Decision

The three-member Panel found that “Rapid Pay” is a plainly descriptive phrase referring to fast or instant payment services, widely used across the financial industry by over 26 companies globally. Critically, the Panel accepted that we acquired rapidpay.com in August 2015 for its inherent descriptive and commercial value – five years before Green Dot even began using the expression “Rapid! Pay” in connection with its mobile application, and three years before the trademarks were formally assigned to them.

The Panel concluded there was no evidence we had ever targeted Green Dot or sought to exploit its brand, and that holding a descriptive domain name for potential sale at a profit is a recognised legitimate interest under the UDRP.

One panelist, Gerald M. Levine, would have gone further and found the complaint to constitute Reverse Domain Name Hijacking – a finding that the complaint was brought in bad faith to harass a legitimate domain holder. While the majority declined to make that finding, it is a significant signal that a well-represented corporate complainant filing against a descriptive domain with these facts walks a very fine line.

The full decision is reproduced below.

ADMINISTRATIVE PANEL DECISION

Green Dot Corporation v. Cyber Capital Technology, Ltd, WIPO Case No. D2026-0947

1. The Parties

The Complainant is Green Dot Corporation, United States of America (“United States”), represented by CSC Digital Brand Services Group AB, Sweden.

The Respondent is Cyber Capital Technology, Ltd, Hong Kong, China, represented by Ankur Raheja of Cylaw Solutions, India.

2. The Domain Name and Registrar

The disputed domain name <rapidpay.com> is registered with Rabbitsfoot.com LLC d/b/a Oxygen.nyc (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 5, 2026. On March 5, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 9, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 10, 2026, 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 March 12, 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 March 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 5, 2026. After Respondent’s request on April 3, 2026, an automatic extension to file response was granted. The Response was filed with the Center on April 7, 2026.

The Center appointed Wilson Pinheiro Jabur, Harini Narayanswamy and Gerald M. Levine as panelists in this matter on May 1, 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.

The Complainant filed an Unsolicited Supplemental Filing on April 15, 2026. The Respondent filed an Unsolicited Supplemental Filing on May 3, 2026.

4. Factual Background

The Complainant, founded in 1999 and based in the United States, is a financial and bank holding company that renders services such as debit, checking, credit, prepaid and employer payroll cards, in addition to money processing services, tax refunds, cash deposits and disbursements.
In the third quarter of the year 2025, the Complainant declared a total operating revenue of USD 1,5 million and a total of current assets over USD 2,5 million (Annex 6.2 to the Complaint).

The Complainant operates as its primary domain names <greendot.com> and <rapidpaycard.com>. The Complainant is the owner, amongst others, of the following trademark registrations:
– United States trademark registration No. 3,165,975 for the word mark RAPID! PAYCARD, filed on January 22, 2004, registered on October 31, 2006, successively renewed, in class 36; and
– United States trademark registration No. 3,247,918 for the word mark RAPID!, filed, on November 4, 2003, registered on May 29, 2007, successively renewed, in class 36.

The Complainant acquired the RAPID! PAYCARD solution on January 25, 2017, having had the aforementioned trademark registrations assigned to it on November 2018.

The disputed domain name was registered on May 31, 2015, and acquired by the Respondent on August 29, 2015. Presently, the disputed domain name is being offered for sale for USD 199,998.

The Respondent is based in Hong Kong, China, and trades descriptive, common-word and brandable domain names for development or sale.

5. Parties’ Contentions
A. Complainant

The Complainant asserts to be well recognized and respected worldwide and in its industry, having made significant investments in advertising and promotion of its trademark in the media and over the Internet through the years, thus, having developed substantial goodwill in the RAPID! PAYCARD and RAPID! brands, which have become distinctive and uniquely associated with the Complainant and its products and services. Furthermore, the Complainant asserts to be a leading corporation in the fintech industry with a market capitalization of approximately USD 0.64 billion as of February 2026 (Annex 6.3 to the Complaint), being its innovative payroll solutions through its Rapid! brand expanding and continuously supporting more than 7,000 employers.

Under the Complainant’s view, the disputed domain name is a combination of the Complainant’s RAPID! trademark and the generic term “pay”, together forming the term “rapidpay”, not avoiding the omission of the term “card” a finding of confusing similarity with the Complainant’s RAPID! PAYCARD and RAPID! trademarks. Furthermore, the Complainant points out that the removal of the exclamation mark does nothing to distinguish the disputed domain name from the Complainant`s trademarks, not diminishing the confusing similarity between them.

As to the Respondent’s lack of rights or legitimate interests, the Complainant argues that:
– the Respondent is not sponsored by or affiliated with the Complainant in any way;
– the Complainant has not given the Respondent permission to use the Complainant’s trademarks in any manner, nor has the Complainant licensed, authorized, or permitted the Respondent to register domain names incorporating the Complainant’s trademark;
– the Respondent is not commonly known by the disputed domain name; and
– the Respondent is not actively using the disputed domain name, rather offering it for sale for an amount that far exceeds the Respondent’s out-of-pocket expenses in registering the disputed domain name.

As to the Respondent’s bad faith registration and use of the disputed domain name, the Complainant contends that its RAPID! PAYCARD and RAPID! trademarks are known internationally, with trademark registrations in the United States, having the Complainant marketed and sold its goods and services using this trademark since 2004, which is well before Respondent’s registration of the disputed domain name.

Under the Complainant’s view, by registering a domain name that incorporates the dominant part of its RAPID! PAYCARD and RAPID! trademarks, the Respondent has created a domain name that is confusingly similar to the Complainant’s trademarks, as well as prior domain name, thus demonstrating that the Respondent had a knowledge of and familiarity with the Complainant’s brand and business.
Furthermore, the Respondent’s offer to sell the disputed domain name for valuable consideration in excess of his out-of-pocket expenses further corroborates the Respondent’s bad faith conduct. Lastly, the Complainant points out that the Respondent ignored the Complainant’s attempts to resolve this dispute outside of this administrative proceeding, failing to reply to the Complainant’s cease-and-desist letter and subsequent reminders, that is another indicator of the Respondent’s bad faith registration and use of the disputed domain name.

In its Unsolicited Supplemental Filing, the Complainant contends that it can claim rights back to 2006, 2007 given the registration dates of the trademark registrations later assigned to it. The Complainant acknowledges that the terms “rapid” and “pay” are dictionary words on their own; however, the combination of them together is not descriptive or dictionary and the Respondent’s choice to register the disputed domain name combining these terms was not coincidental, particularly taking into consideration the Complainant’s long-lasting domain name. The Complainant further reiterates its understanding that the Respondent has not demonstrated any use of the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services given that the disputed domain name is being listed for sale for USD 199,998, an excessive amount far higher than the Respondent’s out-of-pocket expenses for registering it. The Complainant also submits that the searches conducted on a restricted date range search from January 2015 to September 2015 on <google.com.hk>, reveals multiple links referencing the Complainant and its business, what demonstrates the Complainant’s fame, including in the jurisdiction where the Respondent claims to be located. Lastly, the Complainant highlights the sensitive nature of its business as part of the finance industry, which further increases the potential for fraudulent use of the disputed domain name, such as phishing and/or impersonation.

B. Respondent

The Respondent asserts that the disputed domain name consists of “Rapid Pay”, a plainly descriptive phrase that refers to fast or instant payment services, a concept widely used across the financial and payment industries, such as international bank transfers facilitated through the SWIFT network, not being “rapid” an exclusive, coined or uniquely associated with the Complainant. The Respondent further asserts to have registered the disputed domain name for its clear descriptive meaning and general commercial appeal, not to target the Complainant or any alleged trademark rights, in alignment with what Panels have consistently recognized that domain names consisting of dictionary words or descriptive phrases may be lawfully registered and held for their inherent value, particularly by domain investors.

The Respondent further rebuts the Complainant’s assertion to be the owner of trademark across various jurisdictions given that the Complainant only produced evidence of two trademark registrations in the United States, which were assigned to the Complainant in November 2018, and which do not constitute a “global protection”.

The Respondent further points out that the registration for RAPID! PAYCARD has received a disclaimer as to “paycard” and, thus, the Complainant’s distinctive character of its trademark lies on the exclamation mark, given that the word “rapid” directly describes a quality or characteristic of the services, and therefore, any attempt to stretch the protection to cover the plain, unadorned word “rapid”, or combinations thereof such as “Rapid Pay” go well beyond the scope of the registered marks and must be rejected.

In addition to that, the Respondent contends that the Complainant operates in the payroll card and prepaid debit card sector, a market that is heavily regulated, jurisdiction-specific, and shaped by local banking, payments, and employment law; tied to United States employment and payroll infrastructure; and not the kind of universally consumed good or globally distributed service that might give rise to cross-border reputation even without formal international trademark registrations.

Moreover, the Respondent points out that the Complainant launched (or rebranded) a mobile application under the combination “Rapid! Pay” only in the last quarter of 2020, which is five years after the Respondent acquired the disputed domain name and the Complainant cannot credibly contend that the Respondent could have the Complainant in mind when registering the disputed domain name.
The Respondent further submits not to have ever solicited the Complainant or used the disputed domain name to interfere with, prejudice or harm the Complainant or in any way; rather, always having acted in good faith and with a legitimate interest in the disputed domain name for its descriptive meaning, as a domain name investor.

The Respondent also points out that an online research shows that “Rapid Pay” is used globally in contexts unrelated to the Complainant, in varied sectors. According to “www.opencorporates.com”, there are 26 different companies registered with “Rapid Pay” in their corporate name across multiple countries and jurisdictions (Annex-VI(a) to the Response), what further indicates that RAPID and RAPID PAY are not uniquely associated with the Complainant.

