Westmore · UDRP decision
WIPO · Case No. D2025-4757

Suzlongreens.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <suzlongreens.com>. It found the domain confusingly similar to the Complainant’s SUZLON mark because it incorporated the mark in its entirety, with the additional term “greens” not preventing confusing similarity. The Respondent lacked rights or legitimate interests because its prior website used the SUZLON mark and logo and offered energy-related solutions and services in a manner designed to impersonate or pass off as the Complainant. The same conduct demonstrated bad-faith registration and use through an intentional attempt to attract Internet users for commercial gain by creating confusion with the Complainant.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-12
Panelist(s)
Majumder, Shwetasree
Complainant
Suzlon Energy Limited
Respondent
BHAGWATI ENTERPRISES
Disputed domain(s)
suzlongreens.com
Domain history UDRP Intelligence

The timeline behind suzlongreens.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 suzlongreens.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 suzlongreens.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining an entire distinctive mark with an industry-related term can satisfy all three UDRP elements when the associated website reinforces confusion through use of the mark, logo, and overlapping services. It also confirms that taking a website offline after the Complaint does not erase evidence of prior impersonating 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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-12
Panel
Majumder, Shwetasree
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Suzlon Energy Limited v. Bhagwati Enterprises Case No. D2025-4757 1. The Parties The Complainant is Suzlon Energy Limited, India, represented by AZB & Partners, India. The Respondent is Bhagwati Enterprises, India. 2. The Domain Name and Registrar The disputed domain name <suzlongreens.com> 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 November 17, 2025. On November 18, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 19, 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 and contact information in the Complaint. The Center sent an email communication to the Complainant on November 21, 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 amended Complaints on November 24, 2025, and November 26, 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 December 1, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 21, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 23, 2025. page 2 The Center appointed Shwetasree Majumder 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 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is an Indian company incorporated in 1995 and is one of India’s leading renewable energy companies. The Complainant has a global turnover of INR 10,851 crores in the financial year 2024-2025. The Complainant has been listed on the National Stock Exchange of India and the Bombay Stock Exchange since 2005. The Complainant has its presence through subsidiaries, joint ventures, manufacturing facilities, R&D centers, and wind energy projects in numerous countries, including India, Germany, Denmark, the Netherlands (Kingdom of the), the United States of America, China, Brazil, and Australia. The Complainant has been using the SUZLON as part of its corporate name since 1987 and owns multiple registrations across multiple jurisdictions. Details of a few such trade mark registrations for SUZLON are as below: - SUZLON – Indian Registration No. 1901301, registered on December 24, 2009, in International Class 37; - – Indian Registration No. 1901302, registered on December 24, 2009, in International Class 37; - – Indian Registration No. 1347648, registered on March 30, 2005, in International Class 7. - SUZLON – Australian Registration No. 1336959, registered on November 4, 2008, in International Classes 7, 9, 37, 40, 42 and 45. The Complainant’s main business website is “www.suzlon.com”. The disputed domain name <suzlongreens.com> was registered on October 16, 2025. Presently, the disputed domain name does not resolve to an active website. But at the time of filing of the Complaint, the Respondent’s website used the Complainant’s mark SUZLON and the SUZLON logo and offered energy related solution and services. 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 the disputed domain name is confusingly similar to the trademark of the Complainant. The Complainant contends that the disputed domain name is identical or confusingly similar to its trademark and is likely to mislead Internet users into believing that the disputed domain name is associated with, or operated by, the Complainant, as the disputed domain name is descriptive in the context of renewable/green energy, which is precisely the Complainant’s field of business. The Complainant further argues that the Respondent is using the mark SUZLON and the SUZLON logo of the Complainant and offered similar energy-related solutions and services. page 3 The Complainant asserts long-standing and exclusive rights in the trademark SUZLON, which has been used since at least 1987 and continuously since the incorporation of Suzlon Energy Limited in 1995. The Complainant also asserts that the mark SUZLON is a coined and inherently distinctive mark with no dictionary meaning, exclusively associated with the Complainant and its business in renewable energy. The Complainant argues that it has not authorized the Respondent, or any associated person or entity, to use or register the SUZLON mark in any manner, including in the disputed domain name or on the website. The Complainant has submitted evidence demonstrating that the disputed domain name directs users to a website that offers energy solutions which directly overlap with the Complainant’s business, thereby increasing the likelihood of confusion. The Complainant asserts that the Respondent uses a logo and overall presentation similar to SUZLON, reinforcing the false impression of affiliation. The Complainant contends that the disputed domain has been registered to create initial interest confusion, divert Internet traffic, and generate unlawful commercial gain. The Complainant argues that the lack of genuine business details and misleading website content further evidences bad faith, including the possibility that the disputed domain name was acquired for resale or exploitation of the Complainant’s reputation. 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 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 entirety of the mark is reproduced 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. Although the addition of the term “greens” may bear on the assessment of the second and third elements, the Panel finds the addition of such a term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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 page 4 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 with 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. Panels have held that the use of a domain name for illegitimate activity, such as impersonation/passing off of the Complainant, can never confer rights or legitimate interests on a Respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name. The Panel is aware that presently the disputed domain name does not have any hosted content. However, the Respondent’s website was previously designed to impersonate and pass off the Complainant’s marks by using the identical SUZLON mark along with the logo. The Respondent has intentionally sought to attract Internet users for commercial gain by creating a likelihood of confusion by offering the solution and services related to energy domain thereby misleading consumers into believing that the website, its products, or its activities are associated with, sponsored, or endorsed by the Complainant, which is neither a bona fide offering of goods nor a legitimate noncommercial or fair use of the disputed domain name as envisioned under the Policy. 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 intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark. The Panel finds that the Respondent registered the disputed domain name and was using the same, with an intent to pose as the Complainant’s business in an attempt to deceive Internet consumers. Hence, the Panel does not find any plausible legitimate reason for the Respondent to register and use the disputed domain name. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a Respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1. Panels have held that the use of a domain name for illegitimate activity, such as impersonation/passing off of the Complainant, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 5 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 <suzlongreens.com> be transferred to the Complainant. /Shwetasree Majumder/ Shwetasree Majumder Sole Panelist Date: January 12, 2026

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

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