Westmore · UDRP DecisionInspectoratelimited.com
The Panel ordered transfer of <inspectoratelimited.com>. It found the domain confusingly similar to the Complainant’s INSPECTORATE marks, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to create a misleading association with the Complainant. The Panel relied particularly on the domain’s incorporation of INSPECTORATE, the website’s reproduction of the Complainant’s copyrighted material, and representations suggesting a partnership or association with the Complainant.
The timeline behind inspectoratelimited.com
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The case illustrates how a domain combining a trademark with a corporate-style term such as “limited” can remain confusingly similar, particularly where the associated website copies the trademark owner’s material and claims an affiliation. The same conduct was relevant across the rights-or-legitimate-interests and bad-faith analyses.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Bureau Veritas Commodity Services Limited v. Mohamed Mohamed, Art Link Adv Case No. D2021-1803 1. The Parties The Complainant is Bureau Veritas Commodity Services Limited, United Kingdom, represented by Birketts LLP, United Kingdom. The Respondent is Mohamed Mohamed, Art Link Adv, Egypt. 2. The Domain Name and Registrar The disputed domain name <inspectoratelimited.com> is registered with Domain.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 8, 2021. On June 8, 2021, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 8, 2021, 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 and contact information in the Complaint. The Center sent an email communication to the Complainant on June 10, 2021 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 June 14, 2021. 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 June 21, 2021. In accordance with the Rules, paragraph 5, the due date for Response was July 11, 2021. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 12, 2021. The Center appointed Mario Soerensen Garcia as the sole panelist in this matter on July 27, 2021. 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 the certification services company Bureau Veritas Commodity Services Limited (previously known as Inspectorate Holdings PLC), operating in 286 locations globally, including in Egypt, where the Respondent is based. The Complainant’s “Inspectorate” business was acquired by Bureau Veritas in 2010 and provides independent inspection, sampling and testing services for a variety of sectors/goods in each of its locations, under the “INSPECTORATE” name and trading company, since or around 1987. The Complainant owns several registrations incorporating the mark INSPECTORATE, including: - the United Kingdom registration No. UK00002132003, for the word mark INSPECTORATE, registered on May 7, 1997; - the International registration No. 715071, for the device mark INSPECTORATE, with multiple designations, registered on March 16, 1999; and - the United States of America registration No. 3313762, for the word mark INSPECTORATE, registered on October 16, 2007. The Complainant operates its business primarily from the domain name <group.bureauveritas.com> and the Complainant’s ultimate parent company, Bureau Veritas S.A., owns the domain name <inspectorate.co.uk>, which is currently under maintenance. The disputed domain name <inspectoratelimited.com> was registered on April 4, 2017, and resolves to an active website. 5. Parties’ Contentions A. Complainant The Complainant mentions that it has acquired significant goodwill and reputation worldwide in the mark INSPECTORATE in relation to inspection, quality assurance and certification services, having a number of legitimate affiliates who pay fees for the use of the mark and for the technical know-how. One of the Complainant’s customers based in Egypt informed the Complainant about the Respondent’s use of the mark INSPECTORATE and its attempt to associate itself with the Complainant’s business and international reputation. The Complainant argues that the disputed domain name is similar to its registered trademarks. According to the Complainant, given the international presence and reputation of the name “INSPECTORATE”, the disputed domain name was registered with the clear intention to create a false impression of association with the Complainant aiming to attract business or misleadingly divert the public. The Complainant claims that the Respondent lacks rights and any legitimate interests in the disputed domain name, and that it has not made a legitimate noncommercial or fair use of the disputed domain name. Instead, the Respondent has actively and falsely represented itself as being connected with the business of the Complainant. Additionally, the Complainant mentions and shows evidence in the Annexes that the Respondent’s website reproduces the Complainant’s copyrighted works identically and in their entirety, without consent, which confirms that the Respondent registered and is using the disputed domain name in bad faith. Finally, the Complainant requests the transfer of the disputed domain name. