Westmore · UDRP decision
WIPO · Case No. D2025-4837

Sanofiamerica.com

CancellationWIPO-indexed · informational, not legal advice

The Panel found that <sanofiamerica.com> was confusingly similar to Sanofi’s SANOFI mark, that the Respondent had not rebutted the Complainant’s prima facie case concerning rights or legitimate interests, and that passive holding did not prevent a finding of bad faith given the mark’s distinctiveness or reputation and the domain name’s composition. The Panel ordered cancellation of the domain name.

Outcome
Cancelled
At a glance
Provider
WIPO
Outcome
Cancellation
Decision date
2026-01-02
Panelist(s)
Iriarte, Erick
Complainant
Sanofi
Respondent
Powell Will, PowellWill
Counsel
Selarl Marchais · associés
Disputed domain(s)
sanofiamerica.com
Domain history UDRP Intelligence

The timeline behind sanofiamerica.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 sanofiamerica.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 cancellation of sanofiamerica.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that adding a geographic term to a trademark may leave the mark readily recognizable and that an inactive domain can still satisfy the bad-faith element where the panel relies on the mark’s distinctiveness or reputation and the domain’s composition. It also demonstrates the practical importance of rebutting a complainant’s prima facie case on rights or legitimate interests.

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
2026-01-02
Panel
Iriarte, Erick
Full decision
7 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. Powell Will, PowellWill Case No. D2025-4837 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Powell Will, PowellWill, United States of America (“United States” or “U.S.”). 2. The Domain Name and Registrar The disputed domain name <sanofiamerica.com> is registered with Metaregistrar BV (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 20, 2025. On November 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 23, 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 25, 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 November 26, 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 27, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 17, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 18, 2025. page 2 The Center appointed Erick Iriarte as the sole panelist in this matter on December 19, 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), ranking 4th world's largest multinational pharmaceutical company by prescription sales. SANOFI 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. The Complainant is the owner of several SANOFI trademarks (Annex 8 of the Complaint), including registrations in France, European Union, United States and United Kingdom which are registered p rior to the registration of the disputed domain name (November 17, 2025). France: trademark SANOFI, register number 3831592, registered on May 16, 2011, in classes 01; 03; 05; 09; 10; 16; 35; 38; 40; 41; 42; and 44 notably concerning pharmaceutical products; France: trademark SANOFI, register number 96655339, registered on December 11, 1996, in classes 01; 03; 05; 09; 10; 35; 40; and 42 notably concerning pharmaceutical products; European Union: trademark SANOFI, register number 010167351, filed on August 2, 2011, and registered on January 7, 2012, in classes 03; and 05 notably concerning pharmaceutical products; European Union: trademark SANOFI, register number 004182325, filed on December 8, 2004, and registered on February 9, 2006, in classes 01; 09; 10; 16; 38; 41; 42; and 44 notably concerning products in pharmaceutical and medical spheres; U.S.: trademark SANOFI, register number 85396658, filed on August 12, 2011, and registered on July 24, 2012, in class 05 notably concerning pharmaceutical products; and United Kingdom: trademark SANOFI, register number UK00001483425, filed on November 21, 1991, and registered on January 15, 1993, in class 05 notably concerning pharmaceutical products. The official website of the Complainant is: <sanofi.com>, and the Complainant also owns other domain names. The disputed domain name was registered on November 17, 2025, and resolves to an inactive page. 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 encompasses the entirety of the Complainant’s SANOFI trademark. The inclusion of the word “america” in the disputed domain name does not exclude the likelihood of confusion between the SANOFI trademark and the disputed domain name. page 3 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 other terms here, “america”, 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. The Panel finds the second element of the Policy has been established. page 4 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. 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. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness or reputation 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 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 <sanofiamerica.com> be cancelled. /Erick Iriarte/ Erick Iriarte Sole Panelist Date: January 2, 2026

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

Beyond the decision

What Westmore sees around sanofiamerica.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
116,051 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.