This case is a reminder that a Respondent can win a UDRP without winning the argument it fought hardest for. The Complainant, Semify, LLC, held an incontestable US registration for SEMIFY predating the disputed domain’s acquisition by over five years, and the Respondent, a professional domain investor who acquired <semify.ai> for USD 244.96 as one of five “.ai” names purchased in a single transaction, leaned heavily on a portmanteau theory positioning “Semify” as “semi” (semiconductor) plus “-fy,” bolstered by extensive evidence of the SEMI prefix’s ubiquity across the semiconductor and AI industries. The three-member Panel was unpersuaded by that theory, holding that the ability to segment a word into components does not, without more, establish an “established descriptive meaning,” and finding no evidence that “Semify” itself was commonly understood in that manner. The Complaint nonetheless failed on the narrowest of margins under the third element: the Complainant’s AI optimization service launched 31 days after the disputed domain’s registration, the domain was part of a broader, unsolicited multi-domain acquisition, and there was no evidence the Respondent ever approached the Complainant. The Panel went on to decline a finding of Reverse Domain Name Hijacking, characterizing the case as “finely balanced” despite acknowledging the Complaint’s assertions of exclusivity were “expressed too broadly.” Continue reading the full decision below.
Semify, LLC v. James Booth, DomainBooth.com, Case No. DAI2026-0053
1. The Parties
The Complainant is Semify, LLC, United States of America (“United States”), represented by Reinhart Boerner Van Deuren s.c., United States.
The Respondent is James Booth, DomainBooth.com, United Arab Emirates, represented by Cylaw Solutions, India.
2. The Domain Name and RegistrarThe disputed domain name <semify.ai> is registered with Namecheap, Inc. (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 10, 2026. On June 11, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 12, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name that differed from the named Respondent (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on the same day, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on June 17, 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 proceedings commenced on June 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 15, 2026. The Respondent sent email communications to the Center on July 11, 2026, and on July 13, 2026. The Response due date was extended to July 19, 2026, as per the Respondent’s request pursuant to paragraph 5(b) of the Rules. The Response was filed with the Center on July 18, 2026.
The Center appointed Jane Seager, Reyes Campello Estebaranz, and Gerald M. Levine as panelists in this matter on August 20, 2026. The Panel finds that it was properly constituted. Each member of 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
4.1. The Complainant
The Complainant is a company located in Rochester, New York, United States. The Complainant provides white-label digital marketing services, including search engine optimization (“SEO”), advertising and marketing services, pay-per-click (“PPC”) services, Software as a Service (“SaaS”), and AI-driven SEO services.
The Complainant has used the domain name <semify.com> since at least 2020.
In December 2025, the Complainant announced its acquisition of Dragon Metrics, an SEO and AI reporting platform. The Complainant’s AI optimization service was publicly launched on May 11, 2026.
4.2. The Complainant’s Trademark Rights
The Complainant owns United States Trademark Registration No. 6,149,129, SEMIFY, registered on September 8, 2020.
The Complaint also refers to United States Trademark Application Serial No. 99/470,883 for SEMIFY, filed on October 30, 2025, covering, among other things, marketing services using AI and SaaS services using AI tools for search engine optimization.
4.3. The Respondent
The Respondent, James Booth, is based in Ajman, United Arab Emirates, and is the sole owner and principal of DomainBooth FZE LLC. The Respondent is engaged in the acquisition, holding, brokerage, and resale of domain names, particularly generic, descriptive, brandable, and short-character domain names, including “.com” and “.ai” domain names.
4.4. The Disputed Domain Name
The Respondent acquired the disputed domain name on April 10, 2026, for USD 244.96. It was acquired as one of five “.ai” domain names in a single transaction with a total purchase price of USD 5,539.80.
The disputed domain name redirects to a page on the Atom.com domain name marketplace where it is offered for sale for USD 149,995.
There is no evidence in the record of correspondence between the Parties prior to the filing of the Complaint.
5. Parties’ Contentions
A. Complainant
The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name.
The Complainant asserts rights in the trademark SEMIFY. The Complainant emphasizes that it owns an incontestable United States trademark registration for SEMIFY, has used the mark since at least 2020, and claims that SEMIFY is a coined and distinctive term associated exclusively with the Complainant. The Complainant contends that the disputed domain name wholly incorporates the Complainant’s SEMIFY trademark. The Complainant argues that the addition of the country code Top-Level Domain (“ccTLD”) “.ai” does not distinguish the disputed domain name from the Complainant’s trademark. The Complainant submits that the disputed domain name is confusingly similar to its SEMIFY trademark.
