Westmore · UDRP decision
WIPO · Case No. D2025-4588

San0fi.online

CancellationWIPO-indexed · informational, not legal advice

The Panel ordered cancellation of <san0fi.online>. It found the domain confusingly similar to Sanofi’s SANOFI mark because replacing the letter “o” with the number “0” was an obvious or intentional misspelling that left the mark recognizable. The Respondent failed to rebut Sanofi’s prima facie showing of no rights or legitimate interests, and the misspelling and unauthorized use of Sanofi’s logo indicated an intent to confuse users. The Panel also found bad faith because SANOFI was well known and the Respondent knew or should have known of the mark when registering the typo domain.

Outcome
Cancelled
At a glance
Provider
WIPO
Outcome
Cancellation
Decision date
2026-01-12
Panelist(s)
Malte Müller, Tobias
Complainant
Sanofi
Respondent
GoldPrime Ltd
Counsel
Selarl Marchais · associés
Disputed domain(s)
san0fi.online
Domain history UDRP Intelligence

The timeline behind san0fi.online

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 san0fi.online — 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 san0fi.online.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates a direct typosquatting pattern in which a single letter is replaced by a visually similar number and the resulting domain is used for an unauthorized branded login page. The same facts carried weight across all three UDRP elements: recognizability established confusing similarity, the typo and logo use undermined any legitimate-interest claim, and the well-known mark plus deliberate-looking misspelling supported bad faith.

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
Cancellation
Decision date
2026-01-12
Panel
Malte Müller, Tobias
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. GoldPrime Ltd Case No. D2025-4588 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is GoldPrime Ltd, Malta. 2. The Domain Name and Registrar The disputed domain name <san0fi.online> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 5, 2025. On November 6, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 6, 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, Privacy service provided by Withheld for Privacy ehf) 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 12, 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 November 24, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 14, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 15, 2025. The Center appointed Tobias Malte Müller as the sole panelist in this matter on December 29, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background It results from the Complainant’s undisputed allegations that it is a French multinational pharmaceutical company headquartered in Paris (France), one of the world's largest multinational pharmaceutical company by prescription sales. It engages 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. It is a multinational company settled in more than 180 countries on all five continents employing more than 90,000 people. The Complainant is the registered owner of several trademarks worldwide for SANOFI, in particular, European Union trademark registration No. 010167351 SANOFI, registered on January 07, 2012, for goods in classes 3 and 5. In addition, the Complainant owns and uses in connection with its activity several domain names containing the term SANOFI, e.g. <sanofi.com> registered on October 13, 1995. The disputed domain name was registered on October 18, 2025. Furthermore, the undisputed evidence provided by the Complainant proves that the disputed domain name resolved to a webpage displaying without authorization the Complainant’s trademark and logo (i.e., a log-in webpage displaying without authorization SANOFI’s logo requesting personal details in order to proceed with the log-in process). 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. Notably, the Complainant contends that: (1) the disputed domain name <san0fi.online> is confusingly similar to the Complainant’s registered trademark, since it reproduces SANOFI trademarks, regardless of the substitution of the letter “o” in Sanofi by the number “0”, which does not eliminate the likelihood of confusion with the well-known SANOFI trademark; (2) the Respondent has no rights or legitimate interests in the disputed domain name. According to the Complainant, it has never licensed or otherwise authorized the Respondent to use its trademarks or to register any domain name including the above-mentioned trademarks. Consequently, there is no relationship whatsoever between the Parties and the Respondent has clearly modified the Complainant’s trademarks for its own use and incorporated them into the disputed domain name without the Complainant’s authorization. In addition, the Respondent is not using the disputed domain name in connection with a bona fide offering of goods or services. In fact, the disputed domain name has been registered only for the purpose of unfairly attracting Internet users to the Respondent’s website, which imitates a log-in webpage with SANOFI’s logo, designed to collect Internet users details through fraud (phishing); (3) the disputed domain name was registered and is being used in bad faith. According to the Complainant, given the famous and distinctive nature of the mark SANOFI, the Respondent is likely to have had, at least, constructive, if not actual 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 domain name in order to make illegitimate use of it. In addition, the disputed domain name has been registered only for the purpose of unfairly attracting Internet users to the Respondent’s website page 3 which imitates a log in webpage with SANOFI’s logo, designed to collect Internet users’ details through fraud (phishing). B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. Paragraph 4(a) of the Policy requires a complainant to prove each of the following three elements in order to obtain an order that each disputed domain name be transferred or cancelled: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (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. The Panel will therefore proceed to analyze whether the three elements of paragraph 4(a) of the Policy are satisfied. 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 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. 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. In addition, it is the view of this Panel that the replacement of the vowel “O” with the number “0” in the disputed domain name results to be a common, obvious, or intentional misspelling of the Complainant’s well known trademark, and cannot prevent a finding of confusing similarity between the disputed domain name and the Complainant’s trademark since the disputed domain name contains sufficiently recognizable aspects of the relevant mark (see WIPO Overview 3.0 at section 1.9). 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 page 4 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. Moreover, the Panel notes that the disputed domain name consists of a common, obvious, or intentional misspelling of the Complainant’s registered trademark SANOFI, so that this Panel finds it most likely that employing a misspelling in this way signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainant. The Panel finds it most likely that the Respondent registered the disputed domain name with the intention to take advantage of the Complainant’s reputation by registering a domain name containing the Complainant’s trademark with the intent to mislead Internet users. This finding is reinforced by the Respondent’s use of the Complainant’s logo on the website. 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 shares the view of other UDRP panels and finds that the Complainant’s trademark SANOFI is well known. Therefore, this Panel has no doubt that the Respondent positively knew or should have known the Complainant’s trademark when registering the disputed domain name. This is underlined by the fact that the disputed domain name is clearly constituted by a common, obvious, or intentional misspelling of the Complainant’s trademark. Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith, WIPO Overview 3.0 section 3.1.4. The Panel shares this view. 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 <san0fi.online> be cancelled. /Tobias Malte Müller/ Tobias Malte Müller Sole Panelist Date: January 12, 2026

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

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