To Whom It May Concern:
Cybersquatter Complaint Re: PetRescuesByEmily.com
Original Website Documentation and Notice of Unauthorized Use
This page documents the original creation, development, and purpose of the website PetRescuesByEmily.com, along with relevant timeline details and supporting information regarding its current status.
This information is provided for documentation and reference purposes.
PetRescuesByEmily.com
Formal Complaint Regarding Cybersquatting, Copyright Infringement, Trademark Infringement, Registrar Abuse, Misrepresentation, Unauthorized Use of Original Website Content and Other Possible Violations
PLEASE READ BEFORE PROCEEDING
• Please excuse this less than perfect submission due to my current and seriously debilitating vertigo, vestibular damage, vision issues and recent eye surgeries.
• I am limiting screen time and may miss minor inconsistencies.
• Time is of the essence, and I believe it is more important to submit now than delay.
• I do check email as often as possible and can provide clarification or additional documentation upon request.
URGENT
• Domain: PetRescuesByEmily.com
• Expiration Date: April 28, 2026
• Immediate action is respectfully requested.
REFERENCE INFORMATION
• GoDaddy Complaint: DCU101180266
• Cloudflare Report: #22078929
• ICANN Case: DCUO-63316
• WordPress/Automattic response dated March 16, 2026 confirming use of WordPress.org on third party hosting
PURPOSE OF THIS COMPLAINT
• Immediate cessation of unauthorized use
• Restoration of domain ownership
• Preservation of evidence
• Appropriate remedies as allowed under law
INTRODUCTION
• My name is Margaret Scott Lynch, also known as MaggieTheGeek and ZebraMultimedia
• I am submitting this formal complaint regarding my previously registered domain PetRescuesByEmily.com
• I originally registered and created this domain on April 28, 2019
DOMAIN RENEWAL CIRCUMSTANCES
• In early 2025, I performed bulk domain renewals during serious medical issues while preparing for upcoming surgeries
• I intentionally put PetRescuesByEmily.com in my renewal cart
• Renewal of PetRescuesByEmily.com was inadvertently not completed though I thought it had
• Registrant email updates to a more used email apparently also failed
• These issues occurred while using an older iPhone with technical problems
• I only became aware of these failures after the fact in August 2025
IMPORTANT REGARDING EMILY CHASON GILCHRIST
• I, Margaret Scott Lynch, own all rights to the domain and website
• I created, funded, and maintained the site as a pro bono effort
• No profit has ever been generated
•Emily Chason Gilchrist is my niece and the beneficiary of this website only and is not a party to this complaint
• Emily had Web Editor rights and contributed to the website greatly including the “Happy Tails” section and suggested reading as well as FYI sections
•Emily should not be contacted or involved in this matter
PROFESSIONAL BACKGROUND
• I have more than twenty five years of experience in technology and web development
• Former Communications Systems Specialist and Managing Web Editor at Ericsson RTP
• Responsible for corporate intranet, multimedia systems, and internal communications
• Alpha tester for Ericsson mobile devices
• Completed coursework at NC State in HTML, graphics, and usability
• GoDaddy customer since December 19, 2007 with extensive domain management experience
FOUNDATION AND PURPOSE OF THE DOMAIN
• The domain name PetRescuesByEmily.com was intentionally researched and created by me to assist my niece Emily with her pro bono animal rescue work
• It was built to support my niece’s established work in animal rescue and to help the animal loving community
• This was a pro bono project and labor of love
BACKGROUND AND HUMAN CONTEXT
• Emily Chason Gilchrist is my niece and has been legally blind since infancy due to bacterial meningitis
• The family dog Bear played a critical role in her recovery and emotional development
• The family referred to themselves as “Bear Team”
• Emily has overcome lifelong challenges and built a life helping animals
• She has never been able to drive and has faced daily limitations most people cannot imagine
• After experiencing my own vision issues, I now understand her visual difficulties at a much deeper level
• There is no one I admire and respect more than Emily
• Prior to the website, she had helped over 300 animals find “furever” homes
• By 2025, that number exceeded 450
WEBSITE DEVELOPMENT
• I built and launched the website in the Spring of 2019
• I handled all design, development, hosting, and administration
• The site was completely ad free
• No income was ever generated
• I intentionally did not brand the site as my own to avoid any appearance of commercial intent
BRAND AND PUBLIC PRESENCE
• The name PetRescuesByEmily became publicly recognized
• Coordinating Business cards were created and gifted to Emily by her mother and me
• She distributed them while working at a busy grocery store in Marietta, GA and when she changed vocations and began working for a Veterinarian group
• Social media and Gmail accounts were aligned under the name
