Westmore · UDRP decision
WIPO · Case No. D2025-2542

Gles.agency

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <gles.agency>. It found the domain confusingly similar to Complainant’s GLAS mark, that Respondent had not rebutted Complainant’s prima facie showing of no rights or legitimate interests, and that the domain had been registered and used in bad faith. Bad faith was supported by the reputation and distinctiveness of the mark, the domain’s composition, the selection of the “.agency” Top-Level Domain, its similarity to Complainant’s <glas.agency> website and email domain, and passive holding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-08-19
Panelist(s)
Nodine, Lawrence K.
Complainant
Global Loan Agency Services Limited
Respondent
BEVIN BICHAGE
Disputed domain(s)
gles.agency
Domain history UDRP Intelligence

The timeline behind gles.agency

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 gles.agency — 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 gles.agency.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a one-letter domain variation can support transfer even where it has no active website. The Panel treated the domain’s relationship to Complainant’s established website and email format, including use of the same “.agency” Top-Level Domain, as significant evidence of targeting and potential impersonation. It also confirms that passive holding may constitute bad-faith use when the mark’s reputation, the domain’s composition, and the surrounding circumstances point to deliberate targeting.

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
2025-08-19
Panel
Nodine, Lawrence K.
Full decision
7 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Global Loan Agency Services Limited v. BEVIN BICHAGE Case No. D2025-2542 1. The Parties Complainant is Global Loan Agency Services Limited, United Kingdom, internally represented. Respondent is BEVIN BICHAGE, France. 2. The Domain Name and Registrar The disputed domain name <gles.agency> (hereinafter “Disputed Domain Name”) is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 30, 2025. On June 30, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On July 1, 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 (Privacy Protect, LLC) and contact information in the Complaint 1 . The Center sent an email communication to Complainant on July 1, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on July 4, 2025. 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 Respondent of the Complaint, and the proceedings commenced on July 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 28, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on July 29, 2025. 1 The Registrar also advised that the Disputed Domain Name expired June 20, 2025. On July 9, 2025, Complainant paid the fee to renew the Disputed Domain Name. Accordingly, the Disputed Domain Name will expire June 20, 2026. page 2 The Center appointed Lawrence K. Nodine as the sole panelist in this matter on August 5, 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 Complainant, Global Loan Agency Services Limited, uses GLAS (hereinafter the “Mark”) as a trademark for financial services in connection with agency, trustee, and fiduciary services. Complainant alleges that the Mark is “ used extensively in the financial services sector in connection with agency, trustee and fiduciary services.” This allegation is supported by Complainant’s website located at the domain name <glas.agency>, which represents that it has USD 600 billion assets under administration, and offices in 12 locations worldwide, including New York, London, Paris, Madrid, Singapore, and Hong Kong, China. Complainant has received numerous awards from third parties recognizing its success and global reputation 2 . Complainant owns several trademark registrations for the Mark, including: - United Kingdom Trademark registration number UK00003962388 (registered on December 29, 2023) - French Trademark registration number 1791165 (registered on March 12, 2024) The Disputed Domain Name was registered on June 20, 2024. It does not resolve to an active 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. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings 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 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. Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.2.1. 2 These awards include: IJInvestor Awards 2024 (“2024 Restructure of the Year, North America”); Hedgeweek and Private Equity Wire- European Credit Awards 2023 (“Best Debt/Loan Administrator”); “2021 Financial Times Europe’s 1000 fastest growing companies”; “The Sunday Times International Track 200” (ranked 50th). page 3 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 3.0 , section 1.7. 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 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 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 Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name. Respondent has not rebutted 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. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel finds that Respondent registered the Disputed Domain Name in bad faith. Respondent does not deny Complainant’s alleges that the Mark is “ used extensively in the financial services sector in connection with agency, trustee and fiduciary services,” which allegation is supported by facts published on Complainant’s website and third-party awards. The Panel finds, based on the balance of probabilities, that Respondent was aware of and targeted Complainant and its rights when it registered the Disputed Domain Name. Respondent’s selection of the “.agency” Top-L evel Domain is additional evidence that Respondent was aware of and targeted Complainant, whose primary website is built on the <glas.agency> domain name. See WIPO Overview 3.0 , section 3.2.1 (choice of Top-Level Domain may evidence bad faith: particularly where corresponding to the complainant’s area of business activity). Complainant also uses the <glas.agency> domain for email communications. The Disputed Domain Name mimics Complainant's email structure and creates the risk that the Disputed Domain Name could be used for fraudulent email communications. The Panel also finds that Respondent has used the Disputed Domain Name in bad faith. 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 distinctiveness and reputation of 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 finding of bad faith under the Policy. The Panel finds that Complainant has established the third element of the Policy. page 4 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 <gles.agency> be transferred to Complainant. /Lawrence K. Nodine/ Lawrence K. Nodine Sole Panelist Date: August 19, 2025

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

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