Westmore · UDRP DecisionTodtvs.com
The Panel ordered transfer of <todtvs.com>. It found the domain confusingly similar to the Complainant’s registered TOD mark because it incorporated TOD in full, with the additional term “tvs” not preventing confusing similarity. The Respondent lacked rights or legitimate interests because there was no authorization or evidence that the Respondent was commonly known by the domain, and the domain had been used for a subscription streaming website displaying the TOD and BEIN SPORTS marks without a disclaimer. The Panel found bad-faith registration and use because the website’s branding and similar streaming services showed awareness of the Complainant’s mark and an intentional attempt to attract Internet users through confusion for possible commercial gain.
The timeline behind todtvs.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 todtvs.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates a strong targeting pattern where a domain combines a trademark with a term related to the trademark owner’s media business and then uses the domain for a website displaying both the complainant’s mark and an affiliated company’s mark. The Panel treated the domain composition, copied branding, similar services, absence of a disclaimer, and respondent default as mutually reinforcing evidence across rights or legitimate interests and bad faith.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION TOD for Advertising Production and Trade WLL v. Mohammed One, elite Case No. D2025-5025 1. The Parties The Complainant is TOD for Advertising Production and Trade WLL, Qatar, represented by Tmark Conseils, France. The Respondent is Mohammed One, elite, Bahrain. 2. The Domain Name and Registrar The disputed domain name <todtvs.com> (the “Domain Name”) is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 3, 2025. On December 4, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On December 4, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Contact Privacy Inc. Customer 0174545943) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 5, 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 the same day. 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 12, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 10, 2026. page 2 The Center appointed Piotr Nowaczyk as the sole panelist in this matter on January 21, 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 is a wholly owned subsidiary of the Qatari company beIN Media Group LLC, a media group specializing in sports and entertainment broadcasting. Launched in January 2022, the Complainant operates a subscription-based over-the-top (“OTT”) streaming platform providing exclusive live and on-demand sports content in multiple languages, together with premium entertainment and original productions, available throughout the MENA region and Türkiye. The Complainant is the owner of numerous TOD trademark registrations, including: - the International Trademark Registration for TOD (word mark) No. 1643638, registered on October 4, 2021; - the European Union Trade Mark Registration for TOD (word mark) No. 018568220, registered on January 27, 2022; and - the Qatari Trademark Registration for TOD ( figurative mark) No. 150875, registered on August 7, 2022. The Complainant is also the owner of the domain name <tod.tv>, which incorporates the TOD trademark and is used to host its OTT streaming platform. The Domain Name was registered on April 2, 2025. At the time the Complaint was filed, the Domain Name resolved to a website which displayed the TOD figurative mark and purported to offer online streaming services, in particular sports content, through a subscription-based platform (the “Website”). The Website also displayed the BEIN SPORTS trademark, which is owned by the Complainant’s parent company, beIN Media Group LLC. As of the date of this Decision, the Domain Name does not resolve to any active website. 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 Domain Name. First, the Complainant contends that the Domain Name is confusingly similar to the trademark in which the Complainant has rights. Second, the Complainant argues that the Respondent has neither rights nor legitimate interests in the Domain Name. Third, the Complainant submits that the Domain Name was registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings Paragraph 4(a) of the Policy places a burden on the Complainant to prove the presence of three separate elements, which can be summarized as follows: (i) the 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 the Domain Name; and (iii) the Domain Name has been registered and is being used in bad faith. The requested remedy may only be granted if the above criteria are met. At the outset, the Panel notes that the applicable standard of proof in UDRP cases is the “balance of probabilities” or “preponderance of the evidence”. See section 4.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”). A. Identical or Confusingly Similar Under the first element, the Complainant must establish that the Domain Name is identical or confusingly similar to the trademark in which the Complainant has rights. The Complainant holds valid registrations for the TOD trademark. The Domain Name incorporates the TOD trademark in its entirety. As numerous UDRP panels have held, incorporating a trademark in its entirety is sufficient to establish that a domain name is identical or confusingly similar to that trademark. See section 1.7 of the WIPO Overview 3.0. The addition of the term “tvs” in the Domain Name does not prevent a finding of confusing similarity between the Domain Name and the Complainant’s TOD trademark. Panels have consistently held that where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. See section 1.8 of the WIPO Overview 3.0. The Top-Level Domain (“TLD”) “.com” in the Domain Name is viewed as a standard registration requirement and as such is typically disregarded under the first element confusing similarity test. See section 1.11.1 of the WIPO Overview 3.0. Given the above, the Panel considers that the Domain Name is confusingly similar to the Complainant’s TOD trademark. Thus, the Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Under the second element, the Complainant must prove that the Respondent has no rights or