Westmore · UDRP decision
WIPO · Case No. D2025-4769

Iqoslo.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <iqoslo.com>. It found the domain confusingly similar to the Complainant’s IQOS trademark because it reproduced IQOS in its entirety with the additional term “lo.” The Respondent lacked rights or legitimate interests because the prior online shop offered what appeared to be IQOS products, presented itself as “IQOS Turkey,” did not disclose its relationship with the Complainant, and was neither authorized nor commonly known by the domain. Bad faith was established because the website used the IQOS mark and official product images to create a misleading impression of affiliation and attract users for commercial gain, despite IQOS products not then being offered by the Complainant in Türkiye.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-06
Panelist(s)
Bedarida, Fabrizio
Complainant
Philip Morris Products S.A.
Respondent
Oğuz Karakaş
Disputed domain(s)
iqoslo.com
Domain history UDRP Intelligence

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

The decision illustrates how a domain combining a distinctive mark with a short additional term can satisfy the first element when the mark remains fully recognizable. More significantly, the case shows the evidentiary weight given to a commercial website that adopts the trademark owner’s imagery, presents itself as an official geographic operation, and fails to disclose the absence of affiliation. Prior website use remained decisive even though the domain later appeared inactive.

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
2026-01-06
Panel
Bedarida, Fabrizio
Full decision
10 min read · hosted by Westmore

ARBI TRATI O N AND MEDI ATI ON CENTER ADMINISTRATIVE PANEL DECISION Philip Morris Products S.A. v. Oğuz Karakaş Case No. D2025-4769 1. The Parties The Complainant is Philip Morris Products S.A., Switzerland, represented by D.M. Kisch Inc., South Africa. The Respondent is Oğuz Karakaş, Türkiye. 2. The Domain Name and Registrar The disputed domain name <iqoslo.com> is registered with Realtime Register B.V. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 18, 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 20, 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 (The RDAP server redacted the value) 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 an amended Complaint on December 1, 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 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 22, 2025. The Center appointed Fabrizio Bedarida as the sole panelist in this matter on December 26, 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 The Complainant, Philip Morris Products S.A., a Swiss company established under the laws of Switzerland, is part of the group of companies affiliated to Philip Morris International Inc. (jointly referred to as “PMI”). PMI is one of the leading international tobacco companies, with products sold in approximately 180 countries. In the course of transforming its business from combustible cigarettes to Reduced Risk Products (or “RRPs”, which PMI defines as products that present, are likely to present, or have the potential to present less risk of harm to smokers who switch to those products instead of continuing to smoke), PMI has developed a number of products. One of these RRPs developed and sold by PMI is branded IQOS. IQOS is a controlled heating device into which specially designed tobacco products under the brand names “HEETS” and “HeatSticks” are inserted and heated to generate a nicotine-containing aerosol. The Complainant has proven to be the owner of numerous registrations for the IQOS trademark worldwide including in Türkiye. The Complainant is, inter alia, the owner of: International Registration for IQOS, No. 1218246, registered on July 10, 2014; International Registration for IQOS (device), No. 1461017, registered on January 18, 2019; International Registration for IQOS (device), No. 1557546, registered on August 27, 20 20. The disputed domain name was registered on October 7, 2025. Currently the disputed domain name appears to be inactive. However, from the submissions of the Complainant, it appears that previously (at least on November 5, 2025) the disputed domain name resolved to an online shop allegedly offering the Complainant’s IQOS branded products, and presenting itself (in the about us page) as “IQOS Turkey”. However, the Complainant’s IQOS System is not currently sold in Türkiye. In addition, on this website, a number of the Complainant’s copyright-protected official product images and marketing materials were displayed. The Complainant’s trademark registrations predate the registration of the disputed domain name. 5. Parties’ Contentions A. Complainant The Complainant contends that the disputed domain name is confusingly similar to the IQOS trademark, that the Respondent has no rights or legitimate interests in respect of the disputed domain name, and that the disputed domain name has been registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings In order for the Complainant to obtain the transfer of the disputed domain name, paragraphs 4(a)(i)-(iii) of the Policy require that the Complainant must demonstrate to the Panel that: page 3 (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. 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 C omplainant’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 and 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. Although the addition of other terms, here “lo”, may bear on assessment of the second and third elements, the Panel finds the addition of such 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 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. In fact, the Respondent has no connection or affiliation with the Complainant, and the Complainant has not licensed or otherwise authorized the Respondent to use or register any domain names incorporating the Complainant’s trademark. The Respondent does not appear to be commonly known by the disputed domain name, the name “iqos”, or by a similar name. The Respondent does not appear to make any legitimate noncommercial or fair use of the disputed domain name, nor any use in connection with a bona fide offering of goods or services. The Respondent offers for sale what appears to be the Complainant’s products without disclosing the relationship between the Complainant and the Respondent. Moreover, the illegitimacy of the Respondent’s use of the disputed domain name is further shown by the fact that the Complainant does not curren tly offer its IQOS branded products for sale in Türkiye, while the online shop hosted at the disputed page 4 domain name creates the false impression that the Complainant has officially introduced the IQOS products into the Turkish market. Panels have held that the use of a domain name for illegitimate activity, here claimed as impersonation/passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. Finally, the Respondent has not replied to the Complainant’s contentions, alleging any rights or legitimate interests in the disputed domain name. 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. 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. In the present case, the Panel notes that the Respondent could not have been unaware of the existence of the Complainant’s trademarks when registering the disputed domain name. In fact, it appears that the Respondent started offering the Complainant’s IQOS branded products immediately after registering the disputed domain name. In addition, the term “iqos” is not commonly used to refer to tobacco products or electronic devices. It is therefore unlikely that the Respondent chose the disputed domain name without the intention of invoking a misleading association with the Complainant. Indeed, it is evident from the Respondent’s use of the disputed domain name that the Respondent registered and has used the disputed domain name with the intention to attract Internet users to its website, for commercial gain, by creating a likelihood of confusion with the Complainant’s IQOS trademark as to the source, sponsorship, affiliation, or endorsement of its website or location or of a product or service on its website or location, which constitutes registration and use in bad faith pursuant to paragraph 4(b)(iv)of the Policy. This is further supported by the Respondent’s use of the Complainant’s official product images. The illegitimacy of the Respondent’s use of the disputed domain name is further shown by the fact that the Complainant does not currently offer for sale its IQOS branded products in Türkiye, and the online shop hosted at the disputed domain name creates the false impression that the Complainant has launched these products in Türkiye. Panels have held that the use of a domain name for illegitimate activity, here claimed as impersonation/passing off, 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. This Panel thus finds that the above use of the disputed domain name constitutes a disruption of the Complainant’s business and qualifies as bad faith registration and use under paragraph 4(b)(iv) of the Policy. Finally, the Respondent has not responded to (nor denied) the assertions made by the Complainant in this proceeding. page 5 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 <iqoslo.com> be transferred to the Complainant. /Fabrizio Bedarida/ Fabrizio Bedarida Sole Panelist Date: January 6, 2026

