Westmore · UDRP DecisionNalco-ecolab.com
The Panel ordered transfer of <nalco-ecolab.com> after finding all three UDRP elements established. The domain combines Complainant’s ECOLAB and NALCO marks in their entirety, separated by a hyphen. Respondent provided no evidence of rights or legitimate interests and did not answer the Complaint. For bad faith, the Panel relied on the marks’ prior and established reputation, the combination of both marks, passive holding, active MX records, incomplete WhoIs details, Respondent’s default, and the unlikelihood of any plausible good-faith use.
The timeline behind nalco-ecolab.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 nalco-ecolab.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a passive-holding transfer where the domain combined two established marks belonging to the same complainant. The Panel treated the exact combination of both marks, the lack of any response or plausible legitimate explanation, inactive web use, active MX records, and incomplete WhoIs information as a cumulative pattern supporting 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 Ecolab USA Inc. v. 陈洁环 (chen jie huan) Case No. D2025-5209 1. The Parties Complainant is Ecolab USA Inc., United States of America (“USA”), represented by Greenberg Traurig, LLP, the USA. Respondent is 陈洁环 (chen jie huan), China. 2. The Domain Name and Registrar The disputed domain name <nalco-ecolab.com> is registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on December 12, 2025. On December 15, 2025, the Center transmitted by email to the Registrar a request for registrar verification 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 (Not provided) and contact information in the Complaint. The Center sent an email communication to Complainant on December 16, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint in English on December 18, 2025. On December 16, 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 18, 2025, Complainant requested English to be the language of the proceeding. Respondent did not submit any comment on Complainant’s submission. 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent in Chinese and English of the Complaint, and the proceedings commenced on December 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 12, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on January 13, 2026. The Center appointed Yijun Tian as the sole panelist in this matter on January 23, 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 A. Complainant Complainant, Ecolab USA Inc., is a company incorporated in the USA. It is a global leader in water, hygiene, and infection prevention solutions. Complainant provides products and services to millions of customers across the food, energy, healthcare, life sciences, industrial, hospitality, and retail sectors. As of 2024, Complainant reported annual sales of approximately USD 16 billion. Complainant is publicly traded on the New York Stock Exchange under the ticker symbol ECL, with a market capitalization exceeding USD 75 billion as of March 2025. Nalco Water is a wholly owned subsidiary of Complainant. Founded in 1928 and acquired by Complainant in 2011, Nalco Water operates in more than 130 countries, serves over 70,000 customers, and employs more than 11,500 people worldwide. Complainant has exclusive rights in the ECOLAB, NALCO, and NALCO WATER marks (hereinafter the “ECOLAB and NALCO Marks”). Complainant is the owner of numerous trademark registrations worldwide, including Chinese trademark registrations for ECOLAB registered on August 10, 1987 (Chinese Trademark Registration No. 295939) and for NALCO registered on December 14, 2019 (Chinese Trademark Registration No. 31663327). All such registrations are valid and subsisting. Complainant also owns more than 1,300 trademark registrations worldwide for the ECOLAB mark and marks incorporating ECOLAB, as well as numerous registrations in over 110 jurisdictions for the NALCO and NALCO WATER marks. B. Respondent Respondent is 陈洁环 (chen jie huan), China. The disputed domain name <nalco-ecolab.com> was registered on November 19, 2021. The disputed domain name currently leads to an inactive webpage (passive holding). 5. Parties’ Contentions A. Complainant Complainant contends that the disputed domain name is confusingly similar to its ECOLAB and NALCO trademarks. The disputed domain name incorporates the marks in their entirety, with only a hyphen and the “.com” Top-Level Domain (“TLD”) added, which does not avoid confusing similarity. Complainant contends that Respondent has no rights or legitimate interests in the disputed domain name, is not authorised to use Complainant’s marks, and is not commonly known by the disputed domain name. Complainant contends that the disputed domain name was registered and is being used in bad faith. Complainant requests that the disputed domain name be transferred to it. page 3 B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings 6.1. Language of the Proceeding The language of the Registration Agreement for the disputed domain names 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. From the evidence presented on the record, no agreement appears to have been entered into between Complainant and Respondent to the effect that the language of the proceeding should be English. Complainant filed initially its Complaint in English, and has requested that English be the language of the proceeding for the following reasons: (a) Complainant is not able to communicate in Chinese. Requiring translation of the Complaint and supporting materials would impose unnecessary costs and cause delay. (b) The disputed domain name consists of Latin characters and incorporates Complainant’s NALCO and ECOLAB marks, which are English-language marks and have no Chinese script elements. (c) The disputed domain name incorporates well-known trademarks owned by Complainant, and Respondent can reasonably be presumed to have knowledge of English. 