Westmore · UDRP decision
WIPO · Case No. D2025-4561

Sanofi-f.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <sanofi-f.com> to Sanofi. It found the domain confusingly similar to the SANOFI mark because it reproduced the mark in its entirety and the added letter “f” did not prevent confusing similarity. The Respondent did not rebut Sanofi’s prima facie showing concerning rights or legitimate interests. Given the mark’s well-known status, the domain’s composition, and its passive holding, the Panel found registration and use in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-19
Panelist(s)
Agarwal, Vinod K.
Complainant
Sanofi
Respondent
Mary Fowler, BASF
Counsel
Selarl Marchais · associés
Disputed domain(s)
sanofi-f.com
Domain history UDRP Intelligence

The timeline behind sanofi-f.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 sanofi-f.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 sanofi-f.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain that incorporates a well-known mark in full, with only a hyphen and one added letter, can satisfy confusing similarity and support an inference of targeting. It also shows that inactivity does not preclude bad faith where the mark is distinctive and well-known, the domain’s composition points to the complainant, and the respondent offers no contrary explanation.

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
2026-01-19
Panel
Agarwal, Vinod K.
Full decision
14 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. Mary Fowler, BASF Case No. D2025-4561 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Mary Fowler, BASF, Germany. 2. The Domain Name and Registrar The disputed domain name <sanofi-f.com> is registered with Gransy, s.r.o. d/b/a subreg.cz (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 4, 2025. On November 5, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 7, 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 (Not Disclosed Not Disclosed, My Domain Provider) 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 amendment to the Complaint on November 28, 2025. The Center verified that the Complaint together with the amendment to the 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 December 3, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 23, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 26, 2025. page 2 The Center appointed Vinod K. Agarwal, as the sole panelist in this matter on January 9, 2026. 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 Centre to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is a French multinational pharmaceutical company headquartered in Paris (France), ranking 4th world's largest multinational pharmaceutical company by prescription sales. The Complainant is engaged in research and development, manufacturing and marketing of pharmaceutical products for sale, principally in the prescription market, but the firm also develops over-the-counter medication. The Complainant is a full member of the European Federation of Pharmaceutical Industries and Associations (EFPIA). Historically, the Complainant was formed as Sanofi-Aventis in 2004 by the merger of Aventis and Sanofi-Synthélabo, and changed its name to Sanofi in May 2011. The Complainant is a multinational company settled in more than 100 countries on all five continents employing 100,000 people. The Complainant had consolidated net sales of almost 43 billion Euros in 2022. The Complainant’s Research and Development portfolio includes 84 projects in clinical development, 26 of which are at advanced stages. The Complainant offers a wide range of patented prescription drugs to treat patients with serious diseases and has leading positions in seven major therapeutic areas, namely cardiovascular, thrombosis, metabolic disorders, oncology, central nervous system, internal medicine and vaccines. To conclude, the Complainant’s worldwide recognition has been once more enshrined in the annual “L2 Digital IQ Index: Pharmabrand & Healthcare Providers” worldwide brand survey issued April 18, 2011, in which the Complainant appeared in the “Flash of Genius” in reference to its promoting patient resources. Thus, the Complainant is a major player on the worldwide pharmaceutical market. The disputed domain name was registered on October 12, 2025, and it does not resolve to an active website. 5. Parties’ Contentions Complainant A. The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights In relation to element (i), the Complainant contends that the Complainant’s trademark SANOFI is registered in many jurisdictions under different classes notably concerning pharmaceutical products. The Complainant is the rightful owner of the following trademarks. The details of the said registrations of the trademark in different jurisdictions and the classes are as mentioned below: Trade Mark Jurisdiction Registration No. Registration Date IC Class SANOFI France 3831592 December 9, 2011 01; 03; 05; 09; 10; 16; 35; 38; 40; 41; 42; 44 SANOFI France 96655339 December 11, 1996 01; 03; 05; 09; 10; 35; 40; 42 SANOFI France 92412574 March 26, 1992 5 SANOFI France 1482708 August 11, 1988 01; 03; 04; 05; 10; 16; 25; 28; 31 SANOFI European Union 010167351 January 7, 2012 03; 05 page 3 SANOFI European Union 004182325 February 9, 2006 01; 09; 10; 16; 