As to the offer for sale, the Respondent’s indicates that such, in itself, does not constitute a violation of the Policy, especially in this case where the disputed domain name was acquired by the Respondent for its inherently descriptive character, there being a legitimate interest in its potential sale for a profit.
Another point argued by the Respondent is that the other domain names indicated by the Complainant, also held by the Respondent, are all part of the Respondent’s portfolio of common dictionary words, names and descriptive phrases which do not constitute examples of cybersquatting.
As to the lack of reply to the Complainant’s cease-and-desist letters, the Respondent indicates not having received them.

Lastly, the Respondent requests that the Complainant should be found guilty of Reverse Domain Name Hijacking (“RDNH”) given that the Complainant, assisted by specialized counsel, should have known when researching and preparing the Complaint that it could not have prevailed given that the disputed domain name was acquired by the Respondent in 2015, while the Complainant was assigned trademarks in 2018 and never made use of sole combination “Rapid Pay” its business until it renamed its mobile app in 2020 to Rapid! Pay.

In its Unsolicited Supplemental Filing, the Respondent requests that the Complainant’s Unsolicited Supplemental Filing be disregarded given that there were no “exceptional circumstances” that would have allowed for such given that all points brought therein were not new and ought to have been presented at the time of the filing of the Complaint, not being it possible for a Complainant, represented by counsel to file a skeletal complaint, await a response that identifies its weaknesses, and then seek to remedy those weaknesses through supplemental submissions.

In addition to rebutting each of the Complainant’s submissions, the Respondent indicates that the restricted date range search conducted by the Complainant from January 2015 to September 2015 on <google.com.hk>, does not reconstruct historical search results, rather Google applying its current ranking algorithms and current index data to a filtered subset of results carrying a date metadata signal, which is itself unreliable and frequently inaccurate given that the snippets, rankings, and URLs visible in such a screenshot reflect how Google’s present-day infrastructure processes the query, not what any user would have seen on “www.google.com.hk” in August 2015.

6. Discussion and Findings

According to paragraph 4(a) of the Policy, in order to succeed, a complainant must establish each of the following elements:

(i) the disputed domain name is identical or confusingly similar to the 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 has been 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 Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1.

The Panel finds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7.

The Panel finds the first element of the Policy has been established.

B. Rights or Legitimate Interests

Based on the available record and as further discussed below, the Panel finds that the Respondent acquired the disputed domain name because of its inherent potentially descriptive or generic character. As reflected in WIPO Overview 3.1, section 2.10.1, panels have recognized that domain names composed of dictionary words or phrases may support a respondent’s rights or legitimate interests where they are used, or demonstrably intended to be used, in connection with their dictionary meaning and not to trade off third-party trademark rights. See also WIPO Overview 3.1, section 3.1.1. In the present case, there is no indication or evidence that the Respondent targeted the Complainant or sought to capitalize on the reputation of its mark.

Accordingly, the Panel finds the second element of the Policy has not been established.

C. Registered and Used in Bad Faith

The evidence in the case file as presented does not indicate that the Respondent’s aim in registering the disputed domain name was to profit from or exploit the Complainant’s trademark.
Having reviewed the case file, the Panel concludes that while the Complainant’s trademark registrations predate the acquisition of the disputed domain name, the Complainant’s predecessor in title was required to disclaim “Paycard”. A “paycard” can be defined as a prepaid card that employers offer to employees as means to receive wages, compensation or employment-related benefits.1

1 In the United States, Regulation E, 12 C.F.R. § 1005.2(b)(3)(i)(A), defines a “payroll card account” as an account “directly or indirectly established through an employer” to which electronic fund transfers of wages, salary, or other employee compensation are made on a recurring basis, regardless of whether it is operated by the employer, payroll processor, bank, or another person

(“https://www.ecfr.gov/current/title-12/chapter-X/part-1005/subpart-A/section-1005.2”. Visited on May 10, 2026). Visa and Mastercard offer reloadable prepaid cards and indicate that they are alternatives to paper checks; and means for employers to distribute wages to employees as well as an alternative to issuing payroll checks, giving employees access to payroll funds on payday and purchasing capability up to the account balance. (“https://usa.visa.com/dam/VCOM/regional/na/us/pay-with-visa/documents/visa-payroll-card-product-profile.pdf” and “https://www.mastercard.com/pr/business/en/corporate/employee/payroll_card.html”. Visited on May 10, 2026).

As such, “paycard” differs from “rapid pay” which carries a different concept and describes a different function, namely the fast payment of something. The Complainant’s rights in RAPID! and RAPID! PAYCARD do not automatically grant the Complainant exclusive rights in “rapid pay” which, as the Respondent appropriately indicated, is widely used by multiple companies in relation to instant or fast payments.

The Panel also notes that the disputed domain name is being offered for sale, but this is not sufficient on its own, considering the circumstances of this case, to conclude that the Complainant has satisfied its burden of proving registration and use in bad faith.

The Panel finds that the Respondent did not register the disputed domain name in bad faith targeting the Complainant or its trademark rights because the Complainant did not prove that the Respondent registered the disputed domain name due to its significance in relation to the Complainant or any trademark of the Complainant. Furthermore, the Complainant did not prove that its marks were notorious or well-known at the time that the Respondent registered the disputed domain name, nor did it assert or provide any evidence of any use of “rapid pay” at that time. WIPO Overview 3.1, section 3.8.1.

The Complainant also did not provide any evidence showing that the Respondent was targeting the Complainant with the disputed domain name at any point in time. On the contrary, the Panel finds more likely than not that the Respondent registered the disputed domain name due to its value as a descriptive domain name.

The Panel finds the third element of the Policy has not been established.

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 of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.1, section 4.16.

The Respondent requests a finding of RDNH, contending, in particular, that the Complainant, represented by specialized counsel, should have known that it could not prevail because the disputed domain name was acquired in 2015, whereas the Complainant only began using the expression “Rapid! Pay” in connection with its mobile application in 2020, and because the disputed domain name consists of descriptive terms.

The Panel has carefully considered the Respondent’s request. As set out above, the Panel concludes that the Complainant has failed to establish that the Respondent acquired the disputed domain name in order to target the Complainant or its trademark rights. The Panel also finds it more likely than not that the Respondent acquired the disputed domain name because of its descriptive or brandable value.
Nevertheless, the majority of the Panel does not consider that the present record warrants a finding of RDNH. The Complainant has demonstrated rights in the RAPID! and RAPID! PAYCARD trademarks which predate the Respondent’s acquisition of the disputed domain name, and the disputed domain name contains the term “rapid” together with the payments-related term “pay”. Although these circumstances are insufficient, in the present case, to establish that the Respondent targeted the Complainant or its trademarks, they provided a basis for the Complainant to submit its claim for determination under the Policy.

The majority of the Panel also notes that the Complainant relied on the offer for sale of the disputed domain name and asserted that it had sent a cease-and-desist letter and subsequent reminders without receiving a reply. The Respondent disputes having received those communications. While these circumstances do not alter the Panel’s conclusion on the merits, the majority of the Panel is not persuaded that the Complaint was filed in bad faith or primarily to harass the Respondent.
Accordingly, the majority of the Panel declines to make a finding of Reverse Domain Name Hijacking. Mr. Levine would have found RDNH.

7. Decision

For the foregoing reasons, the Complaint is denied.

Wilson Pinheiro Jabur
(Presiding Panelist)

Harini Narayanswamy
(Panelist)

Gerald M. Levine
(Panelist)

Date: May 26, 2026

French insurance giant fails for the second time in nearly a decade, with the 2026 panel finding that “axa” carries independent linguistic and acronym value that forecloses any presumption of targeting — echoing the outcome of WIPO Case No. D2017-2497 against the domain’s previous registrant.

AXA SA, the French insurance and financial services giant employing 154,000 people and serving 95 million customers worldwide, owns registered word trademarks for AXA in France (1984), internationally (1984), India (2003), and the EU (2012). The disputed domain name <axa.org> was originally created in 1997 but acquired by the Respondent, VV Reddi of India, in March 2019 through GoDaddy’s aftermarket for approximately USD 1,550. The Respondent operates an “American eXperience Association” platform at the disputed domain name, framing it as an organic extension of his pre-existing Customer eXperience Association at <cxa.org>, with both initiatives built around the “X = Experience” convention used across the CX industry. The Complainant initiated pre-dispute contact in February 2026; the Respondent engaged constructively, acknowledged concerns, and when pressed on transfer offered only documented out-of-pocket cost recovery of USD 1,600–1,650.

The Panel on the third element, while the Panel found the Respondent’s “American eXperience Association” rationale most likely confected, noting the website’s vague content and the absence of any clear reason for the “American” label, it concluded that confection of a reason for registration is not the same as registration in bad faith. The Panel emphasised that “axa” has independent semantic value as a given name in Arabic and Hebrew, a dictionary word in Kurmanji Kurdish, and a functional three-letter acronym string, meaning there was no basis to say the only conceivable use of the domain was to target the Complainant. The Panel also noted the Respondent’s constructive pre-dispute engagement, willingness to modify use, and cost-recovery-only transfer posture as affirmative evidence against bad faith use. Complaint denied.

ADMINISTRATIVE PANEL DECISION

AXA SA v. VV Reddi, American Experience Association, WIPO Case No. D2026-1113

1. The Parties
The Complainant is AXA SA, France, represented by Plasseraud IP Avocats, France.
The Respondent is VV Reddi, American Experience Association, India, represented by Cylaw Solutions, India.