The Complainant submits that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant asserts that it has not authorized the Respondent to use the SEMIFY trademark, contends that the Respondent is not known by the name “Semify”, and argues that there is no evidence of any legitimate commercial or noncommercial use of the disputed domain name by the Respondent. The Complainant stresses that “Semify” is not a dictionary term. The Complainant submits that the only use of the disputed domain name is to offer it for sale at an exorbitant price, which does not constitute a legitimate interest.
The Complainant further submits that the disputed domain name was registered and is being used in bad faith. The Complainant asserts that the Respondent registered the disputed domain name after the Complainant had established trademark rights and publicly announced its intention to offer AI-related services under the SEMIFY mark. The Complainant contends that the Respondent knew or should have known of the Complainant and its rights in the SEMIFY trademark at the time of registration. The Complainant submits that the timing of the registration, the use of the ccTLD “.ai”, and the categorization of the disputed domain name under “Marketing & Advertising” when offering the disputed domain name for sale indicate that the Respondent knew or should have known of the Complainant’s trademark rights and registered the disputed domain name to capitalize on the value and goodwill associated with the SEMIFY mark. The Complainant argues that the Respondent’s sole use of the disputed domain name is to offer it for sale at a price far exceeding its estimated value, which the Complainant submits is a textbook example of cybersquatting and bad faith registration and use.
The Complainant requests transfer of the disputed domain name.
B. Respondent
The Respondent contends that the Complainant has not satisfied the elements required under the Policy for a transfer of the disputed domain name.
The Respondent acknowledges, solely for purposes of the proceeding, that the Complainant holds a trademark registration for SEMIFY and therefore satisfies the threshold requirement under paragraph 4(a)(i) of the Policy. The Respondent stresses that this concession does not constitute an admission as to the strength, distinctiveness, or scope of the Complainant’s rights.
The Respondent argues that “Semify” is not a coined term exclusively associated with the Complainant. Rather, the Respondent asserts that it is a descriptive or suggestive portmanteau capable of several meanings, including “SEM” and “-ify”, referring to search engine marketing; “semi” and “-fy”, referring to semiconductors; and a combination of “seminar” and “simplify.”
The Respondent notes that the Complainant’s own press releases describe “Semify” as a reference to search engine marketing (“SEM”) and use the term as a verb in connection with the provision of such services. The Respondent further notes that unrelated parties in several countries have used “Semify” in connection with marketing, semiconductor engineering, structural equation modelling, information technology, and other activities, in some cases before the Complainant adopted the name. The Respondent argues that these facts demonstrate that the term is descriptive or suggestive and is not exclusively distinctive of the Complainant.
The Respondent argues that it has rights or legitimate interests in the disputed domain name because it operates an established domain name investment and brokerage business that acquires, holds, and resells generic, descriptive, and brandable domain names. The Respondent asserts that domain name investment is a legitimate commercial activity where the domain name was not acquired to target a trademark owner.
The Respondent states that it acquired the disputed domain name on April 10, 2026, as one of five brandable “.ai” domain names purchased in a single transaction. The Respondent notes that it already held several domain names employing the “-ify” or “-fy” naming pattern. According to the Respondent, these circumstances demonstrate a consistent investment strategy unrelated to the Complainant.
The Respondent asserts that the disputed domain name was acquired for its inherent commercial value as a short, brandable portmanteau, particularly as a combination of “semi”, referring to semiconductors, and “-fy”, used with the ccTLD “.ai”. The Respondent also relies on the term’s other possible meanings and its use by unrelated third parties to argue that the disputed domain name has value independent of the Complainant’s trademark.
The Respondent further argues that offering the disputed domain name for sale does not, by itself, negate a legitimate interest. The Respondent notes that the disputed domain name was listed on an open marketplace and was not offered specifically to the Complainant. The Respondent asserts that the asking price of USD 149,995 was consistent with the prices of comparable names in its portfolio and with reported premium “.ai” domain name sales, rather than being based on the Complainant’s trademark.
The Respondent argues that the Complainant has failed to show that the disputed domain name was registered or used to target the Complainant or its trademark. The Respondent denies having known of the Complainant, its trademark, or its pending AI-related trademark application when registering the disputed domain name.
