Westmore · UDRP DecisionExide-usa.com
The Panel ordered transfer of <exide-usa.com> after finding all three UDRP elements established. The domain reproduced the Complainant’s EXIDE mark in full with the geographic term “USA.” The Respondent did not rebut the Complainant’s prima facie case on rights or legitimate interests. Despite the domain’s non-use, the Panel found bad faith based on the longstanding and distinctive nature of the fanciful EXIDE mark, the domain’s composition, and the absence of a plausible good-faith explanation.
The timeline behind exide-usa.com
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The decision illustrates how a domain consisting of a distinctive coined mark plus a country abbreviation may support both confusing similarity and an inference of deliberate targeting. It also demonstrates that non-use does not preclude bad faith where the mark is longstanding and distinctive, the domain composition implies affiliation, and the respondent offers no contrary explanation.
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 Stryten Energy LLC v. lili Case No. D2026-0797 1. The Parties The Complainant is Stryten Energy LLC, United States of America (“United States or U.S.”), represented by Riebling IP, PLLC, United States. The Respondent is lili, China. 2. The Domain Name and Registrar The disputed domain name <exide-usa.com> is registered with Name SRS AB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 25, 2026. On February 25, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 26, 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 (Protected Protected, Shield Whois) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 26, 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 the same day. 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 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 25, 2026. page 2 The Center appointed Pablo A. Palazzi as the sole panelist in this matter on April 3, 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 provides energy storage solutions to global industries and is the owner of the registered trademark EXIDE in the United States in connection with batteries. A predecessor in interest of the Complainant founded a company dedicated to electricity storage in 1888, and the first EXIDE-branded batteries were sold in 1900. The mark EXIDE was first registered as a trademark in the United States in the year 1901. According to the Complaint, the EXIDE brand powered wakeless torpedoes during World War II and stored the solar energy that charged NASA's historic moon landing module in 1969. According to the Complaint, the trademark EXIDE has been featured in publications since at least 1918. The Complainant is the current owner of the EXIDE registered trademark in the United States (U.S. Trademark Regs. No. 0986811 registered on June 25, 1974; and 1545246 registered on June 27, 1989). The Complainant operates a domain name located at the website “www.exide.com”. The disputed domain name was registered on October 8, 2025. The disputed domain name is not in use. 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. 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 entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. page 3 Although the addition of other terms like “USA” may bear on assessment of the second and third elements, the 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. 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. 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. The Panel notes that the Respondent registered the disputed domain name on October 8, 2025, that is over 125 years after the Complainant's predecessor in interest began using EXIDE as a trademark, and over 50 years after the Complainant's predecessor in interest registered EXIDE as a trademark in the United States (U.S. Trademark Reg. No. 0986811). It is inconceivable that the Respondent was unaware of the Complainant's long-established and widely recognized mark at the time of registration. The Panel further finds that the combination of the Complainant’s mark with the geographic abbreviation “USA” is indicative of bad faith registration and use. The Complainant’s mark is a fanciful term — a coined word with no dictionary meaning or descriptive significance — which renders it inherently distinctive and strongly associated with the Complainant alone. The Respondent’s incorporation of such a fanciful mark in its entirety, together with a country identifier, leaves no plausible explanation for the registration other than an intentional attempt to trade on the Complainant’s goodwill. The Panel therefore considers that no good-faith rationale exists for combining a fanciful trademark with a geographic abbreviation, and that the disputed domain name was designed to create a false impression of association with, or endorsement by, the Complainant. 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 page 4 purposes of the Policy. WIPO Overview 3.1, section 3.3. Having reviewed the available record, the Panel notes the distinctiveness or reputation of the Complainant’s trademark, and the composition of the disputed domain name including the term “USA” where Complainant is located, 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 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 <exide-usa.com> be transferred to the Complainant /Pablo A. Palazzi/ Pablo A. Palazzi Sole Panelist Date: April 13, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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