Westmore · UDRP decision
WIPO · Case No. D2026-0080

Swisslifeasset-managers.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <swisslifeasset-managers.com>. It found the domain reproduced the SWISS LIFE ASSET MANAGERS mark, that the Respondent had not rebutted the Complainants’ prima facie showing of no rights or legitimate interests, and that registration with knowledge of the Complainants’ earlier marks followed by passive holding constituted bad-faith registration and use in the circumstances.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-13
Panelist(s)
Wallberg, Knud
Complainant
Swiss Life AG Swiss Life Intellectual Property Management AG
Respondent
Jean Mionnet
Counsel
FMP Fuhrer Marbach & Partners
Disputed domain(s)
swisslifeasset-managers.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind swisslifeasset-managers.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

Reconstructing the record for swisslifeasset-managers.com…
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of swisslifeasset-managers.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that an inactive domain can satisfy the UDRP bad-faith requirement where it reproduces a pre-existing mark, clearly targets the trademark owner, and the registrant provides no credible explanation. It also shows that allegations about related fraudulent domains may form part of a complaint without being necessary to the Panel’s ultimate reasoning when passive-holding factors independently establish bad faith.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-13
Panel
Wallberg, Knud
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Swiss Life AG, Swiss Life Intellectual Property Management AG v. Jean Mionnet Case No. D2026-0080 1. The Parties The Complainants are Swiss Life AG and Swiss Life Intellectual Property Management AG, Switzerland, represented by FMP Fuhrer Marbach & Partners, Switzerland. The Respondent is Jean Mionnet, France. 2. The Domain Name and Registrar The disputed domain name <swisslifeasset-managers.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 9, 2026. On January 9, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On January 9, 2026, 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 (User #cc40750b Privacy, See PrivacyGuardian.org) and contact information in the Complaint. The Center sent an email communication to the Complainants on January 9, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainants to submit an amendment to the Complaint. The Complainants filed an amendment to the Complaint on January 12, 2026. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on January 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was February 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on February 2, 2026. page 2 The Center appointed Knud Wallberg as the sole panelist in this matter on February 4, 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 Complainants Swiss Life AG and Swiss Life Intellectual Property Management AG are both corporations incorporated under the laws of Switzerland. Swiss Life Intellectual Property Management AG is a subsidiary of Swiss Life AG and is responsible for managing all intellectual property owned within the Swiss Life group. The Complainants hold various trademark registrations of SWISS LIFE and of SWISS LIFE ASSET MANAGERS including Swiss Trademark Registration No. 491528 of SWISS LIFE registered on November 15, 2001, for goods and services in classes 9, 16, 35, 36, 38, 41, and 42, European Union Trademark Registration No. 003438413 of SWISS LIFE registered on October 20, 2006 for goods and services in classes 9, 16, 35, 36, 38, 41, 42, and 44, and Swiss Trademark Registration No. 636952 of SWISS LIFE ASSET MANAGERS registered on November 27, 2012, for services in class 36. The Complainants also hold several domain name registrations that features the SWISS LIFE trademark, such as <swisslife.ch> and <swisslife.com>. The disputed domain name was registered on December 22, 2025. The disputed domain name is not being used for an active website. 5. Parties’ Contentions A. Complainants The Complainants contend that they have satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainants contend that the Respondent infringes the Complainants’ trademark rights as it contains the SWISS LIFE trademark and is identical to the SWISS LIFE ASSET MANAGERS trademark. Furthermore, the Complainants contend that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainants did not give any permission to the Respondent to register and use of the disputed domain name, and the Respondent cannot provide any proper justification as to why it would be entitled to register the disputed domain name. The disputed domain name was thus registered in bad faith. The Complainants finally contend that the disputed domain name is used in bad faith. Although there is currently no website that can be accessed under the disputed domain name, the Respondent may use the disputed domain name in connection with fraudulent activities. In particular, the Complainants assert that the disputed domain name is almost identical to another domain name <swisslifeassetmanagers.com> which is under a separate proceeding filed by the Complainants (Swiss Life AG, Swiss Life Intellectual Property Management AG v. Jean Meyrin, WIPO Case No. D2026-0078). The domain name <swisslifeassetmanagers.com> has been used for sending fraudulent emails. Considering the disputed domain name and the domain name <swisslifeassetmanagers.com> were registered with the same Registrar using the same privacy service and were registered within a short period of time, which suggests there is connection between these two domain names. In fact, the disputed domain name was registered on the same day that the domain name <swisslifeassetmanagers.com> was added to the ACPR and AMF blacklists following the Complainants’ complaint filed on December 18, 2025. The Complainants have reasons to believe that the disputed domain name may also be used with fraudulent activities. page 3 B. Respondent The Respondent did not reply to the Complainants’ contentions. 6. Discussion and Findings According to paragraph 15(a) of the Rules the Panel shall decide the Complaint in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. Paragraph 4(a) of the Policy directs that a complainant must prove each of the following: (i) that the domain name registered by the respondent is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and (ii) that the respondent has no rights or legitimate interests in respect of the domain name; and (iii) that the domain name has been registered and is being used in bad faith. Paragraph 4(a) of the Policy states that the burden of proving that all these elements are present lies with the Complainants. At the same time, in accordance with paragraph 14(b) of the Rules, if a party, in the absence of exceptional circumstances, does not comply with any provision of, or requirement under, the Rules, or any request from the Panel, the Panel shall draw such inferences therefrom as it considers appropriate. 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 Complainants’ 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 Complainants have 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 SWISS LIFE ASSET MANAGERS is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical or confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. 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. 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. Having reviewed the available record, the Panel finds the Complainants have established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainants’ prima facie showing and has not come forward with any relevant evidence page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. In the absence of any explanation by the Respondent, the Panel finds that the inclusion of the Complainants’ trademarks in the disputed domain name signals an intention on the part of the Respondent to confuse users seeking or expecting information on or from the Complainants. 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 notes that the disputed domain name was registered years after the Complainants’ registration of its SWISS LIFE and SWISS LIFE ASSET MANAGERS trademarks and that the Respondent has not offered any explanation for having registered the disputed domain name. Given the circumstances of the case, it is inconceivable to the Panel in the current circumstances that the Respondent registered the disputed domain name without prior knowledge of the Complainants and the Complainants’ marks. The Panel therefore finds that the disputed domain name was registered in bad faith. 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. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness or reputation of the Complainants’ trademarks, and the composition of the disputed domain name clearly targeting the Complainants, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. The Panel finds that the Complainants have established the third element 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 <swisslifeasset-managers.com> be transferred to the Complainants. /Knud Wallberg/ Knud Wallberg Sole Panelist Date: February 13, 2026

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

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