Decision for dispute CAC-UDRP-108973

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

 

The Complainant is the owner of the following trademarks:

• Application no: M2602829, Registration no: 250940, Trademark: Szabó Kristóf (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41;

• Application no: M2602828, Registration no: 250939, Trademark: krisakaszik (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41.

 

FACTS ASSERTED BY THE COMPLAINANT AND NOT CONTESTED BY THE RESPONDENT:

THE COMPLAINANT

The Complainant, Szabó Kristóf, is a Hungarian online Content creator, media personality and Twitch Partner who has been active in the streaming industry since 2018 under the distinctive online name „aszabokristof".

While his earlier career focused on gaming titles like Warzone streaming under the online name "aszabokristof", his current content primarily features live casino streams and high-volatility online slot games using the “krisakaszik” online name and brand. His digital presence extends across multiple platforms such as TikTok, Instagram, and YouTube, where he shares highlights and personal updates having a strong influence within the Hungarian streaming market.

He has consistently used these names across his principal social media channels, including Instagram, TikTok and YouTube. The uniform use of the identifiers across several platforms has created a direct and established association between the names “aszabokristof” and “krisekaszik” and the Complainant.

The Complainant maintains the following significant social media presence:

• Instagram: the account operated under the username @aszabokristof has approximately 45,400 followers;
• TikTok: the account operated under the username @aszaboknstof has approximately 24,700 followers and shows 663.900 interactions (Likes); and;
• YouTube: the Complainant’s YouTube channel (@https://www.youtube.com/c/Szabó Kristóf09) has approximately 166,000 subscribers.

Development and subsequent changes to the Complainant’s online names.

The Complainant has used different online names during the development of his streaming and content-creation activities. The Complainant originally operated under the name 'aszabokristof for online game streaming. His Instagram account continues to use the handle @aszabokristof, although the posts previously published on the account are no longer publicly available. The Complainant also operated a YouTube channel under his name which was subsequently renamed "Nosztalgiacsati". Nevertheless, the channel remains accessible through its original customised URL youtube.com/c/SzabóKristóf09, thereby preserving the connection between the channel and the Complainant's identity.

The Complainant later used the name “krisakaszik' in connection with his Twitch activities related to casino and online gambling activities. That name is no longer displayed on Twitch because the relevant channel was subsequently rebranded as PADREBOBO. A separate Twitch account remains available at twitch.tv/aszabokristof, although the Complainant no longer actively uses that account and it does not currently contain published content.

These subsequent renamings, rebrandings and changes in activity do not alter the fact that the Complainant previously used 'aszabokristof and 'krisakaszik' as distinctive identifiers of his online persona and content-creation activities. They explain why some historical content is no longer publicly visible under the former names, while the remaining account names, customised URLs and platform records continue to evidence the Complainant's earlier use of those identifiers.

The Complainant’s YouTube channel has generated substantial viewing figures, including individual videos with several hundred thousand views and certain videos exceeding one million views. His substantial subscriber and follower numbers demonstrate that the name “aszabokristof” has been exposed to and recognised by a significant section of the Hungarian online public. The available public records identify the Instagram account as belonging to Szabó Kristóf and show tens of thousands of followers, while the YouTube channel had approximately 166,000 subscribers in material indexed before 2 December 2025.

Importantly, this social media presence was established well before 2 December 2025 and 23 April 2026 when the disputed domain names were registered. The Complainant had already used the identifiers “aszabokristof” and ”krisakaszik” for several years in connection with his online entertainment, gaming and promotional activities. Following the subsequent rebranding of certain accounts, the audience and follower base built under those earlier identifiers have remained connected to the Complainant through the channels he currently operates, including 'PADREBOBO' and 'NOSZTALGIACSATI'.

A GamingZion article published on 22 April 2025, several months before the registration of the disputed domain names, included KRISAKASZIK among its list of the six leading Hungarian gambling streamers. The article described him as a distinctive figure in the Hungarian streaming community, providing independent third-party evidence that the KRISAKASZIK name had already acquired public recognition before December 2025.

The scale, duration and consistency of this use demonstrate that, before the registration of the disputed domain names, the names “aszabokristof” and “krisakaszik” had acquired significant public recognition and functioned as a distinctive identifier of the Complainant and his online activities. The evidence therefore supports the conclusion that the Complainant had established unregistered trademark or service mark rights in the names “aszabokristof” and “krisakaszik” before December 2025 and April 2026, the date on which the disputed domain names were registered.

The Complainant did not use these identifiers merely as informal usernames. He used them consistently to identify his streaming and content-creation services, to communicate with his audience and to conduct monetised promotional and commercial activities. The public therefore came to recognise “aszabokristof” and “krisakaszik” as identifiers of the Complainant and the commercial content and services originating from him.

The Complainant is the owner of the following trademarks:

• Application no: 812602829, Registration no: 250940, Trademark: Szabó Kristóf (word mark), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41;

• Application no: M2602828, Registration no: 250939, Trademark: krisakaszik (word mark), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41.

The disputed domain names <aszabokristofbonus.com> and <krisakaszikbonus.com> (hereinafter, the „Disputed Domain Names“) were registered as follows:

• <aszabokristofbonus.com> on 23 April 2026.

The Disputed Domain Name resolves to a Hungarian-language commercial website centered entirely on the identity and online name of the Complainant, Szabó Kristóf, who is known online as “aszabokristof”. The website prominently displays the name ‘aszabokristof’, identifies the Complainant as a Hungarian Twitch Partner streamer, reproduces an image of him and invites visitors to follow his casino streams and discover purportedly recommended casino offers.

The primary commercial purpose of the website is to promote online casino sign-up packages. Under the heading “Kaszinó Üdvözlőcsomagok” (“Casino Welcome Packages”), the website states that the listed online casinos are recommended by the “aszabokristof stream”. It advertises, among other things, a 350% bonus of up to EUR 2,000 plus 200 free spins and a 400% bonus of up to HUF 6,000,000 plus 400 free spins. Each offer is accompanied by prominent calls to action labelled “BÓNUSZ FELVÉTELE” (“Claim Bonus”) and “RÉSZLETEK & FELTÉTELEK” (“Details & Terms”).

The website also contains an extensive biographical section about the Complainant, describing him by his civil name, Szabó Kristóf, recounting his streaming career and presenting the ‘aszabokristof’ name as an established online brand.

Although a disclaimer at the bottom of the website states that it is not the Complainant’s official website, the same footer expressly confirms that the casino offers contain affiliate links. The disclaimer therefore does not alter the commercial nature of the website or prevent the website from creating an impression of association with, endorsement by or commercial connection to the Complainant. 

• <krisakaszikbonus.com> on 2 December 2025.

The Disputed Domain Name resolves to a Hungarian-language commercial website entitled “Krisakaszik – Stream, Online Kaszinó és Exkluzív Bónuszok” (“Krisakaszik – Stream, Online Casino and Exclusive Bonuses”). The website presents itself as a source of “official information”, current casino offers and community events relating to the Complainant’s online identity ‘krisakaszik’.

The website prominently promotes online casino welcome packages. It advertises, among other things, a 350% bonus of up to EUR 2,000 plus 200 free spins and a 400% bonus of up to HUF 6,000,000 plus 400 free spins, accompanied by active calls to action labelled “BÓNUSZ FELVÉTELE” (“Claim Bonus”) and “RÉSZLETEK & FELTÉTELEK” (“Details & Terms”).

The website is specifically and extensively themed around the Complainant. It identifies Szabó Kristóf as being known online as “Krisakaszik”, describes his Twitch casino and conversational streams and characterises him as one of Hungary’s most viewed and influential iGaming and online casino content creators.

The website also expressly connects the ‘krisakaszik’ identity with the Complainant’s earlier ‘aszabokristof’ identity. Under the heading “Az Aszabokristof korszaktól a Kaszinóig” (“From the Aszabokristof Era to Casino”), it states that the Complainant’s digital presence can be traced back to his “aszabokristof” period and describes the change to ‘krisakaszik’ as a rebranding associated with his move into casino-related content.