2. The Domain Name and Registrar
The disputed domain name <axa.org> is registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 12, 2026. On March 16, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 16, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Venky Vijay Reddi, Virtuos Digital Ltd) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 17, 2026, providing the registrant and contact information disclosed by the Registrar, and requesting the Complainant to submit an amendment to the Complaint. The Respondent sent a communication to the Center on March 18, 2026. The Complainant filed an amended Complaint on March 19, 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 March 23, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 12, 2026. The Respondent requested a four-calendar day extension for filing the Response in accordance with Paragraph 5(b) of the Rules, the Response due date was then extended to April 16, 2026. The Response was filed with the Center on April 16, 2026.

On April 17, 2026, the Complainant submitted an unsolicited supplemental filing.
The Center appointed Andrew F. Christie as the sole panelist in this matter on April 22, 2026. The Panel finds that it was properly constituted. 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.

On April 23, 2026, the Respondent submitted an unsolicited supplemental filing in response to the Complainant’s unsolicited supplemental filing.

4. Factual Background
The Complainant is the holding company of the AXA group of companies (“AXA Group”). The AXA Group’s roots go back to the 18th century. After a succession of mergers, acquisitions and name changes involving some of the biggest insurance companies around the world, the trade name AXA was introduced in 1995. Employing 154,000 people worldwide, the AXA Group is a world leader in insurance, saving and asset management, serving 95 million customers. It undertakes numerous activities in three major lines of business: property and casualty insurance; life insurance and savings (retirement products, personal protection and healthcare products); and asset management (involves investing and managing assets).

The Complainant owns the following registrations for the word trademark AXA: French Trademark No. 1270658 (registered on January 10, 1984); International Trademark No. 490030 (registered on December 5, 1984); Indian Trademark No. 1247355 (registered on November 3, 2003); and European Union Trade Mark No. 008772766 (registered on September 7, 2012). It also owns a number of registrations for figurative trademarks incorporating AXA.

The Complainant, or what appears to be a member of the AXA Group, is the registrant of various domain names containing the AXA trademark, including <axa.com>, <axa.net>, and <axa.info>.
The disputed domain name has a creation date of July 10, 1997. The Complainant states that historical WhoIs data shows that the Respondent acquired the disputed domain name in March 2019. The Respondent states that he acquired the disputed domain name in March 2019 “through GoDaddy’s open aftermarket … for approx. USD 1500”. The Complainant provided screenshots, dated March 10, 2026, of the homepage of the website to which the disputed domain name resolved. It has a prominent heading “American Experience Association: Advancing Experience”, and says it is “A global platform uniting leaders to design human-centred experiences”. It later states “As part of our broader umbrella brand, the Customer Experience Association (CXA.org) we are building distinctive and high impact Experience Associations”. Under the heading “American Exxperience (sic) Assoc. Services”, it claims to be “Connecting leaders to shape experience-driven growth worldwide”, and purports to offer “Workshops – Interactive sessions designed to inspire and equip teams for experience innovation” and “Consulting – Tailored guidance to embed experience strategies into your business model”.

In February 2026, the Complainant’s domain name portfolio manager sent a communication to the Respondent about it the disputed domain name. The Respondent replied on February 17, 2026, saying, among other things, that the disputed domain name had been “acquired as Premium Domain several years ago in good faith” as the acronym for his American Experience Association initiative, that there “has never been any intention to imitate, reference, misrepresent, or create confusion with any existing brand, company, or website”, that if there are any specific concerns regarding similarity of branding he was “fully open to reviewing and modifying any such aspects to ensure there is no risk of confusion”, and that he sought “further details regarding the nature and basis of the concern so that I may better understand the issue and respond appropriately”. The Complainant’s domain name portfolio manager responded on February 18, 2026, saying that its client was concerned because the disputed domain name is identical to the client’s AXA trademark and <axa.com> domain name, but that “your claims appear to be true, and your reply has been forwarded to AXA SA for review. We will provide an update you once we have their instructions.”

The Complainant’s domain name portfolio manager further responded to the Respondent on February 25, 2026, saying: “I have discussed this matter with my client and while they appreciate your response, they must restate their preference to transfer the domain name. Kindly review and advise if you are willing to do so.” The Respondent replied on February 25, 2026, reiterating that he acquired the disputed domain name in good faith, that there had never been any intention to reference the Complainant, its brand or industry, or to create confusion of any kind. The Respondent concluded by stating: “In the interest of resolving this matter amicably and without escalation, I would be willing to consider a transfer arrangement that reasonably reflects those documented out-of-pocket expenses.”

On March 21, 2026, following filing of the Complaint, the Respondent’s representative wrote to the Complainant’s representative, to place on record the Respondent’s substantive legal and factual position (the substance of which was subsequently included in the filed Response), to extend a good faith proposal for amicable resolution, and to caution the Complainant that proceeding with a factually and legally deficient Complaint carries material risk. The proposal for amicable resolution: (i) provided evidence of the Respondent’s purchase of the disputed domain name for USD 1,550; (ii) stated annual renewal fees had been paid for approximately seven years, amounting to USD 100; (iii) sought reimbursement in the range of USD 1,600-1,650, “representing a purely cost-recovery arrangement with zero profit element”; and (iv) required that all escrow and transfer related fees arising from the domain transfer process be borne exclusively by the Complainant. There is nothing in the case file indicating what, if anything, was the Complainant’s response to this offer.

As at the date of this Decision, the disputed domain name resolves to a website the homepage of which is very similar to the one shown in the Complainant’s screenshots. The website has a number of other pages accessible from the menus titled “About us”, “Focus areas”, “Membership”, “Research”, “Events”, and “Join”.

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 contends that the disputed domain name is identical to a trademark in which it has rights on the following grounds. The disputed domain name reproduces identically the trademark AXA, which has no particular meaning and is therefore highly distinctive. This trademark is well-known around the world in the field of insurance and financial services. The likelihood of confusion is indisputable since the disputed domain name is solely composed of the well-known trademark AXA, without the addition of any other term. The addition of the generic Top-Level Domain (“gTLD”) “.org” is considered a standard for domain name registration and should therefore not be taken into account in the panel’s comparison of the signs. There are indisputable chances that Internet users may believe that the website at the disputed domain name is another official website of the Complainant.

The Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name on the following grounds. The Respondent used an anonymization service when registering the disputed domain name. There is obviously no relationship whatsoever between the parties involved. If the Respondent acquired the disputed domain name in 2019, it is clearly because it is composed of the term “axa” which has acquired a substantial reputation around the world and remains directly associated with the Complainant in the minds of consumers worldwide. The Respondent has not been commonly known by the disputed domain name or even associated with the name AXA, whereas the AXA trademark appears to be well-know. The Respondent appears to use the disputed domain name in connection with activities relating to consulting and customer experience management. However, such use cannot qualify as a bona fide offering of goods or services within the meaning of the Policy. The Respondent’s claim that the disputed domain name is used in connection with a project referred to as the “American Experience Association” is not credible, because the acronym “AXA” does not naturally correspond to the expression “American Experience Association”. The website associated with the disputed domain name itself contains inconsistencies, including references to “American Exxperience Association Services”, which undermines the credibility of the Respondent’s explanation. The content of the website further undermines the credibility of the Respondent’s explanation. The website indicates that the “American Experience Association (AXA.org)” forms part of a broader initiative referred to as the “Customer Experience Association (CXA.org)”, which is presented as the Respondent’s umbrella brand. This statement suggests that the Respondent’s primary initiative is in fact associated with the acronym “CXA”, rather than “AXA”. In these circumstances, there appears to be no logical reason for selecting the acronym “AXA” for the alleged “American Experience Association”. The services described on the website relate to consulting and customer experience management, which are closely related to services covered by the Complainant’s trademark registrations, including business consulting and management services in Class 35. The Respondent also indicated that the disputed domain name was acquired as a “premium domain”. However, the mere acquisition of a domain name because of its short or memorable character does not confer any rights or legitimate interests where the domain name is identical to a well-known trademark such as AXA. In light of these circumstances, the Respondent cannot claim to be making a bona fide offering of goods or services or a legitimate noncommercial or fair use of the disputed domain name.

The Complainant contends that the Respondent has registered the disputed domain name in bad faith on the following grounds. Although the disputed domain name was originally created in 1997, the relevant date for assessing bad faith under the Policy is the date on which the Respondent acquired the disputed domain name, which was in March 2019. By that time, the AXA trademark had long been internationally well known. The reproduction of the well-known AXA trademark in the disputed domain name is a strong indication of bad faith where the Respondent has no connection with the Complainant. The Respondent purposely chose and registered the disputed domain name because it contained the Complainant’s AXA trademark in its entirety. Given that the Respondent is located in India and the AXA trademark has been registered in India since at least 2003, it is highly unlikely that the Respondent was unaware of the Complainant’s trademark rights when acquiring the disputed domain name in 2019. The AXA trademark is highly distinctive and has no ordinary meaning, making it implausible that the Respondent selected the disputed domain name by coincidence. The Respondent initially registered the disputed domain name through an anonymization service, thereby concealing its identity. While the use of such services is not inherently illegitimate, UDRP panels have frequently considered the use of privacy services, combined with other circumstances of the case, as an additional indicator of bad faith. In addition, the Respondent has indicated that the disputed domain name was acquired as a “premium domain”, which confirms that the Respondent recognized the commercial value associated with the disputed domain name. Given the worldwide reputation of the AXA trademark and the absence of any credible explanation for adopting the acronym “AXA”, the only plausible conclusion is that the Respondent intentionally targeted the Complainant’s well-known trademark when acquiring the disputed domain name. This behavior demonstrates that the Respondent intentionally chose and registered the disputed domain name in order to take unfair advantage of the reputation of the Complainant’s well-known AXA trademark.

