Westmore · UDRP decision
WIPO · Case No. D2025-5151

Sanofisupport-sanofi.com

CancellationWIPO-indexed · informational, not legal advice

The Panel ordered cancellation of <sanofisupport-sanofi.com>. It found the domain confusingly similar to Sanofi’s SANOFI trademark because it reproduced the mark twice with the descriptive term “support.” The Respondent did not rebut Sanofi’s prima facie showing that it lacked rights or legitimate interests. Bad faith was established from the deliberate targeting of the well-known SANOFI mark, the domain’s specific composition, the absence of a plausible good-faith use, and passive holding of the inactive domain.

Outcome
Cancelled
At a glance
Provider
WIPO
Outcome
Cancellation
Decision date
2026-02-03
Panelist(s)
Zeybel, Dilek
Complainant
Sanofi
Respondent
Yogatraining 2025, sanofiind
Counsel
Selarl Marchais · associés
Disputed domain(s)
sanofisupport-sanofi.com
Domain history UDRP Intelligence

The timeline behind sanofisupport-sanofi.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 sanofisupport-sanofi.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 cancellation of sanofisupport-sanofi.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how a domain that repeats a well-known mark and adds an apparently official service term can satisfy all three UDRP elements even without active website use. The decisive combination was the mark’s reputation, the affiliation-signaling composition, the lack of authorization or rebuttal, and the absence of any plausible good-faith use.

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
Cancellation
Decision date
2026-02-03
Panel
Zeybel, Dilek
Full decision
10 min read · hosted by Westmore

