Westmore · UDRP DecisionSanofica.com
The Panel ordered cancellation of <sanofica.com>. It found the domain confusingly similar to Sanofi’s SANOFI marks because it reproduced SANOFI in full and merely added “ca”. The Panel also found that Sanofi had established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. Although the domain did not resolve to an active page, the Panel applied the passive-holding doctrine and found bad-faith registration and use based on the well-known character of the marks, the nature of the domain, the absence of a response or evidence of good-faith use, and the lack of any conceivable good-faith use.
The timeline behind sanofica.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 sanofica.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates application of the passive-holding doctrine to an inactive domain that reproduces a well-known mark in full with a short suffix. The outcome did not depend on an active website: the Panel considered the mark’s status, the domain’s composition, the Respondent’s default, and the absence of any evidence of plausible good-faith use.
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 Sanofi v. Adrian Tham Case No. D2026-0312 1. The Parties The Complainant is Sanofi, France, represented by Marchais & Associés, France. The Respondent is Adrian Tham, Malaysia. 2. The Domain Name and Registrar The disputed domain name <sanofica.com> is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 26, 2026. On the same date, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name and 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 Respondent’s name (Redacted for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf) and contact information on the Complaint. The Center sent an email communication to the Complainant on January 28, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. 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 February 9, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 1, 2026. The Respondent did not submit any response. Accordingly, the Center registered the Respondent’s default on March 4, 2026. page 2 The Center appointed Gilberto Martins de Almeida as the sole panelist in this matter on March 9, 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 Sanofi, a French multinational pharmaceutical company. As for its relevant trademarks, SANOFI mark has been registered since 1988, under the number 1482708 in France. It has also been registered as SANOFI in the European Union, under the number 004182325, since 2006. As for the International Trademark, the Complainant owns the following registrations concerning SANOFI trademark: no. 1091805 (2011), no. 1092811 (2011), no. 1094854 (2011), no. 674936 (1997), no. 591490 (1992). As for domain names, the Complainant has operated under the following domain names: - <sanofi.com> registered on October 13, 1995; - <sanofi.eu> registered on March 12, 2006; - <sanofi.fr> registered on October 10, 2006; - <sanofi.us> registered on May 16, 2002; - <sanofi.net> registered on May 16, 2003; - <sanofi.ca> registered on January 5, 2004; - <sanofi.biz> registered on November 7, 2001; - <sanofi.info> registered on August 24, 2001; - <sanofi.org> registered on July 12, 2001; - <sanofi.mobi> registered on June 20, 2006; - <sanofi.tel> registered on March 17, 2011 The Respondent registered on December 30, 2025, the disputed domain name <sanofica.com>. The disputed domain name does not resolve to any active page. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a cancellation of the disputed domain name. In particular, the Complainant submits that it owns numerous prior trademark registrations for SANOFI in multiple jurisdictions, including France, European Union, the United States of America, the United Kingdom, as well as several prior domain names incorporating the term “sanofi”, all of which precede the registration of the disputed domain name <sanofica.com>. Notably, the Complainant contends that the Respondent is attempting to free ride on its registered trademark by using a domain name almost identical to its own. According to the Complainant, the disputed domain name reproduces the SANOFI mark in its entirety and merely adds the suffix “ca”, which does not prevent confusion and may even suggest a Canada-related website connected to the Complainant. Since SANOFI is a well-regarded and respected corporation, the Respondent could not have been unaware of the Complainant’s rights when registering the disputed domain name. B. Respondent The Respondent did not reply to Complainant’s allegations. page 3 6. Discussion and Findings 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 Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, 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 3.1, section 1.7. The disputed domain name <sanofica.com> incorporates the SANOFI trademark completely. The addition of the letters “ca” doesn’t render the trademark unrecognizable, nor does it prevent finding confusing similarity. SANOFI remains recognizable within the disputed domain name. Therefore, the Panel finds the disputed domain name confusingly similar to the Complainant’s SANOFI 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 that 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 disputed 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 3.1, section 2.1. Having reviewed the available records, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted to the Complainant’s prima facie evidences and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. 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. The disputed domain name is passively held by the Respondent. As discussed in Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003, the relevant issue is whether under the circumstances of a case, it can be held that a respondent is acting in bad faith. page 4 In the present matter, the record shows that the Complainant’s trademarks are well known and the Respondent has failed to submit a response to the Complaint or provide any evidence of good faith use. Considering the above and the nature of the disputed domain name, the Panel finds there is no conceivable good faith use to which the disputed domain name could be put by the Respondent. Therefore, under section 3.3 of the WIPO Overview 3.1, the non-use of the disputed domain name does not prevent a finding of bad faith under the doctrine of passive holding. The Panel finds that the Complainant has satisfactorily configured the third element of the Policy. 7. Decision Given the foregoing reasons, and in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <sanofica.com> be cancelled. /Gilberto Martins de Almeida/ Gilberto Martins de Almeida Sole Panelist Date: March 23, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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