The Complainant contends that the Respondent is using the disputed domain name in bad faith on the following grounds, among others. The Respondent uses the disputed domain name to host a website promoting a project referred to as the “American Experience Association”, allegedly linked to the Respondent’s consulting and digital transformation activities. However, the Respondent’s explanation that the disputed domain name corresponds to the acronym of “American Experience Association” is not convincing, as the acronym “AXA” does not naturally correspond to that expression. The Respondent has expressed a willingness to consider transferring the disputed domain name in exchange for reimbursement of its costs, which may indicate an intention to derive financial benefit from the disputed domain name. Taken together, these circumstances demonstrate that the Respondent registered and is using the disputed domain name in order to take advantage of the reputation of the Complainant’s well-known AXA trademark. Accordingly, the disputed domain name has been registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy.

B. Respondent

The Respondent denies that the Complainant’s assertion, on which it relies on as the cornerstone of both its similarity and bad faith arguments, that “axa” is an invented term with no particular meaning. This assertion is factually incorrect. Firstly, “Axa” is a recognized given name of Arabic and Hebrew origin, carrying meanings including “the one who is protected” and “source of life”. Secondly, the term “axa” is a living dictionary word in Kurmanji Kurdish – one of the world’s major language groups, spoken by an estimated 15–20 million people across Turkey, Syria, Iraq, and Iran – where it means “agha, feudal lord, or master”.

The Respondent acknowledges, solely for purposes of this proceeding, that the Complainant owns registered trademarks and therefore satisfies the first clause of the Policy. However, the strength of the Complainant’s trademark cannot substitute for failure on clause 2 (legitimate interests) and clause 3 (bad faith), each of which must be independently established.

The Respondent contends that he has rights or legitimate interests in the disputed domain name on the following grounds, among others. The Complainant must make a prima facie case that the Respondent lacks rights or legitimate interests. The Respondent then rebuts by demonstrating at least one circumstance under Policy clause 4(c). Here, the Respondent satisfies Policy clause 4(c)(i), demonstrable preparations to use the disputed domain name in connection with a bona fide offering, and independently qualifies under the broader principles of legitimate acronym use.

The disputed domain name was registered in good faith for a business purpose, the “American eXperience Association”, entirely unrelated to the Complainant or finance/insurance. There is no evidence of targeting, free-riding, or any of the bad faith circumstances listed under Policy. The Respondent’s entire business identity is built around three pillars: Customer Experience (CX), Employee Experience (EX), and Everything Experience (XX). In this industry, the letter “X” universally denotes “Experience” – reflected in the Respondent’s own registered trademarks (CXDesk, CXNow, XONOMY), in global platforms such as Oracle CX, and in standard industry abbreviations used by McKinsey, Gartner, Forrester, and every major management consultancy worldwide. This is not a rationalisation invented for this proceeding. It is the documented foundation of 18 years of commercial activity, registered trademarks, and public communications and it is the context within which the disputed domain name was acquired and used. The Respondent has clear and documented rights and legitimate interests in the disputed domain name, having conceived its American eXperience Association (AXA.org) initiative in 2019 as an organic extension of its established Customer eXperience Association (CXA.org) ecosystem, years before any notice of this dispute. The Respondent registered the disputed domain name in good faith for a genuine business purpose entirely unrelated to the Complainant or the insurance/financial services sector. The Respondent registered the disputed domain name because it was an inherently valuable three-letter domain name which corresponded to his existing venture, <CXA.org>.

The Complainant first contacted the Respondent on February 18, 2026, while the website and AXA Platform were already fully functioning. A genuine, unsolicited third-party subscription to a functioning platform is among the strongest possible evidence of bona fide use prior to any notice of dispute. This conclusively establishes demonstrable preparations to use the disputed domain name in connection with a legitimate offering of services, well before any notice of these proceedings, squarely within the meaning of clause 4(c)(i) of the Policy. The Respondent does not rely on the premium nature of the disputed domain name alone. The USD 1,500 acquisition price corroborates genuine intent, as one does not invest USD 1,500 (and hundreds of development hours thereafter) without a genuine purpose. This is the opposite of passive holding. Research demonstrates extensive third-party use of “AXA” entirely unrelated to the Complainant.

The Respondent contends that he did not register or use the disputed domain name in bad faith on the following grounds, among others. Bad faith registration and bad faith use must be independently established. Under established UDRP jurisprudence, bad faith registration requires evidence of targeting the Complainant’s trademark. Targeting is not presumed from registration of letters that coincide with a registered mark, especially where those letters have genuine independent significance for the Respondent. In March 2019, the Respondent had a pre-existing, documented plan for the American eXperience Association built on a 2017 CXA.org foundation. The Respondent has no connection to insurance or financial services. There is no evidence whatsoever that the Respondent was aware of or intended to exploit the Complainant’s mark. The disputed domain name was publicly available at its listed secondary-market price. The Complainant, with a brand worth USD 18 billion, had every opportunity to acquire it for USD 1,500 in 2019. It did not. It cannot now use the UDRP as a reverse-acquisition mechanism. Use of a privacy or proxy registration service is not in itself an indicator of bad faith.

There is zero commercial overlap between the Complainant (insurance, financial services) and the Respondent (CX technology, non-profit association building). The Respondent operates in a completely different universe of goods and services from the Complainant. Where there is no commercial overlap, there can be no plausible confusion, and where there is no plausible confusion, there is no rational basis for a finding of bad faith targeting. No Internet user seeking insurance would land on the website at the disputed domain name and believe they had reached the Complainant’s website.

Policy paragraph 4(b)(i) requires an offer to sell for valuable consideration in excess of documented out-of-pocket costs. The Respondent sought the documented costs only when transfer was insisted upon. After the Complaint was filed, the Respondent’s counsel by letter dated March 21, 2026, formally specified the total reimbursement sought as USD 1,600–1,650, representing the documented acquisition cost of USD 1,550 plus seven years of renewal fees of approximately USD 100, explicitly described as “a purely cost-recovery arrangement with zero profit element, which is permitted in terms of the Policy as well”. Later, the Respondent also communicated on March 30, 2026 concerning additional legal expenses, but the Complainant chose not to accept this reasonable proposal and instead continued with the Complaint, a decision that now carries the risk of a formal Reverse Domain Name Hijacking (“RDNH”) finding on the public record.

The Respondent requests a finding of RDNH against the Complainant on the following grounds. The Complainant, through CSC Global, initiated contact with the Respondent in February 2026 and acknowledged: “your claims appear to be true”. The Complainant has further mischaracterized the Respondent’s documented cost-recovery proposal, framing it as evidence of bad faith, which is an inversion of established UDRP doctrine that no competent practitioner could genuinely believe. Taken together, filing with prior knowledge of a credible defence, suppressing an adverse prior decision, and distorting settlement correspondence, this is precisely the kind of conduct that warrants an RDNH finding. The Complainant entirely omits from its Complaint the prior UDRP case AXA SA v. Advocates Across America, WIPO Case No. D2017-2497, concerning the disputed domain name, which it lost against the previous registrant. This is a material omission in a proceeding where candor is expected. The entire bad faith case rests on the fame of the AXA trademark and the identity of the disputed domain name string, without a single piece of evidence that the Respondent was aware of and sought to exploit the Complainant’s brand. Trademark notoriety alone does not establish bad faith registration. Of 283 AXA-string domain names, the Complainant holds only 30-35. It has not pursued UDRP actions against <axa.co.ke>, <axa.is>, <axa.us>, <axa.hr>, <axa.ro>, or dozens of others. Selective, strategic enforcement against one legitimate registrant is not diligent brand stewardship. This case is not borderline. The Complainant had full information before filing, did not perform proper due diligence and proceeded regardless.

6. Discussion and Findings

A. Preliminary Issue – Unsolicited Supplemental Submissions

As noted in WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1“), section 4.6, paragraph 10 of the UDRP Rules vests the panel with the authority to determine the admissibility, relevance, materiality and weight of the evidence, and also to conduct the proceedings with due expedition. Paragraph 12 of the UDRP Rules expressly provides that it is for the panel to request, in its sole discretion, any further statements or documents from the parties it may deem necessary to decide the case. Unsolicited supplemental filings are generally discouraged, unless specifically requested by the panel. Panels have repeatedly affirmed that the party submitting or requesting to submit an unsolicited supplemental filing should clearly show its relevance to the case and why it was unable to provide the information contained therein in its complaint or response (e.g., owing to some unforeseen or exceptional circumstance).

The Complainant sought to introduce into the case record an unsolicited supplemental filing, on the ground that “the Respondent has introduced a number of factual allegations that warrant clarification”. That is not a sufficient basis for requesting the Panel to exercise its discretion to admit an unsolicited supplemental filing. Furthermore, it appears that none of the matters in the Complainant’s supplemental filing address issues that either had not already been addressed in the Complaint or could not reasonably have been anticipated at the filing of the Complaint would likely arise for consideration. In any event, the Panel has read the Complainant’s supplemental filing and found that none of the material in it makes a material contribution to the determination of the outcome of the case.

Accordingly, the Panel does not admit the Complainant’s supplemental filing and, correspondingly, does not admit the Respondent’s supplemental filing in response to it.

B. 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 3.1, section 1.7.
The Complainant is the owner of a registration for the word trademark AXA. Once the gTLD “.org” is ignored, which is appropriate in this case, the disputed domain name is identical to the Complainant’s word trademark.

The Panel finds the first element of the Policy has been established.

C. Rights or Legitimate Interests

Given the finding on the third element of the Policy (discussed immediately below), it is not necessary for the resolution of this Complaint for the Panel to reach a conclusion on the question of whether the Respondent has demonstrated rights or legitimate interests in the disputed domain name. Accordingly, the Panel makes no finding on this issue.

D. Registered and Used in Bad Faith

The evidence in the case file as presented does not indicate that the Respondent’s aim in registering the disputed domain name was to profit from or exploit the Complainant’s trademark. Moreover, there is no evidence in the case file as presented that indicates that the Respondent has used the disputed domain name in that manner.

