Obvious Typosquat, Zero Evidence

No Evidence Of Bad Faith

Iowa Health System d/b/a UnityPoint Health v. Dan Carpenter / AVENS LLC (FORUM Case FA2605002224358, June 26, 2026).

Unity Point provides health care services (https://www.unitypoint.org). It brought a complaint under the UDRP to try to recover a domain name from the Respondent who had registered the domain name <unitypiont.org> and used it redirect internet users back to the Complainant's own website.

This was an obvious case of typosquatting because of the slight change the Respondent had made to the Complainant’s trademark UNITYPOINT in incorporating it in the domain name.  

But the case failed when it came to proving bad faith.

It failed because the Complainant had not made out a case under any of the specific grounds of bad faith enumerated in paragraph 4(b) of the UDRP.

That was not the end of the matter, of course, because those grounds are without limitation and it is still open to a complainant to rely on general bad faith if the complainant can prove it. 

The trouble was that the Complainant had not shown any evidence (OR EVEN MADE ANY SUBMISSIONS) of general or independent bad faith.

Bad faith therefore failed, as it had not been proved, and it is an essential criterion of proof in cases under the UDRP. The Complaint was therefore denied. As the Panel said : ”Absent evidence of use (or submissions which might enable lack of that evidence to be considered) the Panel is unable to make a finding of use in bad faith”.

This shows, yet again, not just that evidence is important, but that it is vital.