38; 41; 42; 44 SANOFI European Union 000596023 February 1, 1999 03; 05 SANOFI International 1091805 August 18, 2011 01; 03; 05; 09; 10 16; 35, 38; 40; 41; 42; 44 SANOFI International 1092811 August 11, 2011 01; 09; 10; 16; 38; 41; 42; 44 SANOFI International 1094854 August 11, 2011 03; 05 SANOFI International 674936 October 30, 1998 03; 05 sanofi International 591490 September 25, 1992 05 SANOFI United States of America 85396658 July 24, 2012 05 SANOFI United Kingdom UK00001483425 January 15, 1993 05 The Complainant is also the owner of the following domain names among others: <sanofi.com>; <sanofi.eu>; <sanofi.fr>; <sanofi.us>; <sanofi.net>; <sanofi.ca>; <sanofi.biz>; <sanofi.info>; <sanofi.org>; <sanofi.mobi>; <sanofi.tel>. Most of these domain names are registered and used by the Complainant in connection with its activity. The Complainant has stated that all of these trademarks and domain names were registered much before the registration of the disputed domain name by the Respondent. Further, the disputed domain name reproduces SANOFI trademarks. In addition, the Respondent could simply not ignore the Complainant whose trademarks and domain names are also worldwide which do not have any particular meaning and are therefore highly distinctive. The Complainant is a multinational company in the pharmaceutical field which develops, manufactures, distributes and sells a wide variety of pharmaceutical products under the trademark and trade name SANOFI. It has used its trade name for over 40 years and invested substantial financial resources over the years to advertise and promote the company and its SANOFI trademarks in countries all over the world. Also, the reproduction of the Complainant’s trademarks as the dominant part of the contested domain name is confusingly similar to prior above cited trademarks, regardless of the hyphen “-” and the addition of the letter “f” which is the first letter of the country of incorporation of the Complainant (namely France). The contested domain name comprises: (a) an exact reproduction of the Complainant’s trademark; (b) with an additional letter “f”, (b) followed by a Top-Level Domain “.com”. The generic Top-Level-Domain (“gTLD”) used as part of a domain name should be disregarded as it does not serve to distinguish domain names. The relevant comparison to be made is with the second level portion of the disputed domain names. It is also well established that where a domain name wholly incorporates a Complainant’s distinctive trademarks in its entirety, it is confusingly similar to that mark. Therefore, it is concluded that the domain name is confusingly similar to the trademarks over which the Complainant has rights. B. The Respondent has no rights or legitimate interests in respect of the disputed domain name The Registrant does not have any legitimate interest in using the disputed domain name since the name of the Respondent “Not Disclosed Not Disclosed” has no resemblance with the word “SANOFI”. Complainant once more stresses the fact that the word “SANOFI” has no particular meaning and is therefore highly distinctive: page 4 The Respondent has neither prior right nor legitimate interest to justify the use of the already well-known and worldwide trademarks and domain names of the Complainant. Consequently, the Respondent has no prior rights and/or legitimate interest to justify the use of SANOFI trademarks and domain names. Further, the Respondent is not making a legitimate non-commercial or fair use of the disputed domain name nor is he using the disputed domain name in connection with a bona fide offering of goods or services, so as to confer a right or legitimate interest in it in accordance with paragraph 4(c)(i) of the Policy given that the website is not used legitimately by Respondent. Indeed, the disputed domain name website simply refer to an inactive page. Thus, in the absence of any authorization by the Complainant and the lack of legitimate reason in the use of the disputed domain name both prove that the Respondent has no rights or legitimate interest in respect of the domain name. C. The domain name was registered and is being used in bad faith The Complainant has developed a strong reputation in its SANOFI trademark in the pharmaceutical industry through use in connection with its goods and services, including in China, where the Respondent is located. Moreover, it should be considered that, given the famous and distinctive nature of the mark SANOFI, the Respondent is likely to have had notice, as to the existence of the Complainant’s marks at the time he registered the disputed domain name. This suggests that the Respondent acted with opportunistic bad faith in registering the disputed domain name in order to make illegitimate use of it. The Respondent had both constructive and actual knowledge of the Complainant’s mark and chose to exploit it and the goodwill developed in it. Where the Respondent has chosen to register a disputed domain name that is identical or confusingly similar to the Complainant’s trademark and where the trademark in question has through substantial use acquired worldwide fame, reputation and notoriety, a reasonable conclusion is that the trademark is not one that traders could legitimately adopt other than for the purpose of creating