Westmore · UDRP decision
WIPO · Case No. D2026-0759

Taler.buzz

Complaint deniedWIPO-indexed · informational, not legal advice

The Panel denied the Complaint. It found <taler.buzz> confusingly similar to Complainant’s THALER trademark because “thaler” remained recognizable despite omission of the letter “h.” The Panel left rights or legitimate interests undecided and held that Complainant had not proved bad-faith registration and use. In particular, “taler” is a dictionary term with historical currency significance, the THALER mark’s notoriety was not established, the domain was inactive, and Complainant supplied no evidence showing that good-faith use was implausible or that there was a concrete phishing or fraud risk.

Outcome
Denied
At a glance
Provider
WIPO
Outcome
Complaint denied
Decision date
2026-04-22
Panelist(s)
Hartung, Stephanie
Complainant
CA Indosuez (Switzerland) SA
Respondent
Environ Architectural Design AK Maier
Disputed domain(s)
taler.buzz
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind taler.buzz

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 taler.buzz — 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 denied. taler.buzz remained with the respondent.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates the evidentiary limits of relying on passive holding and general phishing concerns where the disputed string has an established dictionary meaning. Even with an earlier trademark, close visual similarity, an inactive domain, and respondent default, the Panel required case-specific evidence supporting trademark targeting and bad faith.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsnot_reached
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
Complaint denied
Decision date
2026-04-22
Panel
Hartung, Stephanie
Full decision
13 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION CA Indosuez (Switzerland) SA v. Environ Architectural Design AK Maier Case No. D2026-0759 1. The Parties Complainant is CA Indosuez (Switzerland) SA, Switzerland, represented by id est avocats sàrl, Switzerland. Respondent is Environ Architectural Design AK Maier, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <taler.buzz> 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 23, 2026. On February 24, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 24, 2026, the Registrar transmitted by email to the Center its verification response confirming that Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to Complainant on February 27, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on February 27, 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 Respondent of the Complaint, and the proceedings commenced on March 4, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 24, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on March 25, 2026. The Center appointed Stephanie G. Hartung as the sole panelist in this matter on April 8, 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. page 2 4. Factual Background Complainant is a company organized under the laws of Switzerland that is active in the financial industry. Complainant has provided evidence that it is the registered owner of various trademarks relating to its THALER brand, including, but not limited to, the following: - Word/device trademark THALER, Swiss Federal Institute of Intellectual Property, registration number: 470901, registration date: March 29, 2000, status: active. Respondent, according to the Registrar verification, is reportedly located in the United States. The disputed domain name was registered on November 26, 2025; it does not resolve to any active content on the Internet. Complainant requests that the disputed domain name be transferred to Complainant. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, Complainant contends to form part of the banking group known as “Crédit Agricole” with roots going back to 1876, belonging nowadays to Europe’s largest banking groups. Also, Complainant has demonstrated to be the legal successor of “Banque Thaler SA”, and as a consequence of a merger with the latter possess of various domain names relating to its THALER brand, e.g. <bankthaler.ch>, <bankthaler.eu>, <banquethaler.ch>, <banquethaler.com>, as well as <banquethaler.eu>. Complainant submits that the disputed domain name, absent any other distinctive element, is confusingly similar to Complainant’s THALER trademark. Moreover, Complainant asserts that Respondent has no rights or legitimate interests in respect of the disputed domain name since (1) Complainant’s THALER trademarks were all registered before the known creation date of the disputed domain name, (2) there is an extreme similarity of the disputed domain name with those trademarks, demonstrating Respondent’s desire to give the illusion of an association with Complainant, and (3) specifically, no use is made of the disputed domain name, as the associated website is not even functional. Finally, Complainant argues that Respondent has registered and is using the disputed domain name in bad faith since (1) the disputed domain name is extremely similar to one of Complainant’s trademarks, (2) the mere absence of use of the disputed domain name is not incompatible with the existence of bad faith, and (3) in the banking sector, look-alike domain names are widely recognized as primary instruments for phishing and financial fraud, why the passive holding of the disputed domain name constitutes a latent threat to the integrity of the financial system and a risk of fraud. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) that Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. page 3 Respondent's default in the case at hand does not automatically result in a decision in favor of Complainant, however, paragraph 5(f) of the Rules provides that if Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute solely based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel may draw such inferences from Respondent’s failure to submit a Response as it considers appropriate. A. Identical or Confusingly Similar First, 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 Complainant’s THALER trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. Complainant has shown rights in respect of its THALER trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. Also, Complainant’s THALER trademark is reproduced within the disputed domain name, only in a slightly modified version, missing the letter “h”, but still recognizable therein. Accordingly, the disputed domain name is confusingly similar to Complainant’s THALER trademark for the purposes of the Policy. WIPO Overview 3.1, sections 1.7 and 1.9. Moreover, it has been held in many UDRP decisions and has become a consensus view among UDRP panels that the applicable Top-Level Domain (“TLD”) in a domain name is generally viewed as a standard registration requirement and as such is disregarded under the first element test, though the meaning of such TLD may be relevant to a panel assessment of the second or third element of the URDP. Accordingly, the existence of the TLD “.buzz” does not dispel the finding of confusing similarity between Complainant’s THALER trademark and the disputed domain name. The Panel, therefore, finds the first element of the Policy has been established. B. Rights or Legitimate Interests Second, paragraph 4(c) of