• Google search results associated the name with Emily
• This established common law trademark presence
SEARCH ENGINE DEVELOPMENT
• The site’s visibility was intentionally developed
• I submitted the site to search engines for indexing
• SEO work was performed over time
• Recognition was not accidental
DESIGN, SOURCE CODE AND COPYRIGHT OWNERSHIP
• The website was custom built using a previously used WordPress template that I was allowed to customize with coding
• I created the layout, navigation, structure, typography, and color palette
• Accessibility and visual design was implemented specifically for Emily
• A custom favicon and visual identity were created
• Custom menus were generated and changed over time
• The current site displays my original front page content and structure
• Custom coded color elements appear on the current site
• These are not default WordPress elements
• The footer still displays “Proudly Powered by WordPress” consistent with my build
• This confirms the site reflects my original work and not an independent creation
• The design, structure, code, and content are protected under copyright and my original Copyright 2019 is still being displayed
• I am the sole creator of the website design and technical implementation
ACCESSIBILITY DESIGN AND CUSTOM COLOR IMPLEMENTATION
• Custom colors were selected for text, hyperlinks, and visited hyperlinks
• These were designed specifically to assist a legally blind user
• These settings required manual configuration
• These are not default WordPress behaviors
• Their presence supports derivation from my original work
CUSTOM FORMATTING AND STRUCTURAL DESIGN
• The site used consistent layout, spacing, and structure
• Navigation and content flow were intentionally designed
• Formatting supported readability and usability
• These elements together form a distinctive design pattern
MISSION STATEMENT AND CONTENT REPRODUCTION
• Our mission statement appears on the current site word for word
• This was original written content created by Emily and me
• This is direct reproduction, not similarity
• This confirms copying of original content
CONTENT OWNERSHIP AND PERMISSIONS
• Stories and images were provided by Emily and pet owners
• All content was shared with permission for publication
• No content was released for reuse elsewhere
• Any current use is unauthorized
DISCOVERY TIMELINE
• May 17, 2025: Emily unable to access site
• July 9, 2025: Archived version confirmed
• June 2025: Domain acquired by third party at GoDaddy auction
• August 2025: Due to confusion with login issues and site missing pictures and header, contacted GoDaddy for assistance and after extensive review of possible issues, to my shock and surprise, loss of domain name was confirmed
CURRENT UNAUTHORIZED USE
• The current site displays my original content
• Internal links are broken or non functional
• The site is misleading and appears active
• It misled Emily and myself in Summer of 2025 and her mother March 2026
• This is not a legitimate independent website
WORDPRESS AND DECEPTIVE PRACTICES
• WordPress confirmed site is not hosted by them
• The site uses WordPress.org software
• The footer creates a false impression of legitimacy
• Combined with copied content, this is deceptive
CLAIM 1: COPYRIGHT INFRINGEMENT
• Original content and design created in 2019
• Protected under federal copyright law
• No authorization was given
• Continued use constitutes infringement
CLAIM 2: TRADEMARK INFRINGEMENT
• PetRescuesByEmily is an established common law trademark
• Public use documented since 2019
• Registrant has no legitimate interest
• The name is uniquely tied to Emily in Marietta, Georgia
CLAIM 3: CYBERSQUATTING AND BAD FAITH
• Domain acquired immediately after lapse
• Registrant concealed behind privacy services
• No contact or legitimate use
• Site left unchanged
• This meets ICANN definition of cybersquatting
BAD FAITH INDICATORS
• No attempt by new Registrant to contact original Registrant
• Retained original content
• Original 2019 Copyright notice remains at footer
• Site never updated
• No legitimate purpose
UDRP ANALYSIS
• Identical to established trademark — satisfied
• No legitimate interest — satisfied
• Bad faith registration and use — satisfied
DECLARATION
• I declare under penalty of perjury that this information is accurate
• I am the owner of the rights being infringed
All rights reserved. Copyright 2025
Original Posting from 20250331 is Below
Page maintained by Margaret Scott Lynch (MaggieTheGeek / ZebraMultimedia)
Contact: MaggieTheGeek@gmail.com
URGENT: Domain PetRescuesByEmily.com expires April 28, 2026. Immediate action requested.
Please Note: Due to my current and seriously debilitating vertigo and vestibular damage issues I am having to limit my screen time and am unable to catch all inconsistencies and errors. My sincerest apologies for not providing a more perfect submission. I know time is of the essence and I would rather submit something to the best of my ability than nothing. I do check emails as often as possible so please make specific requests as needed.
