Westmore · UDRP decision
WIPO · Case No. D2025-4855

Bardehlepartners.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <bardehlepartners.com>. It found the domain confusingly similar to the Complainant’s BARDEHLE source identifier and registered BARDEHLE PAGENBERG trademark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The associated website referred to the Complainant and identified its partners and staff, while the domain was also configured for email use. The Panel treated the potential for phishing or impersonation as an aggravating factor.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-06
Panelist(s)
Souter, George R. F.
Complainant
BARDEHLE PAGENBERG Partnerschaft mbB Patentanwälte Rechtsanwälte
Respondent
Simon Allaeys, EasyAntiCheat Oy
Counsel
Bardehle Pagenberg
Disputed domain(s)
bardehlepartners.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

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

The case illustrates how a domain combining a distinctive law-firm identifier with the business-related term “partners” can support findings of confusing similarity and deliberate targeting. The decision is also notable for distinguishing email capability and potential phishing risk from proof of actual phishing, while still treating that capability as an aggravating bad-faith factor. It further demonstrates the use of respondent-name redaction where the registration appears to involve a third party’s identity.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-06
Panel
Souter, George R. F.
Full decision
6 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION BARDEHLE PAGENBERG Partnerschaft mbB Patentanwälte Rechtsanwälte v. Name Redacted Case No. D2025-4855 1. The Parties The Complainant is BARDEHLE PAGENBERG Partnerschaft mbB Patentanwälte Rechtsanwälte, Germany, represented by Bardehle Pagenberg, Germany. The Respondent is Name Redacted 1 . 2. The Domain Name and Registrar The disputed domain name <bardehlepartners.com> 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 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 (Redacted for Privacy) 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 on November 25, 2025. 1 The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. However, the Panel has attached as Annex 1 to this Decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in these proceedings and has indicated Annex 1 to this Decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST- 12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 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. The Center appointed George R. F. Souter as the sole panelist in this matter on December 23, 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 well-known intellectual property law firm, founded in 1977, with offices in a number of German cities, and in France and Spain. It is the proprietor of European Union trademark registration No. 004566121, registered on July 26, 2006, in respect of the trademark BARDEHLE PAGENBERG. The Complainant, inter alia, presents its business on its official website, <bardehle.com>, and has done so for many years. It also operates and controls the domain name <bardehle.de>. The disputed domain name was registered on October 14, 2025. The Complainant has provided the Panel with a screenshot of the website to which the disputed domain name resolves, which, clearly, refers to the Complainant, including identification of the Complainant’s partners and staff. This website is also configurated to operate emails. 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 claims that the BARDEHLE element of its name is distinctive and functions as a source identifier for the Complainant’s legal services. The Complainant also states that it has never consented to the use of its BARDEHLE mark in connection with the registration of a domain name, or otherwise. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The Panel accepts the Complainant’s claim that the name BARDEHLE functions as a source identifier for the Complainant’s business. page 3 The Panel, accordingly, finds that the Complainant has shown rights in respect of the trademark BARDEHLE for the purposes of the Policy. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.2.1. The entirety of the mark BARDEHLE 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. The mere addition of the descriptive term “partners” to the trademark BARDEHLE does not detract from this finding. WIPO Overview 3.0, section 1.8. The Panel also finds that the disputed domain name is confusingly similar to the Complainant’s registered BARDEHLE PAGENBERG trademark. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests 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. C. Registered and Used in Bad Faith The Panel considers it implausible that the disputed domain name was adopted without having the Complainant’s BARDEHLE trademark in mind, and the subsequent use of the disputed domain name would appear to confirm this. The Panel finds that the disputed domain name was registered in bad faith. The evidence in the case file, namely the screenshot of the website operated under the disputed domain name, indicates that the Respondent’s use of the disputed domain name carries a clear suggestion that it is affiliated with the Complainant. It is well-established in prior decisions under the Policy that the use of a disputed domain name found to be confusingly similar to a complainant’s trademark to refer directly to the complainant constitutes use in bad faith. In the circumstances of the present case, the configuration of the disputed domain name to facilitate email use of the disputed domain name, with its facility to use the email for the purposes of phishing, impersonation, etc., to the possible detriment of the Complainant, is an aggravating factor. The Panel finds that the disputed domain name is being used in bad faith. 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 <bardehlepartners.com> be transferred to the Complainant. /George R. F. Souter/ George R. F. Souter Sole Panelist Date: January 6, 2026

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

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