The website further refers to the Complainant’s alleged management, commercial partners and casino promotions, thereby reinforcing the appearance that it is authorised by, affiliated with or commercially connected to the Complainant. The title appearing throughout the website describes it as the “Krisakaszik Official Fan Page”, while the footer states that the website is intended for informational purposes and does not itself organise gambling. These statements do not dispel the likelihood of confusion created by the Disputed Domain Name, the extensive appropriation of the Complainant’s identity and the prominent promotion of casino offers.

According to Complainant’s non-contested allegations, the Respondent has no rights or legitimate interest in respect of the Disputed Domain Names, and the Complainant is not related in any way to the Complainant’s business.

For this case, the Registrar confirmed that the language of the registration agreement is English. The facts asserted by the Complainant are not contested by the Respondent.

 

• COMPLAINANT:

 First element: Similarity

The Complainant bases his Complaint on the following rights and additionally refers to the consensus opinion of prior UDRP panels that registration of the domain name prior to the filing date of the trademark registration is irrelevant for the purposes of Paragraph 4(a)(i) of the Policy.

The Complainant is the owner of registered Hungarian trademarks for the terms “Szabó Kristóf” and “krisakaszik” as listed below:

• Application no: M2602829, Registration no: 250940, Trademark: Szabó Kristóf (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41;

• Application no: M2602828, Registration no: 250939, Trademark: krisakaszik (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41

Considering that the registration date of the Disputed Domain Names pre-dates the registration of the trademarks in which the Complainant has rights, the Complainant refers to Section 1. 1. of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”).

According to case law the term "trademark or service mark” as used in UDRP paragraph 4(a)(i) encompasses both registered and unregistered (sometimes referred to as common law) marks. Also, the filing/priority date, date of registration are not considered relevant to the first element test. These factors may however bear on a panel's further substantive determination under the second and third elements.

Complainant cites different earlier decisions from UDRP case law to demonstrate that according to the consensus opinion of prior UDRP panels registration of the domain name prior to the filing date of the trademark registration is irrelevant for the purposes of Paragraph 4(a)(i) of the Policy.

2. Confusing similarity between the Szabó Kristóf trademark and <aszabokristofbonus.com>

The Complainant owns rights in the word trademark: Szabó Kristóf. The Disputed Domain Name <aszabokristofbonus.com> incorporates the Complainant's trademark in its entirety, subject only to the omission of spaces and diacritical marks, which cannot be reproduced in the ordinary format of the Disputed Domain Name.

The relevant second-level portion of the Disputed Domain Name may be separated as follows: a + szabokristof + bonus.

The element “szabokristof” is plainly and immediately recognisable as the Complainant's trademark Szabó Kristóf and his personal name. The omission of the accents from the letters as well as the omission of the space between the first name and surname, are purely technical and orthographic differences that do not affect the visual, phonetic or conceptual recognisability of the trademark.

The letter “a” appearing before "szabokristof” is not a random or distinctive addition. In Hungarian, "a" is the definite article corresponding to the English word "the”. Its presence therefore does not alter the identity or meaning of the incorporated name. On the contrary, the expression “a Szabó Kristóf” may be understood by Hungarian-speaking Internet users as referring to “the Szabó Kristóf” or to the particular person known by that name.

The further element "bonus" is an ordinary and descriptive commercial term. lt is particularly suggestive in the present context because the corresponding website promotes online casino welcome packages and sign-up bonuses. The addition of this term does not prevent the Complainant’s trademark from remaining clearly recognisable within the Disputed Domain Name.

Furthermore, the coinciding element is the most impactful element due to its position in the beginning of the Disputed Domain Name. lt is well-established trademark law principle that consumers generally tend to focus on the beginning of a sign when they encounter a trade mark. This is because the public reads from left to right, which makes the part placed at the left pf the sign (the initial Part) the one that first catches the attention of the reader. Thus, high similarity of the contested domain name with the Complainant’s trademark “Szabó Kristóf” and his personal name can be established.

Under the established UDRP test, the first element functions primarily as a standing requirement and involves a relatively straightforward comparison between the trademark and the Disputed Domain Name. Where a domain name incorporates the entirety of a trademark or where the trademark remains recognisable within it, the domain name will normally be considered confusingly similar. The addition of a descriptive or other term does not prevent such a finding.

The combination of “Szabó Kristóf” with suggestive but related terms could suggest improperly to consumers that the Disputed Domain Name and corresponding websites might be directly controlled or authorized by the Complainant. This argument is supported by findings stated in WIPO case 02021-3728, namely that the Disputed Domain Name incorporates the trademark in its entirety, this is sufficient for showing confusing similarity under the Policy.

The generic Top-Level Domain “.com” is a standard technical registration requirement and is generally disregarded for the purposes of the comparison under paragraph 4(a)(i) of the Policy.

Accordingly, neither the Hungarian definite article nor the descriptive term "bonus", nor the omission of accents and spaces prevents the trademark “Szabó Kristóf” from being immediately recognisable in the Disputed Domain Name. Indeed, the addition of the term “bonus” may increase the likelihood that internet users will understand the Disputed Domain Name as referring to a website operated, authorised or endorsed by the Complainant in connection with promotional offers.

The Complainant therefore submits that the Disputed Domain Name <aszabokristofbonus.com> is confusingly similar to the Complainant's “Szabó Kristóf” trademark for the purposes of paragraph 4(a)(i) of the Policy.

3. Confusing Similarity between the krisakaszik tradermark and <krisakaszikbonus.com>.

The Complainant also owns rights in the word trademark “krisakaszik”. The Disputed Domain Name incorporates that trademark identically and in its entirety as its initial and dominant element.

The relevant second-level portion of the Disputed Domain Name may be separated as follows: krisakaszik + bonus.

The element “krisakaszik” is identical to the Complainant's trademark krisakaszik. The only additional element is the word “bonus”, which is a common descriptive and promotional term.

The addition of the term “bonus” does not prevent the trademark from being clearly recognisable in the Disputed Domain Name. Under the established UDRP approach, where the relevant trademark is recognisable within the Disputed Domain Name, the addition of another term—whether descriptive, geographical, meaningless or otherwise—does not avoid a finding of confusing similarity under the first element of the Policy.

In the present case, the added term is also directly related to the content of the corresponding website, which promotes online casino welcome packages and other promotional offers. The term “bonus” therefore does not distinguish the Disputed Domain Name from the Complainant’s trademark. Instead, reinforces the impression that the domain name identifies a website connected with promotional offers made by, authorised by or otherwise associated with the Complainant under the “krisakaszik” brand.

The generic Top-Level Domain “.com” is a technical registration element and should be disregarded in the comparison under paragraph 4(a)(i) of the Policy.

The Disputed Domain Name therefore consists of the Complainant's trademark in its entirety followed by a descriptive commercial term. The trademark remains immediately and unambiguously recognisable within the Disputed Domain Name.

The Complainant accordingly submits that the Disputed Domain Name <krisakaszikbonus.com> is confusingly similar to the Complainant’s 'krisakaszik' trademark for the purposes of paragraph 4(a)(i) of the Policy.

Panels consistently hold that if the trademark is recognizable within the domain name, confusing similarity exists. This applies even where elements are added, removed, modified or structure is slightly changed. Adding or modifying terms does not avoid confusing similarity if the mark remains identifiable.

Based on the cases listed above and with reference to the WIPO Overview 3.1., Section 1.7, in the UDRP practice confusing similarity is assessed by a side-by side comparison of the mark and domain name. Furthermore, it is well established practice that exact identity is not required; recognizability of the mark is enough.

The Complainant avers that the top-level domain name “.com” is required only for technical reasons and can be ignored for the purposes of comparison of the Disputed Domain Name to the Complainant's marks, as is common in UDRP proceedings.