Given the substantial use and reputation of the Complainant’s AXA trademark, the Panel is satisfied that the Respondent was aware of the Complainant and its trademark at the time it registered the disputed domain name (which both parties agree was in March 2019). At that time, the Respondent would have understood that it could not use the disputed domain name in any manner which would cause confusion with the Complainant’s trademark. It is not surprising, therefore, that the Respondent has not done so.
The Respondent asserted that he registered the disputed domain name to use for his “American eXperience Association”, being “an organic extension of its established Customer eXperience Association (CXA.org) ecosystem”. Put bluntly, the Panel views this explanation as artificial. The website resolving from the disputed domain name contains only vague and general of statements as to the purpose of the Association. It is not clear to the Panel that the Association in fact provides any substantive services. Moreover, it is not clear why the Association has “American” in its name. There appear to be only two references to American or America on the website. The first, on the “About us” page under the heading “Why Experience Matters”, is the statement “American Experience Association (AXA.org) is deeply influenced by the American Marketing Association (AMA.org) to galvanize the importance of CX in the Age of Commoditization”. The second, on the “About us” page under the heading “Our Mission”, is the statement “Although we are named the American Experience Association, we operate from India with a strong virtual presence, serving a global community without geographical boundaries”. The Panel can see nothing on the website which justifies why this Experience Association is called an “American” one. The Panel considers it most likely that the Respondent has confected the concept of an American Experience Association so as to provide a reason for registering the disputed domain name and a purported bona fide use of it.

However, the fact that the Respondent most likely confected a reason for registration and for use of the disputed domain name is not necessarily the same thing as the Respondent having registered and used the disputed domain name in bad faith. The disputed domain name has an inherent value due to the fact that it is comprised of only three characters. While it is true that those three characters are also the Complainant’s trademark, that is not the only semantic value of the three characters. The Respondent’s assertion those three characters are a given name of Arabic and Hebrew origin, and a word in Kurmanji Kurdish, appear to be valid. Furthermore, while not common, there are words in English that begin with the letter “x”. Thus, the three characters “axa” can operate as an acronym, thereby providing an additional semantic value to the character string.

For these reasons, this is not a case in which there is no conceivable good faith use to which the disputed domain name could be put. Accordingly, the Panel does not accept the Complainant’s assertion that the only plausible conclusion is that the Respondent intentionally targeted the Complainant’s well-known trademark when acquiring the disputed domain name. The Panel is of the view that, the Complainant has not definitively proven that, more likely than not, the reason the Respondent registered the disputed domain name is because of and to target the Complainant, rather than due to its inherent value as three-letter domain name and the potential non-infringing uses to which it could be put.
Importantly, there is no evidence in the case record showing that the Respondent has acted in bad faith. There is no evidence that the disputed domain name has been used in a manner which has, or is likely to, cause confusion between the Respondent and the Complainant. The Panel is satisfied that a typical Internet user visiting the Respondent’s website would not think that it was in connected with the Complainant.

Furthermore, there is evidence in the case record that the Respondent replied constructively to the Complainant’s concerns about the disputed domain name, indicated willingness to comply with suggestions from the Complaint for modifying use of the disputed domain name to ensure there is no risk of confusion, and, when pressed by the Complainant on transferring the disputed domain name, indicated it was willing to do so merely for reasonable, documented out-of-pocket expenses.
Having duly considered all of the relevant evidence in the case record, the Panel finds that the Complainant has not discharged its evidentiary burden and that the third element of the Policy has not been established.

E. 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 of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.1, section 4.16.

Section 4.16 of the WIPO Overview 3.1, lists, non-exhaustively, circumstances which previous panels have considered to be indicative of a complaint having been brought in bad faith. One such circumstance is facts which demonstrate that the complainant clearly ought to have known it could not succeed under any fair interpretation of facts reasonably available prior to the filing of the complaint. As discussed above, there is no evidence showing that the Respondent acted in bad faith when registering and using the disputed domain name. Nevertheless, given the apparently confected nature of the Respondent’s motivation for registering the disputed domain name, the Panel is not persuaded that the Complainant should have known it could not succeed under any fair interpretation of facts reasonably available at the time it filed the Complaint.

Accordingly, the Panel finds that the Complaint was not brought in bad faith, in an attempt at Reverse Domain Name Hijacking, and therefore did not constitute an abuse of the administrative proceeding.

7. Decision

For the foregoing reasons, the Complaint is denied.

Andrew F. Christie
Sole Panelist
Date: May 15, 2026

Social Expansion LLC DBA TalentPop v. Jared Orkin,

WIPO Case No. D2026-0445

1. The Parties

Complainant is Social Expansion LLC DBA TalentPop, United States of America (“United States”),
represented internally. Respondent is Jared Orkin, United States.

2. The Domain Name and Registrar
The disputed domain name <talentpop.com> (hereinafter the “Disputed Domain Name”) is registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 3,
2026. On February 4, 2026, the Center transmitted by email to the Registrar a request for registrar
verification in connection with the Disputed Domain Name. On February 4, 2026, the Registrar transmitted by email to the Center its verification response confirming that Respondent is listed as the registrant and providing the contact details.

The Center verified that the 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 Respondent of the Complaint, and the proceedings commenced on February 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 5, 2026. Respondent requested an automatic extension of the Response on March 6, 2026. On March 9, 2026, the Center confirmed the Response due date was extended to March 15, 2026. The Response was filed with the Center on March 14, 2026.

The Center appointed Lawrence K. Nodine as the sole panelist in this matter on March 24, 2026. The Panel finds that it was properly constituted. 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.

Panel Order

On April 9, 2026, the Panel issued an Order asking the parties to clarify when the Disputed Domain Name was registered by or transferred to Respondent and to clarify whether either party was related to prior owners of the Disputed Domain Name. Both parties filed timely responses.

4. Factual Background

Complainant provides staffing services to businesses, including staffing for outsourced customer support, executive assistants, and marketing assistants for e-commerce and technology companies. Complainant’s customers consist of businesses operating in the e-commerce and technology sectors.

Complainant has operated continuously under the TALENTPOP name since April 2020 and has a pending application at the USPTO claiming use in commerce since 2021. Complainant operates its primary website at <talentpop.co>.

Respondent Jared Orkin is Chief Executive Officer of Activate Talent, LLC, which, since 2023, has been in business recruiting and providing remote staffing for e-commerce and digital businesses. Respondent promotes its business via its website at <activatetalent.com>.

On January 20, 2026, Respondent purchased the Disputed Domain Name from GoDaddy (The Disputed Domain Name was originally registered by an unrelated third party in 2001. There is no evidence that Respondent was related to the original registrant.)

Respondent redirects the Disputed Domain Name to <activatetalent.com>. The term TALENTPOP does not appear in the text displayed on Respondent’s <activatetalent.com> website.

5. Parties’ Contentions

A. Complainant

Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Name.

Notably, with respect to the issue most relevant to the Panel’s decision, Complainant alleges that it “operated continuously under the TALENTPOP name since April 2020 and has, over approximately six (6) years, built goodwill, brand recognition, and a commercial presence in its industry”. Accordingly, Complainant contends that it owns unregistered common law rights in TALENTPOP as a trademark.

Although not relevant to the issues that are, in the Panel’s view, determinative, the Panel acknowledges that Complainant also contends that Respondent is a competitor and that Respondent is using the Disputed Domain Name in bad faith to exploit Complainant’s business reputation and cause confusion to attract Internet traffic, which it then redirects to Respondent’s competing website.

B. Respondent

Respondent contends that Complainant has not satisfied all three of the elements required under the Policy for a transfer of the Disputed Domain Name.

With respect to the issue most relevant to the Panel’s decision, Respondent contends that Complainant
has not offered evidence to support its claim of unregistered rights.

Although not relevant to the determinative issue, the Panel acknowledges that Respondent also contends that:

• • “Talent Pop” is descriptive; that both component terms (“Talent” and “Pop”) are frequently combined for their descriptive connotations in the recruiting and human resources fields; and that Respondent registered the Disputed Domain Name because of its descriptiveness.
• There is substantial third-party use of similar trademarks.
• The Complaint alleges trademark dispute between competitors that is outside the scope of the
  Policy.

6. Discussion and Findings

Identical or Confusingly Similar 

The Panel finds the first element of the Policy has not been established. Although Complainant alleges that it has used TALENTPOP as a trademark since April 2020, and points to Internet Archive screenshots to support this claim, Complainant has not offered any evidence regarding the quantity or scope of this use.

This is not sufficient under the Policy. As is explained in WIPO Overview 3.1, section 1.3. “specific
evidence including for example documented evidence of figures relating to sales, marketing, asnd/or social media endorsements supporting assertions of acquired distinctiveness should be included in the complaint; conclusory allegations of unregistered or common law rights, even if undisputed in the particular UDRP case, would not normally suffice to show secondary meaning.”

Although the Panel finds that Complainant has not submitted sufficient evidence to satisfy the Policy, the Panel does not find that no such rights exist. On the contrary, Complainant’s website scrolls the brand names of many prominent companies with which Complainant purports to have done business.

Evidence to substantiate and quantify Complainant’s relationship with these clients could have helped Complainant support its claim of unregistered trademark rights.

Because Complainant has not satisfied the requirements of Policy paragraph 4(a)(i), the Panel need not address the requirements of Policy paragraphs 4(ii) and 4(a)(iii).

That said, the Panel makes some observations:

While the Respondent asserts that he was unaware of the Complainant, the Panel notes that the Parties are competitors and the disputed domain name is identical to the claimed mark, with the exception of the Top Level Domain.