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings As per paragraph 4(a) of the Policy, the Complainant must prove that: (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. A. Identical or Confusingly Similar The Complainant is the owner of trademark registrations for INSPECTORATE in different jurisdictions, which predate the disputed domain name. The disputed domain name comprises the Complainant’s mark INSPECTORATE in its entirety. The addition of the term “limited” in the disputed domain name does not prevent a finding of confusing similarity with the Complainant’s trademarks. It is the general view among UDRP panels that the addition of merely dictionary, descriptive, or geographical words to a trademark in a domain name does not avoid a finding of confusing similarity under the first element of the UDRP (for example, Ansell Healthcare Products Inc. v. Australian Therapeutics Supplies Pty, Ltd , WIPO Case No. D2001-0110 ). Also, as numerous prior UDRP panels have recognized, the incorporation of a trademark in its entirety or a dominant feature of a trademark is sufficient to establish that a domain name is identical or confusingly similar to the complainant’s mark. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“ WIPO Overview 3.0 ”), section 1.7. The Panel finds that paragraph 4(a)(i) of the Policy has been proved by the Complainant, i.e. , the disputed domain name is confusingly similar to the Complainant’s trademarks. B. Rights or Legitimate Interests The Respondent has not submitted a response to the Complaint. There is no evidence that the Respondent has any authorization to use the Complainant’s trademark or to register a domain name containing the trademark INSPECTORATE. There is no evidence that the Respondent is making a legitimate noncommercial or fair use of the disputed domain name or that before any notice of the dispute the Respondent has made use of, or demonstrable preparations to use the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services. Instead, the Complainant reported that it has conducted local searches in Egypt, which concluded that the Respondent has represented itself as having a partnership/association with the Complainant, for commercial gain. Moreover, the Respondent’s website reproduces the Complainant’s copyrighted works identically and in their entirety, without the Complainant’s consent. The Panel finds that the use of the disputed domain name, which incorporates the Complainant’s trademark, does not correspond to a bona fide use of the disputed domain name under the Policy. For the above reasons, the Panel finds that the condition of paragraph 4(a)(ii) of the Policy has been satisfied, i.e ., the Respondent has no rights or legitimate interests in the disputed domain name. C. Registered and Used in Bad Faith The trademark INSPECTORATE enjoys reputation and is recognized in the segment of inspection, quality assurance and certification services and it has been registered by the Complainant in different jurisdictions. The Complainant’s mark is already recognized in its segment and it is clear that the Respondent knew about the Complainant’s services and its trademark rights at the time of the registration of the disputed domain, due to the Respondent’s decision to reproduce identical the Complainant’s copyrighted works in its website and also representing itself as partner and/or as a company associated with the Complainant. In this case, therefore, a domain name that reproduces the mark INSPECTORATE in its entirety is undoubtedly suggestive of the Respondent’s bad faith. It does not seem to make any sense for the Respondent to register the disputed domain name, except to mislead potential clients of the Complainant. Therefore, this Panel finds that the Respondent has intentionally attempted to cause confusion with the Complainant’s trademark by misleading Internet users to believe that the disputed domain name belongs to or is associated with the Complainant. This Panel finds that the Respondent’s attempt of taking unfair advantage of the trademark INSPECTORATE as described in paragraph 4(b)(iv) of the Policy has been demonstrated. Moreover, the Respondent has chosen not to respond to the Complainant’s allegations. In these circumstances, and as found in the panel’s decision in The Argento Wine Company Limited v. Argento Beijing Trading Company , WIPO Case No. D2009-0610 , “the failure of the Respondent to respond to the Complaint further supports an inference of bad faith”. For the above reasons, the Panel finds that the condition of paragraph 4(a)(iii) of the Policy has been satisfied, i.e ., the disputed domain name was registered and is being used in bad faith. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <inspectoratelimited.com> be transferred to the Complainant. Mario Soerensen Garcia Sole Panelist Date: August 10, 2021
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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