4. Website Content reinforces confusing similarity.

Although the assessment under the first element of the UDRP is principally based on a comparison between the Complainant’s trademarks and the Disputed Domain Names, panels may also take account of the content of the associated websites where that content confirms that the respondent is targeting the complainant or its mark.

In the present case, the content of both websites reinforces, rather than dispels, the confusing similarity between the Disputed Domain Names and the Complainant's trademarks.

The website at <aszabokristofbonus.com> is centred entirely on the Complainant's identity. lt prominently uses the name “aszabokristof”, identifies the Complainant by his civil name, “Szabó Kristóf”, describes him as a Hungarian Twitch Partner streamer and reproduces his image. lt also invites visitors to follow his streams and discover purported casino offers associated with him.

The same website presents casino welcome packages as offers recommended by the "aszabokristof stream" and prominently displays commercial Calls to action for claiming bonuses. lt further contains an extensive biography of the Complainant, describes his streaming career and repeatedly uses the name “aszabokristor” as the identifier of his online persona and brand.

The website also refers to the Complainant's Twitch channel, social-media presence, gaming history, audience, monetisation model and online activities in considerable detail. lt lists his Twitch, TikTok, Instagram and YouTube presence and presents these platforms as part of a single online ecosystem supporting the “aszabokristof” brand.

Likewise, the website at <krisakaszikbonus.com> is expressly devoted to the Complainant and the ‘krisakaszik’ mark. Its principal heading reads “Krisakaszik – Stream, Online Casino and Exclusive Bonuses”, and the website presents itself as a source of official information, casino offers and community events relating to that name.

The website identifies Szabó Kristóf as being known online as ‘krisakaszik’, describes his Twitch activities and characterises him as a prominent Hungarian iGaming and online casino content creator. It also promotes substantial casino welcome packages immediately alongside this biographical content.

Significantly, the website expressly links the Complainant’s two online identities. Under the heading “From the Aszabokristof Era to Casino”, it explains that the Complainant previously operated under the name ‘aszabokristof’ and later rebranded as ‘krisakaszik’. This connection demonstrates that the Respondent was not merely using coincidentally similar expressions, but was specifically aware of and targeting the Complainant’s established online identities and marks.

The website further refers to the Complainant’s alleged management, commercial relationships, partners, streaming style, community terminology and promotional activities. It thereby creates the overall impression of an official, authorised or commercially connected website devoted to the Complainant and his business activities.

Taken together, the reproduction of the Complainant’s names, images, biography, career history, social-media presence, online aliases, audience and commercial activities strongly confirms that the Disputed Domain Names were deliberately selected to target the Complainant’s trademarks. The addition of the term “bonus” does not distinguish the Disputed Domain Names. Rather, in light of the casino-promotional content of the websites, it reinforces the impression that the websites provide bonus offers authorised, recommended or endorsed by the Complainant.

Accordingly, the website content supports the conclusion that the Disputed Domain Names were chosen with the Complainant and his trademarks specifically in mind and confirms the confusing similarity between:

• the Szabó Kristóf trademark and <aszabokristofbonus.com>; and
• the krisakaszik trademark and <krisakaszikbonus.com>.

With reference to section 1.15 of the WIPO Overview 3.1, the Complainant submits that the content of the websites associated with the Disputed Domain Names confirms that the Respondent is targeting the Complainant’s marks and may therefore support a finding of confusing similarity.

The Complainant submits that it has established rights in the ‘SZABÓ KRISTÓF’ and ‘krisakaszik’ trademarks for the purposes of the Policy. Each Disputed Domain Name incorporates the relevant trademark in a clearly recognisable form, and the associated website content expressly targets the Complainant, his identity and his commercial activities. Accordingly, the disputed domain names are confusingly similar to the Complainant’s trademarks under paragraph 4(a)(i) of the Policy.

5. Initial interest confusion

The Complainant asserts that the Disputed Domain Names are in and of themselves confusing. Such “initial interest confusion” is inevitable given that the Disputed Domain Names are confusingly similar to the Complainant’s personal name, trade name and trademarks as detailed above.

Therefore, the Complainant contends that Internet users who type the Disputed Domain Names into their browsers or see them among search engine results or in e-mail addresses would reasonably assume that they were operated, sponsored or endorsed by the Complainant.

As such, the Complainant contends that the Disputed Domain Names are, in and of themselves, confusingly similar to the Complainant’s trademarks

SUMMARY:

The Complainant owns registered trademark rights in ‘Szabó Kristóf’ and ‘krisakaszik’. The Disputed Domain Name <aszabokristofbonus.com> incorporates the Complainant’s ‘Szabó Kristóf’ mark in a clearly recognisable form, with only the Hungarian definite article “a” placed before it and the descriptive term “bonus” added after it. Likewise, <krisakaszikbonus.com> incorporates the ‘krisakaszik’ mark identically and in its entirety, followed only by the descriptive term “bonus”. These additions do not prevent a finding of confusing similarity, and the generic Top-Level Domain “.com” should be disregarded for the purpose of the comparison. Accordingly, the Disputed Domain Names are confusingly similar to trademarks in which the Complainant has rights.

In all these circumstances, taken individually or cumulatively, the Complainant contends that the first UDRP element has been established, namely that the Respondent’s Disputed Domain Names are identical or confusingly similar to a name, trade mark or service mark in which the Complainant has rights.

Second element: Rights or legitimate interest

The Complainant must establish a prima facie case that the Respondent lacks rights or legitimate interests in the Disputed Domain Names <aszabokristofbonus.com> and <krisakaszikbonus.com>. Once such a prima facie case has been established, the burden of production shifts to the Respondent to demonstrate rights or legitimate interests in the Disputed Domain Names.

Accordingly, the Complainant seeks to make out a prima facie case to demonstrate that the Respondent does not have rights or legitimate interests in the Disputed Domain Names.

The Complainant submits that the Respondent has no rights or legitimate interests in either Disputed Domain Name for the following reasons:

1. No authorisation and Respondent not commonly known by the names

The Respondent is not commonly known by the Disputed Domain Names and no prior use (Policy 4(c)(ii))

There is no evidence that the Respondent is commonly known by either “aszabokristofbonus”, “krisakaszikbonus”, “aszabokristof” or “krisakaszik” prior to or after the registration of the Disputed Domain Names. The publicly available registration data does not identify the Respondent by any of these names, and the Respondent has used a privacy service in connection with both registrations.

The Complainant has found no evidence that the Respondent owns any trademarks incorporating the term ‘Szabó Kristóf’ or ‘krisakaszik’. Equally, the Complainant has found no evidence that the Respondent has ever traded legitimately under the business name ‘Szabó Kristóf’ or ‘krisakaszik’.

Respondent is not a licensee of the Complainant and has not received any permission, consent or acquiescence from the Complainant to use its ‘Szabó Kristóf’ and ‘krisakaszik’ marks or its variations in association with the registration of the Disputed Domain Names or, indeed, any domain names, services or products.

In the circumstances of the present case, the Respondent’s actual use of the Disputed Domain Names does not confer rights or legitimate interests, because the websites target the Complainant, falsely suggest affiliation and promote commercial casino offers.

2. No bona fide offering of goods or services and no legitimate non-commercial or fair use

The Complainant reiterates that the Respondent has no rights or legitimate interests in the Disputed Domain Names. The Respondent’s use is not incidental or descriptive and amounts to trademark infringement: it has adopted ‘Szabó Kristóf’ and ‘krisakaszik’ as a brand and domain name in the same commercial field as the Complainant. This is clear commercial use taking commercial advantage of the Complainant’s reputed brands.

Both Disputed Domain Names resolve to commercial websites that appropriate the Complainant’s identity, online aliases, biography, images and streaming activities in order to promote online casino offers and sign-up bonuses.

