Panel Finds RDNH Against Complainant Pursuing Domain Investor’s Vowel-Elided Abbreviation in SNGLR.com
Daniel Diemers is a Swiss entrepreneur and co-founder of the SNGLR Group, holding registered trademarks for SNGLR in Switzerland and internationally, along with a large portfolio of snglr.* domain names. The one domain he did not own was <snglr.com>. When it dropped and came up for auction on DropCatch.com in March 2026, Diemers participated, placing a back order and bidding three times before being outbid by a professional domain investor, who promptly listed the domain for sale on Afternic. Diemers responded by writing to DropCatch.com alleging trademark infringement and filing a UDRP complaint with WIPO, both on the same day he lost the auction. A three-member panel had little difficulty dismissing the case. The Respondent, a professional domain investor with a portfolio of short vowel-elided abbreviations, had legitimate interests in “snglr” as a vowel-stripped rendering of the common English word “singular.” The Complainant had also failed to demonstrate that the Respondent had any knowledge of the SNGLR trademark at the time of registration, particularly given that the string is used by various third parties across different sectors.
The panel went further and found Reverse Domain Name Hijacking. The reasoning was straightforward, the Complainant had sat at the same auction table, lost, and immediately turned to the UDRP as a Plan B. He had even acknowledged in his own Complaint that the Respondent was a professional domain investor, making it difficult to argue the filing was anything other than a deliberate attempt to recover through legal process what he could not win commercially. The panel also noted that Diemers, despite being self-represented, is a sophisticated businessman who has been managing domain and trademark portfolios since 2019 and could reasonably be expected to understand the limits of the UDRP before filing. The takeaway is clear, the UDRP is not an appeals process for losing a domain auction, and panels will not hesitate to say so.
ADMINISTRATIVE PANEL DECISION
DANIEL DIEMERS v. Domain Admin, WIPO Case No. D2026-1004
1. The Parties
The Complainant is Daniel Diemers, Switzerland, self-represented.
The Respondent is Domain Admin, Saint Kitts and Nevis, represented by Cylaw Solutions, India.
2. The Domain Name and Registrar
The disputed domain name <snglr.com> is registered with DropCatch.com LLC (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 9, 2026. On March 9, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 11, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. On March 17, 2026, the Center sent an email communication requesting the Complainant to amend the Complaint to cure formal deficiencies. The Complainant submitted an Amended Complaint on March 20, 2026.
The Center verified that the Complaint together with the amended Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).
In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceeding commenced on March 24, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 17, 2026. The Response was filed with the Center on April 17, 2026.
The Center appointed Sebastian M.W. Hughes, Willem J. H. Leppink, and Gerald M. Levine as the Administrative Panel in this matter on May 11, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7.
4. Factual Background
A. Complainant
The Complainant is an individual resident in Switzerland and the owner of two registrations for the trade mark SNGLR (the “Trade Mark”): registration No. 738909 in Switzerland, with a registration date of November 20, 2019; and International registration No. 1539077, designating Germany, France, and the Benelux countries, with a registration date of May 4, 2020.
The Complainant is also the owner of the domain names <snglr.group>, <snglr.digital>, <snglr.tech>, <snglr.ai>, <snglr.art>, <snglr.capital>, <snglr.vc>, <snglr.blog>, <snglr.world>, <snglr.biz>, <snglr.design>, <snglr.company>, <snglr.consulting>, <snglr.online>, <snglr.support>, <snglr.guru>, <snglr.media>, <snglr.foundation> and <snglr.network> comprising the Trade Mark; four of which, <snglr.group>, <snglr.digital>, <snglr.vc> and <snglr.tech>, are resolved to active websites operated by the group of Swiss companies of which the Complainant is the original co-founder, chairman and shareholder: SNGLR Holding AG, SNGLR Digital AG, SNGLR Capital AG, SNGLR XLabs AG, and SNGLR NFT AG (the “SNGLR Group”).
The companies associated with the Complainant provide a wide range of consulting, venture capital, technology, and artificial technology related services under the Trade Mark.
B. Respondent
The Respondent is an entity or individual located in Saint Kitts and Nevis, carrying on business as a professional domain name investor. The Panel notes that Annex I (a) to the Response indicates the Respondent to be associated with the company Global IP Holdings Inc.
C. The Disputed Domain Name
The disputed domain name was registered on February 28, 2026, and acquired by the Respondent, as the successful anonymous bidder in the auction hosted by DropCatch.com, on March 3, 2026 (the “DropCatch.com Auction”), following the expiry of the previous registration for the disputed domain name.
