Westmore · UDRP DecisionAxainternationalstudents.com
The Panel ordered transfer of <axainternationalstudents.com> to AXA SA. It found the domain confusingly similar to the AXA trademark because it incorporated AXA in full and the addition of “international students” did not prevent confusing similarity. The Respondent did not rebut the Complainant’s prima facie showing of no rights or legitimate interests, and the domain carried a risk of implied affiliation. Bad faith was established based on the domain’s composition, the Complainant’s fame, the misleading reference to services for international students, the absence of evidence of contemplated good-faith use, and passive holding.
The timeline behind axainternationalstudents.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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The decision illustrates how a famous or widely recognized mark combined with descriptive terms closely associated with the complainant’s claimed customer group can support findings across all three UDRP elements, even where the domain has not been actively developed. The outcome rested on the mark’s complete incorporation, implied-affiliation risk, the absence of rebuttal or evidence of legitimate plans, and the circumstances supporting passive-holding 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 AXA SA v. Elena Fernandez, Byte Insurtech Case No. D2026-0551 1. The Parties The Complainant is AXA SA, France, represented by Plasseraud IP Avocats, France. The Respondent is Elena Fernandez, Byte Insurtech, Spain. 2. The Domain Name and Registrar The disputed domain name <axainternationalstudents.com> (the “Domain Name”) is registered with IONOS SE (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 10, 2026. On February 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On February 11, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (No information) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 11, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amendment to the Complaint on February 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 February 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 10, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 23, 2026. page 2 The Center appointed Mathias Lilleengen as the sole panelist in this matter on March 30, 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 to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is a global company in insurance, saving and asset management, serving 94 million customers, and employing 154,000 people worldwide. The trade name AXA was introduced in 1985. AXA is listed on the Paris Stock Exchange and the New York Stock Exchange. The Complainant owns trademark registrations for AXA, such as International Trademark No. 490030, registered on December 5, 1984. The Complainant has registered different domain names, such as <axa.com> registered on October 23, 1995 and <axa.fr> registered on May 20, 1996. The Domain Name was registered on June 10, 2024. At the time of the Complaint, and at the time of drafting the decision, the Domain Name resolved to the webpage of the Registrar. 5. Parties’ Contentions A. Complainant The Complainant provides evidence of trademark registrations and argues that the Domain Name reproduces the Complainant’s trademark in its entirety. The added terms “international students” directly refer to the Complainant’s offering of insurance products specifically designed for students studying abroad. The Complainant argues that the Respondent has no rights or legitimate interests in respect of the Domain Name. The Complainant has not permitted the Respondent to use its trademark. The Respondent is not commonly known by the Domain Name. The Domain Name has resolved to an inaccessible webpage. Such passive holding of a domain name does not constitute legitimate noncommercial use of it. The Complainant argues that its trademark is widely known, and the Respondent was aware of the Complainant’s trademark at the time of registration of the Domain Name. The Respondent has not used the Domian Name, but passive holding may be considered, in certain circumstances, as used in bad faith. The Respondent has registered the Domain Name to take undue advantage of the Complainant’s reputation. B. Respondent The Respondent did not reply to the Complainant’s contentions, but sent an informal email on February 12, 2026, requesting information on “next procedural steps and deadlines for submitting my Response as Respondent”. The Center acknowledged receipt of the Respondent’s email indicating the due date for a Response, referring to its website as to further information on the UDRP. page 3 6. Discussion and Findings A. Identical or Confusingly Similar The test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the Domain Name. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0“), section 1.7. The Complainant has established that it has rights in the trademark AXA. The Domain Name incorporates the trademark with the addition of “international students”. The addition does not prevent a finding of confusing similarity between the Domain Name and the trademark. For the purpose of assessing the confusing similarity under paragraph 4(a)(i) of the Policy, the Panel may ignore the generic Top-Level- Domain (“gTLD”); see WIPO Overview 3.1, section 1.11.1. 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 the 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. If the respondent fails to come forward with relevant evidence, the complainant is deemed to have satisfied the second element. See WIPO Overview 3.1, section 2.1. Having reviewed the record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interest in the Domain Name. The Respondent has not rebutted the Complainant’s showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the Domain Name. Based on the record, the Respondent is not affiliated or related to the Complainant. There is no evidence that the Respondent has registered the Domain Name as a trademark or acquired trademark rights. There is no evidence of the Respondent’s use of, or demonstrable preparations to use, the Domain Name in connection with a bona fide offering of goods or services. Furthermore, the Panel finds that the nature of the Domain Name carries a risk of implied affiliation, particularly noting Complainant’s claim of offering insurance products specifically designed for students studying abroad. WIPO Overview 3.1, section 2.5.1. 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. Due to the composition of the Domain Name and the fame of the Complainant, it is probable that the Respondent was aware of the Complainant when the Respondent registered the Domain Name. To the extent that the parking page may amount to a non-active use by the Respondent, the Panel notes that the non-use of the Domain Name does not prevent a finding of bad faith under the doctrine of passive holding. The Complainant is known in the insurance industry, the Respondent has not provided any evidence of actual or contemplated good-faith use, and the nature of the Domain Name is misleading noting the Complainant provides services to international students. page 4 For the reasons set out above, the Panel concludes that the Domain Name was registered and is being used in bad faith, within the meaning of paragraph 4(a)(iii) of the Policy. 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 the Domain Name <axainternationalstudents.com> transferred to the Complainant. /Mathias Lilleengen/ Mathias Lilleengen Sole Panelist Date: April 13, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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