Westmore · UDRP decision
WIPO · Case No. D2025-5133

Thesanofi.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <thesanofi.com> to Sanofi. It found the domain confusingly similar to the SANOFI mark because it incorporated the mark in full with only the English article “the”; found no rights or legitimate interests because Sanofi had made a prima facie case that was unrebutted and the VPN-service use was neither bona fide nor legitimate noncommercial or fair use; and found bad-faith registration and use because the Respondent was or should have been aware of the widely known, earlier SANOFI mark and used the domain to attract Internet users for commercial gain through confusion.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-12
Panelist(s)
Simone, Joseph
Complainant
Sanofi
Respondent
张彩凤 (Zhang Cai Feng), 张彩凤 (Zhang Cai Feng)
Counsel
Selarl Marchais · associés
Disputed domain(s)
thesanofi.com
Domain history UDRP Intelligence

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

The case is a straightforward example of a domain reproducing a well-established mark in full with only a common article added, followed by unrelated commercial use. It also illustrates how an unrebutted prima facie case under the second element, combined with commercial website use that the Panel viewed as exploiting trademark confusion, can support transfer under all three UDRP elements.

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
2026-02-12
Panel
Simone, Joseph
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. 张彩凤 (Zhang Cai Feng), 张彩凤 (Zhang Cai Feng) Case No. D2025-5133 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is 张彩凤 (Zhang Cai Feng), 张彩凤 (Zhang Cai Feng), China. 2. The Domain Name and Registrar The disputed domain name <thesanofi.com> is registered with Xin Net Technology Corporation (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on December 9, 2025. On December 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 12, 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 December 12, 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 in English on December 23, 2026. On December 12, 2025, the Center informed the Parties in Chinese and English, that the Language of the Registration Agreement for the disputed domain name is Chinese. On December 23, 2025, the Complainant requested English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint in Chinese and English, and the proceedings commenced on January 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was January 25, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 26, 2026. The Center appointed Joseph Simone as the sole panelist in this matter on January 29, 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 French multinational pharmaceutical company headquartered in Paris, France, and is one of the world’s largest pharmaceutical companies in terms of prescription sales. It employs more than 100,000 people in over 100 countries. The Complainant has an extensive global portfolio of trade marks incorporating the term “sanofi”, including the following: - International Trade Mark Registration for SANOFI No. 1092811 in Classes 1, 9, 10, 16, 38, 41, 42, 44, registered on August 11, 2011 designating Australia, Georgia, Japan, Republic of Korea, Cuba, Russian Federation, and Ukraine, amongst other jurisdictions; - International Trade Mark Registration for SANOFI No. 674936 in Classes 3 and 5, registered on June 11, 1997 designating Switzerland, Cuba, Romania, Russian Federation, and Ukraine, among other jurisdictions; and - China Trade Mark Registration for SANOFI No. 1386355 in Class 5, registered on April 21, 2000. The disputed domain name <thesanofi.com> was registered on July 18, 2025. The Complainant has submitted evidence indicating that at the time of filing the Complaint, the disputed domain name resolved to a page advertising a VPN service. 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 registered by the Respondent is identical or confusingly similar to the Complainant’s SANOFI marks and the mere addition of the term “the”, does not eliminate similarity where the SANOFI mark remains clearly recognizable. The Complainant asserts that it has not authorized the Respondent to use the SANOFI mark, and there is no evidence to suggest that the Respondent has used, or has undertaken any demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. The Complainant further contends that the Respondent has used the disputed domain name in a deliberate attempt to generate click-through revenue. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Preliminary Issue: Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the Registration Agreement. The Complaint was filed in English. The Complainant requested that the language of the proceeding be English for the following reasons: - The Complainant has used its SANOFI trademark and trade name for over 40 years and invested substantial financial resources over the years to advertise and promote the company and its SANOFI trademarks and domain names in countries all over the world, including China, and its international business is primarily operated in English; - The disputed domain name is comprised of the English article “the” and an exact reproduction of the Complainant’s SANOFI trademark; and - The disputed domain name is registered in Latin characters rather than Chinese. The Respondent did not make any specific submissions with respect to the language of the proceeding. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time and costs (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1). Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English. 