The majority of the Response is focused on attacking any claim to unregistered trademark rights, for example, the Respondent points to a number of third party uses (including the prior registrant of the disputed domain name) of the term “pop” being used in the talent industry; the Panel has doubts that all of the uses invoked by the Respondent squarely support his case. The Respondent suggests that the disputed domain name is a “common combination” and a dictionary word and also descriptive and laudatory.

The Respondent also suggests that “pop” is an acronym with various meanings and that; while this may be true, it strikes the Panel that the Respondent is offering a number of narratives which are not necessarily aligned, and which cumulatively serve to call into doubt the true registration intentions. The Respondent also mentions a USPTO-registered mark on the Supplemental Register for “POPUP TALENT” with “talent” disclaimed and even goes so far as to suggest that “a registrant has every right to register the most apt and quintessentially descriptive term for its business, even if it is confusingly similar to domain name or trademark”.

While the Panel cannot discount the Respondent’s claim to not have been aware of the Complainant, above all, it is noted that the parties are in the same industry. At the same time, there are sufficient questions concerning the scope of the Complainant’s reputation (which it could have addressed in the Complaint) and the potential strength of its mark – whether eventually registered or not (and whether on the Principal or Supplemental Register) such that the Panel considers this case advanced by the Complainant, at least based on the evidence provided, not capable of reaching a disposition (let alone carrying its burden).

7. Decision 

For the foregoing reasons, the Complaint is denied without prejudice to the Complainant’s ability to refile.

Lawrence K. Nodine 
Sole Panelist
Date: April 29, 2026

 

Comment: “The Panel’s decision reinforces a fundamental principle of the UDRP: the burden of proof lies squarely on the Complainant. In this case, the Complainant relied on conclusory allegations of common law rights without providing the necessary sales, marketing, or social media evidence required to show secondary meaning. Our defense successfully highlighted these evidentiary gaps, ensuring that the Disputed Domain Name remained with its rightful registrant.”

ADMINISTRATIVE PANEL DECISION
Etihad Airways v. Hale Com
Case No. DAI2025-0058

1. The Parties
The Complainant is Etihad Airways, United Arab Emirates (“UAE”), represented by Clyde & Co., UAE.
The Respondent is Hale Com, United States of America (“United States” or “US”), represented by Archer
Softech, India.

2. The Domain Name and Registrar
The disputed domain name <etihad.ai> is registered with .AI Registry (the “Registry”).

3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 31, 2025. On November 4, 2025, the Center transmitted by email to the Registry a request for registrar verification in connection with the disputed domain name. On November 5, 2025, the Registry transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. On November 6, 2025, the Center received an email communication from the Respondent.

The Center verified that the 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 November 14, 2025. In accordance with the Rules,
paragraph 5, the original due date for Response was December 4, 2025. On November 26, 2025, the
Respondent sent an email communication requesting an extension under paragraph 5(b) of the Rules.

On the same day, the Center confirmed that the Respondent was granted the automatic four calendar day
extension for response; the new due date for Response was December 8, 2025. The Response was filed
with the Center on December 8, 2025.

The Center appointed Matthew Kennedy, Luca Barbero, and Gerald M. Levine as panelists in this matter on January 13, 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

The Complainant is the national airline of the UAE. It commenced operations in November 2003 and now operates one of the largest airlines in the UAE. It carried more than two million passengers in a single month in August 2025. It has won multiple industry awards, including Cargo Airline of the Year 2015 (Air Cargo Week Awards); Airline of the Year 2016 (Air Transport World Awards); Cargo Airline of the Year 2022 (Aviation Achievement Awards); and Air Cargo Operator of the Year 2022 (Logistics Middle East Awards).

The Complainant owns trademarks in multiple jurisdictions, including the following:

− United States trademark registration number 3329038 for ETIHAD, registered on November 6, 2007,
specifying services in class 39, including airline transportation services;
− UAE trademark registration number 161681 for ETIHAD, registered on December 25, 2011, specifying
services in class 43, including services for providing food and drink;
− UAE trademark registration number 155789 for a stylized ETIHAD mark, registered on May 15, 2013,
specifying services in class 39, including airline services for the transportation of passengers and cargo; and
− United States trademark registration number 4374230 for ETIHAD, registered on July 30, 2013,
specifying services in class 35, including advertising services.

The above trademark registrations are current. The United States registrations include the information that the English translation of the word “Etihad” is “union”. The Complainant has registered the domain name <etihad.com> that it uses in connection with a multilingual website where it provides information about itself and offers flight reservation services. The Complainant has also registered the domain name
<etihadairways.com> that redirects to <etihad.com>.

The Respondent “Hale Com” or “Hale” is allegedly a company and its alter ego is a domain name investor
based in the United States (both are referred to below as “the Respondent”). The evidence on file shows
that in 2017 the Respondent signed up for an online course that was part of a program on practical deep
learning for coders. The Respondent holds multiple domain names in the “.ai” country code Top-Level
Domain (“ccTLD”), including <motor.ai>, <acquisition.ai>, <artifact.ai>, <banco.ai>, <das.ai>, <doha.ai>, <internship.ai>, <institution.ai>, <kismet.ai>, <mdm.ai>, <ser.ai>, and the disputed domain name.

The disputed domain name was created on December 16, 2017 and acquired by the Respondent in his personal name at auction on or about August 7, 2023 for a price of USD 631. The registrant name was
changed to “Hale Com” at some point between August 26, 2023 and November 15, 2023 but the contact
information in the WhoIs database was left incomplete. (The Respondent submits that he redacted part of the WhoIs information because he was a victim of identity theft a few years ago. In the Response, he undertakes to correct this when the disputed domain name is unlocked.)

The disputed domain name resolves to a webpage hosted by a domain name broker. At the time when the
Complaint was filed, the webpage advertised the disputed domain name for sale at an asking price of USD 98,500. At the time of this Decision, the webpage advises that the disputed domain name is registered but might still be available; it displays a button to purchase the disputed domain name but no longer displays a price. “Etihad” is a Latin transliteration of an Arabic word “اتحاد “meaning “union” or “unity”.

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.

Notably, the Complainant contends that the disputed domain name is identical to its ETIHAD mark. The
Complainant has established substantial goodwill and reputation in, and has become exclusively associated with the ETIHAD trademark worldwide.

The Respondent has no rights or legitimate interests in respect of the disputed domain name. The
Complainant has not authorized the Respondent to use its ETIHAD mark, nor is there any relationship
between the Parties that would entitle the Respondent to use the mark. The Respondent is not commonly
known by the disputed domain name. The disputed domain name automatically redirects to a website where it is advertised for sale to the general public at an asking price of USD 98,500, which cannot constitute a bona fide offering of goods or services for the purposes of the Policy.

The disputed domain name has been registered and is being used in bad faith. The disputed domain name is not being used in connection with any legitimate interests. Rather, it is being offered for sale suggesting that the Respondent has registered or acquired the disputed domain name primarily for commercial gain for the purpose of selling, renting, or otherwise transferring the disputed domain name to the Complainant or to third parties such as a competitor, for valuable consideration in excess of the Respondent’s documented out-of-pocket costs directly related to the disputed domain name.

Furthermore, the Respondent creates a likelihood of confusion with the Complainant and its trademarks by registering a domain name that incorporates the Complainant’s ETIHAD trademark, which demonstrates that the Respondent is using the domain to confuse unsuspecting Internet users looking for the Complainant’s services and to mislead them as to the source of the disputed domain name and/or capitalize on the reputation and goodwill of the Complainant’s mark.

B. Respondent

The Respondent contends that the Complainant has not satisfied all the elements required under the Policy for a transfer of the disputed domain name.

At the outset, the Respondent submits that “Etihad” is the transliteration of a common Arabic word meaning “union” or “unity” and is therefore inherently non-distinctive. Just as the word “United” itself cannot be exclusively appropriated by United Airlines, the same principle should apply to the word “Etihad” in Arabic.

The Respondent submits that he is a US-based technology professional specializing in artificial Intelligence (“AI”), currently employed in the AI sector. Over the course of his career, he has contributed to multiple AI projects and has extensive experience. He studied AI and deep learning with Fast.AI at the University of San Francisco in person starting in 2017. Beginning in 2018, he started registering “.ai” domain names in order to launch vision and speech AI apps.

The Respondent acknowledges that the Complainant has standing under the Policy but submits that the
Complainant has not made a prima facie case that the Respondent lacks a right or legitimate interest in the disputed domain name. The Respondent needs no license or authorization from the Complainant to offer it for sale. The Respondent has been a domain name investor for numerous years and maintains a portfolio of hundreds of domain names. The Respondent acquired the disputed domain name to develop an Arabic translation and speech web application but, due to the rise of Large Language Models, the use case for a stand-alone Arabic application became redundant. Hence, the Respondent put the disputed domain name up for sale via a third party service in mid-2024 and, as of today, it is part of the Respondent’s stock-in-trade.

The Respondent’s portfolio includes several “.ai” domain names, with a consistent focus on short, common word or other generic “.com” domain names. His portfolio includes Arabic/Urdu domain names such as <kismet.ai> (meaning ‘fate’); <ser.ai> (a unit of weight); <waz.ai> (meaning “preaching”); and <das.ai> (meaning “ten”). The Respondent has offered certain other “.ai” domain names at prices even higher than USD 98,500. The price for the disputed domain name was set below USD 50,000 about a year ago and was only increased after reports of numerous “.ai” sales, in line with broader market trends. “Etihad” is not uniquely associated with the Complainant but is used in other contexts including the technology, financial, insurance, and construction sectors. This widespread usage and the common nature of the term demonstrate that the Respondent had ample legitimate reason to register the disputed domain name for an AI project and later retain it as an investment.

