Westmore · UDRP decision
WIPO · Case No. D2025-4563

Sanofi.wales

CancellationWIPO-indexed · informational, not legal advice

The Panel ordered cancellation of <sanofi.wales>. It found the domain identical to the Complainant’s SANOFI trademark, found no rights or legitimate interests based on the inactive website, lack of any apparent connection between the Respondent’s name and the domain, and the unrebutted prima facie case, and found bad-faith registration and use under the passive-holding doctrine. The bad-faith finding relied on the Complainant being well-known, the Respondent’s failure to respond, concealment of identity and apparently false contact details, and the implausibility of any good-faith use.

Outcome
Cancelled
At a glance
Provider
WIPO
Outcome
Cancellation
Decision date
2025-12-30
Panelist(s)
Kondo, Keiji
Complainant
Sanofi
Respondent
Host Master, Njalla Okta LLC
Counsel
Selarl Marchais · associés
Disputed domain(s)
sanofi.wales
Citation weightCited by 1 later decision · relies on 1 authority
Domain history UDRP Intelligence

The timeline behind sanofi.wales

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.wales — 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 cancellation of sanofi.wales.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how an exact-match domain incorporating a well-known mark can satisfy all three UDRP elements even when the domain has never displayed active content. The result rested not on inactivity alone, but on the combined circumstances of long-prior trademark rights, the Complainant’s well-known status, respondent default, identity concealment and apparently false contact details, and the absence of any plausible good-faith use.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Cancellation
Decision date
2025-12-30
Panel
Kondo, Keiji
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. Host Master, Njalla Okta LLC Case No. D2025-4563 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Host Master, Njalla Okta LLC, Saint Kitts and Nevis. 2. The Domain Name and Registrar The disputed domain name <sanofi.wales> is registered with Tucows Domains Inc. (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 5, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 11, 2025, providing the registrant and contact information disclosed by the Registrar, and requesting the Complainant to submit an amendment to the Complaint. The Complainant filed amended Complaints on November 12, 2025, and November 13, 2025. The Center verified that the Complaint together with the amended Complaints 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 19, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 9, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 11, 2025. page 2 The Center appointed Keiji Kondo as the sole panelist in this matter on December 17, 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 The Complainant is a French multinational pharmaceutical company headquartered in Paris (France). Its consolidated net sales was 43 billion Euros in 2022. Historically, the company 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’s Research and Development portfolio includes 84 projects in clinical development, 26 of which are at advanced stages. The Complainant’s worldwide recognition has been shown in an annual worldwide brand survey issued on April 18, 2011. The Complainant is the owner of the many trademarks, and among the Complainant’s trademark portfolio is the following trademark registration: − French trademark SANOFI number 1482708, registered on August 11, 1988, in classes 01; 03; 04; 05; 10; 16; 25; 28; 31, among which class 5 covers pharmaceutical products. The disputed domain name was registered on July 31, 2025. The disputed domain name resolves to an inactive website. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for cancellation of the disputed domain name. Notably, the Complainant contends that: The disputed domain name reproduces the Complainant’s trademark in its entirety. The Complainant is a multinational company in the pharmaceutical field. The reproduction of the Complainant’s trademark as a whole is confusingly similar to the Complainant’s trademark. The disputed domain name comprises: (a) an exact reproduction of the Complainant’s trademark; (b) followed by a generic top-level domain (“gTLD”) “wales”. It is well established that the gTLD used as part of a domain name should be disregarded as it does not serve to distinguish domain names. It must be taken into account that the likelihood of confusion is ascertained by the reputation of the Complainant’s trade name, trademarks, domain names and more generally speaking goodwill. The Respondent does not have any rights or legitimate interests regarding the disputed domain name. It is obvious that the Respondent does not have any rights or legitimate interests in using the disputed domain name since the Respondent did not even indicate his/her/its identity. Indeed, the details provided on the identity of the Respondent are non-existing. Such incomplete details should serve as an indicator of an absence of legitimate interest as it does for bad faith registration and use. The Complainant has never licensed or otherwise authorized the Respondent to use its trademark or to register any domain name that includes the Complainant’s trademark. Consequently, there is no relationship whatsoever between the Parties and the Respondent has incorporated the Complainant’s trademark into the disputed domain name without the Complainant’s authorization. page 3 