D. Use of the Disputed Domain Name
The disputed domain name has not been used in respect of an active website, but is being offered for sale by the Respondent via the Afternic.com website hosted by GoDaddy (the “Afternic.com Website”).
5. Parties’ Contentions
A. Complainant
The Complainant contends that he has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
Notably, the Complainant contends that the Trade Mark is a distinctive, coined term with no generic or dictionary meaning, and, in light of the Complainant’s established rights in the Trade Mark, it is implausible that the Respondent registered the disputed domain name without knowledge of the Trade Mark.
As to lack of rights or legitimate interests, the Complainant asserts that the Respondent’s profile, including its use of a privacy-focused email service, is consistent with the profile of a professional domain name investor rather than an entity with a legitimate connection to the SNGLR mark.
As to bad faith registration and use, the Complainant contends that the disputed domain name was registered primarily for the purely commercial purpose of selling, renting or otherwise transferring the disputed domain name to the Complainant or to a competitor of the Complainant, for valuable consideration in excess of the Respondent’s out-of-pocket expenses directly related to the disputed domain name (bad faith under paragraph 4(b)(i) of the Policy); that the Complainant, as the founder of the SNGLR Group, participated in the DropCatch.com Auction – first, by placing a back order ahead of the activation of the disputed domain name on February 28, 2026; and secondly, by placing three (unsuccessful) bids during the auction on March 3, 2026 – that the timing of the registration, via the DropCatch.com service specifically designed to catch expiring domain names, indicates that the Respondent was aware of the Trade Mark and deliberately targeted the disputed domain name; and (citing Telstra Corporation Limited v Nuclear Marshmallows, WIPO Case No. D2000-0003) that the passive holding of a domain name has been recognised by UDRP panels as constituting bad faith.
B. Respondent
The Respondent contends that the Complainant has not satisfied all three of the elements required under the Policy for a transfer of the disputed domain name.
As to the first element, the Respondent asserts that it cannot acknowledge that the Complainant holds registrations for the Trade Mark, as the registration documents annexed with the Complaint are in languages other than English, and, accordingly, the Complaint should be dismissed on this ground alone.
As to the second element, the Respondent contends that, as a professional domain name investor with an existing portfolio of domain names – including, in particular, several four-to-five letter domain names consisting of abbreviated or vowel-elided renderings of common words – the Respondent has rights or legitimate interests in the disputed domain name, being a valuable vowel-elided abbreviation of the English word “singular”. The Respondent points in this regard to a number of examples of third-party use of the string “snglr” or similar strings, and contends that, in such circumstances, the string is not exclusively associated with the Complainant.
As to bad faith registration and use, the Respondent contends that it had no knowledge of the Complainant or of its registrations for the Trade Mark when it registered the disputed domain name following its successful bid at the DropCatch.com Auction on March 3, 2026; that the Respondent’s purchase of the disputed domain name via public auction, without knowledge of the Complainant or of its Trade Mark, and the Respondent’s subsequent offer to sell the disputed domain name via the Afternic.com Website, fails to meet the requirement under paragraph 4(b)(i) of the Policy that the Respondent registered the disputed domain name with the intent to sell it to the Complainant or one of its competitors; and that the Complainant’s passive holding argument is without merit in the circumstances of this case.
The Respondent seeks a finding of Reverse Domain Name Hijacking against the Complainant, contending that this case amounts to a “Plan B” scenario, whereby the Complainant has filed the Complaint herein, having first attempted to purchase the disputed domain name at the DropCatch.com Auction. The Respondent relies further in this regard on the fact the Complainant wrote to DropCatch.com on March 9 2026, following the auction, alleging trade mark infringement, requesting that DropCatch.com investigate the matter, put a hold on the disputed domain name and provide the Complainant with additional information, and notifying DropCatch.com that the Complainant was simultaneously preparing the present Complaint.
The Respondent also relies on the “without prejudice” letter sent to the Complainant by the Respondent’s representatives on March 27, 2026, inviting the Complainant to withdraw the Complaint before the filing of the Response herein.
6. Discussion and Findings
A. Identical or Confusingly Similar
It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trade mark and the disputed domain name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7.
The Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1.
The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7.
The Panel considers the Respondent’s contentions in respect of the first element are disingenuous and lacking in merit. It is true that the registration certificates for the Complainant’s Swiss and International registrations for the Trade Mark are in German and French, respectively. However, both the Respondent, as a professional domain name investor, and its representative, a law firm specialising in domain name disputes and trademark law, would have had no difficulty confirming the veracity of the registration certificates for the Trade Marks filed together with the Complaint, using publicly available sources (including the free and online international Global Brand Database provided by WIPO; and the online Swiss trade mark register provided by the Swiss Federal Institute of Intellectual Property).
