Westmore · UDRP decision
WIPO · Case No. D2025-2116

Hrairalo.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <hrairalo.com>. It found the domain confusingly similar to the Complainant’s AIRALO logo trademark because it incorporated the dominant verbal element AIRALO with the prefix “hr”. The Respondent did not rebut the Complainant’s prima facie case on rights or legitimate interests, and the Panel rejected the registrar-listed names “Resources Airalo” and “Human Resources Airalo” as actual names establishing that the Respondent was commonly known by the domain. Bad faith was found under the passive-holding doctrine, based on the trademark’s distinctiveness or reputation, the domain’s composition, and the Respondent’s failure to respond.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-07-30
Panelist(s)
Kondo, Keiji
Complainant
AirGSM Pte. Ltd.
Respondent
Resources Airalo, Human Resources Airalo
Disputed domain(s)
hrairalo.com
Domain history UDRP Intelligence

The timeline behind hrairalo.com

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 hrairalo.com — 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 hrairalo.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a domain combining a distinctive mark with an employment-related prefix may be assessed where the registrar-listed respondent details also invoke that employment theme. The Panel did not accept those details at face value as proof that the Respondent was commonly known by the domain. The case also demonstrates that inactivity can support transfer when passive holding is accompanied by a distinctive or reputed mark, a targeting domain composition, and an unexplained respondent default.

