Westmore · UDRP DecisionKhadipaper.com
The Panel ordered transfer of <khadipaper.com>. It found the domain confusingly similar to the Complainant’s KHADI trademark because it incorporated the mark in its entirety with the additional term “paper.” The Respondent lacked rights or legitimate interests because the third-party PMEGP-KVIC certificate submitted through an informal email did not establish any relationship with the named Respondent, did not authorize use of the KHADI mark, concerned different manufacturing activities, and postdated the domain registration by about one year. Bad faith was established from the unauthorized registration of a domain incorporating the Complainant’s well-known mark and its use for a parked page containing sponsored links intended to attract users for commercial gain through confusion.
The timeline behind khadipaper.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 khadipaper.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that participation in a government-linked financing or registration program does not, without more, establish permission to use the program administrator’s trademark in a domain name. It also shows the importance of proving the chain of authority between the named registrant, an informal correspondent, and any third-party business whose documents are invoked. A post-registration certificate addressing activities unrelated to the domain’s additional term was insufficient, particularly where the actual domain use consisted of sponsored links.
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 Khadi & Village Industries Commission v. Isha Computer Case No. D2025-5164 1. The Parties The Complainant is Khadi & Village Industries Commission, India, represented by Fidus Law Chambers, India. The Respondent is Isha Computer, India. 2. The Domain Name and Registrar The disputed domain name <khadipaper.com> is registered with PDR Ltd. d/b/a PublicDomainRegistry.com (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 11, 2025. On December 11, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 12, 2026, 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 sent an email communication to the Complainant on December 12, 2026, providing the registrant and contact information disclosed by the Registrar. 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 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 5, 2026. The Response was filed with the Center on December 17, 2025. The Center commenced the panel appointment process on January 12, 2026. The Complainant filed an unsolicited supplemental filing on January 30, 2026. The Center appointed Harini Narayanswamy as the sole panellist in this matter on January 19, 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. page 2 4. Factual Background The Complainant is a statutory body created by the government of India under the Khadi and Village Commission Act of 1956. The Complainant is engaged in providing employment in rural areas and promotes and sells products under the KHADI trademark. The Complainant owns a large portfolio of trademark registrations for the KHADI mark in India and several other jurisdictions. The Complainant’s Indian trademark registrations include: KHADI word mark under class 16, with registration number 2851533 registration date November 27, 2014. KHADI word mark under class 24, with registration number 2851542 registration date November 27, 2014. KHADI word mark under class 25, with registration number 2851543 registration date November 27, 2014. The Respondent registered the disputed domain name on February 16, 2024. The disputed domain name is not used by the Respondent and is presently parked. At the time of filing the present Complaint, the disputed domain name resolved to a landing page which displayed pay-per-click links. 5. Parties’ Contentions A. Complainant The Complainant contends that its objective is to provide socio-economic benefit to rural industry in India. Its activities provide large scale employment to rural weaker sections and generate employment in about 248,000 villages in India. The Complainant contends that its programs are done in coordination with other agencies. It also implements the “Prime Minister’s Employment Generation Programs” (PMEGP) for upliftment of artisans, weavers and small- scale village and rural industries. The Complainant states that the KHADI trademark has acquired significant goodwill due to its extensive promotion at exhibitions and trade-fairs and its collaborations with leading brands. For instance, the collection of four design labels were displayed during the Lakme Fashion Week ,14th edition on August 23, 2018 under the KHADI mark. The Complainant has filed evidence of its promotions through print and electronic media and contends that it has a large following on social media platforms where it promotes the KHADI mark. The Complainant states that it certifies and authorizes retail sellers, organizations, societies and institutions as licensed users of the KHADI trademark. Notably, the Complainant states that an authorized user status of the KHADI trademark can be obtained by submitting an application to the Khadi Institutions Registration & Certification Sewa (KIRCS). The Complainant states that it has revitalized India’s handmade paper tradition and promotes 2,640 handmade paper units. The Complainant’s projects for handmade paper include the Kumarappa National Handmade Paper Institute in Jaipur. The Complainant states that it has revived a 1000-year-old ancient method of making “Monpa” handmade paper, which provides employment and stable source of income to local youth. The Complainant states that