Westmore · UDRP decision
WIPO · Case No. D2026-0616

Alfalavalphils.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <alfalavalphils.com>. It found the domain confusingly similar to the Complainant’s ALFA LAVAL mark because the mark remained recognizable despite the addition of “phils.” The Respondent lacked rights or legitimate interests because there was no authorization, evidence of being commonly known by the domain, bona fide offering, or legitimate noncommercial use. Bad faith was established from the longstanding and widely known mark, the geographically suggestive domain composition, the parked webpage, the absence of a plausible good-faith explanation, and the Respondent’s failure to respond.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-02
Panelist(s)
Majumder, Shwetasree
Complainant
Alfa Laval Corporate AB
Respondent
Jeffrey Hilario, alfalavalphils
Counsel
Advokatbyrån Gulliksson AB
Disputed domain(s)
alfalavalphils.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind alfalavalphils.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 alfalavalphils.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of alfalavalphils.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how an entire distinctive mark combined with a geographic abbreviation may create not only confusing similarity but also an implied-affiliation concern. It also shows that listing a domain-derived term as the registrant organization does not by itself establish that a respondent is commonly known by that name. The passive-holding finding rested on the totality of the documented circumstances rather than inactivity alone.

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
2026-04-02
Panel
Majumder, Shwetasree
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Alfa Laval Corporate AB v. Jeffrey Hilario, alfalavalphils Case No. D2026-0616 1. The Parties The Complainant is Alfa Laval Corporate AB, Sweden, represented by Advokatbyrån Gulliksson AB, Sweden. The Respondent is Jeffrey Hilario, alfalavalphils, Philippines. 2. The Domain Name and Registrar The disputed domain name <alfalavalphils.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 13, 2026. On February 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 13, 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 (The RDAP server redacted the value) and the contact information in the Complaint. The Center sent an email communication to the Complainant on February 16, 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 17, 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 20, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 12, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 13, 2026. page 2 The Center appointed Shwetasree Majumder 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, Alfa Laval Corporate AB, is a company incorporated in Sweden and operating in the fields of heat transfer, separation, and fluid handling technologies across multiple industries. The Complainant owns a substantial portfolio of trademark registrations for ALFA LAVAL worldwide, with the first registration dating back to 1897. The Complainant’s mark ALFA LAVAL is registered in more than 200 jurisdictions and details of some of such trademark registrations are as below: - ALFA LAVAL – Denmark Registration No. VR 189800198, registered on December 5, 1898, in international classes 7 and 11. - ALFA LAVAL – United States of America Registration No. 0764251, registered on February 4, 1964, in international classes 6, 7, 8, 9, 11, 12, 16, 21, and 28. - ALFA LAVAL – European Union Registration No. 003481702, registered on March 3, 2005, in international classes 1, 6, 7, 9, 11, 37, and 42. The Complainant operates through its official website “www.alfalaval.com”, which was registered on May 12, 1997. The Complainant also owns several other domain names incorporating the ALFA LAVAL mark. The disputed domain name was registered on January 29, 2026. The Respondent is listed as being located in the Philippines. The disputed domain name resolves to a parked webpage containing minimal content, consisting primarily of a clickable element that redirects users to a third-party website-building service. 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. The Complainant contends that the disputed domain name is identical or confusingly similar to the Complainant’s ALFA LAVAL mark. The Complainant states that the disputed domain name incorporates the ALFA LAVAL mark in its entirety, and that the addition of the term “phils” does not distinguish the disputed domain name from the Complainant’s trademark. The Complainant asserts that it owns an extensive portfolio of registered trademarks for ALFA LAVAL worldwide, with its first registration dating back to 1897, and that the mark has been in continuous use for over a century, acquiring well-known status globally across multiple industries. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant asserts that the Respondent has no business or legal relationship with the Complainant and has not been authorised or licensed to use the ALFA LAVAL mark. The Complainant further submits that the disputed domain name resolves to a webpage with no substantive content and merely redirects users to a third-party website-building service, which demonstrates the absence of any bona fide offering of goods or services. page 3 The Complainant further contends that the disputed domain name was registered and is being used in bad faith. The Complainant asserts that the Respondent registered the disputed domain name with knowledge of the Complainant and its well-known ALFA LAVAL mark and intentionally sought to take advantage of its reputation. The Complainant further submits that the Respondent has taken steps to conceal its identity and has not demonstrated any intention of legitimate use. In light of the passive holding of the disputed domain name, the Complainant contends that the disputed domain name was registered and is being used in bad faith within the meaning of the Policy. 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. 