The disputed domain name was neither registered nor is being used in bad faith. There is no evidence
whatsoever to support the Complainant’s narrow contention that the disputed domain name was registered because of the Complainant’s trademark only, and not due to it being a transliteration of a common Arabic word meaning “union” or “unity”. The Respondent registered the disputed domain name because of its inherent meaning and suitability as a generic, brandable term in the “.ai” space, rather than with any intention of targeting the Complainant’s trademark. Speculating and investing in inherently valuable domain names is a legitimate business and in good faith. Given the Respondent’s Arabic roots and AI background, and the common descriptive meaning of “Etihad” in the Arabic language, the disputed domain name was registered in good faith to develop an Arabic translation web-based App. The Respondent did not offer the disputed domain name for sale for more than a year after its registration. The Respondent’s general offer for sale of the common word disputed domain name for USD 98,500 through a broker is not any kind of bad faith, as the Respondent never approached the Complainant. No right of the Complainant or its mark has in any manner been violated.

The Respondent requests that the Panel issue a finding of Reverse Domain Name Hijacking since there is
no basis for this claim and the Complainant (through its counsel) knew or should have known that before
filing the Complaint that it would not succeed in proving at least one of the three elements of the Policy.
Proceedings under the Policy must not be commenced in a brash and totally unjustifiable attempt to pressure a domain name owner into releasing a legitimately held domain name.

6. Discussion and Findings

Paragraph 4(a) of the Policy provides that a complainant must demonstrate each of the following elements:
(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 has been registered and is being used in bad faith.
The burden of proof of each element is borne by the Complainant. Failure to demonstrate any one element will result in denial of the Complaint.

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. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7.

The Complainant has shown rights in respect of the ETIHAD trademark for the purposes of the Policy. See WIPO Overview 3.0, section 1.2.1.

The entirety of the ETIHAD mark is reproduced within the disputed domain name. The only additional
element is the ccTLD extension “.ai” which, as a standard requirement of domain name registration, may be disregarded in the assessment of identity or confusing similarity for the purposes of the Policy.

Accordingly,  the disputed domain name is identical to the mark for the purposes of the Policy. See WIPO Overview 3.0, sections 1.7 and 1.11.1.

Therefore, the Panel finds the first element of the Policy has been established.

B. Rights or Legitimate Interests

Given the Panel’s findings regarding the third element of paragraph 4(a) of the Policy, it is unnecessary to consider the second element.

C. Registered and Used in Bad Faith

The Panel notes that the third element of paragraph 4(a) of the Policy contains two requirements that apply conjunctively. A complainant must show both that the disputed domain name has been registered or acquired in bad faith and also that it is being used in bad faith. The former requires a demonstration that the Respondent knew, or should have known of the Complainant and/or the Complainant’s trademark at the time when it registered or acquired the disputed domain name and that it registered or acquired the disputed domain name with a bad faith intention targeting the Complainant and/or its mark.

In the present dispute, the disputed domain name was acquired by the Respondent in 2023, years after the registration of the Complainant’s ETIHAD mark, including in the United States, where the Respondent is based. The disputed domain name is identical to the ETIHAD mark, but the mark is not a coined term. The Complainant asserts that it has established substantial goodwill and reputation in the ETIHAD trademark worldwide. The Complainant has been operating its airline since 2003, which was 20 years before the Respondent acquired the disputed domain name, and has won various industry awards during that time. It presents figures showing that it transported millions of passengers per year in recent years. Nowhere in the detailed Response does the Respondent deny awareness of the Complainant or its mark at any relevant time. Accordingly, the Panel is willing to infer that the Respondent knew of the Complainant and its mark when he acquired the disputed domain name.

Nevertheless, the disputed domain name is a transliteration of the common Arabic word “اتحاد“, meaning
“union” or “unity”, which is not an exclusive reference to the Complainant. The Respondent, who plausibly attests that he is an Arabic speaker born in Djibouti, submits that it was in this ordinary, dictionary word sense that he understood the term when deciding to acquire the disputed domain name. His evidence shows that the Arabic word “ اتحاد)“etihad) is used in different contexts, such as a gathering of people, a student union, a larger corporation, or a group of countries. According to evidence presented by the Respondent, the Complainant itself has explained on social media that “‘Etihad’ means ‘union’ in Arabic, which also refers to the Union of the seven Emirates.” The UAE national day is known as “Eid al Etihad”.

The Respondent submits that “Etihad” is a generic, brandable term that has been independently adopted by various parties due to its common meaning in the Arabic language. The evidence shows that this term is relatively common in branding in the Middle East, Africa, and Asia, across a range of sectors. For example, there are active websites for Etihad Advanced Investment, Etihad National Holding, Etihad Energy Services, Etihad Capital, Etihad Hospitality, Al-Etihad Gold, Etihad Food Industries, Etihad Medical Services, Etihad Sugar Mills, Etihad Technology, Etihad Town, Etihad Blue Contracting Co., El Etihad (engineering and electromechanical), Etihad Holding, Etihad Leading Investment, Al-Etihad Gasket Factory, Bank Al-Etihad, Etihad Zurmati Cold Storage Company, Etihad Club, and Etihad Logistics. According to search results presented by the Respondent, over 200 companies in different jurisdictions incorporate “Etihad” in their company names; including many that are active and do not appear to be affiliated with the Complainant.

The Panel sees no evidence on the record that the Respondent acquired the disputed domain name based
on its trademark significance rather than its meaning as a transliteration of a common word. The disputed domain name does not contain any term that refers to the Complainant (such as “airways”) nor does the ccTLD extension “.ai” have any apparent connection to the Complainant’s operations (whether it is understood as a ccTLD reference or to artificial intelligence). The disputed domain name has not been used with website content displaying the Complainant’s stylized mark or related to its services. The Respondent did not contact the Complainant. The Respondent has no pattern of bad faith registrations as far as the Panel is aware; on the contrary, his portfolio of domain names in the “.ai” ccTLD contains at least 11 others consisting of a dictionary word or a transliteration of a word (although none other is clearly a transliteration of an Arabic word).

The Complainant argues that the offering of the disputed domain name for sale is evidence of bad faith.
However, generally speaking, prior UDRP panels have found that the practice as such of registering a
domain name for subsequent resale (including for a profit) would not by itself support a claim that the
respondent registered the domain name in bad faith with the primary purpose of selling to a trademark owner (or its competitor). See WIPO Overview 3.0, section 3.1.1. In the present dispute, the Panel is unable to determine that the Respondent’s asking price of USD 98,500 reflected the disputed domain name’s value as a trademark rather than as a transliteration of a common word in the “.ai” ccTLD.

While the Respondent fails to substantiate his allegation that he originally intended to use the disputed
domain name with a web application and only offered it for sale later, that does not alter the Panel’s
conclusion in the circumstances of this case.

Accordingly, the evidence in the case file as presented does not indicate that the Respondent’s aim in
registering the disputed domain name was to profit from or exploit the Complainant’s trademark. Therefore, the Panel finds the third element of the Policy has not been established.

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 of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. See WIPO Overview 3.0, section 4.16.

In the present dispute, the Complainant failed to address the material circumstance that its ETIHAD
trademark is a transliteration of an Arabic word meaning “union”. The Complainant and its legal
representative are both based in the UAE and can be presumed to be aware of that circumstance; indeed, it is noted on a trademark registration certificate annexed to the Complaint. Even though the Complainant may have obtained the transfer of other domain names in prior UDRP proceedings without addressing this circumstance, the Complainant should have appreciated the factual differences in the present dispute, in particular, the composition of the disputed domain name and the absence of targeting of the Complainant or its mark. While the Complainant alleged that the offering of the disputed domain name for sale constituted evidence of targeting, this was based on the premise that the term “Etihad” is uniquely associated with the  Complainant. The Complainant, which has legal representation, should have appreciated the weakness of its case and the need to provide evidence of targeting in light of the dictionary meaning of “ اتحاد) “etihad).

Therefore, the Panel finds that the Complaint has been brought in bad faith and constitutes an attempt at
Reverse Domain Name Hijacking.

7. Decision

For the foregoing reasons, the Complaint is denied.

Matthew Kennedy
Presiding Panelist

Luca Barbero
Panelist

Gerald M. Levine
Panelist
Date: January 22, 2026

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION

La Banque Populaire Val de France v. Kaparthi Jonnalagadda
WIPO Case No. D2025-46381.

The Parties
The Complainant is La Banque Populaire Val de France, France, represented by La SELARL JB avocat, France.
The Respondent is Kaparthi Jonnalagadda, India, represented by Cylaw Solutions, India.

2. The Domain Name and Registrar
The disputed domain name <vdft.com> is registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History
The Complaint was filed in French with the WIPO Arbitration and Mediation Center (the “Center”) on November 7, 2025. On November 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 10, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 11, 2025, 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, in French, on November 12, 2025.
On November 11, 2025, the Center informed the parties in English and French, that the language of the registration agreement for the disputed domain name is English. On November 12, 2025, the Complainant confirmed its request that French be the language of the proceeding. The Respondent objected to the Complainant’s request.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 November 13, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 3, 2025. The Respondent requested on November 27, 2025, an extension of the Response due date. The Respondent was granted the automatic four calendar day extension for response under paragraph 5(b) of the Rules and the Response was therefore due December 7, 2025. The Response was filed in English with the Center on December 1, 2025.
The Center appointed Wilson Pinheiro Jabur as the sole panelist in this matter on December 16, 2025. The Panel finds that it was properly constituted. 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

The Complainant is a French credit provider, part of the BCPE group. The Complainant provides credit to buyers and private investors in connection with new residential programs under the VAL DE FRANCE TRANSACTIONS or VDFT mark since 2012.