The website at <aszabokristofbonus.com> presents casino welcome packages as offers recommended by the “aszabokristof stream” and invites users to claim substantial promotional packages, including a 350% bonus of up to EUR 2,000 plus 200 free spins and a 400% bonus of up to HUF 6,000,000 plus 400 free spins.

Similarly, the website at <krisakaszikbonus.com> is presented as a website concerning “krisakaszik”, online casino streaming and exclusive bonuses. It identifies the Complainant by name, describes his activities and promotes substantially the same types of casino welcome packages through prominent calls to action.

The website at <aszabokristofbonus.com> expressly states that the casino offers displayed on the website contain affiliate links. The Respondent is therefore using a domain name incorporating the Complainant’s identity to attract Internet users and redirect them to commercial casino offers for financial gain.

Commercial Exploitation is evidenced via Affiliate Marketing statement: The commercial nature of the site at <aszabokristofbonus.com> is explicitly admitted by the Respondent in the footer of the website, which states: "The casino offers on the page contain affiliate links" ("Az oldalon lévő kaszinó ajánlatok affiliate linkeket tartalmaznak"). Using a domain name that incorporates a Complainant's mark to divert traffic to commercial affiliate links for referral commission does not constitute a bona fide offering of goods or services under Paragraph 4(c)(i) or a legitimate non-commercial or fair use under Paragraph 4(c)(iii) of the Policy.

Although the materials presently available for <krisakaszikbonus.com> do not contain the same express affiliate-link disclosure, that website is also plainly commercial in nature. It prominently promotes casino bonuses, identifies alleged casino partners and invites visitors to claim promotional packages. This use is neither legitimate non-commercial use nor fair use under paragraph 4(c)(iii) of the Policy.

The websites falsely suggest an official or authorised connection. The overall content and presentation of both websites create the impression that they are official, authorised or commercially connected with the Complainant. Both websites make extensive use of the Complainant’s names, online aliases, personal history, images, social-media activities and casino-related content.

The website hosted under the Disputed Domain Name <aszabokristofbonus.com> is a commercial affiliate portal dedicated to online casino referrals. The website features high-value promotional "Casino Welcome Packages" ("Kaszinó Üdvözlőcsomagok") that are falsely framed as being "recommended by the aszabokristof stream" ("Az aszabokristof stream által ajánlott online kaszinók"). Visitors are directed to click call-to-action buttons such as "BÓNUSZ FELVÉTELE" (Claim Bonus) to redeem offers like a "350% bonus up to €2,000 + 200 free spins" and a "400% bonus up to 6,000,000 HUF + 400 free spins".

The website at <krisakaszikbonus.com> even presents itself as a “Krisakaszik Official Fan Page” and refers to “official information”, casino offers and community events. Such wording increases, rather than removes, the likelihood that users will believe that the website has been authorised by the Complainant.

Such use is calculated to create the impression that the websites and casino promotions are authorised, recommended or endorsed by the Complainant. Use of the Complainant’s marks and identity in this manner cannot constitute a bona fide offering under paragraph 4(c)(i) of the Policy.

Such use cannot constitute a bona fide offering of goods or services. Where a respondent adopts a domain name confusingly similar to an earlier trademark and uses it for competing services, that conduct trades on the goodwill of the trademark owner and is properly characterized as infringing or misleading use, not legitimate trade. The Respondent’s offering therefore cannot establish rights or legitimate interests under paragraph 4(c)(i) of the Policy.

Complainant referred to some applicable cases.

Nor is the Respondent commonly known by the Disputed Domain Names in any legitimate sense. Any claimed association with the name ‘Szabó Kristóf’ and ‘krisakaszik’ arises only from the Respondent’s own adoption of a sign that is confusingly similar to the Complainant’s trademarks and used in direct competition with the Complainant’s services. A respondent cannot create a legitimate interest merely by developing a website or writing blog articles if the domain name itself was selected to trade on or interfere with the trademark owner’s goodwill. A respondent cannot create a legitimate interest by selecting and using a confusingly similar name for competing services after the Complainant’s trademark rights and market presence already existed.

In summary, use that deliberately trades on the goodwill associated with the Complainant’s marks and falsely suggests affiliation cannot constitute a bona fide offering under paragraph 4(c)(i) of the Policy.

3. Disclaimers do not create rights or legitimate interests, and the Respondent cannot establish rights or legitimate interests on the basis of alleged fan-site use

Lastly, the Complainant submits that the disclaimer does not create rights or legitimate interests.

The footer of the website at <aszabokristofbonus.com> states that the website is not the official website of aszabokristof and was created for entertainment and informational purposes. This disclaimer confirms that the Respondent is aware that it has no official relationship with the Complainant. However, the disclaimer does not cure the misleading nature of the Disputed Domain Name or the website. It appears only after the Respondent has already used the Complainant’s identity to attract users and promote commercial casino offers. Nor can a disclaimer create rights or legitimate interests where the domain name itself falsely suggests affiliation and the website is operated for commercial gain.

The Respondent cannot establish rights or legitimate interests in the Disputed Domain Name <krisakaszikbonus.com> by characterising the corresponding website as a “fan page”.

Section 2.7.1 of the WIPO Overview 3.1 provides that, for purposes of assessing fair use under paragraph 4(c)(iii) of the Policy, a fan or informational site must be active, genuine, and clearly distinct from any official website of the complainant. The overview further recognises that purported fan or informational sites may constitute merely a pretext for cybersquatting. Where, as here, the Disputed Domain Name incorporates the Complainant’s trademark together with an additional term, the Panel must consider the overall circumstances, including the composition of the domain name, the content of the corresponding website, whether the site creates an impression of affiliation, and whether the use is genuinely fair. WIPO Overview 3.1, sections 2.5 and 2.7.

The Disputed Domain Name does not itself signal that it is operated by an independent fan. Rather, it combines the Complainant’s ‘krisakaszik’ mark with the directly relevant term “bonus”. In the context of the Complainant’s gambling-related online presence, the term “bonus” naturally refers to casino and gambling promotions. The resulting domain name therefore appears to designate a website connected with, endorsed by, or operated in association with the Complainant, rather than an independent fan website.

Although the footer of the website states that it is intended only for informational purposes and does not itself organise gambling — “Ez az oldal csak információs célokat szolgál, és nem szervez szerencsejátékot” — the website prominently displays casino offers, including welcome packages and calls to action inviting visitors to claim bonuses. The website therefore goes materially beyond providing information about, or expressing admiration for, the Complainant. It uses the Complainant’s identity and ‘krisakaszik’ mark as a means of attracting Internet users to gambling-related commercial promotions.

Section 2.7.3 of the WIPO Overview 3.1 confirms that, where a domain name combines a trademark with an additional descriptive or laudatory term, a legitimate interest may arise only where the use is fair in all of the circumstances. The non-commercial nature of a genuine fan site weighs in favour of fair use, and panels have accepted only limited incidental commercial activity in appropriate circumstances, for example to offset domain-name registration or hosting costs. The commercial gambling promotions appearing on <krisakaszikbonus.com> are plainly of a different character. They form a prominent and substantive part of the website and are directly connected with the meaning of the additional term “bonus” appearing in the disputed domain name.

The Disputed Domain Name itself combines the Complainant’s mark with a commercially meaningful gambling term, while the corresponding website prominently promotes casino bonuses. Rather than merely discussing or celebrating the Complainant, the Respondent is taking advantage of the attraction of the Complainant’s identity and trademark to draw Internet users to gambling promotions.

The disclaimer at the bottom of the website does not cure this conduct. As recognised in WIPO Case No. D2025-4169, a disclaimer is not determinative where the domain name and the overall presentation of the website nevertheless suggest that the website operates with the trademark owner’s approval or authorisation. Internet users are first attracted by the disputed domain name itself, and the Respondent cannot create an initial misleading impression of affiliation and then rely on a footer disclaimer to establish fair use.