it has developed a plastic mixed handmade paper, which is recyclable and biodegradable under its innovative project called REPLAN (REduce PLAstic from Nature). The Complainant asserts that it has used the mark since 1956 and that “Khadi” is part of its trade name and corporate name. The Complainant contends that use of the KHADI mark by the Respondent is likely to mislead its patrons, consumers and the general public. The Complainant states that the disputed domain name is confusingly similar to the trademark. The Complainant argues that the Respondent lacks rights or legitimate interest in the disputed domain name and has registered and used the disputed domain name in bad faith. The Complainant states that it has page 3 satisfied each of the elements required under the Policy, and requests for transfer of the disputed domain name. B. Respondent The Respondent did not file a formal response in these proceedings. An informal email communication was sent to the Center on December 16, 2025, from the email address disclosed by the Registrar by a person identifying himself as Dr. Miteshkumar Salariya. The subject line of the email states: “Request for Immediate Unlock of Domain – No Domain Name Violation”. Dr. Miteshkumar Salariya states in the email that he is authorised to manage and take care of his client Brahmani Khadi Saranjam Utpdan Kendra’s digital and domain related matters. Dr. Miteshkumar Salariya goes on to state that his client has been certified under the Prime Minister Employment Guarantee Program (PMEGP) and is registered under the Khadi and Village Industries Commission (KVIC), and has submitted the client’s PMEGP-KVIC registration certificate as evidence. The “Certificate of Registration” is issued in favour of Brahmani Khadi Saranjam Utpadan Kendra, and it states that the unit has been financed under the Prime Minister’s Employment Generation Program for manufacture of “Amber Charkh a and Electric Pottery Wheel”. The certificate mentions that it is valid from April 1, 2025, to March 31, 2028. Based on the document submitted, it is alleged that there is no trademark infringement or misuse of the disputed domain name. It is further alleged in the email, that the disputed domain name is being used for legitimate business purposes such as uploading content related to Khadi products, business information and promotional activities in accordance with KVIC guidelines. Dr. Miteshkumar Salariya requests for unlocking of the disputed domain name, as it causes operational difficulties and is unable to upload or update content on the website at the disputed domain name. 6. Discussion and Findings Three elements need to be established by the Complainant, in order to obtain the remedy of transfer of the disputed domain name under paragraph 4(a) of the Policy: (i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent lacks rights or legitimate interests in the disputed domain name; and (iii) The disputed domain name was registered and is being used in bad faith by the Respondent. 6.1 Preliminary Issues: Unsolicited Supplemental Filing The Complainant made an unsolicited supplemental filing on January 30, 2026, after the appointment of the Panel. Having reviewed the Complainant’s supplemental filing, the Panel considers that most of the issues that it raises are in the form of a rebuttal to the arguments submitted within the Respondent’s email. The Panel is already able to assess those issues on the face of evidence. Accordingly, the Panel does not exercise its discretion to accept the Complainant’s supplemental filing. 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 of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0“), section 1.7. page 4 The Complainant has filed evidence of its trademark registrations for the KHADI mark. 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 entirety of the mark 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. Although the addition of the word “paper” may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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. (i) Before any notice to the respondent of the dispute, the use by the respondent of demonstrable preparations to use the domain name in connection with a bona fide offering of goods and services or; (ii) The respondent, as an individual, business or other organization has been commonly known by the domain name, even if the respondent has acquired no trade mark or service mark rights or; (iii) The respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. 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 Panel finds from the material on record that the Respondent is not commonly known by a name or a business name that corresponds to the disputed domain name. The email communication from Dr. Miteshkumar Salariya does not mention his relationship with the named Respondent, Isha Computers. Furthermore, the communication has not disclosed the Respondent’s relationship with “Brahmani Khadi Saranjam Utpdan Kendra”. The document filed by Dr. Miteshkumar Salariya titled “Certificate of Registration”, is dated February 14, 2025, and is issued by The Khadi & Village Industries Commission, (KVIC) Gujarat Ministry of Micro, Small & Medium Enterprises (Govt. Of India) Ahmedabad. The certificate is issued in the name of “Brahmani Khadi Utpadan Kendra”, located in Gandhinagar. Its proprietor’s name is mentioned as Kinjal Bhavesh Salriya. The certificate mentions that the unit is financed under the PMEGP for setting up a manufacturing unit for “Amber Charkha and Electric Pottery Wheel” (it does not mention “khadi” nor “paper”) and provides details of production capacity, service