The Complainant operates the domain name <banquepopulaire.fr/valdefrance> and owns the domain name <vdft.fr> (registered on December 8, 2014).

The disputed domain name was registered on April 21, 2005, and resolves to a parked webpage offering it for sale for USD 89,999.

The Respondent is a domain name investor based in India, holding other four-letter domain names.

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.

Initially, the Complainant requests that French be the language of the proceedings given that, not only the disputed domain name makes reference to the VAL DE FRANCE TRANSACTIONS or VDFT mark used by the Complainant which is the owner of the trademark BANQUE POPULAIRE VAL DE FRANCE, declared notorious in France, but also to the fact that the Respondent selected a privacy protection service so as to conceal its identity, resulting the need to translate the Complaint into English a disproportional charge on the Complainant.

Notably, the Complainant asserts to be a French credit provider, part of the BPCE group, providing credit services under the unregistered VAL DE FRANCE TRANSACTIONS or VDFT mark since 2012, which became a distinctive trademark given the more than 570,000 clients served and revenues of more than EUR 1.6 million in 2022.

According to the Complainant, the disputed domain name fully incorporates its VDFT mark, being likely to cause confusion and to lead consumers to mistakenly believe that the disputed domain name is affiliated with or sponsored by the Complainant.

Under the Complainant’s view the Respondent has no rights or legitimate interests in respect of the disputed domain name given that the Respondent:

i. selected a privacy protection service so as to conceal its identity;
ii. never acquired rights authorizing it to register or use the disputed domain name; and
iii. does not use, and has not made demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services under the Policy.

Lastly, the Complainant sustains that its VDFT mark is notorious in its segment, there being no good faith use of the disputed domain name by the Respondent, who selected a privacy protection service to conceal its identity, what makes it impossible to conceive any good faith use to which the disputed domain name could be put other than to infringe the Complainant’s rights or to harm Internet users and customers of the Complainant. Furthermore, the disputed domain name is being offered for sale for large amounts which are in excess of the registration costs, a further indicative of the Respondent’s bad faith and intent to profit on the Complainant’s notoriety.

B. Respondent

In its Response, the Respondent contends the following:
The language of the proceedings is to be English given that that is the language of the disputed domain name registration agreement. Furthermore, the Respondent is located in India and understands only English and the local Indian languages. Moreover, given that the Complainant is represented by counsel, could and should have ensured that the Complaint and supporting documents were filed in English, particularly after the Center’s explicit invitation.

The Respondent asserts to be a generic four-letter domain investor, having registered the disputed domain name for its inherent value as a four-letter domain name and which can be used in connection with different fields and meanings, making it a valuable asset. The Respondent further asserts to own other four-letter domain names in his portfolio.

The Respondent submits that he has never solicited the Complainant, nor has he at any time used the disputed domain name either to interfere with the Complainant’s activities, to cause harm to the Complainant, or in any manner that could be regarded as bad faith under the Policy.
The Respondent argues that a “straightforward search of the WIPO Global Brand Database confirms that
there is no registered trademark for ‘VDFT’ anywhere in the world”, and more than that, the Complainant should fail at the first element given that it has not shown apparent common law or unregistered rights in “VDFT” visible from open-source Internet searches.

Moreover, the Respondent sustains that the domain name <vdft.fr> has never been actively used (Annex VI to the Response) and that the webpage available at https://www.banquepopulaire.fr/valdefrance/professionnels/banque-populaire-val-de-france-immobilier/val-de-france-transactions does not use the acronym VDFT being it unclear on what basis the Complainant claims to have any trademark rights (registered or unregistered) in the acronym “VDFT”.

Under the Respondent’s point of view, there is simply no exclusive right in “VDFT” that can be assumed in favor of the Complainant, as it is merely an acronym of the Complainant’s subsidiary corporate name, also not having the Complainant shown use of “VDFT” as an unregistered mark in an open, continuous, extensive, and uninterrupted manner over any significant period so as to acquire common law rights or
acquired distinctiveness (secondary meaning).

As to his rights or legitimate interest, the Respondent argues that he has been a domain name investor for the last numerous years and maintains a portfolio of hundreds of domain names, including numerous four-letter domain names, what is not against the Policy.

Lastly, the Respondent reiterates that he had no knowledge of the Complainant or its subsidiary company until having received notice of these proceedings. Furthermore, the offer for sale of the disputed domain name is rather a legitimate use on the part of a domain name investor and does not violate the Policy given that the Respondent has not targeted the Complainant which, in its turn did not have any rights at the time of the registration of the disputed domain name over “VDFT”.
The Respondent submits that given that the Complainant is represented by counsel, it ought to have undertaken a minimal due diligence before filing the Complaint and should be held to a higher standard and found guilty of Reverse Domain Name Hijacking (“RDNH”).

6. Discussion and Findings

6.1. Procedural Matter – Language of the Proceeding
The language of the Registration Agreement for the disputed domain name is English. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement.

The Complaint was filed in French. The Complainant requested that the language of the proceeding be French given that, under its view, the disputed domain name makes reference to the VAL DE FRANCE TRANSACTIONS or VDFT mark used by the Complainant which is the owner of the trademark BANQUE POPULAIRE VAL DE FRANCE, declared notorious in France; also having the Respondent selected a privacy protection service so as to conceal his identity, thus resulting the need to translate the Complaint into English a disproportional charge on the Complainant.

The Respondent requested that the language of the proceeding be English as he does not understand French.

In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1).

Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English.

6.2. Substantive Matter

According to paragraph 4(a) of the Policy, in order to succeed, a complainant must establish each of the following elements:
(i) the disputed domain name is identical or confusingly similar to the 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 has been 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 3.0, section 1.7.
The Complainant contends that it has unregistered rights in the VDFT mark by virtue of its use since 2012 in connection with its VAL DE FRANCE TRANSACTIONS credit service.
As foreseen in the WIPO Overview 3.0, section 1.3, “to establish unregistered or common law trademark rights for purposes of the UDRP, the complainant must show that its mark has become a distinctive identifier which consumers associate with the complainant’s goods and/or services. Relevant evidence demonstrating such acquired distinctiveness (also referred to as secondary meaning) includes a range of factors such as (i) the duration and nature of use of the mark, (ii) the amount of sales under the mark, (iii) the nature and extent of advertising using the mark, (iv) the degree of actual public (e.g., consumer, industry, media) recognition, and (v) consumer surveys.”

However, the Complainant has failed to produce sufficient evidence showing actual use of the acronym “VDFT” in its commercial activities as a source identifier, being it the Panel’s view that the Complainant relied solely on the fact that such is the acronym of VAL DE FRANCE TRANSACTIONS. The lack of any unregistered trademark in VDFT is further corroborated by the Complainant’s webpage available at https://www.banquepopulaire.fr/valdefrance/professionnels/banque-populaire-val-de-france-immobilier/val-de-france-transactions in which at no point the acronym is used in a trademark sense.
In addition to that, in spite of apparently owning the domain name <vdft.fr>, no use of this domain name, present or past could be found.

The Panel finds the first element of the Policy has not been established in the present proceeding.

B. Rights or Legitimate Interests

The Panel finds that the Respondent registered the disputed domain name for its intrinsic four-letter nature and is entitled to offer it for sale, especially considering that the Respondent has never targeted the Complainant or used the disputed domain name in a manner that could be found harmful to the Complainant or Internet users.

The Panel finds the second element of the Policy has not been established.

C. Registered and Used in Bad Faith

The evidence in the case file as presented does not indicate that the Respondent’s aim in registering the disputed domain name was to profit from or exploit the Complainant’s trademark.

The Panel notes that the disputed domain name is being offered for sale, but this is not sufficient on its own, considering the circumstances of this case, to conclude that the Complainant has satisfied its burden of proving registration and use in bad faith. The Panel finds that the Respondent did not register the disputed domain name in bad faith targeting of the Complainant or its trademark rights because the Complainant did not prove that the Respondent registered the disputed domain name due to its significance in relation to the Complainant or any trademark of the Complainant. Furthermore, the Complainant did not prove to be well-known as VDFT, at the time that the Respondent registered the disputed domain name. WIPO Overview 3.0, section 3.8.1. While the Panel notes that there seemed to have been a change of use of the disputed domain name around 2013 (according to Wayback Machine), and it is plausible that the Respondent may have acquired the disputed domain name at a time different to the original creation date, the Complainant did not provide any relevant evidence showing that the Respondent was targeting the Complainant with the  disputed domain name at any point in time. On the contrary, the Panel finds more likely than not that the Respondent registered it due to its value as a four-letter domain name.

The Panel finds the third element of the Policy has not been established.

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 of the complaint is not, on its own, sufficient to constitute reverse domain name hijacking. WIPO Overview 3.0, section 4.16.

This is a clear case in which the Complainant, represented by Counsel, ought to have known that it could not have succeeded under the Policy: the Complainant has not shown unregistered rights over VDFT; the disputed domain name was registered in 2005 (without evidence showing a later acquisition by the Respondent), well before the Complainant started offering its VAL DE FRANCE TRANSACTIONS service in 2012; the disputed domain name consists of a four letter domain name that can be read as different acronyms; the Complainant intends to rely on its alleged notoriety which however does not extend to VAL DE FRANCE TRANSACTIONS and particularly not to VDFT based on the evidence provided by the Complainant; there is no bad faith use by the Respondent, who is not and has never targeted the Complainant.

The Panel finds that the Complaint has been brought in bad faith and constitutes an attempt at Reverse Domain Name Hijacking.

7. Decision

For the foregoing reasons, the Complaint is denied and the Complainant is found guilty of RDNH.

/Wilson Pinheiro Jabur/
Wilson Pinheiro Jabur
Sole Panelist
Date: December 26, 2025