Accordingly, the Respondent’s use of <krisakaszikbonus.com> is neither a genuine fan-site use nor legitimate non-commercial or fair use within paragraph 4(c)(iii) of the Policy. The purported “fan page” characterisation is contradicted by the commercial nature of the website and does not confer any rights or legitimate interests on the Respondent.

Crucially, using disclaimers on both websites, the Respondent acknowledges its lack of rights or legitimate connection to the Complainant. These disclaimers operate as an explicit admission that the Respondent has no official relationship with the Complainant, yet continues to commercially exploit the Complainant's identity without authorization. The websites feature high-value promotional "Casino Welcome Packages" that are falsely framed as being "recommended by the aszabokristof stream" ("Az aszabokristof stream által ajánlott online kaszinók").

Summary: The Respondent was not authorised to use the Complainant’s marks, is not commonly known by the Disputed Domain Names and used the websites to promote commercial casino offers while falsely suggesting an association with the Complainant. The use was neither bona fide nor genuinely non-commercial or fair. The Complainant has therefore established a prima facie case that the Respondent has no rights or legitimate interests in the Disputed Domain Names.

Based on the above, the Complainant argues that the Respondent’s use is commercial, competitive, and brand-identifying. It is not non-commercial fair use, commentary, criticism, or a merely descriptive use. The Respondent therefore has no rights or legitimate interests in the Disputed Domain Names.

Accordingly, the Respondent’s use of <aszabokristofbonus.com> and <krisakaszikbonus.com> does not amount to a bona fide offering of services, does not reflect legitimate trademark use in trade, and does not give rise to any rights or legitimate interests in the disputed domain names.

In all these circumstances, taken individually or cumulatively, the Complainant asserts that it has established a prima facie case along the lines anticipated by section 2.1 of the WIPO Overview 3.1 that the Respondent has no rights or legitimate interests in the disputed domain names.

Third element: Bad faith

The Complainant asserts that the Respondent by using the domain names, 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.

Furthermore, the Complainant asserts that the Respondent has registered the Disputed Domain Names primarily for the purpose of disrupting the business of a competitor.

1. Knowledge and deliberate targeting

The Complainant submits that the Respondent had actual knowledge of the Complainant and his marks. The Respondent’s deliberate targeting is demonstrated by the following circumstances:

As detailed above, the Complainant has built a highly distinctive personal brand and online reputation under the monikers ‘aszabokristof’ and ‘krisakaszik’ as a Hungarian Twitch Partner streamer since 2018. The Respondent was undeniably aware of the Complainant's identity and reputation when registering the Disputed Domain Names.

The websites are entirely constructed around the Complainant's persona, featuring:

• Detailed biographical information about Szabó Kristóf (the Complainant's real name), his career trajectory, and how he became a known Hungarian streamer.
• Explicit descriptions of the Complainant's live streaming schedule, slot gaming content, and Twitch Partner status.
• Details regarding the Complainant's gaming equipment setup ("loadout") and live streaming metrics (e.g., 10,000+ followers).
• Direct links to the Complainant's actual off-platform social media profiles (such as Twitch, TikTok, Instagram, and YouTube).
• Sections addressing community discussions, rumours, and Reddit threads regarding the Complainant.

The registration of a domain name incorporating a highly specific and unique streamer name, coupled with a website entirely themed around that exact individual, leaves no doubt that the Respondent registered the Disputed Domain Names in bad faith with the Complainant's brand directly in mind.

Given that the Disputed Domain Names are confusingly similar to the Complainant’s personal name and trademarks, the Complainant asserts that it is inconceivable that the Respondent did not have the Complainant firmly in mind when registering them.

2. Intentional attraction for commercial gain – paragraph 4(b)(iv)

As detailed above, the Respondent is using <aszabokristofbonus.com> and <krisakaszikbonus.com> to attract Internet users to commercial websites offering competing services.

The Respondent’s commercial use of the confusingly similar signs for the same services is the relevant bad-faith conduct.

Taken together, these elements show a clear pattern of conduct: (1) impersonating or trading on the Complainant’s brand, trademarks and personal name through the domain names, (2) creating consumer confusion as to source or affiliation, and (3) redirecting users to a competing service for commercial gain. This conduct constitutes bad faith use under established domain name dispute principles, as the Respondent is intentionally attempting to attract internet users by creating a likelihood of confusion with the Complainant’s marks, and then diverting them to a competitor’s website. Accordingly, the use of <aszabokristofbonus.com> and <krisakaszikbonus.com> is in bad faith.

Under Paragraph 4(b)(iv) of the Policy, bad faith is established where a Respondent intentionally attempts to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement.

Here, the Respondent has registered the domain names containing the Complainant's trademarks and personal name plus the commercial descriptive term "bonus" to capture search queries from fans and viewers looking for bonuses associated with the Complainant. The website at <aszabokristofbonus.com> expressly contains affiliate links. The website at <krisakaszikbonuscom> likewise promotes numerous casino partners and invites visitors to claim casino bonuses, demonstrating a plainly commercial purpose even though the available materials do not contain an express affiliate-link disclosure. This way the Respondent is trading off the goodwill of the Complainant’s marks to generate click-through referral commissions. This directly disrupts the Complainant's ability to control his brands, channel store, and monetisation avenues.

The presence of the footer disclaimer ("This page is not the official page..." or “This site is for informational purposes only and does not organize gambling.”) does not cure the Respondent’s bad faith. On the contrary, it reinforces it. The disclaimers on both websites are located at the bottom of the page, whereas initial interest confusion arises when Internet users search for the Complainant’s marks and arrive at either of the Disputed Domain Names. By the time the user might read the disclaimers, they have already been successfully diverted to the Respondent’s commercial sites and exposed to commercial casino offers and, in the case of <aszabokristofbonus.com>, expressly disclosed affiliate links, which is the precise commercial objective of the Respondent.

This evidence demonstrates that the ‘aszabokristof’ and ‘krisakaszik’ trade name were used prior to the registration of the Disputed Domain Names and were already widely known within its niche market segment. Therefore, it is difficult to believe that the Respondent was unaware of the Complainant’s existence and its branding when registering the Disputed Domain Names.

The website content therefore confirms that the Disputed Domain Names were selected to target the Complainant’s ‘aszabokristof’ and ‘krisakaszik’ trade names and the ‘Szabó Kristóf’ and ‘krisakaszik’ trademarks and supports a finding of confusing similarity.

Knowledge and targeting may be inferred from the circumstances, including the identity of the market, the overlap in services, the same audience.

Accordingly, the Disputed Domain Names <aszabokristofbonus.com> and <krisakaszikbonus.com> were registered and are being used in bad faith.

3. Bad faith under paragraph 4(b)(iii): disruption of a competitor

The Complainant further submits that the Disputed Domain Names were registered and are being used primarily for the purpose of disrupting the business of a competitor within the meaning of paragraph 4(b)(iii) of the Policy.

The Complainant conducts commercial streaming and promotional activities under the ‘aszabokristof’ and ‘krisakaszik’ brands, including casino-related content and commercial partnerships. The Respondent uses the Disputed Domain Names to target the same audience and to promote competing casino offers by exploiting the Complainant’s names, reputation and online identity.

By presenting unauthorised casino promotions as being associated with or recommended by the Complainant, the Respondent diverts Internet users and potential commercial opportunities away from the Complainant and interferes with the Complainant’s ability to control the use and monetisation of his brands. To the extent that the Respondent receives affiliate commissions or other commercial benefits from such referrals, the Respondent competes with the Complainant for the same Internet traffic and commercial audience.

Accordingly, the registration and use of the Disputed Domain Names disrupt the Complainant’s business and constitute further evidence of bad faith under paragraph 4(b)(iii) of the Policy

4. Concealment and absence of genuine contact information

The Complainant argues that the use of a privacy service by the Respondent is indicative of bad faith.