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
2025-07-30
Panel
Kondo, Keiji
Full decision
11 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION AirGSM Pte. Ltd. v. Resources Airalo, Human Resources Airalo Case No. D2025-2116 1. The Parties The Complainant is AirGSM Pte. Ltd., Singapore, represented by Lewis Silkin LLP, United Kingdom. The Respondent is Resources Airalo, Human Resources Airalo, Brazil. 2. The Domain Name and Registrar The disputed domain name <hrairalo.com> is registered with Squarespace Domains II LLC (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 29, 2025. On May 30, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On May 30, 2025, the Registrar transmitted by email to the Center its verif ication response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verif ied that the Complaint satisf ied the f ormal requirements of the Unif orm 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 f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on June 10, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 30, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on July 12, 2025. The Center appointed Keiji Kondo as the sole panelist in this matter on July 16, 2025. The Panel f inds 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. page 2 4. Factual Background The Complainant was incorporated in 2019, using the trademark AIRALO. Since 2019 it has grown to be regarded as a leading provider of digital SIM (eSIM) cards, providing its services to over 20 million customers in over 200 countries. The Complainant employs over 200 people, spread over 44 countries and 6 continents. It conducts its business primarily through its core website, found at “www.airalo.com”, and its AIRALO-branded sof tware applications. According to the Complainant, its iOS app has received over 66,000 independent reviews (with an average score of 4.6 out of 5). Its Android app has been downloaded over 5 million times, and has received over 80,000 reviews, with an average score of 4.5 out of 5. The Complainant is the proprietor of a global portfolio of trademark rights for its AIRALO logo depicted below: Among the Complainant’s trademark portfolio is included the f ollowing trademark registration: Singapore Trademark Registration No. 40201914330P, registered on December 19, 2019 f o r the f ollowing designated goods and services: Class 9: Sof tware and applications f or mobile devices. Class 35: Online retail services. Class 38: Telecommunications. The Complainant also has an International Trademark Registration No. 1701049 for the same logo, covering such jurisdictions as Australia, Brazil, Japan, Indonesia, Viet Nam, Thailand, Canada, the United States of America, and the European Union, which is based on the above Singaporean registration. The disputed domain name was registered on June 18, 2024. The disputed domain name is not currently resolving to an active website. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy f or a transf er of the disputed domain name. Notably, the Complainant contends that: The disputed domain name is highly similar to the Complainant’s trademark in that it replicates the distinctive verbal element of the Complainant’s trademark, AIRALO, and includes the letters “hr”, an acronym for human resources. For the purposes of assessing identity and conf using similarity under paragraph 4(a)(i) of the Policy, it is permissible f or the Panel to ignore the generic Top-Level Domain. To the best of the Complainant’s knowledge, the Respondent does not own any registered rights in a trademark for AIRALO or the terms “hr airalo”. The term “airalo” is a coined term. It is inherently distinctive page 3 and carries no descriptive connotations. The Complainant has not given consent f or the Respondent to reg ister a domain name that incorporates its distinctive trademark, AIRALO. The disputed domain name does not point to an active website or holding page. The Complainant has submitted a prima f acie case showing that the Respondent has no rights or legitimate interests in respect of the disputed domain name. Paragraph 4(b) of the Policy sets out, without limitation, certain circumstances which, if found, are deemed to be evidence of use and registration in bad faith. It is to be observed that whilst paragraph 4(a)(iii) requires a showing of both registration and use in bad f aith paragraph 4(b) appears not to distinguish between registration and use. Nevertheless, the Complainant submits that the Respondent registered and uses the disputed domain name in bad f aith. The consensus view amongst WIPO panelists is that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. While panelists will look at the totality of the circumstances in each case, f actors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant's trad emark; (ii) the f ailure of the respondent to submit a response or to provide any evidence of actual or contemplated good-f aith use; (iii) the respondent’s concealing its identity or use of f alse contact details (noted to be in breach of its registration agreement); and (iv) the implausibility of any good f aith use to which the domain name may be put. It is submitted that the Complainant’s trademark is highly distinctive and benefits from a strong reputation. It is submitted that point (i) above is satisfied. The WhoIs details confirm that the disputed domain name was registered around f ive years af ter the Complainant f iled its Singaporean trademark registration f or its AIRALO logo. As demonstrated by the popularity of the Complainant’s website and mobile applications, the Complainant enjoyed substantial success bef ore the Respondent chose to register the disputed domain name. At the very least, the Respondent should have been aware of the Complainant’s business when registering and using the disputed domain name, given the high degree of reputation in the AIRALO trademarks. It is to be noted that, although paragraph 4(a)(iii) requires evidence of both registration and use in bad f aith, paragraph 4(b) makes clear that passive holding of a domain name does not preclude a finding of bad f aith. In this context, the Complainant contends that the Respondent has, accordingly, registered and used the disputed domain name in bad f aith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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. page 4 The Complainant owns a trademark registration for a logo in which a term “ AIRALO” is the dominant verbal element. The verbal element of the Complainant’s trademark is reproduced within the disputed domain name, with the addition of the term “hr” at the beginning of the disputed domain name. The addition of the letters “hr” would not prevent an average observer of the disputed domain name f rom recognizing the AIRALO trad emark in the disputed domain name. Accordingly, the disputed domain name is conf usingly similar to the Complainant’s trad emark f or the purposes of the Policy. WIPO Overview 3.0 , section 1.7. The Panel f inds the f irst 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 of ten primarily within the knowledge or control of the 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0 , section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. First of all, the disputed domain name is not currently resolving to an active website. Accordingly, the disputed domain name is not used either f or bona f ide of f ering of goods or services or f or a legitimate noncommercial or f air purposes. Secondly, the Panel also concludes that the Respondent has not been commonly known by the disputed domain name. In this regard, the Panel notes that the name of the Respondent is “ Resources Airalo”, and its organization is “Human Resources A iralo”, according to the response from the Registrar. For the f ollowing reasons, however, the Panel concludes that these names are not actual names of the Respondent and its organization. First of all, the Panel notes that the Respondent has not responded to the Complaint. Secondly, the registration date of the Complainant’s Singaporean trademark reg istratio n predates the registration of the disputed domain name by about four and a half years, and, considering the Complainant’s business success achieved by the time of registration of the disputed domain name, the Respondent should have known the Complainant’s trademark before it registered the disputed domain name. Theref ore, it is more probable than not that the Respondent chose its name and organization to cause conf usion with the Complainant. If the name of the Respondent and its organization were the actual names of them, it should have been quite easy to respond to the Complaint by showing that they are their actual names. Theref ore, the Panel concludes that the Respondent has not been commonly known by the disputed domain name. The Panel f inds the second element of the Policy has been established. page 5 C. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. Panels have f ound that the non-use of a domain name would not prevent a f inding of bad f aith under the doctrine of passive holding. WIPO Overview 3.0 , section 3.3. Having reviewed the available record, the Panel notes the distinctiveness or reputation of the Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a f inding of bad f aith under the Policy. In this case, the Panel especially notes that the Respondent has not submitted a response to the Complaint. In the context of this case, silence of the Respondent supports the finding of bad faith in registration and use of the disputed domain name. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <hrairalo.com> be transf erred to the Complainant. /Keiji Kondo/ Keiji Kondo Sole Panelist Date: July 30, 2025

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

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