Greenberg Gross LLP v. GreenbergGrossLLP.com

No. CV-25-01176-PHX-MTL (D. Ariz. Feb. 12, 2026) · United States District Court for the District of Arizona · February 12, 2026 · No. No. CV-25-01176-PHX-MTL

Summary

The United States District Court for the District of Arizona grants Greenberg Gross LLP’s ex parte application to waive publication of notice in an in rem cybersquatting action involving the domain name GreenbergGrossLLP.com. The court finds that effective publication is impossible because the registrants concealed their identities and locations, and it directs the Clerk to enter default against the domain name. The court denies as moot the plaintiff’s motion for an extension of time to effectuate service.

Court
United States District Court for the District of Arizona
Jurisdiction
United States District Court for the District of Arizona
Decision date
February 12, 2026
Docket number
No. CV-25-01176-PHX-MTL
Disposition
other

Questions Presented

  1. Whether the court could waive the Anti-Cybersquatting Consumer Protection Act's service-by-publication requirement when the domain-name registrants concealed their identities and could not reasonably be reached by publication.
  2. Whether the Clerk should be directed to enter default against the in rem domain-name defendant after Plaintiff complied with the applicable service provisions.
  3. Whether Plaintiff's motion for an extension of time to effectuate service remained necessary after the service application was granted.

Holdings

  1. The court may waive the publication requirement, and publication was properly waived because effective notice by publication was impossible where the registrants concealed their identities and could not reasonably be located.
  2. Because Plaintiff complied with the applicable service provisions of the Anti-Cybersquatting Consumer Protection Act through diligent mail and email efforts, the Clerk was directed to enter default as to the GreenbergGrossLLP.com domain name.

Court Document

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