an impression of an association with the Complainant. In the light of the above, it will be demonstrated that the disputed domain name was registered and is used in bad faith. The disputed domain name resolves to an inactive website as it has been established in many UDRP cases that passive holding under the appropriate circumstances falls within the concept of the domain name being used in bad faith. Finally, the lack of use of the disputed domain name particularly close to those used by the Complainant is likely to cause irreparable prejudice to their general goodwill because Internet users could be led to believe that Complainant is not on the Internet or that the Complainant is out of business. Therefore, the registration and use of the disputed domain name by the Respondent is in bad faith and the requirement of paragraph 4(a)(iii) has been established. Respondent The Respondent did not reply to the Complainant’s contentions. page 5 6. Discussion and Findings According to 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; and (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 According to the information submitted by the Complainant, the Complainant is the owner of several SANOFI trademark registrations in many jurisdictions. The disputed domain name reproduces the Complainant’s trademark in its entirety. The addition of the word “f” in the disputed domain name does not prevent a finding of confusing similarity. Therefore, the Panel finds that the disputed domain name <sanofi-f.com> is confusingly similar to the trademarks of the Complainant. B. Rights or Legitimate Interests According to paragraph 4(c) of the Policy, the Respondent may demonstrate its rights to or legitimate interest in the disputed domain name by proving any of the following circumstances: (i) before any notice to the Respondent of the dispute, the Respondent’s 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; or (ii) the Respondent (as an individual, business or other organization) has been commonly known by the disputed domain name, even if the Respondent has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate non-commercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. 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. There is no evidence to suggest that the Respondent is commonly known by the disputed domain name. The Complainant has not authorized the Respondent to use the name and their trademark SANOFI. In view of the fact that the Complainant has not licensed or otherwise permitted the Respondent to use its trademark or to apply for or use the disputed domain name incorporating the trademark of the Complainant, the Panel finds that the Respondent chose the disputed domain name to create an impression of an association with the Complainant. Based on the evidence in the Complaint, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name. page 6 C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy states that any of the following circumstances, in particular but without limitation, shall be considered evidence of the registration or use of the domain name in bad faith: (i) Circumstances indicating that the Respondent has registered or acquired the disputed domain name primarily for the purpose of selling, renting, or otherwise transferring the disputed domain name registration to the Complainant who is the owner of the trademark or service mark or to a competitor of that Complainant, for valuable consideration in excess of documented out-of-pocket costs directly related to the domain name; or (ii) The Respondent has registered the disputed domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that it has engaged in a pattern of such conduct; or (iii) The Respondent has registered the disputed domain name primarily for the purpose of disrupting the business of a competitor; or (iv) By using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, internet users to its web site or other on-line location, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s web site or location or of a product or service on its web site or location. The Panel notes the fact that the Complainant’s trademarks predate the disputed domain name by many years, and the trademark SANOFI is very well-known. Therefore, the Panel finds it inconceivable that the Respondent registered the disputed domain name without intention to cause confusion between the Complainant’s trademark and the disputed domain name. Accordingly, the Panel finds that the disputed domain name has been registered in bad faith. The disputed domain name does not resolve to an active website. 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. Having reviewed the available record, the Panel notes the distinctiveness and well-known status 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 finding of bad faith under the Policy. The Panel concludes that the registration and use of the disputed domain name amount to bad faith. Paragraph 4(a)(iii) of the Policy is satisfied. 7. Decision In accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <sanofi-f.com> be transferred to the Complainant. /Vinod K. Agarwal/ Vinod K. Agarwal Sole Panelist January 19, 2026

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

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