Westmore · UDRP decision
WIPO · Case No. D2025-5000

Snsautomation.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <snsautomation.com>. It found that the Complainant had established unregistered rights in SNS and SNS AUTOMATION through sustained use in the industrial and automation sector. Although the Respondent had historically used “SNS Automation” as a business name, its post-rebrand redirection of the domain to its competing MTI Automation website and its handling of emails sent to @snsautomation.com did not establish a legitimate interest. For bad faith, the Panel treated the Respondent’s assumption of effective control no later than 2023—not the domain’s original 1997 creation—as the relevant event and found that the redirection and email practices intentionally exploited confusion and disrupted the Complainant’s business communications.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-27
Panelist(s)
Chumak, Yuri
Complainant
2786256 Ontario Ltd. dba SNS Industrial Group
Respondent
Lajos Csombo, 7693320 Canada Inc
Counsel
Desmond Sanfilippo
Disputed domain(s)
snsautomation.com
Domain history UDRP Intelligence

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

This decision illustrates how a panel may analyze a long-established domain where the challenged conduct concerns a later assumption of effective control rather than the original creation date. It also shows that historical use of a business name within a prior commercial relationship may not establish a present legitimate interest when the respondent has rebranded but continues using the old-name domain to redirect competing traffic and handle potentially misdirected email.

