Westmore · UDRP decision
WIPO · Case No. D2026-0813

Alstorngroups.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <alstorngroups.com> to Alstom. It found the domain confusingly similar to the ALSTOM mark because the mark remained recognizable despite replacement of the letter “m” with “rn”. The Respondent lacked rights or legitimate interests, and the domain’s prior use for third-party advertising links, later passive holding, composition, privacy-service use, and the absence of any explanation supported a finding of registration and use in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-02
Panelist(s)
Beier, Dietrich
Complainant
Alstom
Respondent
MOREL Morgan
Counsel
Lynde · associes
Disputed domain(s)
alstorngroups.com
Domain history UDRP Intelligence

The timeline behind alstorngroups.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 alstorngroups.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 alstorngroups.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a visually deceptive letter substitution can leave a mark recognizable for confusing-similarity purposes and, when combined with PPC use and other circumstances, support findings on all three UDRP elements. It also demonstrates that moving from an advertising parking page to passive holding does not prevent a bad-faith finding where the totality of the record indicates targeting.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-02
Panel
Beier, Dietrich
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Alstom v. MOREL Morgan Case No. D2026-0813 1. The Parties The Complainant is Alstom, France, represented by Lynde & Associes, France. The Respondent is MOREL Morgan, United States of America (“US”). 2. The Domain Name and Registrar The disputed domain name <alstorngroups.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 25, 2026. On February 26, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name and another domain name. On February 27, 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 (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 27, 2026, with the registrant and contact information of nominally multiple underlying registrants revealed by the Registrar, requesting the Complainant to either file separate complaint(s) for the disputed domain names associated with different underlying registrants or alternatively, demonstrate that the underlying registrants are in fact the same entity and/or that all domain names are under common control. The Complainant filed an amended Complaint on March 3, 2026, withdrawing one domain name from the proceedings. 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 March 4, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 24, 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 Dietrich Beier as the sole panelist in this matter on March 27, 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 created in 1928. It is a global leader in the world of transport infrastructures, employing 34,000 professionals in more than 60 countries. Between April 1, 2024 and March 31, 2025, the Complainant’s order intake reached EUR 19.8 billion. The Complainant’s sales also reached EUR 18.5 billion. The Complainant is proprietor of numerous trademarks worldwide, among them the US Trademark Registration N°4570546 ALSTOM filed on February 24, 2011 and registered on July 22, 2014 in several classes, as well as European Union Trademark Registration N°948729 ALSTOM filed on September 30, 1998 and registered on August 8, 2001 in several classes, both trademarks being in effect. The Complainant is also proprietor of several domain names for the Second-Level Domain “alstomgroup” with different Top-Level Domains. The disputed domain name was registered on January 21, 2026, was connected with a parking page with advertising links to third party websites, became later inactive and nowadays leads to a WhoIs verification page. 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 trademark rights and the replacement of the letter “m” with the similar letters “rn” represents typosquatting. Furthermore, the Respondent is not affiliated in any way to the Complainant nor did the Complainant authorized him to register a domain name composed of the mark. In view of the well-known character of the mark ALSTOM, the Complainant considers it as virtually impossible that the Respondent was not aware of the Complainant’s activities, at the time it registered the disputed domain name. Also, the hiding of its identity is an indication of bad faith. Lastly, the disputed domain name being inactive does not prevent an assessment of bad faith if the above circumstances are present. 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 3 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 clearly recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. 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 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. This is in particular the case since the Complainant did not grant any permission or consent to the Respondent to use its trademarks. Furthermore, the Respondent has no legitimate interest in the disputed domain name since there is no indication that the Respondent is commonly known by the name “ALSTORN” or “alstorngroups.com” nor that the Respondent is using the disputed domain name in connection with a bona fide offering of related goods or services. The use of the disputed domain name to resolve to a parking site with advertisings for third parties cannot be considered a bona fide offering of goods and services under the Policy. The Panel therefore finds that the Respondent does not have rights or legitimate interests in the disputed domain name. C. Registered and Used in Bad Faith Due to the intensive use of the Complainant’s distinctive marks, being registered for many decades in many jurisdictions at the time of the registration of the disputed domain name, the Respondent must have been well aware of the Complainant and its trademarks when registering the disputed domain name. The Complainant had not authorised the Respondent to make use of its mark. At the time of this Decision the disputed domain name leads to a WhoIs verification page. UDRP 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. page 4 Furthermore, the Panel notes that at the time the Complaint was filed, the disputed domain was resolving to a parking page with advertising links to third party websites. The above circumstances indicate that the Respondent registered and used the disputed domain name primarily with the intention of attempting to attract, for commercial gain, Internet users to its potential website or other online locations, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of such website or location, or of a product or service on such website or location. The Respondent’s failure to come forward with any explanation for the registration of the disputed domain name in a Response, the use of a privacy service to conceal the Respondent’s identity and the PPC links indicate that the Respondent targeted the Complainant. The Panel therefore considers the disputed domain name to have been registered and used in bad faith in accordance with paragraph 4(a)(iii) of the Policy. The Panel finds the third element of the Policy has been established. 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 <alstorngroups.com> be transferred to the Complainant. /Dietrich Beier/ Dietrich Beier Sole Panelist Date: April 2, 2026

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

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