Westmore · UDRP DecisionSaint-gobainindia.com
The Panel ordered transfer of <saint-gobainindia.com>. It found the domain confusingly similar to the Complainant’s SAINT-GOBAIN mark because the mark remained recognizable despite the addition of the geographic term “india”. The Respondent had no authorization, affiliation, commonly known status, or bona fide or fair use. Bad faith was established from the Respondent’s likely awareness and targeting of the Complainant, the initial passive holding of the domain, and its subsequent commercial use for a Chinese-language sports-betting and gambling website through confusion with the Complainant’s mark.
The timeline behind saint-gobainindia.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 saint-gobainindia.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an entire trademark with a geographic term can simultaneously satisfy confusing similarity and support an inference of targeting. It also demonstrates that a panel may assess both the domain’s inactive state at filing and materially different active use by the decision date. Here, passive holding did not prevent a bad-faith finding, while the subsequent gambling portal provided an additional basis under paragraph 4(b)(iv).
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 Compagnie de Saint-Gobain v. li fa Case No. D2026-0713 1. The Parties The Complainant is Compagnie de Saint-Gobain, France, represented by Nameshield, France. The Respondent is li fa, Hong Kong, China. 2. The Domain Name and Registrar The disputed domain name <saint-gobainindia.com> (the “Disputed Domain Name”) is registered with Gname 041 Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 19, 2026. On February 19, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On February 20, 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) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 20, 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 20, 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 amended Complaint, and the proceedings commenced on February 26, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 18, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 19, 2026. page 2 The Center appointed Monica Novac as the sole panelist in this matter on March 25, 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 a French company with a history dating back 350 years ago, specialized in the production, processing and distribution of materials for the construction and industrial markets. Currently, the Complainant is one of the top industrial groups worldwide, with a turnover of approximately EUR 46.6 billion in 2024, and employing approximately 161,000 people globally. The Complainant holds several trademark registrations for SAINT-GOBAIN in various jurisdictions, including the following: - International Trademark Registration No. 740183 SAINT-GOBAIN (word), registered on July 26, 2000, in classes 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 17, 19, 20, 21, 22, 23, 24, 37, 38, 40, and 42, designating numerous jurisdictions, including China; - International Trademark Registration No. 740184 , registered on July 26, 2000, in classes 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 17, 19, 20, 21, 22, 23, 24, 37, 38, 40, and 42, designating numerous jurisdictions, including China; and - International Trademark Registration No. 596735 , registered on November 2, 1992, in classes 1, 6, 9, 11, 12, 16, 17, 19, 20, 21, 22, 23, and 24, designating China. The Complainant also owns the domain name <saint-gobain.com>, registered on December 29, 1995. The Respondent is reportedly located in Hong Kong, China. The Respondent registered the Disputed Domain Name on December 28, 2025. As per the evidence filed by the Complainant, on the date of filing the Complaint, the Disputed Domain Name resolved to an inactive webpage with Mail Exchange servers being configured. On the date of rendering this Decision, when accessed by the Panel, the Disputed Domain Name resolves to a website in Chinese language which purports to be an online sports-betting and gambling portal which also contains commercial banners and advertisements 1 . 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 the Complainant’s SAINT-GOBAIN trademark; - the Respondent has no rights or legitimate interests in the Disputed Domain Name; and - the Disputed Domain Name has been registered and it is being used in bad faith. 1 The Panel notes it has used translation tools to translate the website content into English. page 3 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 that the Complainant’s SAINT-GOBAIN mark is recognizable within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the SAINT-GOBAIN mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. The Disputed Domain Name also contains the term “india”, however the Panel finds that the addition of this element does not prevent finding a confusing similarity between the Disputed Domain Name and the Complainant’s trademark for the purposes of the Policy. According to WIPO Overview 3.1, section 1.8, where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. According to WIPO Overview 3.1, section 1.11.1, the generic Top-Level Domain “.com” in the Disputed Domain Name is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. 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. page 4 It is accepted by the Panel that the Complainant has not authorized nor licensed the Respondent to use its SAINT-GOBAIN trademark or to register the Disputed Domain Name. The Respondent is not affiliated to the Complainant in any way. There is also no evidence that the Respondent is commonly known by the Disputed Domain Name. In view of the composition of the Disputed Domain Name, the Panel is of the opinion that the Respondent more likely than not registered the Disputed Domain Name with the ultimate intent to mislead Internet users and to erroneously make them believe that the Disputed Domain Name is operated by or associated with the Complainant. The Panel considers that the composition of the Disputed Domain Name signals the Respondent’s intention of taking unfair advantage of the Complainant’s mark. At the time of filing of the Complaint, the Disputed Domain Name did not resolve to any active website. Therefore, the Disputed Domain Name has not been used for any bona fide offering of goods or services nor for a legitimate noncommercial or fair use. On the date of rendering this Decision, when accessed by the Panel, the Disputed Domain Name resolves to a website in the Chinese language that appears to be an online sports-betting and gambling portal, also containing commercial banners and advertisements. Such use of the Disputed Domain Name, which incorporates the Complainant’s mark in its entirety, can neither be considered a bona fide offering of goods or services nor a legitimate noncommercial or fair use of the Disputed Domain Name in the sense of paragraphs 4(c)(i) and (iii) of the Policy. In view of all the above, 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. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.1, section 3.2.1. In the present case, the Panel notes that the Complainant registered and used its SAINT-GOBAIN trademark well-before the Respondent registered the Disputed Domain Name. In view of the worldwide presence of the Complainant, as well as the composition of the Disputed Domain Name, in the absence of any explanation from the Respondent regarding its choice to include the Complainant’s trademark in the Disputed Domain Name, it is unlikely that the Respondent was not aware of the Complainant’s trademark when registering the Disputed Domain Name. The Disputed Domain Name was inactive when the Complaint was filed. Panels have found that the non- use of a domain name would not by itself prevent a finding of bad faith under the doctrine of passive holding. To the contrary, in looking at the totality of circumstances in each case, panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the Disputed Domain Name, 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 believes that the Respondent targeted the Complainant when registering the Disputed Domain Name. Moreover, the Panel finds that the Respondent’s current use of the Disputed Domain Name to attract Internet users to a sports-betting and gambling website falls under the provisions of paragraph 4(b)(iv) of the Policy. More specifically, paragraph 4(b)(iv) of the Policy provides that the use of a domain name to intentionally attempt “to attract, for commercial gain, Internet users to [the respondent’s] web site or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, page 5 sponsorship, affiliation, or endorsement of [the respondent’s] web site or location or of a product or service on [the respondent’s] web site or location” is evidence of registration and use in bad faith. Moreover, and as previously held by UDRP panels, the Panel is of the opinion that the use of the Disputed Domain Name especially in relation to gambling services creates a negative association with the Complainant’s trademark and business and it is considered evidence of Respondent’s bad faith. The Panel also notes the Respondent’s failure to submit a response in the present proceeding, which may be considered as a further indication supporting the Panel’s finding of the Respondent’s bad faith. Having reviewed the record, the Panel finds the Respondent’s registration and use of the Disputed Domain Name constitutes bad faith under the Policy. 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 <saint-gobainindia.com> be transferred to the Complainant. /Monica Novac/ Monica Novac Sole Panelist Date: April 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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