6.2 Substantive Issues 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. The Panel acknowledges that the Complainant has established rights in the SANOFI trade marks. WIPO Overview 3.0, section 1.2.1. Disregarding the generic Top-Level Domain (“gTLD”) “.com”, the disputed domain name incorporates the term “sanofi” which is identical to the Complainant’s SANOFI trade mark. The term “the” does not prevent a finding of confusing similarity. WIPO Overview 3.0, sections 1.7, 1.8, and 1.11.1. page 4 The Panel therefore finds that the Complainant has satisfied the requirements of paragraph 4(a)(i) of the Policy in establishing its rights in the SANOFI trade marks and in showing that the disputed domain name is confusingly similar to its marks. 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. In this case, the Complainant asserts that it has not authorized the Respondent to use its trade marks and there is no evidence to suggest that the Respondent has used, or undertaken any demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Having reviewed the available records, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent did not file a response and has therefore failed to assert factors or put forth evidence to establish that it enjoys rights or other legitimate interests in the disputed domain name. According to the Complaint, the Respondent is not affiliated or connected with the Complainant in any manner, and the Complainant has not granted the Respondent any license or authorization to use or register a domain name incorporating the Complainant’s SANOFI trade marks. The Respondent did not respond to the Complaint and did not provide any information or factors that could potentially establish prior rights or legitimate interests in the disputed domain name. Furthermore, there is no evidence indicating that the Respondent has engaged in any legitimate noncommercial or bona fide use of the disputed domain name. The Complainant has presented evidence linking the disputed domain name to a website offering VPN services, which also does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. On the contrary, this demonstrates the Respondent’s intention to trade off the Complainant’s reputation. Accordingly, and based on the Panel’s findings below, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name pursuant to paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith The third and final element that a complainant must prove is that the respondent has registered and is using the disputed domain name in bad faith. Paragraph 4(b) of the Policy states that any of the following circumstances in particular, but without limitation, shall be considered as evidence of the registration and use of a domain name in bad faith: (i) circumstances indicating that the respondent registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant (the owner of the trade mark or service mark) or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or page 5 (ii) circumstances indicating that the respondent registered the domain name to prevent the owner of the trade mark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or (iii) circumstances indicating that the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) circumstances indicating that the respondent is using the domain name to intentionally attempt to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on its website or location. The examples of bad faith registration and use set forth in paragraph 4(b) of the Policy are not meant to be exhaustive of all circumstances in which bad faith may be found. Other circumstances may also 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. For reasons discussed under this and the preceding heading, the Panel believes that the Respondent’s conduct in this case constitutes bad faith registration and use of the disputed domain name. In the present case, the Panel observes that the disputed domain name <thesanofi.com>, is composed of the Complainant’s SANOFI trade mark together with the term “the”, a common English article. The Complainant’s SANOFI trade mark registrations predate the registration of the disputed domain name. The Panel finds that the Respondent was or should have been aware of the Complainant’s trade marks at the time of registration. This finding is supported by the composition of the disputed domain name, which has included in its entirety of the Complainant’s registered SANOFI trade marks. Prior to the registration date of the disputed domain name, the SANOFI mark was already widely known and directly associated with the Complainant’s activities. A simple online search for the term “sanofi” would have revealed the existence of the established SANOFI brand. WIPO Overview 3.0, section 3.2.2. The evidence shows that the disputed domain name resolved to a websites offering VPN services. This constitutes use in bad faith under paragraph 4(b)(iv) of the Policy. By using the disputed domain name, the Respondent intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the services offered on the parking page. The Respondent clearly sought to capitalize on the reputation of the Complainant’s mark to attract Internet users to visit its site for commercial gain. Accordingly, the Panel finds that the Respondent has registered and used the disputed domain name pursuant to paragraph 4(a)(iii) 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 <thesanofi.com> be transferred to the Complainant. /Joseph Simone/ Joseph Simone Sole Panelist Date: February 12, 2026

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

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