To Whom It May Concern
Re: GoDaddy Complaint DCU101180266
Re: Cloudflare Report #22078929
Re: ICANN Case DCUO-63316
Re: Per WordPress/Automattic Trust and Safety response dated March 16, 2026 — confirmed site uses WordPress.org software hosted by third party, establishing additional deceptive practices as detailed below
Important: Regarding Emily Chason Gilchrist
Emily Chason Gilchrist is the beneficiary of this website and domain only. She is not a party to this complaint. I, Margaret Scott Lynch, own all rights. I registered the domain, built the site, paid all costs and hosted it entirely as a pro bono act in support of her pro bono animal rescue advocacy. No one has ever profited from this website in any way. Emily Chason Gilchrist should not be contacted, disturbed or drawn into this process in any way.
Summary of Complaint
On April 28, 2019, I, Margaret Scott Lynch, registered and developed the domain PetRescuesByEmily.com as a pro bono website for my legally blind niece, Emily Chason Gilchrist, an animal rescue advocate who has helped facilitate the placement of more than 450 animals into loving homes.
In early 2025, during serious illness and preparation for multiple surgeries, the domain renewal inadvertently lapsed. The domain was purchased at GoDaddy auction in June 2025 by an unknown registrant concealed behind Domains By Proxy LLC. That registrant is currently operating my original 2019 website without authorization, displaying my original copyrighted content, my original design, my original photographs and a 2019 copyright notice that belongs to me.
This constitutes copyright infringement, trademark infringement, cybersquatting and false and deceptive content. The clone was so convincing that it fooled me, Emily and Emily’s mother Isabel — all people intimately familiar with the original site.
On March 16, 2026, Automattic/WordPress Trust and Safety confirmed the site uses WordPress.org open source software hosted by a third party and that they have no jurisdiction. This confirms our source code findings and establishes an additional deceptive practice — the unauthorized display of WordPress branding to create a false appearance of legitimacy.
Source Code Evidence: Extracted March 14, 2026
The following source code was extracted directly from the live site on March 14, 2026. Every file path references content created by Margaret Scott Lynch and uploaded to her GoDaddy hosting account in May 2019. The current registrant created none of it.
src=”/wp-content/uploads/2019/05/Making-Tracks-www.PetRescuesByEmily.jpg”
src=”/wp-content/uploads/2019/05/Jill-Home.png”
src=”/wp-content/uploads/2019/05/Zoie-and-Jill-1024×911.jpg”
background-image: url(“/wp-content/uploads/2019/05/1500-paws-test.jpg”)
/wp-content/themes/twentyten/style.css?ver=20240716
Copyright 2019, All Rights Reserved — www.PetRescuesByEmily.com
Five Key Findings:
1. All images dated May 2019 — every image references /wp-content/uploads/2019/05/ confirming they were uploaded to my GoDaddy account in May 2019
2. Original WordPress TwentyTen theme — the theme I installed in 2019, not selected by the current registrant
3. Copyright 2019 notice — displayed in the footer of the current site; the current registrant acquired the domain in June 2025 and has no right to display this notice
4. Frozen calendar — the WordPress sidebar calendar displays September 2024 with the 13th highlighted as today; September 13, 2024 was indeed a Friday, proving the current registrant has never once logged in or administered the site
5. Original navigation architecture — all page slugs including Happy Tails, Shelters, Fostering, Topi the Corgi, Dee Dee and individual rescue animals by name are my original architecture; the menu contains personal family references meaningless to any outside party
Wayback Machine Archive Evidence
The Internet Archive’s Wayback Machine contains 38 documented captures of PetRescuesByEmily.com between February 2020 and March 2026, constituting an independent public record of continuous active operation under original ownership.
Full archive, all 38 captures:
https://web.archive.org/web/*/petrescuesbyemily.com
Earliest capture February 23, 2020:
https://web.archive.org/web/20200223124942/http://petrescuesbyemily.com
Last known intact capture September 13, 2024:
https://web.archive.org/web/20240913162245/https://petrescuesbyemily.com/
ICANN Reference Links
Supporting Visual Evidence
Please see supporting screenshots below. These include before and after images of the website including photographs of Jill and Zoie, the beloved dogs who were mascots of the original PetRescuesByEmily.com website as well as coordinating business card.
20260331 Screenshots of Cyber Squatter Site for www.PetRescuesByEmily.com
Contact and Signature
I have substantial evidence to support every statement on this page. Full documentation is available upon request.
Note: I am not an attorney but I have consulted one and all future rights are protected and preserved. All statements of fact are my own. Documentation has been organized and formatted with AI assistance.
Margaret Scott Lynch / ZebraMultimedia / MaggieTheGeek
MaggieTheGeek@gmail.com | Raleigh, North Carolina
Reference: Cloudflare #22078929 | GoDaddy DCU101180266 | ICANN DCUO-63316