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). Considering the following aspects, the Panel has decided that the language of the proceeding shall be English: (a) the disputed domain name is registered in Latin characters, rather than Chinese script; (b) the generic Top-Level Domain (“gTLD”) of the disputed domain names is “.com”, so the disputed domain name seems to be prepared for users worldwide, particularly English speaking countries; (c) the Center has notified Respondent of the language of the proceeding in both Chinese and English, and (d) Respondent has indicated no objection to Complainant’s request that English be the language of the proceeding. 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: Three Elements 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. Based on the available record, the Panel finds 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. page 4 The Panel further finds that the disputed domain name incorporates the ECOLAB and NALCO marks in their entirety, separated only by a hyphen. The addition of a hyphen does not prevent a finding of confusing similarity. Accordingly, the disputed domain name is confusingly similar to Complainant’s trademarks for purposes of the Policy. See WIPO Overview 3.0, section 1.7. Based on the available record, 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 Respondent may demonstrate rights or legitimate interests in a disputed domain name. While 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 often impossible 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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied with the second element. WIPO Overview 3.0, section 2.1. Having reviewed the record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain names. Respondent has not rebutted Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain names, such as those enumerated in the Policy or otherwise. More specifically: (i) There is no evidence that Respondent is using the disputed domain name in connection with a bona fide offering of goods or services. The disputed domain name incorporates Complainant’s well-known ECOLAB and NALCO marks in their entirety, and Complainant has not licensed, authorised, or otherwise permitted Respondent to use its marks or to register any domain name incorporating them. (ii) There is no evidence that Respondent has been commonly known by the disputed domain name. The WHOIS information identifies the registrant as “陈洁环 (Chen Jie Huan),” which bears no resemblance to the disputed domain name. There is also no evidence that Respondent holds any trademark rights in ECOLAB, NALCO, or any similar designation. The disputed domain name was registered long after Complainant’s marks became well established and widely known. (iii) There is no evidence of legitimate noncommercial or fair use. The disputed domain name resolves to an inactive webpage. Passive holding of a domain name incorporating well-known marks does not confer rights or legitimate interests under the circumstances of this case, particularly where the domain name also has active MX records, suggesting potential email use. Based on the available record, 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. In the present case, the Panel finds that Respondent registered and is using the disputed domain name <nalco-ecolab.com> in bad faith. Complainant’s ECOLAB and NALCO trademarks long predate the registration of the disputed domain name and are widely used and registered internationally, including in page 5 China. The disputed domain name wholly incorporates both marks. In the absence of any explanation from Respondent, the Panel finds it more likely than not that Respondent had Complainant’s marks in mind at the time of registration. 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 faith. WIPO Overview 3.0, section 3.2.1. UDRP Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. Having reviewed the record, the Panel finds the non-use of the disputed domain name does not prevent a finding of bad faith in the circumstances of this proceeding. While panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put. WIPO Overview 3.0, section 3.3. Having reviewed the record, the Panel notes that Complainant’s ECOLAB and NALCO marks are distinctive and well established; Respondent has not filed a response or provided any evidence of actual or contemplated good-faith use; the disputed domain name combines two of Complainant’s well-known marks; the disputed domain name resolves to an inactive webpage; it has active MX records indicating configuration for email use; and the WhoIs details appear incomplete (no street name and details). In these circumstances, any plausible good-faith use of the disputed domain name is unlikely. Accordingly, the Panel finds that the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Therefore, the disputed domain name was registered and is being used in bad faith. Based on the available record, 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 disputed domain name <nalco-ecolab.com> be transferred to Complainant. /Yijun Tian/ Yijun Tian Sole Panelist Date: February 13, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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