Westmore · UDRP decision
WIPO · Case No. D2024-4379

G4security.net

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <g4security.net> to G4S Limited. It found the domain confusingly similar to the G4S mark because the mark remained recognizable; found no rights or legitimate interests because the Respondent did not rebut the Complainant’s prima facie case and the prior competing PPC use was not bona fide; and found bad-faith registration and use based on the mark’s reputation, the security-related composition of the domain, its prior competing PPC links, and its subsequent passive holding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2024-12-19
Panelist(s)
Soerensen Garcia, Mario
Complainant
G4S Limited
Respondent
DOMAIN.COM Holding Account, Confiscated for Abuse or Non-Payment
Disputed domain(s)
g4security.net
Domain history UDRP Intelligence

The timeline behind g4security.net

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Westmore reconstructs the full history behind g4security.net — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of g4security.net.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain can target a short mark by appending letters that create a word closely associated with the trademark owner’s services. It also demonstrates that a shift from competing PPC use to inactivity does not erase the significance of the earlier use or preclude application of the passive-holding doctrine.

The three-part test
Identical or Confusingly SimilarMet
Rights or Legitimate InterestsMet
Registered and Used in Bad FaithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2024-12-19
Panel
Soerensen Garcia, Mario
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION G4S Limited v. DOMAIN.COM Holding Account, Confiscated for Abuse or Non-Payment Case No. D2024-4379 1. The Parties The Complainant is G4S Limited, United Kingdom, represented by SafeNames Ltd., United Kingdom. The Respondent is DOMAIN.COM Holding Account, Confiscated for Abuse or Non-Payment, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <g4security.net> is registered with Network Solutions, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 24, 2024. On October 24, 2024, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 25, 2024, 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 (PERFECT PRIVACY, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 29, 2024, 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 October 30, 2024. The Center verified that the Complaint [together with the amendment to the Complaint/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 6, 2024. In accordance with the Rules, paragraph 5, the due date for Response was November 26, 2024. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 27, 2024. page 2 The Center appointed Mario Soerensen Garcia as the sole panelist in this matter on December 5, 2024. 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 global security company headquartered in London, United Kingdom, which provides security and facility services in around 90 countries across the world. The Complainant was founded in 1901 and it has been operating under the name G4S (or Group 4 Securicor) since 2004, offering a diverse range of services, divided into the categories of “Security Solutions”, “Cash Solutions”, “Consulting Services”, Care and Justice Services”, and the “G4S Academy”. The Complainant is the owner of several trademark rights around the world on G4S, including the following registrations: - United States trademark G4S, No. 3378800, registered on February 5, 2008; - International trademark G4S, No. 885912, registered on October 11, 2005; - European Union trademark G4S, No. 015263064, registered on September 20, 2016. The Complainant is also the owner of the domain name <g4s.com>, created on December 1, 1999, which corresponds to its main website. This website is also available in multiple languages and includes many country-specific pages. The Respondent was identified as DOMAIN.COM Holding Account, Confiscated for Abuse or Non-Payment. The disputed domain name <g4security.net> was registered on August 23, 2024, and is currently inactive. The Complainant provided evidence that the disputed domain name previously resolved to pay-per-click (“PPC”) links in the security field. 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 argues that the disputed domain name is confusingly similar to the Complainant’s marks since it reproduces the trademark G4S in its entirety, adding the term “security” in a portmanteau form, which is associated with the services offered by the Complainant. There is no evidence that the Respondent has made demonstrable preparations to use the disputed domain name for legitimate purposes, nor is there any evidence that the Respondent is using the disputed domain name in connection with a bona fide offering of goods and services. According to the Complainant, the disputed domain name is currently inactive, which could lead online users to believe that the Complainant’s services or website have become inoperable. However, the Complainant mentions that the disputed domain name previously used to display PPC links that redirected users to third- party websites offering similar services to the Complainant, which constitutes a clear attempt to generate commercial gain by misleading online users. The Complainant adds that the Respondent has no rights or legitimate interests in respect of the disputed domain name. page 3 The Complainant says that given the global renown of the Complainant, and the Respondent’s clear and prominent use of the Complainant’s mark in the disputed domain name, it is clear that the Respondent was aware of the Complainant’s rights in the G4S mark. The Complainant also argued that it sent a cease-and-desist letter to the Respondent but it chose not to respond, which is further evidence of bad faith. The Complainant concludes that because the disputed domain name is so obviously connected with the Complainant, the Respondent’s actions suggest opportunistic bad faith in violation of the Policy. 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 In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three following elements is satisfied: (i) the disputed domain name is identical or confusingly similar to the trademarks or service marks 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 Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the trademark G4S is reproduced and recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms, in this case “ecurity”, may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the page 4 respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Panels have found that the use of a domain name to host a parked page comprising PPC links does not represent a bona fide offering where such links compete with or capitalize on the reputation and goodwill of the complainant’s mark or otherwise mislead Internet users, as demonstrated in the Complaint. WIPO Overview 3.0, section 2.9. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. In the present case, the Panel notes that at the time the disputed domain name was registered, the Respondent was clearly aware of the G4S trademarks as the Complainant’s trademark registrations as well as its domain names predate the registration date of the disputed domain name. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1. The Panel notes that the disputed domain name includes the term “ecurity”, in addition to the Complainant’s G4S trademark, which in this case is suggestive of the registration of the disputed domain name in bad faith considering that such added term is apparently intended to be perceived as “security”, which is related to the services offered by the Complainant. The Panel finds that by resolving the disputed domain name to a website with competing PPC links the Respondent has intentionally attempted to cause confusion with the Complainant’s trademark by misleading Internet users to believe that its website belongs to or is associated with the Complainant, for the Respondent’s commercial benefit. Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 5 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 <g4security.net> be transferred to the Complainant. /Mario Soerensen Garcia/ Mario Soerensen Garcia Sole Panelist Date: December 19, 2024.

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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