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
2026-01-27
Panel
Chumak, Yuri
Full decision
15 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION 2786256 Ontario Ltd. dba SNS Industrial Group v. Lajos Csombo, 7693320 Canada Inc Case No. D2025-5000 1. The Parties The Complainant is 2786256 Ontario Ltd. dba SNS Industrial Group, Canada, represented by Desmond Sanfilippo, Canada. The Respondent is Lajos “Louis” Csombo, 7693320 Canada Inc, Canada, self-represented. 2. The Domain Name and Registrar The disputed domain name <snsautomation.com> is registered with Squarespace Domains II LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 2, 2025. On December 3, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 5, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 December 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 4, 2026. The Response was filed with the Center on January 3, 2026. page 2 The Center appointed Yuri Chumak as the sole panelist in this matter on January 16, 2026. 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 operates in Canada in the distribution of industrial and automation products. The Complaint asserts that the Complainant and related entities within the “SNS” business have used the designations “SNS”, “SNS Automation”, and “SNS Industrial” for many years in connection with such products and services. The Complaint includes corporate and business registration materials and historical use materials referencing “SNS” and “SNS Automation”, including incorporation documents and business registrations, and materials showing multiple operating locations using “SNS Automation” branding. The disputed domain name was initially registered/created on October 16, 1997. According to the undisputed allegation in the Complaint, the initial registration of the disputed domain name was made by the Complainant. The record reflects that the disputed domain name has been used in the industrial and automation sector in which both parties operate. It is undisputed that the Respondent presently exercises registrant and administrative control over the disputed domain name. The disputed domain name resolves, by redirection, to the Respondent’s website at “www.mtiautomation.com”. The parties’ dispute arises in the context of a prior business relationship. The Respondent asserts that 7693320 Canada Inc., the Respondent’s company, has been registered in Quebec as doing business under the name “SNS Automation” since 2010, and that it used that name in the course of business. The Respondent further asserts that, in 2019, it acquired the remaining shares of 7693320 Canada Inc. pursuant to a Sale Purchase and Loan Agreement (the “Agreement”), and that the disputed domain name formed part of the corporation’s assets at that time. The Respondent also states that, following the Complainant’s threat of legal proceedings, it rebranded from “SNS Automation” to “MTI Automation” in May 2023, and that it redirected traffic from the disputed domain name to its “www.mtiautomation.com” website in connection with that rebrand. The Complainant disputes that the Respondent had authorization to take or retain registrant control of the disputed domain name. The Complainant asserts that an IT service provider associated with the parties’ prior relationship implemented domain-level redirection, and that the Respondent caused or participated in the acquisition and continued control of the disputed domain name following the deterioration of the parties’ relationship. The Complainant also asserts that emails sent to addresses at the disputed domain name have been forwarded and answered by the Respondent or its employees, in circumstances alleged to evidence confusion and diversion of business communications. The Respondent acknowledges that emails sent to certain “@snsautomation.com” addresses are being forwarded to a Respondent employee, and states that this was done to ensure that supplier and customer emails do not go unanswered. The record further reflects that there have been related legal proceedings between persons or entities associated with the parties, including proceedings in the Superior Court of Quebec referenced by the Respondent. The Panel considers that the present administrative proceeding is not stayed by reason of such proceedings, and limits its findings to the matters required to be determined under the Policy. page 3 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. In summary, the Complainant contends: (i) the disputed domain name is confusingly similar to service marks in which the Complainant has rights, including SNS and SNS AUTOMATION, and that such rights arise from long-standing use in Canada in the automation and industrial products sector; (ii) the Respondent has no rights or legitimate interests in the disputed domain name, including because the Respondent is alleged to have obtained control of the disputed domain name through improper means, and because the disputed domain name is being used to redirect to a competitor site and in a manner alleged to facilitate the receipt and answering of business emails not intended for the Respondent; and (iii) the disputed domain name was registered and is being used in bad faith, including because the Respondent is alleged to have taken control of the disputed domain name through improper means with knowledge of the Complainant’s rights and prior use, and is using it to disrupt the Complainant’s business and to create confusion for commercial gain. The Complainant requests transfer of the disputed domain name. B. Respondent The Respondent contends that the Complainant has not satisfied the elements required under the Policy. In summary, the Respondent contends: (i) the Complainant has no registered trademark rights in “SNS Industrial”, “SNS Automation”, or similar, and the Respondent denies that the disputed domain name is confusingly similar to “SNS Industrial Group”; (ii) the Respondent has rights or legitimate interests, including because 7693320 Canada Inc, acquired by the Respondent, has been registered in Quebec as doing business under the name “SNS Automation” since 2010, was widely known by that name, and the disputed domain name was an asset of 7693320 Canada Inc at the time of the 2019 share purchase transaction; and (iii) the Respondent denies “hijacking” or “stealing” the disputed domain name. The Respondent states that it rebranded to “MTI Automation” in May 2023 and redirected the disputed domain name to its new website, and that customer and supplier emails are forwarded to ensure communications do not go unanswered. The Respondent requests denial of the Complaint. page 4 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 Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.0, section 1.3. On this record, the Panel is satisfied that the Complainant has established rights, for purposes of the Policy, in unregistered trademarks comprised of “SNS”. The Complaint includes evidence of sustained and consistent use by the Complainant and its predecessors of the designation “SNS” and “SNS Automation” in connection with the sale and distribution of industrial and automation products, including historical corporate and business records, marketing materials, and evidence of use of the designation as a source identifier in the ordinary course of trade. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. 