Westmore · UDRP DecisionAtr-aircraft.net
The Panel ordered transfer of <atr-aircraft.net>. It found the domain confusingly similar to the Complainant’s ATR mark, that the Respondent had no rights or legitimate interests, and that the domain was registered and used in bad faith. The domain combined ATR with “aircraft,” closely matched the Complainant’s existing domain names, and resolved to a parking page containing links associated with the Complainant’s mark and activities.
The timeline behind atr-aircraft.net
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 atr-aircraft.net — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a recognizable mark with a term describing the trademark owner’s core business can support findings across all three UDRP elements, particularly where the resulting domain closely mirrors the complainant’s existing domains and is used for related parking-page 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 Avions de Transport Régional GIE v. Anthony moore Case No. D2026-0598 1. The Parties The Complainant is Avions de Transport Régional GIE, France, represented by DLA Piper Luxembourg, Luxembourg. The Respondent is Anthony moore, United States of America (“US”). 2. The Domain Name and Registrar The disputed domain name <atr-aircraft.net> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 12, 2026. On February 12, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 12, 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 (Unknown registrant) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 13, 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 amended Complaint on February 18, 2026. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on February 19, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 12, 2026. page 2 The Center appointed Angelica Lodigiani as the sole panelist in this matter on March 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. 4. Factual Background The Complainant was established in 1981 as a partnership between the French aviation conglomerate Airbus Group and the Italian multinational aerospace company Leonardo S.p.A. It is one of the world’s leading manufacturers of regional aircraft, with its ATR-42 and ATR-72 models being the bestselling in the market segment of aircraft with less than 90 seats. The Complainant has offices in various countries worldwide, including in France, the US, Singapore, China, and Japan, and customer offices in India, Brazil, and South Africa. Since its establishment, the Complainant has sold more than 1,700 aircraft to over 200 airlines in more than 100 countries. The Complainant is the owner of a large portfolio of ATR word and figurative marks, registered in various jurisdictions worldwide, including in the US. Among these, the Complainant is the owner of the following trademarks: - ATR (word), US trademark registration No. 2440292, filed on September 21, 1999, and registered on April 3, 2001, for goods in class 12; International registration No. 1282453 registered on October 2, 2015, covering goods and services in classes 12, 16, and 39, designating numerous countries, including the US; - ATR (word), European trademark registration No. 004956959 filed on March 14, 2006, and registered on May 21, 2008, for goods and services in classes 12, 16, and 39. The Complainant is also the owner of the domain names <atr-aircraft.com> and <atr-aircraft.fr>, which were both registered on April 8, 2015. On February 18, 2026, the Complainant sent cease-and-desist email to the Respondent, via the email provided by the Respondent to the Registrar, requesting that the transfer of the disputed domain name. However, no reply was received. The disputed domain name was registered on January 29, 2026, and resolves to a page featuring what appears to be pay-per-click links. According to the information provided by the Registrar of the disputed domain name, the Respondent is an individual living in the US. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends that the disputed domain name is confusingly similar to its ATR mark as the term “atr” is fully recognizable in the disputed domain name and the addition of the descriptive word “aircraft” cannot prevent a finding of confusing similarity. page 3 The Complainant also contends that the Respondent lacks rights or legitimate interests in the disputed domain name. The mere possession of the disputed domain name does not generate any rights or legitimate interests in favor of the Respondent. The Complainant has not granted the Respondent any license or authorization over the ATR mark that would allow the registration of the disputed domain name. The Respondent is not an authorized distributor of the Complainant’s products and services, nor has it ever had a commercial relationship with the Complainant. Furthermore, it does not appear that the Respondent is commonly known by the disputed domain name. The disputed domain name does not host an active website for the sale of goods or services but only a page with different links, some of which refer to the Complainant and its ATR mark. The inclusion of the term “aircraft”, relating to goods and services provided by the Complainant, in the disputed domain name, creates a risk of implied affiliation as the disputed domain name effectively suggests sponsorship or endorsement by the Complainant. It is unlikely that the Respondent would have adopted the Complainant’s mark if not for the purpose of creating the impression that the disputed domain name is associated with, or originates from, the Complainant. The Complainant states that the Respondent has registered and has been using the disputed domain name in bad faith. The ATR mark is well-known in the aviation industry, and the Complainant enjoys extensive reputation in the market. The ATR mark has a marked presence in the most important social networks and a simple search on the Internet using the keyword “atr” shows that all the results of the first page of the search refer to the Complainant. Such a reputation is also reflected in the company’s figures. In 2023, the Complainant delivered 44 percent more aircraft than