The Respondent asserts that the Complainant is a regional, white-label B2B SEO reseller based in the United States, with no demonstrated presence, customers, reputation, or brand recognition in the United Arab Emirates, where the Respondent is based. The Respondent argues that constructive notice of the Complainant’s trademark is insufficient under the Policy and that the Complainant has produced no evidence of the Respondent’s actual knowledge of the Complainant’s trademark.
The Respondent notes that the Complainant’s AI optimization service was publicly launched on May 11, 2026, 31 days after the disputed domain name was acquired. The Respondent therefore argues that it could not have acquired the disputed domain name to target that service. The Respondent also notes that the Complainant’s AI-related trademark application was filed on an intent-to-use basis and had not resulted in established use-based rights in AI services at the time of registration.
The Respondent asserts that it selected the ccTLD “.ai” because of the disputed domain name’s independent value at the intersection of semiconductors and AI, as well as the broader commercial demand for premium “.ai” domain names. The Respondent rejects the contention that the ccTLD itself demonstrates knowledge of the Complainant.
The Respondent further argues that the asking price does not establish bad faith under paragraph 4(b)(i) of the Policy. The Respondent asserts that bad faith would require evidence that the disputed domain name was acquired primarily for sale to the Complainant or a competitor of the Complainant. Here, the disputed domain name was listed for sale generally, the Respondent never approached the Complainant, and the asking price was allegedly supported by comparable aftermarket listings and sales.
Finally, the Respondent argues that the disputed domain name’s inclusion in a “Marketing & Advertising” marketplace category does not demonstrate targeting. The Respondent asserts that this categorization reflects the descriptive meaning “SEM + ify” and notes that the disputed domain name also appeared in more than 20 other categories, including AI, technology, software, finance, consulting, and analytics.
The Respondent requests a finding of Reverse Domain Name Hijacking. The Respondent argues that, despite being represented by specialist counsel, the Complainant claimed that it had exclusively coined and used “Semify”, contrary to its own statements and evidence of third-party use. The Respondent further asserts that the Complainant alleged targeting of an AI service launched only after registration of the disputed domain name and relied principally on the public listing and asking price without producing evidence that the Respondent knew of or targeted the Complainant.
6. Discussion and Findings
In order to prevail, the Complainant must demonstrate on the balance of probabilities that it has satisfied the requirements of paragraph 4(a) of the Policy:
(i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights;
(ii) The Respondent has no rights or legitimate interests in respect of the disputed domain name; and
(iii) The disputed domain name was registered and is being used in bad faith.
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 trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7.
The Panel finds that the Complainant has established rights in the trademark SEMIFY for purposes of the Policy. The registration details of the Complainant’s trademark are set out in the factual background section above. 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 finds that the first element of the Policy has been established.
B. Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name.
Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving that a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1.
The Complainant has established that it has not authorized the Respondent to use the SEMIFY trademark and that the Respondent is not commonly known by the disputed domain name. The disputed domain name redirects to a domain name marketplace page where it is offered for sale for USD 149,995.
Generally speaking, UDRP panels have accepted that aggregating and holding domain names (usually for resale) consisting, for example, 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. WIPO Overview 3.1, section 2.1. Merely characterizing a domain name as descriptive or “brandable”, however, does not automatically confer rights or legitimate interests. Panels assess such claims in light of the overall circumstances. WIPO Overview 3.1, section 2.10.1.
The Respondent relies principally on its established domain name investment and brokerage business and contends that it acquired the disputed domain name for its inherent value as a short and brandable portmanteau. The Respondent submits that “Semify” is capable of several meanings, including “SEM” and “-ify”, referring to search engine marketing; “semi” and “-fy”, referring to semiconductors; and a combination of “seminar” and “simplify”.
The Panel has reservations regarding the Respondent’s characterization of “Semify” as a portmanteau. The Respondent’s principal proposed constructions, “SEM + -ify” and “semi + -fy”, combine an acronym, abbreviation, or prefix with the suffix “-(i)fy”. The ability to divide a term into possible components does not, by itself, show that it is a portmanteau or possesses an established descriptive meaning.
Nor does the evidence show that “Semify” was commonly used or understood in the semiconductor or AI industries in the manner asserted in the Response. The proposed construction based on “seminar” and “simplify” derives from a description previously used by a domain name marketplace when advertising <semify.com> for sale, rather than from evidence of a generally understood meaning of the term.The Panel has also considered the evidence of third-party adoption or use of “Semify”, including uses relating to digital marketing, semiconductor engineering, structural equation modelling, IT, and retail. The fact that other parties may use “Semify” in the course of trade does not necessarily make the term descriptive. Nor does the apparent coexistence of multiple users of the term, without more, confer rights or legitimate interests on the Respondent in the disputed domain name.
