Westmore · UDRP DecisionScientific-sessions.org
The Panel ordered transfer of <scientific-sessions.org>. It found that the Complainant had established unregistered rights in SCIENTIFIC SESSIONS through extensive use since 1986 and that the domain was identical to that mark. The Respondent lacked rights or legitimate interests because the domain was used for an unauthorized conference-related registration website that created confusion and was not bona fide. Bad faith was established under paragraph 4(b)(iv) based on intentional attraction of users for inferred commercial gain, and the website's inconspicuous disclaimer did not cure the confusion. The Panel also found that the Respondent was almost certainly connected with the respondent in an earlier similar case involving <ahascientificsessions.org>.
The timeline behind scientific-sessions.org
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates how longstanding conference branding can establish unregistered UDRP rights and how an exact-match domain used for unauthorized event-registration services strongly supports findings on all three elements. It also confirms that an inconspicuous disclaimer will not neutralize bad faith where the domain and website as a whole impersonate or target the complainant’s event.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION American Heart Association, Inc. v. Roger Hartlieb, Medcon Case No. D2025-4518 1. The Parties The Complainant is American Heart Association, Inc., United States of America (“United States”), represented by Scheef & Stone, LLP, United States. The Respondent is Roger Hartlieb, Medcon, India. 2. The Domain Name and Registrar The disputed domain name <scientific-sessions.org> is registered with PDR Ltd. d/b/a PublicDomainRegistry.com (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 31, 2025. On November 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 4, 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 (Unknown Individual or Entity) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 7, 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 on November 7, 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 the Respondent of the Complaint, and the proceedings commenced on November 11, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 1, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 4, 2025. page 2 The Center appointed Adam Taylor as the sole panelist in this matter on December 10, 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 Since 1986, the Complainant has used the mark SCIENTIFIC SESSIONS for its annual educational conferences in the field of cardiovascular health. On December 21, 2023, the Complainant applied for a United States trade mark for SCIENTIFIC SESSIONS under Serial No. 98325504. The disputed domain name was registered on August 4, 2025. As of October 27, 2025, the disputed domain name resolved to a website that was branded “CONGRESS/REGISTRATION”, and which contained the prominent heading “ATTEND SCIENTIFIC SESSIONS 2025” plus the date/location of the Complainant’s 2025 conference, followed by a purported registration form. The footer included the following disclaimer: “This site is an independent informational/service website and is not affiliated with or endorsed by any medical association. All product names and registered trademarks mentioned on this website are the property of their respective owners. For official conference information and registration, visit the conference’s official site.” The Respondent’s website also purported to offer “Group Registration” (which is not a facility provided by the Complainant) as well as a “Housing Request” form to request accommodation quotes and an “Exhibitors Request” form. The Terms and Conditions on the Respondent’s website indicated that it was operated by “Medcon”/“Medconn” (both spellings are used). On November 15, 2024, the Complainant obtained transfer of <ahascientificsessions.org> from a respondent named “Amman Dusad, Medconn”, located in India. In that case, the domain name had also been used for a website that purported to allow visitors to register for the Complainant’s conference. See American Heart Association, Inc. v. Amman Dusad, Medconn, WIPO Case No. D2024-4051 (“the Previous Case”). 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. 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 first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between page 3 the Complainant’s trade mark 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 Panel finds the Complainant has established unregistered trade mark or service mark rights for the purposes of the Policy. WIPO Overview 3.0, section 1.3. In particular, the Complainant has provided evidence of extensive use of SCIENTIFIC SESSIONS for its annual educational conferences in the field of cardiovascular health. Moreover, the fact that the Respondent is shown to have been targeting the Complainant’s mark supports a finding that its mark has achieved significance as a source identifier. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical 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 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 recognised 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 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. As to paragraph 4(c)(i) of the Policy, and as further discussed in section 6.C. below, the Panel considers that the Respondent has used the disputed domain name to intentionally attempt to attract, confuse and profit from Internet users seeking the Complainant’s goods and/or services. The composition of the disputed domain name (identical to the Complainant’s mark) and the content of the website at the disputed domain name (offering registration and other services relating to the Complainant’s conference), create a risk of Internet user confusion. Such use of the disputed domain name is not bona fide. 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 considers that the Respondent has intentionally attempted to attract Internet users to its website for commercial gain by creating a likelihood of confusion with the Complainant’s trade mark in accordance with paragraph 4(b)(iv) of the Policy. page 4 Not only does the disputed domain name comprise the Complainant’s mark, but the Respondent has used the disputed domain name for a website that includes the mark in a prominent heading, and which purports to offer registration and other services relating to the Complainant’s conference, although the Respondent is not authorised to do so. In the Panel’s view, the Respondent cannot rely on the disclaimer, which is far from prominent and unlikely to be seen by most users of the site. In any case, the mere existence of a disclaimer cannot cure bad faith where, as here, the overall circumstances point to bad faith. Indeed, the Panel considers that the Respondent’s use of a disclaimer amounts to an admission that users may be confused. WIPO Overview 3.0, section 3.7. In these circumstances, it is reasonable to infer that the Respondent is intent on commercial gain. Furthermore, the Respondent has likely engaged in a pattern of such conduct. Given the common use of “Medcon”/“Medconn”, the Respondent is almost certainly connected with the respondent in the Previous Case, where the Panel found that the domain name <ahascientificsessions.org> “dishonestly masquerade[d]” as that of the Complainant and, like here, had been used for a website that purported to sell tickets for the Complainant’s conference. The Panel finds that the Complainant has established the third element of the Policy. 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 <scientific-sessions.org> be transferred to the Complainant. /Adam Taylor/ Adam Taylor Sole Panelist Date: December 24, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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