in the previous year and sold 53 percent more aircraft. During this period, the Complainant opened 160 routes and generated more than USD 400 million from customer support and services, representing a 15 percent increase with respect to 2022. Given the Complainant’s extensive reputation and that of its ATR mark, not to mention the fact that the disputed domain name includes the term “aircraft”, which refers to the Complainant’s activity, it can be easily inferred that the Respondent was aware of the Complainant’s trademark rights at the time of the registration of the disputed domain name. At the time of the filing of the Complaint, the disputed domain name did not resolve to a website through which the Respondent was offering goods and/or services on a bona fide basis. If the relevant conditions are met, the non-use of the disputed domain name amounts to bad faith use under the doctrine of passive holding. The Complainant maintains that given the reputation of its mark, any good-faith use of the disputed domain name is implausible. The disputed domain name is inherently misleading and was registered by the Respondent for the sole purpose of generating confusion among Internet users searching for the Complainant’s goods and services, and for illegitimately occupying the disputed domain name to obtain an unlawful economic benefit. This conclusion is reinforced by the fact that the landing page hosted by the disputed domain name displays a series of links associated with the Complainant and its ATR marks. These links are misleading and suggest an economic link between the Complainant and the Respondent. B. Respondent The Respondent did not reply to the Complainant’s contentions. 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. page 4 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 Panel finds the mark is recognizable within the disputed domain name. Although the addition of other term here, “aircraft”, may bear on assessment of the second and third elements, t he 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 3.1, section 1.8. Accordingly, 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 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 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 record, 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 the Complainant’s prima facie showing 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. At the time of the filing of the Complaint, the disputed domain name resolves a parking page containing links referring to the Complainant’s ATR mark and activity. Therefore, the Respondent does not appear to have used or made demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services. Moreover, nothing in the case file shows that the Respondent has been commonly known by the disputed domain name. At the time of the filing of the Complaint, the disputed domain name resolved to a parking page containing links referring to the Complainant’s industry and its ATR marks. These are most likely pay-per-click links from which the Respondent presumably derives a profit. The use of a domain name to host a parked page comprising pay-per-click links does not represent a bona fide offering of goods and services where such links compete with or capitalize on the reputation and goodwill of the complainant’s mark or otherwise mislead Internet users. WIPO Overview 3.1, section 2.9. The disputed domain name reproduces the Complainant’s ATR mark followed by a hyphen and the term “aircraft”. Such term is strictly linked to the Complainant and its trademark and business. Accordingly, the composition of the disputed domain name cannot constitute fair use as it effectively impersonates or suggests sponsorship or endorsement by the Complainant. Furthermore, the use that the Respondent is making of the disputed domain name does not amount to a legitimate noncommercial or fair use. Using the disputed domain name to direct users to a parking page containing links referring to the Complainant’s activity and its ATR mark suggests that the Respondent intends to target the Complainant’s mark to divert consumers to the Respondent’s parking page for commercial gain. page 5 Accordingly, 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 the Complainant has provided sufficient evidence supporting a finding of reputation for its ATR mark. Moreover, the disputed domain name combines the Complainant’s mark with the term “aircraft”, indicating the Complainant’s area of activity. It is therefore clear that the Respondent was aware of the Complainant’s mark at the time of the registration of the disputed domain name. The Panel takes note that the disputed domain name is almost identical to the Complainant’s domain names <atr-aircraft.com> and <atr-aircraft.fr>, which indicates the Respondent’s intention to capitalize on the Complainant’s reputation. The registration of a domain name including a third party’s well-known trademark with no rights or legitimate interests amounts to registration in bad faith under the circumstances of this case. As far as use in bad faith is concerned, while the Respondent is not using the disputed domain name for an actual offering of goods and services, it is using it to access a parking page containing links bearing the Complainant’s ATR mark or referring to the Complainant’s activities. All considered and in the absence of any contrary evidence, the Panel is of the opinion that the Respondent is gaining a profit from each click on these links. Accordingly, the Panel finds that by using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its webpage, by creating a likelihood of confusion with the Complainant's mark as to the source, sponsorship, affiliation, or endorsement of the Respondent's webpage. The lack of reply to the Complainant’s cease and desist letter further corroborates a finding of bad faith. 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 <atr-aircraft.net> be transferred to the Complainant. /Angelica Lodigiani/ Angelica Lodigiani Sole Panelist Date: April 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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