The Respondent further relies on press releases issued in connection with the Complainant’s rebranding in 2020, which described “Semify” as a reference or “nod” to search engine marketing and used the term as a verb when explaining the Complainant’s services. Those statements explain the Complainant’s selection and promotion of the SEMIFY mark, but do not necessarily demonstrate ordinary third-party use of “Semify” as a descriptive term.
On the other hand, the Respondent has produced evidence relevant to its claimed rights or legitimate interests. In particular, it relies on its established domain name investment activities, its purchase of the disputed domain name as one of five “.ai” domain names in a single transaction, its portfolio of other “-ify” or “-fy” domain names, third-party uses of “Semify”, and the generalized nature of the offer for sale. There is no evidence that the Respondent approached the Complainant in an attempt to sell the disputed domain name directly to it.
The Parties’ competing submissions under the second element raise questions that overlap with the issue of trademark targeting under the third element. In light of the Panel’s conclusion below that the Complainant has not established that the disputed domain name was registered in bad faith, it is unnecessary for the Panel to reach a conclusion under the second element of the Policy.
C. Registered and Used in Bad Faith
Paragraph 4(b) of the Policy sets out a non-exhaustive list of circumstances evidencing the registration and use of a domain name in bad faith.
Under paragraph 4(b)(i) of the Policy, bad faith may be found where circumstances indicate that a respondent registered or acquired a domain name primarily for the purpose of selling it to the complainant, or to a competitor of the complainant, for valuable consideration exceeding the respondent’s documented out-of-pocket costs directly related to the domain name.
The Complainant’s registered rights in the SEMIFY trademark predate the Respondent’s acquisition of the disputed domain name by more than five years. The Complainant’s later application covering AI-related services and the subsequent launch of its AI optimization service do not affect those earlier rights. They are nevertheless relevant to the Complainant’s contention that the Respondent selected the “.ai” ccTLD to target its AI-related activities. In this regard, the Complainant announced its acquisition of Dragon Metrics before the Respondent acquired the disputed domain name but launched its AI optimization service only after the acquisition.
Several circumstances support the Complainant’s case. The disputed domain name is identical to the SEMIFY trademark; it was acquired after the Complainant had established its rights and announced the Dragon Metrics acquisition; it was included in a “Marketing & Advertising” category on the Respondent’s marketplace; and it was offered for USD 149,995 after having been acquired for USD 244.96.
Prior panels have recognized that, given the global reach of the Internet and search engines, knowledge of a complainant’s trademark may be inferred where the mark is widely known or highly specific and the respondent cannot credibly claim to have been unaware of it, particularly where the respondent is a professional domain name investor. Relevant factors may include the nature of the domain name, the chosen Top-Level Domain, its use, and the respondent’s registration pattern. WIPO Overview 3.1, section 3.2.2.
Prior panels have also recognized that professional domain name investors, particularly those undertaking bulk or automated registrations, have an affirmative obligation to avoid trademark-abusive registrations. A deliberate failure to screen acquisitions against readily available online sources may, depending on the circumstances, support a finding of wilful blindness. WIPO Overview 3.1, section 3.2.3.
The Respondent has not provided evidence that it conducted trademark screening or other due diligence before acquiring the disputed domain name. A basic Internet or trademark search for “Semify” would likely have revealed the Complainant’s website and United States trademark registration. Given the Respondent’s experience as a professional domain name investor, the absence of evidence of screening weighs against it. In the circumstances of this case, however, that fact does not provide a sufficient basis to infer that the Respondent knew of and targeted the Complainant when acquiring the disputed domain name.
The Complainant has not submitted evidence regarding the extent of the SEMIFY mark’s reputation at the relevant time, such as evidence of sales, advertising, market share, website traffic, customer reach, or broader recognition. Although the Complainant maintained an established online presence at the domain name <semify.com>, the record does not show that its trademark was widely known internationally. The Respondent’s location in the United Arab Emirates does not preclude a finding of knowledge, particularly given the international nature of its business, but the Complainant’s online presence does not itself establish that the Respondent knew of the Complainant or targeted its trademark.