ARBITRATION AN D MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. Yogatraining 2025, sanofiind Case No. D2025-5151 1. The Parties The Complainant is Sanof i, France, represented by Selarl Marchais & Associés, France. The Respondent is Yogatraining 2025, sanof iind, United States of America. 2. The Domain Name and Registrar The disputed domain name <sanofisupport-sanof i.com> is registered with Tucows Domains Inc. (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 10, 2025. On December 11, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On December 16, 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 (Contact Privacy Inc. Customer 0176727013) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on December 16, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on December 23, 2025. The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on December 24, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was January 13, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on January 14, 2026. page 2 The Center appointed Dilek Zeybel as the sole panelist in this matter on January 20, 2026. The Panel f inds 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 Sanof i, a French multinational pharmaceutical company headquartered in Paris, engaged globally in the research and development, manufacture, and marketing of pharmaceutical products, primarily for the prescription market, as well as over-the-counter medicines. It operates in more than 180 countries and reported consolidated net sales of EUR 43 billion in 2022 and EUR 37.7 billion in 2021. The Complainant’s trademark SANOFI is protected by numerous trademark registrations in multiple jurisdictions worldwide, including, but not limited to, the f ollowing: - French trademark SANOFI, no. 1482708, registered on August 11, 1988. - European Union trademark SANOFI, no. 000596023, registered on February 1, 1999. - International trademark SANOFI, no. 674936, registered on June 11, 1997. The Complainant also owns a portfolio of domain names incorporating its SANOFI trademark, including <sanofi.com>, <sanofi.eu>, <sanofi.fr>, <sanofi.us>, <sanofi.net>, <sanofi.ca>, <sanofi.biz>, <sanof i.inf o>, <sanof i.org>, <sanof i.mobi>, and <sanof i.tel>. The Respondent registered the disputed domain name on November 21, 2025. At the time of the Complaint and as of the date of this Decision, the disputed domain name resolves to an inactive webpage. There is no evidence of any relationship between the Complainant and the Respondent. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisf ied each of the elements required under the Policy f or a cancellation of the disputed domain name. In particular, the Complainant contends that the disputed domain name is conf usingly similar to its earlier registered SANOFI trademark and is liable to suggest an af f iliation with the Complainant, thereby taking unf air advantage of the reputation of its well -known marks. Further, the Complainant submits that the disputed domain name reproduces the SANOFI trademark twice and that the addition of the descriptive term “support” does not prevent a finding of conf using similarity, as the SANOFI trademark has no particular meaning and is theref ore highly distinctive. The Complainant also states that the Respondent is not authorized to register or use the Complainant’s marks, has no rights or legitimate interests in the disputed domain name, and is not related to the Complainant in any way. The Complainant further contends that the registration and holding of the disputed domain name adversely af f ect the Complainant and its well-known marks. Finally, the Complainant submits that the disputed domain name resolves to an inactive website and that such passive holding, in light of the distinctiveness and reputation of the SANOFI trademark, constitutes evidence of registration and use in bad f aith. page 3 The Complainant further relies on the Respondent’s use of a privacy protection service as an additional indicator of bad f aith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules directs the Panel as to the principles to be applied in determining the dispute: “A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable.” The Policy provides, at paragraph 4(a), that each of the three elements must be made f or a complaint to prevail: (i) the disputed 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 respect of the disputed domain name; (iii) the disputed domain name has been registered and is being used in bad f aith. Pursuant to paragraph 14(b) of the Rules, where a party does not comply with any provision of the Rules, the Panel may draw such inf erences as it considers appropriate. Considering the Parties’ submissions, the Policy, the Rules, the Supplemental Rules, and applicable law, the Panel’s f indings with respect to each of the above elements are set out below. A. Identical or Confusingly Similar It is well accepted that the f irst element f unctions 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 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 Panel f inds the mark is recognizable 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. Although the addition of the descriptive term “support” may bear on the assessment of the second and third elements, the Panel finds that the disputed domain name, which reproduces the Complainant’s SANOFI trademark twice, remains confusingly similar to that mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The Panel f inds the f irst 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. page 4 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 of ten 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 f orward 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 f ails to come f orward with such relevant evidence, the complainant is deemed to have satisf ied the second element. WIPO Overview 3.0, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima f acie 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 f orward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name, such as those enumerated in the Policy or otherwise. Furthermore, the Respondent registered the disputed domain name without the Complainant’s authorization and is neither a distributor, partner, nor a licensee of the Complainant. Finally, the Panel notes that the disputed domain name reproduces the Complainant’s SANOFI trademark in its entirety, repeated twice, together with the additional term “support”. This composition of the disputed domain name carries a risk of implied af f iliation, which cannot constitute f air use. Such use does not constitute a bona fide offering of goods or services, nor a legitimate noncommercial or f air use, and therefore supports the Panel’s conclusion that the Respondent lacks rights or legitimate interests in the disputed domain name. The Panel f inds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, f or 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 f aith. By registering the disputed domain name, which incorporates the Complainant’s well-kno wn SANOFI trademark together with the term “support”, and by passively holding the disputed domain name without any active use, the Respondent has f ailed to demonstrate any plausible good f aith use. In this case, such passive holding constitutes evidence of registration and use in bad f aith. 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 f aith. WIPO Overview 3.0, section 3.2.1. Panels have also found that the mere registration of a domain name conf usingly similar to a f amous or widely-known trademark by an unaffiliated entity may support an inf erence of bad f aith, particularly where combined with other circumstances. The Panel shares this view. WIPO Overview 3.0, section 3.1.4. Panels have f ound that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a f inding of bad f aith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. In the present case, the Panel notes that the disputed domain name does not resolve to an active website. However, under the doctrine of passive holding, the lack of active use does not, as such, prevent a f inding of bad f aith. In the circumstances of this case, including the reputation of the Complainant’s SANOFI trademark and the absence of any plausible good faith registration and use by the Respondent, the Panel f inds that the disputed domain name has been registered and is being used in bad f aith. page 5 Further, the Panel notes that the disputed domain name reproduces the Complainant’s SANOFI trademark twice, combined with the descriptive term “support” and separated by a hyphen. The Panel f inds it implausible that the Respondent arrived at such a specific composition by mere coincidence. Given the well- known status of the SANOFI trademark, the Panel concludes that the Respondent knew or should have known of the Complainant’s trademark rights and deliberately targeted the Complainant when registering the disputed domain name. The Panel f inds that the Complainant has established the third element of the Policy. 7. Decision For the f oregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <sanofisupport-sanof i.com> be cancelled. /Dilek Zeybel/ Dilek Zeybel Sole Panelist Date: February 3, 2026

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

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