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 a legitimate interest in it in accordance with paragraph 4(c)(i) of the Policy. Generally speaking, panel decisions regularly recognize opportunistic bad faith in cases in which the disputed domain name appears confusingly similar to a Complainant’s well-known trademark. Moreover, it should be considered that, given the famous and distinctive nature of the Complainant’s trademark, the Respondent is likely to have had, at least, constructive notice as to the existence of the Complainant’s trademark 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. It is obvious that the Respondent registered in bad faith the disputed domain name corresponding to the Complainant’s trademark. The Respondent’s behavior can in no way be the result of a mere coincidence. The Complainant further contends that the disputed domain name has obviously been registered for the purpose of creating a likelihood of confusion – or at least an impression of association – between the Complainant’s trademark and the disputed domain name. It must be reminded that the Complainant is nowadays one of the world leaders among pharmaceutical companies, ranking first in Europe and ranked fourth in the world in the pharmaceutical industry. Under these circumstances, it is inconceivable that the Respondent registered the disputed domain name without knowledge of the Complainant or its trademark. The Respondent should have registered the disputed domain name for making unfair benefit freeriding the reputation of the Complainant’s trademark. For now, the disputed domain name resolves to an inactive website. It has been established in many UDRP decisions that passive holding under the appropriate circumstances falls within the concept of the domain name being used in bad faith. The leading case in this regard that the Complainant relies on is Telstra Corporative Limited v. Nuclear Marshmallows, WIPO Case No D2000-0003, in which the Panel found that in order to establish that the respondent was using a domain name in bad faith it was not necessary to find that it had undertaken any positive action in relation to the domain name. Indeed, in circumstances of inaction (“passive holding”), this behavior 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 the domain names used by the Complainant is likely to cause irreparable prejudice to their general goodwill because Internet users could be led to believe that the Complainant is not on the Internet or worse, that the Complainant is out of business. Consequently, the disputed domain name has been both registered and used in bad faith without any rights or legitimate interests by the Respondent. 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 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 is the owner of the French trademark registration for SANOFI, the Complainant’s trademark, and it is reproduced in the disputed domain name in its entirety. Addition of the gTLD “wales” should be disregarded in finding a confusing similarity. page 4 The entirety of the Complainant’s trademark 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 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. The Panel finds no similarity between the Respondent’s name and the disputed domain name. It is inconceivable that the Respondent has been known by the disputed domain name. In addition, since the disputed domain name resolves to an inactive website, it is clear that the disputed domain name is in no way used either in connection with a bona fide offering of goods or services, or as a legitimate noncommercial or fair use. Having reviewed the available record, the Panel finds that 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. Furthermore, generally speaking UDRP panels have found that domain names identical to a complainant’s trademark carry a high risk of implied affiliation. WIPO Overview 3.0, section 2.5.1. 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 the Respondent registered the disputed domain name nearly thirty- seven years after the Complainant’s French trademark registration. Considering the worldwide business of the Complainant, it is inconceivable that the Respondent registered the disputed domain name without knowledge of the Complainant. Accordingly, the Panel finds that the Respondent registered the disputed domain name in bad faith. The Panel further notes that the disputed domain name currently resolves to an inactive 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. In finding that “non-use” should be regarded as use in bad faith, panelists usually look at the totality of the circumstances in each case, and factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) page 5 the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put. (WIPO Overview 3.0, section 3.3) In the present case, the Panel finds that: (i) the Complainant is well-known: (ii) the Respondent failed to submit a response; (iii) the Respondent conceals its identity, and uses apparently false contact details; and (iv) it is implausible that there would be any good faith use to which the disputed domain name may be put, especially considering the nature of the Complainant’s trademark SANOFI. Accordingly, the Panel finds that the Respondent has been using the disputed domain name in bad faith. 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 <sanofi.wales> be cancelled. /Keiji Kondo/ Keiji Kondo Sole Panelist Date: December 30, 2025

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

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