the Policy provides a list of circumstances in which 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 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, at the very least, has doubts whether Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Complainant’s assertions in that respect include (1) the timing of Complainant’s THALER trademarks’ registration which took place well before the registration of the disputed domain name, (2) the “extreme” similarity of the disputed domain name with those trademarks, demonstrating Respondent’s desire to give the illusion of an association with Complainant, and (3) the non-use of the disputed domain name. The Panel notes that the term “taler” as it is reflected in the disputed domain name is not identical, however similar to the term “thaler” as it is reflected in Complainant’s THALER trademark. Both terms refer, as researched by the Panel within its limited powers set forth by paragraph 10 of the Rules, to the currency “Taler” (often spelled “Thaler” until 1901) which is one of the most significant European silver coins, having served as the standard currency from the early modern period through to the 19th century. Consequently, page 4 the term “taler” is a dictionary word, the registration of which, as recognized by UDRP panels, does not by itself automatically confer rights or legitimate interest on a respondent. WIPO Overview 3.1, section 2.10. By the same token, UDRP panels also widely agree that aggregating and holding domains names (usually for resale) consisting of e.g., dictionary words can be bona fide and is not per se illegitimate under the UDRP. WIPO Overview 3.1, section 2.1. Also, from the registration of the dictionary term “taler” as a domain name as such, it may not be concluded under the circumstances of this case that Respondent did target Complainant and its THALER trademark. In this context, the Panel expressly notes that Complainant’s THALER trademarks enjoy protection specifically for the territory of Switzerland, and Complainant has brought nothing forward as to the notoriety of these trademarks, neither within Switzerland nor abroad, from which the Panel could have concluded that Respondent must have been aware of these national trademarks when it registered the disputed domain name. The Panel, however, decided to leave it open whether or not Respondent has rights or legitimate interests in respect of the dispute domain name, as this Complaint still fails for the reasons set out in Section C below. C. Registered and Used in Bad Faith Third, 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. Complainant’s assertions in that respect include that (1) the disputed domain name is extremely similar to one of Complainant’s trademarks, (2) the mere absence of use of the disputed domain name is not incompatible with the existence of bad faith, and (3) in the banking sector, look-alike domain names are widely recognized as primary instruments for phishing and financial fraud, why the passive holding of the disputed domain name constitutes a latent threat to the integrity of the financial system and a risk of fraud. Indeed, Complainant is right when pointing to the view of UDRP panels that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.1, section 3.3. By the same token, the Panel also notes that Complainant, however, has not addressed any of the factors that need be considered relevant in applying the passive holding doctrine in order to support a finding of bad faith despite the non-use of the dispute domain name. These factors include in the first place e.g., the degree of distinctiveness or reputation of Complainant’s THALER trademark (WIPO Overview 3.1, section 3.3.) which the Complaint does not touch upon at all. Also, the Complaint does not provide any kind of explanation as to the implausibility of any good faith use to which the disputed domain name may be put. Certainly, the mere similarity with Complainant’s THALER trademark is not per se an exclusion criteria, especially given that the term “taler” of which the disputed domain name is composed is a dictionary term which can apply in a wide variety of contexts. Also, the disputed domain name includes not only the dictionary term “taler”, but also the TLD “.buzz”, a term commonly used in connection with publicity or news, and which, although it may in some contexts be associated with financial or cryptocurrency-related developments, does not necessarily relate to the financial industry in which Complainant is active. Last, Complainant correctly points to the fact that in the banking sector, look-alike domain names are widely recognized as primary instruments for phishing and financial fraud, and so concludes that the passive holding of the disputed domain name constitutes a latent threat to the integrity of the financial system and a risk of fraud. Still, Complainant has missed the opportunity to address any of the typical circumstances that might demonstrate not only a latent, but a concrete risk of such fraud to the disadvantage of Complainant, e.g., the sending of phishing emails or at least the activation of MX servers under the disputed domain name demonstrating the intent to send emails thereunder, alternatively or additionally e.g., the involvement of Respondent in any other kind of fraudulent activities or as a party in former UDRP proceedings from which this Panel could have concluded that it is at least more likely than not that the disputed domain name in the future will be put to a bad faith use rather than to a good one. page 5 Having said so, the Panel wishes to emphasize that the case at hand is distinct from a number of cases in which UDRP panels recently found in favor of Complainant. In, e.g., CA Indosuez (Switzerland) SA v. Tedy Perin (WIPO Case No. D2026-0761 <thaler-assets.com>), the panel pointed to the very composition of the disputed domain name, consisting of Complainant’s identical THALER trademark and the descriptive term “assets” which directly relates to the banking business, and so concluded that the overall plausibility of any good faith use of the disputed domain name was low. Also, in CA Indosuez (Switzerland) SA v. Detlef Baur (WIPO Case No. D2026-0762 <thaler.info>), again the setting was different, too, in that the disputed domain name contained Complainant’s full and identical THALER trademark and the generic TLD “.info”, which seems to the Panel more likely to present a risk to be used for phishing purposes, than in this proceeding . The Panel, therefore, concludes that Complainant with regard to the specific setting in the case at hand has failed to meet its burden of proof under paragraph 4(b)(iii) of the Policy in showing that Respondent has registered and is using the disputed domain name in bad faith, and so finds that Complainant has not established the third element of the Policy. In this context, it also carries weight in the eyes of the Panel that Complainant has been legally represented in this UDRP proceeding which further increases the demands placed on a thorough presentation of Complainant’s arguments. 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 Complaint be denied. /Stephanie G. Hartung/ Stephanie G. Hartung Sole Panelist Date: April 22, 2026

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

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