Westmore · UDRP decision
WIPO · Case No. D2025-4854

Airbusmanual.app

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <airbusmanual.app> after finding all three UDRP elements satisfied. The domain incorporated the AIRBUS trademark with the term “manual” and resolved to a login or account-creation page whose browser tab was titled “Airbus AI Assistant – Chat with Aircraft Models.” The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use based principally on the fame of AIRBUS, the domain’s implied affiliation with an official Airbus technical application, and the website’s express reference to Airbus aircraft models.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-15
Panelist(s)
Azevedo, Rodrigo
Complainant
Airbus SAS
Respondent
Cho-lin Yang
Disputed domain(s)
airbusmanual.app
Citation weightCited by 1 later decision
Domain history UDRP Intelligence

The timeline behind airbusmanual.app

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 airbusmanual.app — 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 airbusmanual.app.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a famous mark combined with terms that imply technical documentation and software functionality can strengthen findings beyond ordinary confusing similarity. Here, “manual” and “.app” reinforced an apparent official Airbus use, while the Airbus-specific browser title provided direct contextual evidence of targeting. The transfer did not depend on a definitive phishing finding.

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
2026-01-15
Panel
Azevedo, Rodrigo
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Airbus SAS v. Cho-lin Yang Case No. D2025-4854 1. The Parties The Complainant is Airbus SAS, France, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Cho-lin Yang, United States of America. 2. The Domain Name and Registrar The disputed domain name <airbusmanual.app> is registered with CloudFlare, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 21, 2025. On November 24, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 25, 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 (DATA REDACTED) and contact information in the Complaint. The Center sent an email communication to the Complainant on November 26, 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 November 27, 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 November 28, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 18, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 19, 2025. The Center appointed Rodrigo Azevedo 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 The Complainant is Airbus SAS, a leading aerospace corporation headquartered in France, engaged in the design, manufacture, and delivery of commercial aircraft, helicopters, defense, and space-related systems. The Complainant is the owner of numerous trademark registrations for the AIRBUS trademark across multiple jurisdictions, including international trademark registration No. 1112012, registered on June 24, 2011. The Complainant also owns and operates the domain name <airbus.com>, registered since May 23, 1995. The disputed domain name <airbusmanual.app> was registered on August 2, 2025, and is currently linked to a login or account creation webpage, with the browser tab displaying the title “Airbus AI Assistant – Chat with Aircraft Models,” which falsely suggests an association with the Complainant. 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: (i) The disputed domain name is identical or confusingly similar to the Complainant’s trademark. The Complainant asserts that it is the owner of the AIRBUS trademark, as evidenced by multiple trademark registrations, including those shown in Annex 1 of the Complaint. The mere holding of a national or regional trademark satisfies the threshold requirement for standing under Paragraph 4(a)(i) of the Policy. The disputed domain name captures its AIRBUS trademark in its entirety and merely adds the descriptive term “manual” and a standard Top-Level Domain (“.app”), both of which are insufficient to avoid a finding of confusing similarity. It is well-established under UDRP precedent that the addition of descriptive terms to a mark does not prevent a finding of confusing similarity, especially where the trademark remains clearly recognizable within the domain name. (ii) The Respondent has no rights or legitimate interests in the disputed domain name. The Complainant states that it has not licensed, authorized, or otherwise permitted the Respondent to use its AIRBUS trademark, including in a domain name. The Respondent is not sponsored by or affiliated with the Complainant in any way. Furthermore, the Respondent is not commonly known by the disputed domain name. The public WhoIs information identifies the registrant as “DATA REDACTED,” and the subsequent registrar disclosure identified the individual as “Cho-lin Yang,” neither of which bears any resemblance to the disputed domain name. This absence of evidence that the Respondent is commonly known by the disputed domain name supports a finding that the Respondent lacks rights or legitimate interests pursuant to Paragraph 4(c)(ii) of the Policy. Additionally, the Respondent’s use of a privacy service at the time of filing the Complaint is cited as further evidence of a lack of legitimate interest, based on prior UDRP panel findings. Furthermore, the Respondent registered the disputed domain name significantly after the Complainant filed for registration of its AIRBUS trademark. Finally, the disputed domain name resolves to an unauthorized website with the browser tab displaying the title “Airbus AI Assistant – Chat with Aircraft Models,” which falsely suggests an association with the Complainant. The site contains only a login portal that appears designed to collect user credentials, indicating potential phishing activity. This use exploits the page 3 Complainant’s trademark, reputation, and goodwill to create confusion, divert traffic for the Respondent’s benefit, and possibly facilitate fraudulent acquisition of users’ personal and financial information. (iii) The disputed domain name was registered and is being used in bad faith. The Complainant argues that, given the fame of the AIRBUS trademark and its global reputation in the aerospace industry, it is inconceivable that the Respondent was unaware of the Complainant’s rights at the time of registration. The Respondent deliberately targeted the Complainant’s trademark, as evidenced by the browser tab associated with the disputed domain name which reads “Airbus AI Assistant – Chat with Aircraft Models.” This shows that the Respondent intentionally attempted to attract Internet users by creating a likelihood of confusion with the AIRBUS trademark. The disputed domain name resolves to a login portal that encourages users to submit their credentials, which is likely part of a phishing scheme. Use of a domain name for phishing is per se evidence of bad faith under UDRP jurisprudence. This is compounded by the Respondent’s use of a privacy service to conceal their identity and their failure to respond to cease-and-desist correspondence prior to the filing of the Complaint. On the totality of the evidence, it is more likely than not that the Respondent registered and is using the disputed domain name in bad faith, specifically to exploit the goodwill of the AIRBUS trademark and deceive unsuspecting users. 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 3.0, section 1.7. Annex 1 to the Complaint shows numerous trademark registrations for AIRBUS. Based on the available record, the Panel finds 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 disputed domain name incorporates the Complainant’s trademark AIRBUS, with the addition of the expression “manual” as a suffix. The disputed domain name also presents the gTLD extension “.app.” Although the addition of other terms (here, “manual”) may bear on assessment of the second and third elements, the Panel finds it 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. It is also well established that the addition of a gTLD (such as “.app”) is typically disregarded when determining whether a domain name is confusingly similar to a complainant’s trademark as such is viewed as a standard registration requirement. WIPO Overview 3.0, section 1.11.1. Therefore, the Panel finds the disputed domain name is confusingly similar to the Complainant’s trademark and that 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 page 4 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 no indication that the Respondent is commonly known by the disputed domain name. The Complainant has asserted that the Respondent is not an authorized representative, nor has obtained any permission for registering the disputed domain name. The Panel finds that the nature of the disputed domain name, comprising the Complainant’s famous trademark and linked to a website under the browser tab tittle “Airbus AI Assistant – Chat with Aircraft Models”, indicate a clear awareness of the Complainant and its trademark and an intent to possibly take unfair advantage of such, which does not support a finding of any rights or legitimate interests. Furthermore, the Panel finds that the composition of the disputed domain name carries a risk of implied affiliation. WIPO Overview 3.0, section 2.5.1. Based on the available record, 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. When the disputed domain name was registered in 2025, the AIRBUS trademark was already famous and had been directly connected with the Complainant’s aircrafts and services worldwide for many decades. The disputed domain name includes the trademark AIRBUS in its entirety. According to the WIPO Overview 3.0, section 3.1.4, UDRP panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith. The Panel believes that – taking into consideration the worldwide fame of the AIRBUS brand – the addition of the term “manual” is not enough to disassociate the disputed domain name from the AIRBUS trademark owned by the Complainant. In fact, the Panel understands that this addition, followed by the gTLD extension “.app”, may create a likelihood of confusion with the Complainant's trademark, , suggesting that it is an official application addressing technical information about AIRBUS aircrafts. The Panel also concludes that the Respondent was clearly aware of the Complainant’s trademark and that the registration of the disputed domain name was not a mere coincidence, especially considering the reference to “Airbus AI Assistant – Chat with Aircraft Models” on the browser tab title when accessing the page 5 disputed domain name. The Panel holds that the Respondent is intentionally attempting to create a likelihood of confusion with the Complainant’s trademark as to the source, affiliation, or endorsement of the disputed domain name. Therefore, having reviewed the record, the Panel finds the registration and use of the disputed domain name constitutes bad faith under 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 <airbusmanual.app> be transferred to the Complainant. /Rodrigo Azevedo/ Rodrigo Azevedo Sole Panelist Date: January 15, 2026

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

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