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 Panel finds that the disputed domain name wholly incorporates the ALFA LAVAL mark, which remains clearly recognisable within the disputed domain name, and that the addition of this term does not prevent a finding of confusing similarity for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.8. 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 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 recognised 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 3.1, section 2.1. The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name. The Panel notes that the Respondent has no relationship whatsoever with the Complainant. The Respondent is not affiliated with the Complainant’s business and has never been authorised, licensed, or otherwise page 4 permitted to use the ALFA LAVAL mark. There is no evidence that the Respondent is commonly known by the disputed domain name or has acquired any trademark or service mark rights in the term “alfalavalphils”. The disputed domain name incorporates the Complainant’s trademark in its entirety, appended with the term “phils” – an abbreviation commonly used to denote the Philippines, the Respondent’s listed location. Such addition is likely to convey to Internet users that the domain name corresponds to an official Philippines branch, subsidiary, or distributor of the Complainant. Further, the Panel notes that the registrant organization identified in the registration details of the disputed domain name is “alfalavalphils”, however, there is no evidence before the Panel that the Respondent is actually commonly known by the disputed domain name or “alfalavalphils”, which reinforces the Panel’s inference that there was no innocent or independent basis for the Respondent’s registration of the disputed domain name. Having reviewed the record, the Panel finds that the Complainant has established a clear prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has failed to rebut this prima facie case and has not submitted any evidence demonstrating rights or legitimate interests under paragraph 4(c) of the Policy or otherwise. The Panel further observes that the disputed domain name resolves to a parked webpage with minimal content, consisting primarily of a link to a third-party website-building service. None of the circumstances described under paragraph 4(c) of the Policy are present: the Respondent has not used or prepared to use the disputed domain name in connection with a bona fide offering of goods or services; the Respondent is not commonly known by the domain name; and there is no basis to suggest that the Respondent is making a legitimate noncommercial or fair use of the domain name. The Panel finds that such passive use does not constitute demonstrable preparations to use the domain name in connection with a bona fide offering of goods or services under the Policy. WIPO Overview 3.1, section 2.2. The Panel also finds that the composition of the disputed domain name, which wholly incorporates the Complainant’s ALFA LAVAL mark, carries a risk of implied affiliation. In the absence of any evidence to the contrary, such passive holding does not confer rights or legitimate interests on the Respondent. WIPO Overview 3.1, section 2.5.1. In these circumstances, and in the absence of any plausible explanation for the Respondent’s registration and use of the disputed domain name, the Panel finds that the Respondent lacks rights or legitimate interests in the disputed domain name. 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 incorporates the Complainant’s distinctive ALFA LAVAL mark in its entirety, together with the geographic abbreviation “phils”. The Panel finds that such a composition is likely to mislead Internet users into believing that the disputed domain name is connected with or officially affiliated with the Complainant. The Panel further notes that the disputed domain name was registered on January 29, 2026 – nearly 129 years after the Complainant’s first trademark registration and over 28 years after the Complainant established its official online presence at the domain name <alfalaval.com>. It is inconceivable that the Respondent could have registered a domain name so closely mirroring such a globally prominent and longstanding mark without actual knowledge of the Complainant and its rights. page 5 As discussed in the preceding paragraphs, the disputed domain name resolves to a webpage with minimal content. The Panel finds that such passive holding does not prevent a finding of bad faith in the circumstances of this case. UDRP panels have consistently held that passive holding of a domain name that incorporates a well-known trademark – particularly in the absence of any plausible good faith explanation – can constitute bad faith use within the meaning of the Policy. The circumstances here, including the strength of the Complainant’s mark, composition of the disputed domain name, the absence of any response or claimed legitimate non-infringing purpose from the Respondent, collectively satisfy the criteria for passive holding in bad faith as articulated in Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003. WIPO Overview 3.1, section 3.3. Paragraph 4(b) of the Policy sets out a non-exhaustive list of circumstances indicating bad faith, and other factors may also be relevant in assessing whether a domain name has been registered and used in bad faith. WIPO Overview 3.1, section 3.2.1. The Panel further notes that the Complainant’s ALFA LAVAL mark is longstanding and widely known, and the Respondent has failed to provide any explanation for its registration and use of the disputed domain name. The totality of circumstances – the incorporation of a well-known mark, the geographic specificity of the appended term, the lack of active or legitimate use, the absence of any response – collectively demonstrate that the disputed domain name was more likely than not registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy. WIPO Overview 3.1, section 3.3. The Panel finds that the Complainant has 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 <alfalavalphils.com> be transferred to the Complainant. /Shwetasree Majumder/ Shwetasree Majumder Sole Panelist Date: April 2, 2026

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

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