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

Beyond the decision

What Westmore sees around iqoslo.com

The decision is only the record. Westmore connects it to the cases, authorities, panelists, parties and domain evidence surrounding it.

Connected to Westmore UDRP Intelligence
115,979 decisions · citations · panelists · parties · domain history
Eleanor · UDRP intelligence
Ask Eleanor about this decision
Ask Eleanor about this decision

A short, grounded explanation drawn only from this decision's record — not legal advice or a prediction.

Unlocking Eleanor for this case uses 1 of your complimentary Intelligence unlocks· 3 remaining

Grounded in the Westmore record for this decision. Research/informational only — not legal advice or a prediction of any outcome.

Westmore Professional · Unlock the intelligence

The decision is only the beginning.

You've seen what happened. Now discover the deeper intelligence behind the case, the panelist, the parties and the authorities that matter.

Citation Intelligence
How this decision is cited and treated across the corpus.
Panelist Intelligence
The panel's tendencies, outcomes and reasoning patterns.
Domain History
Ownership chronology — creation vs. respondent acquisition.
Opposing-Party Research
Complainant, counsel and portfolio context.
Independent Case Review
Eleanor challenges your filing before the other side does.
Professional Matters
Open, research and manage matters end to end.
$395/month
Unlock Westmore Professional Annual & firm seats available · cancel anytime
Take the next step
Westmore UDRP · find the right service

Westmore UDRP records draw on WIPO-indexed decisions and are provided for research and informational purposes only. Not legal advice, a clearance opinion, or a prediction of any outcome.

Essential cookies only. Nothing is sold or shared.