The evidence of unrelated uses of “Semify” in several jurisdictions and fields also weighs against inferring the Respondent’s knowledge and targeting of the Complainant solely from the composition of the disputed domain name. In addition, the disputed domain name was acquired as one of five “.ai” domain names in a single transaction. The Respondent has an established domain name investment business and owns other names employing the “-ify” or “-fy” naming pattern. These circumstances provide a plausible context for the acquisition of the disputed domain name unrelated to the Complainant.
As discussed under the preceding element, the Panel has reservations regarding the Respondent’s proposed semiconductor-related interpretation of “Semify”. The Respondent has not shown that the term has a commonly recognized meaning in the semiconductor or AI industries. The weakness of that explanation, however, does not establish the Complainant’s competing allegation of trademark targeting.
While the disputed domain name’s inclusion in the “Marketing & Advertising” category corresponds to the Complainant’s field of activity, its appearance in numerous other categories and the possible interpretation of “SEM” as an abbreviation for search engine marketing reduce the weight of that evidence as an indicator that the Respondent was aware of and targeted the Complainant.
The Panel has also considered the Respondent’s offer to sell the disputed domain name for USD 149,995. The difference between the acquisition cost and asking price is substantial. Paragraph 4(b)(i) of the Policy, however, requires circumstances indicating that the Respondent acquired the disputed domain name primarily for the purpose of selling it to the Complainant or a competitor of the Complainant. In this case, the disputed domain name was offered generally through an open marketplace. There is no evidence that the Respondent approached the Complainant, referred to it in the listing, or otherwise directed the offer to the Complainant or one of its competitors. The Respondent has also produced evidence of substantial prices for other domain names in its portfolio and of reported high-value sales of other “.ai” domain names.
The exact match with the SEMIFY trademark, the chronology of the Complainant’s rights, the Respondent’s professional status, the absence of evidence of trademark screening, the marketplace categorization, and the substantial asking price weigh in the Complainant’s favour. Those circumstances must be weighed against the limited evidence regarding the extent of the SEMIFY mark’s reputation, the evidence of third-party uses of “Semify”, the Respondent’s established investment activities, the multi-domain name acquisition, its portfolio of similarly composed domain names, the generalized offer for sale, and the absence of any communication directed to the Complainant.
Having considered the evidence as a whole, the Panel finds that the Complainant narrowly fails to establish, on the balance of probabilities, that the Respondent knew of and targeted the Complainant or its SEMIFY trademark when acquiring the disputed domain name. Nor has the Complainant established that the Respondent acquired the disputed domain name primarily for the purpose of selling it to the Complainant or a competitor of the Complainant within the meaning of paragraph 4(b)(i) of the Policy.
The Panel therefore finds that the Complainant has not sufficiently established that the disputed domain name was registered in bad faith. As paragraph 4(a)(iii) of the Policy requires both registration and use in bad faith, it is unnecessary for the Panel to reach a separate conclusion regarding bad faith use.
The Panel finds that the Complainant has failed to establish the third element of the Policy.
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 in the complaint is not, on its own, sufficient to constitute Reverse Domain Name Hijacking. WIPO Overview 3.1, section 4.16.
The Panel has considered the Respondent’s request for a finding of Reverse Domain Name Hijacking, including the fact that the Complainant is represented by experienced counsel. The Panel acknowledges that the Complaint included certain assertions that were expressed too broadly, notably as to the exclusive association of “Semify” with the Complainant.
Nevertheless, the Panel is far from considering that this is a “textbook example of Reverse Domain Name Hijacking”, as claimed by the Respondent. The Complainant holds a trademark registration for SEMIFY that predates the Respondent’s acquisition of the disputed domain name by more than five years, and the disputed domain name is identical to that trademark. Furthermore, according to the WIPO Global Brand Database, the Complainant is the sole owner of subsisting trademark rights in the term “semify”. The
circumstances surrounding the Respondent’s acquisition and subsequent offer for sale of the disputed domain name provided a reasonable basis for the Complainant to pursue the matter under the Policy.
The Panel considers that the case was finely balanced, with the Respondent prevailing only narrowly on the basis that the evidence fell short of establishing bad faith registration on the balance of probabilities.
The Panel therefore declines to make a finding of Reverse Domain Name Hijacking.
7. Decision
For the foregoing reasons, the Complaint is denied.
Jane Seager
(Presiding Panelist)
Reyes Campello Estebaranz
(Panelist)
Gerald M. Levine
(Panelist)
Date: September 7, 2026
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