Decision for dispute CAC-UDRP-108620

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 relies on unregistered (common law) trademark rights in the designation “HappyHorse”. On April 7, 2026, a new AI video generation software was published anonymously under the name “HappyHorse” on the AI benchmarking platform Artificial Analysis. It received positive reviews and widespread attention immediately. On April 10, 2026, the Complainant revealed that it was the publisher of “HappyHorse”. The Complainant owns the corresponding domain names <happyhorse.com> (created September 23, 1997), <happyhorse.cn> (created on May 5, 2016), and <happyhorse.ai> (created April 13, 2023). Alibaba Innovation Private Limited, a wholly-owned indirect subsidiary of the Complainant, has filed various pending trademark applications for „HAPPYHORSE“ in Singapore, Canada and Mexico (all filed in April 9, 2026) and in the US (filed on April 10, 2026).

The disputed domain name <happyhorse-ai.com> was registered on April 7, 2026, i.e., on the same day that the „Happy Horse“ AI model was first published.

The Complainant is a multinational company that specializes in e-commerce, retail, the internet, and technology. Founded in China on June 28, 1999, it provides C2C, B2C, and B2B sales services via Chinese and global marketplaces. It also provides local consumer, digital media and entertainment, logistics, and cloud computing services. It hosts the world's largest B2B (Alibaba.com), C2C (Taobao), and B2C (Tmall) marketplaces.

In April 2026, the Complainant launched “HappyHorse-1.0”, an innovative artificial intelligence model designed to transform textual and visual content into video formats. On April 7, 2026, HappyHorse-1.0 appeared on the benchmarking platform Artificial Analysis without identifying its affiliation with the Complainant. The Artificial Analysis platform is a “video arena” where users submit a text prompt or reference image, and the system generates outputs from two different AI models. Users see both results without knowing which AI model produced which and then select their preferred result. As soon as HappyHorse-1.0 was launched on April 7, 2026, it placed at the top of both the text-to-video and image-to-video rankings on Artificial Analysis. On April 10, 2026, the Complainant publicly revealed that it was the publisher of the HappyHorse-1.0 AI model.

The Respondent originally used the disputed domain name <happyhorse-ai.com> for a website that promoted “HappyHorse AI” as the “new state-of-the-art AI video & audio model”. This website was not in any way connected to, affiliated with, or authorized by the Complainant or its group of companies. The website did not inform its users about this lack of connection, affiliation, or authorization.

On April 14, 2026, the Complainant’s representatives sent a cease-and-desist email to the Respondent, requesting that the Respondent stops using the disputed domain name for its website and transfers the domain name to the Complainant. The Respondent did not reply to this email, but deactivated the website described above, resulting in the disputed domain name now showing an empty web page.

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

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.

On June 3, 2026, the Panel issued a procedural order:

(i) inviting the Complainant to clarify the specific rights on which the Complaint is based by June 10, 2026;
(ii) inviting the Respondent to respond to the Complainant’s supplemental submission, if any, by June 17, 2026; and
(iii) postponing the projected decision date to June 19, 2026.

The Complainant filed a supplemental submission on June 10, 2026. The Respondent did not respond to the original Complaint or to this supplemental submission.

1.

The Panel accepts that the Complainant has established unregistered or common law trademark rights in the name “HappyHorse” for the purposes of the Policy, by demonstrating that “HappyHorse” has become a distinctive identifier among users of AI models and systems for the Complainant’s AI video generation software. The model name “HappyHorse-1.0” combines the product name “HappyHorse” with a version number (“-1.0”), allowing the relevant public to easily identify “HappyHorse” as the product name. The Panel accepts the Complainant’s contention that the positive reviews and widespread attention that the Complaint’s “HappyHorse” product received in the days and weeks following its release are sufficient evidence of the claimed unregistered or common law trademark rights. The Respondent did not challenge this contention.

The Policy does not require that the Complainant’s unregistered or common law trademark rights already existed on the date on which the disputed domain name was registered, i.e., on April 7, 2026. This timing factor is only relevant to the separate “bad faith” requirement of the Policy, which will be discussed below.

The disputed domain name is confusingly similar to the Complainant’s distinctive “HappyHorse” trademark. The only difference between the mark and the disputed domain name is the descriptive suffix “-ai”. This descriptive suffix does not diminish but rather emphasizes the overall impression that the disputed domain name is connected to the Complainant’s trademark.

2.

The Panel further finds that the Complainant successfully submitted prima facie evidence that the Respondent has neither made any use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services, nor is making a legitimate non-commercial or fair use of the disputed domain name, nor is commonly known under the disputed domain name. This even applies if the Respondent should have offered goods or services on his website that were related to the Complainant’s own “HappyHorse” AI model. According to the “Oki Data test”, the following cumulative apply in such a case (cf. Section 2.8 of the WIPO Overview 3.1):

(i) the Respondent must actually be offering the goods or services at issue;
(ii) the Respondent must use the site to sell only the trademarked goods or services;
(iii) the site must accurately and prominently disclose the Respondent’s relationship with the Complainant; and
(iv) the Respondent must not try to “corner the market” in domain names that reflect the trademark.

According to the prima facie evidence presented by the Complainant, the Respondent’s website did not comply with the third requirement of this Oki Data test. This is sufficient to conclude that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent did not challenge the Complainant’s prima facie evidence.

3.

The Panel further finds that the Complainant successfully submitted prima facie evidence that the Respondent has registered and used this disputed domain name in bad faith, namely by intentionally attempting to attract, for commercial gain, internet users to its website, by creating a likelihood of confusion with the Complainant's trademark as to the source, sponsorship, affiliation, or endorsement of the Respondent's website (paragraph 4(b)(iv) of the Policy).

The Respondent may have registered the disputed domain name before the Complainant accrued unregistered trademark rights. However, given the timing of events, namely:

- the public launch of “HappyHorse-1.0” on April 7, 2026;

- the social media buzz that the launch immediately created;

- the Respondent's registration of the disputed domain name on exactly the same date; and

- the Respondent's use of the disputed domain name for a website dealing with exactly the same subject matter as the Complainant's “HappyHorse” AI model;

It is clear that the Respondent intended to unfairly capitalize on the Complainant’s nascent trademark rights (cf. Section 3.8.2 of the WIPO Overview 3.1). Again, the Respondent did not challenge the Complainant’s prima facie evidence.