The Panel finds the first element of the Policy has been established.
B. Rights or Legitimate Interests
The Panel notes that the Respondent purchased the disputed domain name (via the DropCatch.com Auction, as a professional domain name investor), and subsequently offered it for sale. See e.g., WIPO Overview 3.1 section 2.1 (“Over the course of many UDRP cases, panels have acknowledged further grounds that, although not specifically articulated in the UDRP, may establish respondent rights or legitimate interests in a domain name. For example, generally speaking, panels have accepted that aggregating and holding domain names (usually for resale) consisting e.g., of acronyms, dictionary words, common phrases, or unique/catchy or memorable terms (alone or in combination) can be bona fide and is not per se illegitimate under the UDRP where the respondent can show that the purpose of the registration was not to target a trademark. [See in particular section 2.10.]”). The Panel moreover notes the disputed domain name is comprised of a five-letter acronym and that there are no indications, based on the available record, of an intention to capitalize on the Complainant’s Trade Mark WIPO Overview 3.1, section 2.10.
The Panel finds the second element of the Policy has not been established.
C. Registered and Used in Bad Faith
The evidence in the case file as presented does not indicate that the Respondent’s aim in registering the disputed domain name was to profit from or exploit the Complainant’s Trade Mark.
In all the circumstances, the Panel is unable to conclude that the Respondent, in registering the disputed domain name and subsequently offering it for sale via the Afternic.com Website, targeted the Complainant and its Trade Mark. The Panel notes that the disputed domain name is comprised of a five-letter acronym, also used by third parties in different segments. The Panel also finds that the Respondent did not register the disputed domain name, under paragraph 4(b)(i) of the Policy, for the purpose of selling it specifically to the Complainant or a competitor of the Complainant, and the Complainant has failed to provide any evidence of its notoriety at the time of the registration of the disputed domain name which could indicate that the Respondent had knowledge of the Complainant’s trade mark rights and that the Respondent more likely than not registered the disputed domain name with those rights in mind.
The Panel finds the third element of the Policy has not been established.
D. Reverse Domain Name Hijacking
Paragraph 15(e) of the Rules provides that, if after considering the submissions, the Panel finds that the Complaint was brought in bad faith, for example in an attempt at Reverse Domain Name Hijacking or to harass the domain-name holder, the Panel shall declare in its decision that the Complaint was brought in bad faith and constitutes an abuse of the administrative proceeding. The mere lack of success of the Complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.1, section 4.16.
Panels tend to be more willing to make a finding of Reverse Domain Name Hijacking where complainants are legally represented – reasoning that, in such circumstances, complainants ought to be held to a higher standard.
Although in the present proceeding the Complainant is not legally represented, the Complainant is clearly a successful and highly educated individual. The Complainant, as the co-founder of the SNGLR Group, has significant personal experience since 2019 in registering and maintaining the Complainant’s portfolio of domain name and Trade Mark registrations used by the SNGLR Group.
Having participated in the DropCatch.com Auction himself, placing three bids but, ultimately, being outbid by the Respondent – the Panel finds that the Complainant’s conduct in first sending a letter to DropCatch.com on March 9, 2026, and in subsequently filing this Complaint amounts to Reverse Domain Name Hijacking, in particular in light of the Complainant’s acknowledgments in the body of the Complaint that the Respondent is a professional domain name investor.
The Panel would also note that, whilst the Complainant is not legally represented, there is readily-available and accessible jurisprudence regarding domain name disputes online (including, in particular, WIPO Overview 3.1, which is publicly available via the WIPO website). The Panel considers that, in light of the fact the Complainant has been, since 2019, in charge of the registration of the SNGLR domain names and Trade Mark (including, as acknowledged by the Complainant, the fact that he had, in 2019 and 2020, tried contacting the previous registrant), the Complainant is likely conversant with domain name registration and disputes procedure or, at the very least, ought to have conducted the necessary research and familiarised himself with the procedure before filing the Complaint.
The Panel is not however persuaded that the Respondent’s somewhat self-serving “without prejudice” letter – sent after the filing of the Complaint and the commencement of this proceeding – is supportive of a finding of Reverse Domain Name Hijacking, the relevant question being the state of the Complainant’s knowledge at the time of filing of the Complaint.
The Panel finds that the Complaint has been brought in bad faith and constitutes an attempt at Reverse Domain Name Hijacking.
7. Decision
For the foregoing reasons, the Complaint is denied.
Sebastian M.W. Hughes Presiding Panelist
Willem J. H. Leppink Panelist
Gerald M. Levine Panelist
Date: May 25, 2026
