WIPO D2025-1673 · decided 17 June 2025
JDS Development LLC d/b/a JDS Development Group, JDS Development FL LLC v. Konstantis Bravarskis
The parties
- Complainant
- JDS Development LLC d/b/a JDS Development Group, JDS Development FL LLC
- Respondent
- Konstantis Bravarskis
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found jdsdevelopmentllc.com confusingly similar to the JDS DEVELOPMENT GROUP trademark, because "jds" and "development" form its dominant portion and the abbreviation "llc" does not prevent recognition. |
| 4(a)(ii) No rights or legitimate interests | The panel accepted the criticism was genuine but found no legitimate interest, because the domain name had no critical term such as "sucks" and suggested the Complainants ran it. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith, because the domain name falsely suggested affiliation with the Complainants and the Respondent targeted the JDS DEVELOPMENT GROUP trademark when registering and using it. |
Why does JDS Development matter for a complaint today?
JDS Development Group is a New York City and South Florida property developer founded by Michael Stern. Its trademark, United States Registration No. 7302234, was registered on February 13, 2024. On February 25, 2025, someone registered jdsdevelopmentllc.com and used it for a website "dedicated to exposing the fraudulent activities of Michael Stern". The Respondent, Konstantis Bravarskis, filed no response. The panel, Steven A. Maier, accepted that criticism was the genuine purpose of the website and expressed no view on whether the allegations were true. The case turned on the domain name. Section 2.6 of the WIPO Overview 3.1 says panels tend to accept a genuine criticism site on a name such as trademarksucks.com, but that even genuine criticism does not necessarily extend to a domain name identical to the trademark, because of the risk of impersonation. jdsdevelopmentllc.com was not identical, but it added only "llc", which matched the Complainants' own company names. Visitors would assume the Complainants ran it. Transfer was ordered on June 17, 2025, less than two months after filing. If someone attacks your business from a domain name that looks official, the UDRP can recover that domain name. The order transfers the domain name only.
What does the WIPO Overview 3.1 say?
The WIPO Overview 3.1 summarises how WIPO panels decide each issue. These sections cover the same point of law.
- Section 2.6: Does a criticism site support respondent rights or legitimate interests?
- Section 2.5.1: What are some core factors UDRP panels look at in assessing fair use?
Who decided the case?
A single panelist, Steven A. Maier, decided the case on 17 June 2025.
Read the decision
The full text is published by the WIPO Arbitration and Mediation Center. We summarise it here; the decision itself is the authority.
Summarised by Gergana Dimitrova. Checked against the published decision on 23 October 2026.
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