legitimate interests in the Domain Name. A right or legitimate interest in the Domain Name may be established, in accordance with paragraph 4(c) of the Policy, if the Panel finds any of the following circumstances (in particular but without limitation): (i) that the Respondent has used or made preparations to use the Domain Name or a name corresponding to the Domain Name in connection with a bona fide offering of goods or services prior to the dispute; or (ii) that the Respondent is commonly known by the Domain Name, even if the Respondent has not acquired any trademark rights; or (iii) that the Respondent is making a legitimate noncommercial or fair use of the Domain Name without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark. page 4 In the present case, the Panel finds that the Complainant has established a prima facie case that the Respondent does not have any rights or legitimate interests in the Domain Name, and the burden of production shifts to the Respondent. See section 2.1 of the WIPO Overview 3.0. Although given the opportunity, the Respondent has not submitted any evidence indicating that any of the circumstances foreseen in paragraph 4(c) of the Policy or otherwise are present in this case. On the contrary, it results from the evidence on record that the Complainant’s TOD trademark registration predates the registration of the Domain Name. There is no evidence in the case record that the Complainant has licensed or otherwise permitted the Respondent to use the TOD trademark or to register the Domain Name incorporating this trademark. There is also no evidence to suggest that the Respondent has been commonly known by the Domain Name. Moreover, the Panel considers that the composition of the Domain Name, which incorporates the entirety of the Complainant’s mark with the term “tvs” possibly referring to “televisions”, carries a risk of implied affiliation with the Complainant. See section 2.5.1 of the WIPO Overview 3.0. Furthermore, it results from the evidence on record that the Respondent does not make use of the Domain Name in connection with a bona fide offering of goods or services, nor does it make a legitimate noncommercial or fair use of the Domain Name. On the contrary, at the time the Complaint was filed, the Domain Name resolved to a website displaying the TOD figurative mark and purporting to offer online streaming services mainly related to sports content through a subscription-based platform, with no disclaimer as to the lack of any relationship with the Complainant. The Website also displayed the BEIN SPORTS trademark, which is owned by the Complainant’s parent company, beIN Media Group LLC. The Panel finds that such use of the Domain Name in this case does not confer any rights or legitimate interests on the Respondent. In sum, the Respondent has failed to invoke any circumstances, which could demonstrate, pursuant to paragraph 4(c) of the Policy, any rights or legitimate interests in respect of the Domain Name. Thus, there is no evidence in the case file that refutes the Complainant’s prima facie case. The Panel concludes that the second element of the Policy has been established. C. Registered and Used in Bad Faith Under the third element, the Complainant must prove that the Domain Name has been registered and is being used in bad faith. Bad faith under the UDRP is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark. See section 3.1 of the WIPO Overview 3.0. Under paragraph 4(b) of the Policy, evidence of bad faith registration and use includes, without limitation: (i) circumstances indicating the domain name was registered or acquired primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the owner of a trademark or to a competitor of the trademark owner, for valuable consideration in excess of the documented out-of-pocket costs directly related to the domain name; or (ii) circumstances indicating that the domain name was registered in order to prevent the owner of a trademark from reflecting the mark in a corresponding domain name, provided it is a pattern of such conduct; or (iii) circumstances indicating that the domain name was registered primarily for the purpose of disrupting the business of a competitor; or page 5 (iv) circumstances indicating that the domain name has intentionally been used in an attempt to attract, for commercial gain, Internet users to a website or other online location, by creating a likelihood of confusion with a trademark as to the source, sponsorship, affiliation, or endorsement of the website or location or of a product or service on a website or location. As indicated above, the Complainant’s rights in the TOD trademark predate the registration of the Domain Name. This Panel finds that the Respondent was or should have been aware of the Complainant’s TOD trademark at the time of registration, given the Respondent’s use of the Domain Name to resolve to the Website prominently displaying the TOD figurative mark and offering purportedly similar services. Moreover, it has been proven to the Panel’s satisfaction that the TOD trademark is well known and unique to the Complainant, at least within the field of digital media and online streaming services, particularly in the sports sector. Thus, the Respondent could not ignore the reputation of the TOD trademark. In sum, the Respondent registered the Domain Name with the expectation of taking advantage of the reputation of the Complainant’s TOD trademark. Furthermore, at the time of filing of the Complaint, the Domain Name was used in bad faith to resolve to the Website offering purported online streaming services, in particular sports content, under the TOD figurative mark. The Panel finds, having regard to the totality of the circumstances of the case, that the Respondent has intentionally attempted to attract, for possible commercial gain, Internet users to the Website by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the Website. For the reasons discussed above, the Panel finds the third element of the Policy has been established. 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 Domain Name <todtvs.com> be transferred to the Complainant. /Piotr Nowaczyk/ Piotr Nowaczyk Sole Panelist Date: February 2, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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