The Complainant does not rely on the use of a privacy service as independent proof of bad faith. However, in combination with the trademark-targeting websites, the absence of genuine operator details and the unauthorised use of the Complainant’s manager’s contact information, the Respondent’s concealment is an additional factor supporting bad faith.

The Complainant refers to section 3.6 of WIPO Overview 3.1. As noted above, the Respondent has not provided genuine or effective operator contact information on the websites.

The Complainant asserts that the use of the privacy shield, and false or incomplete contact information in the WhoIS and on the websites is indicative of the Respondent’s bad faith as it demonstrates that the Respondent seeks to conceal itself from the Panel and the Complainant.

The Complainant further submits that the circumstances surrounding the Respondent’s contact information support a finding of registration and use in bad faith. The Respondent’s identity is concealed through privacy services, and neither website provides a reliable means of contacting the person responsible for registering and operating the Disputed Domain Names.

The website at <aszabokristofbonus.com> does not identify its operator or provide any contact details for the domain-name holder. Although the website contains various navigation links, the publicly available page does not disclose an e-mail address, name or other effective means of contacting the Respondent.

The website at <krisakaszikbonus.com> contains a “Contact” link; however, according to the Complainant’s evidence, the contact page does not identify or provide contact details for the Respondent and instead refers users to the contact information of the Complainant’s manager, without authorization. The Respondent has therefore appropriated the Complainant’s representative’s details while withholding its own identity and contact information.

Consequently, the Complainant had no effective means of identifying the Respondent or sending a cease-and-desist letter directly to the person controlling the Disputed Domain Names. The concealment of the Respondent’s identity, combined with the absence of genuine operator contact details and the unauthorised use of the Complainant’s manager’s information, further supports the conclusion that the Disputed Domain Names were registered and are being used in bad faith.

Summary:

The Complainant does not rely on the Respondent’s use of a privacy service as independent proof of bad faith. However, the Respondent concealed its identity while operating websites that specifically targeted the Complainant and did not provide genuine contact information for their operator. The website at <aszabokristofbonus.com> disclosed no effective operator contact details, while the contact page at <krisakaszikbonus.com> listed the Complainant’s manager’s contact information without authorisation rather than identifying the Respondent. These circumstances prevented the Complainant from contacting the actual operator and provide an additional indication of bad faith. 

5. Blocking of the websites in Hungary does not cure the prior bad-faith use

At the time of the Complaint, the Disputed Domain Names did not resolve to functioning websites when accessed from Hungary because the Hungarian Supervisory Authority for Regulatory Affairs had blocked access to them. The Complainant understands that this blocking measure is territorial, and the websites may remain accessible from other jurisdictions.

In any event, the subsequent blocking or suspension of the websites does not alter their documented prior use. The annexes presented show that the Respondent previously used the Disputed Domain Names to target the Complainant and promote casino offers for commercial purposes. That earlier conduct remains relevant to the assessment of registration and use in bad faith.

6. Fictitious or materially inaccurate registrant information

The registrant information disclosed by the Registrar provides further evidence of bad faith. For both Disputed Domain Names, the Registrar identified the same purported registrant, “Kateiva Kazimieras”, with the same e-mail address, telephone number and postal address:

75 Palemonas prospektas, Vilkomiria, LT-45798, Lithuania
E-mail: citarnosis89@gmail.com
Telephone: +380 738955593

The same details are repeated in the registrant, administrative, technical and billing contact fields for both domain names.

The purported postal address appears to be fictitious or, at a minimum, materially inaccurate and internally inconsistent.

• “Vilkomiria” is not the current name of a Lithuanian city. It is a historical form of the name of present-day Ukmergė; official information published by Ukmergė municipality confirms that “Vilkomiria” appears as a historical name in old chronicles and that the city has officially been known as Ukmergė since 1918;
• the disclosed street designation, “Palemonas prospektas”, does not correspond to the ordinary contemporary form of the relevant Lithuanian street name identified in public sources;
• the Registrar data place “Lithuania” in the City field, while Lithuania is simultaneously identified as the country, further demonstrating that the address information is improperly structured; and
• the telephone number provided by the purported Lithuanian registrant begins with +380, which is the international calling code for Ukraine, rather than Lithuania.

Taken together, these discrepancies strongly indicate that the Respondent supplied fictitious, incomplete or materially inaccurate contact information when registering the Disputed Domain Names. This is particularly significant in circumstances where the Respondent simultaneously used a privacy service, provided no genuine operator information on the websites and, in the case of <krisakaszikbonus.com>, used the Complainant’s manager’s contact information instead of disclosing its own.

The provision of apparently fictitious or materially inaccurate registration details is therefore an additional factor supporting the conclusion that the Respondent sought to conceal its identity and avoid accountability for its trademark-abusive conduct, and further supports a finding of bad faith.

Summary: The Respondent registered the Disputed Domain Names with actual knowledge of the Complainant and deliberately used them to attract Internet users to casino promotions by creating a false impression of affiliation or endorsement. The detailed appropriation of the Complainant’s names, images, biography and online activities, together with the commercial website content and concealment of the actual operator, establishes registration and use in bad faith under paragraphs 4(a)(iii) and 4(b)(iv) of the Policy.

Based on the above, the Complainant asserts that the disputed domain names were registered and are being used in bad faith (Policy, paras. 4(a)(iii), 4(b); Rules, para. 3(b)(ix)(3))

The Complainant therefore concludes that in all these circumstances, taken singly or cumulatively, that on balance it is more likely than not that the Disputed Domain Names were registered and are used in bad faith within the meaning of the Policy.

The Complainant asserts that the Respondent, by registering and using the Disputed Domain Names, has intentionally attempted to attract, for commercial gain, Internet users to his website or other online location, by creating a likelihood of confusion with the ‘aszabokristof’ and ‘krisakaszik’ brands, personal name and trademarks as to the source, affiliation, or endorsement of it’s website or location or of a product or service on his website or location (paragraph 4(b)(iv) of the Policy).

RESPONDENT

Respondent did not reply to the Complaint.

 

The Complainant has, to the satisfaction of the Panel, shown the Disputed Domain Names are 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 Names (within the meaning of paragraph 4(a)(ii) of the Policy).

 

The Complainant has, to the satisfaction of the Panel, shown the Disputed Domain Names have been registered and are 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.

 

Preliminary Issue: Consolidation of Complaint consolidated against multiple respondents

Paragraph 10(e) of the UDRP Rules grants a Panel the power to consolidate multiplate domain name disputes. At the same time, paragraph 3(c) of the UDRP Rules provides that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder. 

In assessing whether a complaint can be filed against multiple respondents, panels look at whether (i) the domain names or corresponding websites are subject to common control, and (ii) the consolidation would be fair and equitable to all parties. Procedural efficiency would also underpin panel consideration of such a consolidation scenario.

See paragraph 4.11.2 of the WIPO Overview 3.1.

The Complainant requested this Panel to analyze the possibility that the Disputed Domain Names and the named Respondent should be consolidated in a single UDRP proceeding. The Registrar’s disclosure dated 9 September 2026 showed that the Disputed Domain Names were registered by same person so there is no need to analyze in more detail this specific aspect.

PRINCIPAL REASONS FOR THE DECISION

According to Paragraph 4(a) of the Policy, the complainant is required to prove each of the following three elements to obtain an order that a domain name should be transferred or cancelled:

(i) the domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and

(ii) the respondent has no rights or legitimate interests in respect of the domain name; and

(iii) the domain name has been registered and are being used in bad faith.

The Panel has reviewed in detail the evidence available to it and has come to the following conclusions concerning the satisfaction of the three elements of paragraph 4(a) of the Policy in the proceeding:

THE DISPUTED DOMAIN NAMES ARE CONFUSINGLY SIMILAR TO THE MARKS OF THE COMPLAINANT.

As described at WIPO Overview 3.1, section 1.7., the first element functions primarily as a standing requirement and the standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the complainant’s trademark and the Disputed Domain Names.