capacity and number of people employed. There is however no mention regarding the use of the KHADI trademark in the document as licensed user or otherwise. Having reviewed the available record, the Panel finds that the submissions claiming rights allegedly on behalf of the Respondent are without merit, for the following reasons: First , that the certificate of registration is issued in the name of “Brahmani Khadi Saranjam Utpadan Kendra”, and not the name of the Respondent. Second, the PMEGP-KVIC certificate is not a license or permission to use the Complainant’s trademark. Third, the document relates to a manufacturing unit financed under the PMEGP for “Amber Charkha and page 5 Electric Pottery Wheel” and does not mention paper manufacture. No explanation has been given for use of the word “paper” with the KHADI mark in the disputed domain name. Fourth, the PMEGP-KVIC certificate is dated February 14, 2025, which is about one year after registration of the disputed domain name. This clearly indicates that the certificate of registration, which is filed as evidence, did not exist at the time the disputed domain name was registered. The document filed does not show that the Respondent is a valid authorized licensee of the Complainant’s mark for the reasons discussed. Therefore, the question of the Respondent or any of its clients having any rights or legitimate interests does not arise. The Panel finds the Respondent does not have authorization or license to use the mark, and the use of the Complainant’s well-known mark in the disputed domain name creates an implied affiliation with the mark and is likely to mislead Internet users as to source, origin or affiliation of the disputed domain name. Furthermore, the disputed domain name is parked and is not being used by the Respondent. It has been consistently found in previous cases that a disputed domain name registration that unauthorizedly uses a well-known mark, and is used to host competing links, is not bona fide or legitimate use of a domain name. For the reasons discussed, the Complainant has made a prima facie case that the Respondent lacks rights or legitimate interests. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The third element under paragraph 4(a)(iii) of the Policy requires the Complainant to establish the disputed domain name has been registered and used in bad faith by the Respondent. The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy specifies circumstances, in particular, but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. 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 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. (i) Circumstances indicate that the respondent has registered or acquired the domain name primarily for purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of respondent’s documented out-of-pocket costs directly related to the domain name; or (ii) The respondent has registered the domain name in order to prevent the owner of the trademark 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) The respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) By using the disputed domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the respondent’s 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 the respondent’s website or location. The Complainant has argued that the registration and use of the disputed domain name show the Respondent’s intent to benefit from the reputation associated with its mark. The Panel acknowledges that it has been consistently found by UDRP panels that registration of a confusingly similar domain name to a widely known or reputed trademark by someone who is not affiliated with the owner of the trademark and has not shown good reason for registration of the disputed domain name or its legitimate use, can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4. page 6 The Panel further notes that the communication purportedly on behalf of the Respondent is ambiguous and misleading and it fails to disclose the relationship with the named Respondent. It has been submitted that the disputed domain name is being used in connection with a legitimate business and used for uploading content related to Khadi products. However, on the contrary, the evidence on record does not support this contention, as the disputed domain name is not being used, but it is parked, and the landing page has sponsored links. The Panel also finds the document filed as evidence, the PMEGP- KVIC certificate, was acquired a year after the disputed domain name was registered. In any event, the document itself does not show any legitimate authorization to use the Complainant’s mark, all of which are clearly misleading submissions without any merit. At the time of filing the Complaint, the disputed domain name resolved to a website with sponsored links. The Panel finds that by using the disputed domain name, the Respondent intentionally attempted to attract, for commercial gain, Internet users to its website, by creating a likelihood of confusion with the Complainant’s mark. The Panel finds for the reasons discussed, that the Complainant has established the third element of the Policy, that the disputed domain name has been registered in bad faith and is being used in bad faith. The Complainant has satisfied all three elements required under the Policy for transfer of the disputed domain name. 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 <khadipaper.com> be transferred to the Complainant. /Harini Narayanswamy/ Harini Narayanswamy Sole Panelist Date: February 3, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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