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. The Complainant has made out a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Complainant alleges and supports, with documentary evidence, that the disputed domain name is being used (i) to redirect Internet users to the Respondent’s “www.mtiautomation.com” website in circumstances where the Respondent operates in the same industrial and automation sector, and (ii) to receive and respond to emails sent to “@snsautomation.com” addresses in a manner alleged to create confusion and to interfere with the Complainant’s business communications. The Respondent relies principally on (a) its historical use of “SNS Automation” as a business name since 2010, and (b) its position that the disputed domain name formed part of the assets of 7693320 Canada Inc. at the time of the 2019 share purchase transaction and was not reserved to the Complainant. The Panel accepts that the Respondent has presented evidence of historical use of the designation “SNS Automation” in the course of business. page 5 However, the issue under the Policy is not whether the Respondent previously used “SNS Automation” as a business name, but whether the Respondent has demonstrated a right or legitimate interest in controlling and using the disputed domain name, and whether the Respondent’s present use of the disputed domain name constitutes a bona fide offering of goods or services or another form of legitimate use within the meaning of paragraph 4(c) of the Policy. Several considerations are material on this record. First, the parties’ prior business relationship and the surrounding circumstances support that the Respondent’s historical use of “SNS Automation” arose in a context connected to the Complainant’s SNS business and its operations. The record further reflects that the Respondent’s continued use of the disputed domain name following the deterioration of that relationship was disputed and objected to by the Complainant. The evidence includes a contractual provision addressing a corporate name change after a defined period, as well as correspondence in which the Complainant asserted that the Respondent was required to cease using the “SNS Automation” trademark and to transfer the disputed domain name. Second, the Respondent’s own case is that it rebranded in May 2023 to “MTI Automation” and implemented a redirection from the disputed domain name to “www.mtiautomation.com”. In the circumstances of this case, the use of a domain name corresponding to “SNS Automation” to route Internet users to a differently branded business operating in the same sector has the effect of trading on residual goodwill associated with the “SNS Automation” designation and diverting Internet traffic intended for the Complainant or its SNS- related operations. Third, the record contains examples in which emails sent to “@snsautomation.com” addresses were answered by a Respondent employee in a manner indicating a willingness to quote, process, or engage with orders or inquiries. The Respondent states that email forwarding was configured to ensure that supplier and customer emails do not go unanswered. In the circumstances of this dispute, where the Complainant asserts ongoing use of the “SNS Automation” designation and where the Respondent had already rebranded to “MTI Automation”, the Panel considers that the forwarding and answering of emails intended for “@snsautomation.com” recipients supports a finding that the Respondent’s use of the disputed domain name does not constitute a bona fide offering of goods or services within the meaning of the Policy and is inconsistent with a legitimate interest. Taking the record as a whole, the Panel finds that the Respondent has not demonstrated rights or legitimate interests in the disputed domain name for the purposes of 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. The disputed domain name was initially registered/created in 1997. The Panel finds, however, that the present dispute does not concern the original registration/creation of the disputed domain name, but rather the Respondent’s subsequent assumption and exercise of registrant and administrative control in the context of the parties’ prior business relationship. Based on the record, including the Respondent’s acknowledged ability to redirect the disputed domain name to its own website, to configure email forwarding from addresses at the disputed domain name, and to retain renewal and administrative control following the breakdown of the parties’ relationship, the Panel finds, on the balance of probabilities, that the Respondent had improperly assumed effective control of the disputed domain name no later than 2023. In such circumstances, panels consider the date of that acquisition or assumption of control as the relevant date for assessing registration in bad faith under paragraph 4(a)(iii) of the Policy. page 6 Panels have recognized that in assessing bad faith registration, it is appropriate to consider the timing and circumstances of the respondent’s conduct, including subsequent use of the domain name and changes in such use. Where a domain name is used in a manner falling within paragraph 4(b)(iv), and where the respondent lacks rights or legitimate interests, such use may support an inference of bad faith registration. See WIPO Overview 3.0, section 3.2.1. The Panel notes the Respondent’s assertion that the disputed domain name formed part of the assets acquired in the course of the parties’ prior transaction. The Panel makes no determination as to the parties’ respective contractual rights. For the purposes of the Policy, however, the relevant inquiry is whether the disputed domain name has been registered and is being used in bad faith. On this record, the Panel finds that, by the time the Respondent had assumed and was exercising effective registrant control of the disputed domain name no later than 2023, including by implementing a redirection from the disputed domain name to the Respondent’s “www.mtiautomation.com” website, the Respondent was aware of the Complainant’s longstanding use of the designation “SNS”, and of the provision contained in the Agreement of 2019 which indicated “16. Corporate name change: The Corporation can change its name at any time within 2 years of signing this agreement, and, after that 2 year period, if so required by Tavane [associated with the Complainant] it shall change its name”. Even though the Agreement did not contain any express prohibition regarding the acquisition and/or registration of domain names, said clause can be understood as indicative that the Respondent had no claim to the “SNS” designation, including in domain names. Therefore, the Panel finds, on balance, that the Respondent’s acquisition of the disputed domain name was in bad faith. Moreover, in the circumstances of this case, the Respondent’s use of a domain name corresponding to “SNS Automation” to route Internet users to a differently branded competing business supports a finding that the Respondent intentionally attempted to attract Internet users by creating a likelihood of confusion as to source, sponsorship, affiliation, or endorsement within the meaning of paragraph 4(b)(iv) of the Policy. The Panel also finds that the Respondent’s use of the disputed domain name in connection with receiving and responding to emails sent to “@snsautomation.com” addresses, in circumstances where such emails were reasonably likely to be intended for the Complainant’s personnel or operations, further supports a finding of bad faith use. The examples in the record are consistent with conduct designed to capitalize on confusion and to disrupt the Complainant’s business communications in a competitive context. In the Panel’s assessment, the record supports that the Respondent’s continued use of the disputed domain name in the circumstances of this case is likely to cause confusion and to divert business communications. Accordingly, the Panel finds that the disputed domain name has been registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of 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 <snsautomation.com> be transferred to the Complainant. /Yuri Chumak/ Yuri Chumak Sole Panelist Date: January 27, 2026

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

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