In this vein, this element requires the Panel to consider: i) if the Complainant has rights in a relevant mark; and ii) if the Disputed Domain Names are identical or confusingly similar to that mark.

As to the first point, the Complainant has confirmed that it is the owner of the following two trademark registrations:

• Aplication no: M2602829, Registration no: 250940, Trademark: Szabó Kristóf (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41; 
• Application no: M2602828, Registration no: 250939, Trademark: krisakaszik (word), Registration date: 28 August 2026, Place: Hungary, Int. Class: 41.

The Panel acknowledges that the Disputed Domain Names were registered before the registration of the Complainant’s trademarks. However, it is well-established under the UDRP that the first element serves as a standing requirement; i.e. the Policy makes no specific reference to the date on which the holder of the trademark or service mark acquired rights as long the trademark rights are in existence at the time the complaint is filed.

See paragraph 1.1.3. of the WIPO Overview 3.1.

In the current case, the Disputed Domain Names <aszabokristofbonus.com> and <krisakaszikbonus.com> are composed as follows:

• <aszabokristofbonus.com>; includes the trademark “Szabó Kristóf” with the only inclusion of the vowel “a” before the trademark plus the addition of the generic term “BONUS”;

• <krisakaszikbonus.com>; includes the trademark “krisakaszik” with the only addition of the generic term “BONUS”.

In assessing confusing similarity, the Panel finds the Disputed Domain Names are confusingly similar to the Complainant’s trademark, as it incorporates the entirety of the Complainant’s trademarks plus the generic term “BONUS” in both cases. For the case of the Disputed Domain Name <aszabokristofbonus.com>, it also includes an “a” before the trademark, however and as indicated by the Complainant, in the Hungarian language this vowel is the definite article equivalent to "the" in English, used before nouns starting with a consonant.

In this regard, UDRP panels agree that 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. See paragraph 1.8. of the WIPO Overview 3.1.

UDRP panels agree that the TLD may usually be ignored for the purpose of determination of identity or confusing similarity between a domain name and the Complainant’s trademark as it is technical requirement of registration. See paragraph 1.11.1 of WIPO Overview 3.1. Therefore, the Panel concludes that the Complainant has satisfied the requirement under paragraph 4(a)(i) of the Policy and the Disputed Domain Names are confusingly similar to Complainant’s marks.

RESPONDENT’S LACK OF RIGHTS OR LEGITIMATE INTERESTS IN THE DISPUTED DOMAIN NAMES.

The second element of the Policy requires that the Complainant establishes that the Respondent has no rights or legitimate interests in the Disputed Domain Names. The generally adopted approach by UDRP panels, when considering the second element, is that if a complainant makes out a prima facie case, the burden of proof shifts to the respondent to rebut it - see WIPO Overview 3.1., paragraph 2.1.

The Complainant submits that the Respondent has never been authorized, expressly or impliedly, to use its trademarks or to register any domain name incorporating or confusingly similar to them. The Complainant further states that it has no relationship with the Respondent and that there is no evidence the Respondent owns any trademark or trade name corresponding to the Disputed Domain Names.

The record contains no indication that the Respondent has been commonly known by the Disputed Domain Names within the meaning of paragraph 4(c)(ii) of the Policy. The use of a privacy protection service, coupled with the absence of any evidence of a personal, corporate, or other legitimate identifier matching the Disputed Domain Names, supports the conclusion that the Respondent is not commonly known by it.

Furthermore, the Complaint argues that it does not have any relationship with the Respondent whatsoever. Finally, the Complainant indicated that there is no evidence that the Respondent has acquired any rights in a trademark or trade name corresponding to the Disputed Domain Names.

From the information provided by the Complainant, there is no evidence or reason to believe that the Respondent (as an individual, business or other organization) has been commonly known by the Disputed Domain Names.

The Respondent name “Kateiva Kazimieras” provided in the Registrars verification dated 09 September 2026 is all what it links the Disputed Domain Names with the Respondent. Absent of any other evidence such as a personal name, nickname or corporate identifier, the Panel is of the opinion that the Respondent is not commonly known by the Disputed Domain Names.

In terms of the evidence provided by the Complainant, the websites connected to the Disputed Domain Names have been used as follows:

• <aszabokristofbonus.com>: the Disputed Domain Name resolves to a Hungarian-language commercial website centered entirely on the identity and online name of the Complainant, Szabó Kristóf, who is known online as “aszabokristof”. The website prominently displays the name ‘aszabokristof’, identifies the Complainant as a Hungarian Twitch Partner streamer, reproduces an image of him and invites visitors to follow his casino streams and discover purportedly recommended casino offers. The primary commercial purpose of the website is to promote online casino sign-up packages. Under the heading “Kaszinó Üdvözlőcsomagok” (“Casino Welcome Packages”), the website states that the listed online casinos are recommended by the “aszabokristof stream”. It advertises, among other things, a 350% bonus of up to EUR 2,000 plus 200 free spins and a 400% bonus of up to HUF 6,000,000 plus 400 free spins. Each offer is accompanied by prominent calls to action labelled “BÓNUSZ FELVÉTELE” (“Claim Bonus”) and “RÉSZLETEK & FELTÉTELEK” (“Details & Terms”). The website also contains an extensive biographical section about the Complainant, describing him by his civil name, Szabó Kristóf, recounting his streaming career and presenting the ‘aszabokristof’ name as an established online brand. The website includes a disclaimer at its bottom stating that it is not the Complainant’s official website and that the website is only intended for entertainment and informational purposes. Furthermore, the disclaimer’s part also indicates that the casino offers on the site contain affiliate links.

• <krisakaszikbonus.com>: the Disputed Domain Name resolves to a Hungarian-language commercial website entitled “Krisakaszik – Stream, Online Kaszinó és Exkluzív Bónuszok” (“Krisakaszik – Stream, Online Casino and Exclusive Bonuses”). The website presents itself as a source of “official information”, current casino offers and community events relating to the Complainant’s online identity ‘krisakaszik’. The website prominently promotes online casino welcome packages. It advertises, among other things, a 350% bonus of up to EUR 2,000 plus 200 free spins and a 400% bonus of up to HUF 6,000,000 plus 400 free spins, accompanied by active calls to action labelled “BÓNUSZ FELVÉTELE” (“Claim Bonus”) and “RÉSZLETEK & FELTÉTELEK” (“Details & Terms”). The website is specifically and extensively themed around the Complainant. It identifies Szabó Kristóf as being known online as “Krisakaszik”, describes his Twitch casino and conversational streams and characterises him as one of Hungary’s most viewed and influential iGaming and online casino content creators. The website also expressly connects the ‘krisakaszik’ identity with the Complainant’s earlier ‘aszabokristof’ identity. Under the heading “Az Aszabokristof korszaktól a Kaszinóig” (“From the Aszabokristof Era to Casino”), it states that the Complainant’s digital presence can be traced back to his “aszabokristof” period and describes the change to ‘krisakaszik’ as a rebranding associated with his move into casino-related content. The website further refers to the Complainant’s alleged management, commercial partners and casino promotions, thereby reinforcing the appearance that it is authorised by, affiliated with or commercially connected to the Complainant. The title appearing throughout the website describes it as the “Krisakaszik Official Fan Page”, while the footer states that the website is intended for informational purposes and does not itself organise gambling.

The Respondent presents the websites associated with both Disputed Domain Names as fan or informational sites. One website state that it is not the Complainant’s official website and is intended only for entertainment and informational purposes; the other describes itself as «Krisakaszik Official Fan Page”. These descriptions, however, must be assessed against the websites’ content and use.

Under WIPO Overview 3.1., section 2.7.1., a fan or informational site must be active, genuine, and clearly distinguishable from the complainant’s official website. Panels examine whether the claimed purpose instead serves as a pretext for cybersquatting. Here, both websites advertise online casino welcome packages, including bonuses. The Complainant submits that these promotions reveal a commercial purpose inconsistent with the Respondent’s claimed informational or fan-related use.

