Westmore · UDRP DecisionAlstomgroupltd.com
The Panel ordered transfer of <alstomgroupltd.com>. It found the ALSTOM mark recognizable in the domain despite the addition of “group” and “ltd”; found that the Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests; and found bad-faith registration and use. The bad-faith determination rested on the mark’s pre-existing reputation, including in India, the Panel’s finding that the Respondent knew of the mark, and passive holding circumstances that made any good-faith use implausible.
The timeline behind alstomgroupltd.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 alstomgroupltd.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how an inactive domain can satisfy the bad-faith requirement when it wholly incorporates a distinctive and well-recognized mark, adds terms that reinforce an apparent corporate association, and is held by a respondent who provides no good-faith explanation. The Panel treated “group” and “ltd” as insufficient to avoid confusing similarity and considered the domain’s correspondence with the Complainant’s naming practices relevant to knowledge and bad faith.
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 Alstom v. Ansel Anton, Arglobal Case No. D2026-1052 1. The Parties The Complainant is Alstom, France, represented by Lynde & Associes, France. The Respondent is Ansel Anton, Arglobal, India. 2. The Domain Name and Registrar The disputed domain name <alstomgroupltd.com> is registered with Internet Domain Service BS Corp (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 11, 2026. On March 12, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 23, 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 (REDACTED FOR PRIVACY) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 23, 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 March 24, 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 March 25, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 14, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 15, 2026. The Center appointed Andrew Brown K.C. as the sole panelist in this matter on April 21, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration page 2 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 founded in 1928. It is headquartered in France. The Complainant is a major player in the field of transport infrastructure, employing some 34,000 employees in more than 60 countries. The Complainant plays a significant role in the manufacture and overhaul of railway rolling stock. The Complainant owns a number of relevant registrations for the trademark ALSTOM (“the ALSTOM Trademark”) including: Trademark Jurisdiction Number Registration Date Class ALSTOM India 1806682 April 15, 2009 9 and12 ALSTOM India 1798988 March 24, 2009 37, 39, 40 and 42 ALSTOM International Registration 1528691 December 4, 2019 9, 12, 37 and 42 ALSTOM European Union 948729 August 8, 2001 6, 7, 9, 11, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41 and 42 The disputed domain name was registered on February 25, 2026, and does not resolve to an active website. 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 it has trademark rights to the ALSTOM Trademark with respect to a wide range of goods and services relating to transport infrastructure. The Complainant states that its trademark is established all over the world and most notably in India, where the Respondent has his address. The Complainant states that it has had a long presence in India. The Complainant claims a worldwide reputation and goodwill in its ALSTOM Trademark. Further, the Complainant relies on the fact that it has numerous domain names incorporating its ALSTOM Trademark, including <alstom.com> and <alstomgroup.com>. It also has domain registrations for <alstomgroup.com>, <alstomgroup.net>, <alstomgroup.fr>, <alstomgroup.eu> and <alstomgroup.in>. The Complainant alleges that the disputed domain name is a combination of the Complainant’s ALSTOM Trademark and of the generic element “group” and the abbreviation of “Limited”, “ltd”. It states that the disputed domain name is confusingly similar to its ALSTOM Trademark and will be directly perceived by Internet users to be a reference to it. The Complainant asserts that several WIPO panels have found there to be confusingly similarity when a disputed domain name incorporates a complainant’s trademark and only adds generic terms. The Complainant draws attention to several previous WIPO UDRP decisions which have held that the ALSTOM Trademark is famous or well-known: ALSTOM v. Daniel Bailey, WIPO Case No. D2010-1150 and page 3 Alstom S.A. and General Electric Company v. Sichuan Shanghai Electric Power T&D Engineering Co., Ltd, WIPO Case No. DCO2016-0030. The Complainant contends that the Respondent has no rights or legal interests in the disputed domain name. In this regard it states that: (a) the Respondent is not affiliated to it. (b) the Complainant has never authorized a third party to register a domain number comprising or including its ALSTOM Trademark. (c) the Complainant wrote a cease-and-desist letter to the Respondent at the contact address in WHOIS and that this remains unanswered. (d) the Respondent has not made use of or preparations to use the disputed domain name in connection with a bona fide offering of goods and services. The Complainant states that the disputed domain name has been registered in bad faith. It asserts that the disputed domain name was acquired long after the Complainant’s ALSTOM Trademark became well-known. In view of the fact that its ALSTOM Trademark is well-known, the Complainant states that it is virtually impossible for the Respondent to not have been aware of the ALSTOM Trademark at the time of registration. As to use in bad faith, the Complainant notes that the disputed domain name is inactive. The Complainant contends that the disputed domain name takes unfair advantage of its ALSTOM Trademark and the mark’s significant reputation. It states that the words “alstom” and “group” are included in all email addresses of its employees. It claims that this use will result in confusion as to who owns or operates 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 Panel finds the Complainant has established unregistered trademark or service mark rights for the purposes of the Policy. WIPO Overview 3.1, section 1.3. The Panel finds the mark is recognizable 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. Although the addition of other terms (here, “group” and “ltd ”) may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s 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. page 4 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. In the present case, the Panel finds that the disputed domain name has been registered in bad faith for the following reasons: (a) The Complainant has clearly demonstrated its rights to the ALSTOM Trademark and that the trademark was well-known and had goodwill and a reputation well prior to registration of the disputed domain name on February 25, 2026. That goodwill and reputation particularly extended to India. The Complainant’s trademark registrations and its use of that mark well pre-date the registration of the disputed domain name. (b) The Panel finds that the Respondent knew of the Complainant’s ALSTOM Trademark when he registered the disputed domain name. The disputed domain name incorporates the ALSTOM Trademark with the suffix “group” which has been and is used by the Complainant in a number of its domain name registrations and in all email addresses of its employees. (c) In any event, any good faith search of the Internet before registration of the disputed domain name would have revealed to the Respondent the Complainant’s trademark rights in an existing use of ALSTOM Trademark. The Panel is also satisfied that, by application of the well-established passive holding doctrine, the Respondent has used the disputed domain name in bad faith. Previous panels, having looked at the totality of the circumstances in each case, have considered the following factors to be relevant in applying the passive holding doctrine (WIPO Overview 3.1 para 3.3): (a) the degree of distinctiveness or reputation of the Complainant’s mark. In this case the Panel is satisfied that the Complainant’s ALSTOM Trademark is distinctive and well-recognized. (b) the failure of the respondent to submit a response or to provide any evidence of actual or contemplative good faith use. In this case there is no such evidence. page 5 (c) the respondent concealing its identity or use of false contact details (noted to be in breach of its registration agreement). In this case the respondent has disguised its identity. Applying all these considerations, the Panel finds it implausible that the disputed domain name may be put into any good faith use and is satisfied that the doctrine of passive holding applies in this case and that this supports a finding of bad faith use of the disputed domain name. The Panel therefore 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 <alstomgroupltd.com> be transferred to the Complainant. /Andrew Brown K.C./ Andrew Brown K.C. Sole Panelist Date: April 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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