other services than the Complainant’s, disrupting Complainant’s business.”); and Six Continents Hotels, Inc., v. Bunjong Chaiviriyawong, WIPO Case No. D2013-1942 (by using disputed domain name in connection with a website that “offers… services in competition with the Complainant… the Respondent, by such use, intentionally attempted to attract Internet users, expecting to reach the website corresponding to the Complainant’s services and to obtain information about the Complainant’s activity, to services related to another [company], by creating a likelihood of confusion with the Complainant’s trademark and business, and damaging the Complainant’s business”).

Accordingly, the Panel finds that Complainant has proven the third element of the Policy.