The relevant assessment is contextual. The WIPO Overview 3.1., sections 2.5.2 and 2.5.3 identify commercial links, misleading presentation, and whether the website genuinely supports its claimed purpose as relevant considerations. Although section 2.7.3 of the WIPO Overview 3.1. recognizes that some commercial activity may be permissible, for example to offset registration or hosting costs, the Complainant submits that the casino promotions here constitute substantive commercial advertising rather than incidental support for a genuine fan site.

Nor do the websites’ descriptions establish their independence from the Complainant. The designation “Krisakaszik Official Fan Page” reinforces, rather than dispels, an impression of official authorization. Under section 2.5.2 of the WIPO Overview 3.1. clarity about the website’s independent operation is relevant to fair use. Further, section 3.7. of the WIPO Overview 3.1. explains that a disclaimer cannot cure bad faith where the overall circumstances otherwise establish it.

This reasoning is supported by the WIPO Case Nr. D2017- 0892 Casumo Media Limited v. WhoisGuard, Inc. / Bonus Network concerning <casumocasinobonus.com> and <casumofreespins.net> where the Panelist indicated the following:

“The Domain Names do not resolve to any bona fide offering of goods or services by the Respondent. Even if the Respondent has claimed that it is “planning to use as a review for casumo bonuses and comparison of them to other available offers in the industry”, there is no evidence to back this allegation, and there is no evidence that such use would be non-commercial, which is a requirement for criticism or fan-sites to be generate rights and legitimate interests under the UDRP. There are many UDRP decisions where the respondent argues that the domain name is being used for a free speech purpose but the panel finds that it is primarily a pretext for commercial advantage”.

Accordingly, the Complainant submits that the Respondent’s fan-site and informational-site descriptions do not establish legitimate non-commercial or fair use under paragraph 4(c)(iii) of the Policy. The casino advertising, considered together with the websites’ presentation, supports the conclusion that the Respondent is using the Disputed Domain Names to exploit the Complainant’s reputation for commercial purposes.

Therefore, the Panel concludes that neither the Respondent nor the evidence establishes that the Respondent has any right or legitimate interest to the Disputed Domain Names. The Complainant has therefore also satisfied the requirement under paragraph 4(a)(ii) of the Policy.

THE DISPUTED DOMAIN NAMES HAVE BEEN REGISTERED AND ARE BEING USED IN BAD FAITH IN ACCORDANCE WITH THE POLICY.

Paragraph 4(a)(iii) of the Policy indicates that Complainant must assert that the Respondent registered and are using the Disputed Domain Names in bad faith. In this sense, Paragraph 4(b) of the Policy sets out four circumstances which if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:

(i) circumstances indicating that the Respondent has registered or acquired the Disputed Domain Names primarily for the purpose of selling, renting, or otherwise transferring the Disputed Domain Names 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 Respondent’s documented out-of-pocket costs directly related to the Disputed 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 Respondent has engaged in a pattern of such conduct; or

(iii) The Respondent has registered the Disputed Domain Names primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the Disputed Domain Names, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to the Respondent’s website or other on-line 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.

As above indicated, the Complainant filed the complaint against the Disputed Domain Names <aszabokristofbonus.com> registered on 23 April 2026 and <krisakaszikbonus.com> registered on 2 December 2025 based on the trademarks registered on 28 August 2026; i.e. almost 8 months after the registration of the Disputed Domain Names.

The UDRP doctrine is clear in the sense that only in exceptional cases would a complainant be able to prove a respondent’s bad faith where a domain name has been registered before a Complainant has acquired trademark rights.

Those certain limited circumstances are mainly found where the facts of the case establish that the respondent’s intent in registering the domain name was to unfairly capitalize on the complainant’s nascent (typically as yet unregistered) trademark rights. Such scenarios include registration of a domain name: (i) shortly before or after announcement of a corporate merger, (ii) further to the respondent’s insider knowledge (e.g., a former employee), (iii) further to significant media attention (e.g., in connection with a product launch or prominent event), or (iv) following the complainant’s filing of a trademark application.

To be able to assess whether this case can be considered as an exceptional one, the Complainant needs to show first of all that it had unregistered rights or common law trademark rights acquired by the time the Disputed Domain Names were registered.

In this regard, to establish unregistered or common law trademark rights for purposes of the Policy, the complainant must show that its mark has become a distinctive identifier which consumers associate with the complainant’s goods and/or services.

Relevant evidence demonstrating such acquired distinctiveness (also referred to as secondary meaning) includes a range of factors such as (i) the duration and nature of the use of the mark (which may include social media presence and engagement), (ii) the amount of sales under the mark and during which time period, (iii) the nature and extent of advertising using the mark – including evidence of expenditures over a relevant time period, (iv) the degree of actual public (e.g., consumer, industry such as trade and professional associations, media) recognition, and (v) consumer surveys. The fact that a respondent is shown to have been targeting the complainant’s mark (e.g., based on the manner in which the mark is used on the related website or impersonating documents or other instruments) may also support the complainant’s assertion and evidence that its mark has achieved significance as a source identifier.

See sections 1.1.3 and 3.8.1 & 3.8.2. of WIPO Jurisprudential Overview 3.1.

In order to support the claim connected with the two trademarks, the Complainant provided with the following evidence:

• Printouts and screenshots of Complainant's TikTok, Instagram, and YouTube accounts related to the name “aszabokristof” where activity and/or mentions of this username can be seen at least dated 2020;

• Printouts and screenshots of Complainant’s TikTok, Instagram, and YouTube accounts related to the name “krisakaszik” where activity under this username can be seen during 2025 either through the Instagram account or under the website www.krisakaszik.com in accordance with the information provided via The Way Back Machine;

• Printouts and screenshots of Complainant's YouTube account related to the name “nosztalgiacsati” – which is displayed under the following URL: https://www.youtube.com/c/SzabóKristóf09 and where activity can be traced at least since 2020;
  
  
• Printout of Complainant's Twitch account related to the name 'padrebobo' (earlier account name: 'krisakaszik”;
  
  
• Printout of online media article dated April 22, 2025, listing Complainant among the Top 6 Hungarian Gambling Streamers —The Best of 2025- related to the name “krisakaszik”.

Although that evidence, standing alone, does not conclusively establish unregistered trademark rights at the dates of registration of the Disputed Domain Names, it must be assessed together with the Respondent’s subsequent conduct. Both websites extensively reproduce the Complainant’s names, online aliases, images, personal history and social-media activities, while promoting casino offers and creating an impression of official affiliation. Considered cumulatively, these circumstances support the Panel’s inference that the Respondent had the Complainant in mind at registration and intended to capitalize unfairly on the Complainant’s emerging commercial identity and nascent trademark rights. See WIPO Overview 3.1., section 3.8.2.

The Respondent has provided no explanation rebutting that inference. Further, although privacy protection is not inherently indicative of bad faith, the Panel considers its use here, in the context of the Respondent’s deliberate targeting and misleading commercial activities, consistent with intentional concealment from an anticipated complainant or avoidance of notification of UDRP proceedings. In particular, it seems that the registrant information provided by the Respondent appears materially inaccurate in terms of the evidence provided by the Respondent; e.g. the telephone number provided by the purported Lithuanian registrant begins with +380, which is the international calling code for Ukraine, rather than Lithuania. In these circumstances, it reinforces the inference of bad faith. See WIPO Overview 3.1., section 3.6.

Last but not least, the Respondent is not making a legitimate noncommercial or fair use of the Disputed Domain Names – as above described.

On the totality of the evidence and the balance of probabilities, the Panel finds that the Respondent registered and used the Disputed Domain Names in bad faith within the meaning of paragraph 4(a)(iii) of the Policy.

 

Accepted 

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