Westmore · UDRP DecisionSafrrangroup.com
The Panel ordered transfer of <safrrangroup.com>. It found the domain confusingly similar to the SAFRAN mark because the mark remained recognizable despite the additional “r” and the term “group.” The Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. Bad faith was established from the intentional misspelling of the widely known mark, imitation of the Complainant’s domain-name pattern, and passive holding in the totality of the circumstances; configured MX servers were considered a possible further indication of bad faith.
The timeline behind safrrangroup.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
The decision illustrates how a one-letter typo combined with a term matching the complainant’s corporate domain-name pattern can support findings across all three UDRP elements. It also shows that an inactive website does not foreclose bad faith where the mark’s reputation, the targeting evident from the domain’s composition, and other circumstances such as MX configuration point toward abuse.
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 Safran v. Chen Chen Case No. D2026-1163 1. The Parties The Complainant is Safran, France, represented by Ebrand France, France. The Respondent is Chen Chen, United States of America. 2. The Domain Name and Registrar The disputed domain name <safrrangroup.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 18, 2026. On March 18, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 18, 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 User #44ec3a99, See PrivacyGuardian.org) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 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 March 23, 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 17, 2026. page 2 The Center appointed Taras Kyslyy as the sole panelist in this matter on April 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 an international high-technology group, operating in the aviation, defense and space markets. The Complainant has a global presence, with more than 95,000 employees and sales of EUR 16,5 billion in 2020. The Complainant is listed on NYSE Euronext Paris. Its share is part of the French stock market index, CAC 40 and of the European market index. The Complainant is the owner of numerous trademarks for SAFRAN, including for instance International trademark registration No. 884321, registered on August 5, 2005. The Complainant is also the holder of numerous domain names composed of the SAFRAN trademark and the term “group”, for instance <safran-group.com>, <safran-group.fr>, and <safrangroup.com>. These domain names are resolving or redirecting to the website “www.safran-group.com”, which promotes the activities of the Complainant. The disputed domain name was registered on February 17, 2026 and does not resolve to any active website. MX servers have been configured on the disputed domain name. 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 identical or confusingly similar to the Complainant’s trademark. The disputed domain name is composed with “safrran” and “group”. This combination reminds the combination “safran group”, which refers directly to the Complainant and its activities, and moreover to its strategic domain names composed with “safran” and “group”. In this case, the addition of one “r” to “safran” does not prevent the trademark SAFRAN from being recognized phonetically and visually, and the composition with “group” makes the disputed domain name confusingly similar to the Complainant’s trademark and domain names. This strong similarity is characteristic of typosquatting practices. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not commonly known under the name “Safran Group” or “Safrran Group” according to the company database. Also, according to general research on the Internet, the term “safrran” and “group” only refers to the Complainant company and trademark. Before any notice to the Respondent of the dispute, there is no evidence of the Respondent’s use of the disputed domain name in connection with a bona fide offering of goods or services. The Respondent does not use the disputed domain name to operate an active website promoting its own activity. The purpose of this typosquatting registration is to imitate the Complainant for fraudulent purposes. Given the composition of the disputed domain name the Respondent wanted to refer to the Complainant. The Complainant’s trademark is internationally known. The Respondent ought to have been aware of it and cannot reasonably evidence having any legitimate purpose to register the disputed domain name. page 3 Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The composition chosen by the Respondent creates a risk of confusion in the mind of the Internet users as it is a clear act of typosquatting. The Respondent has registered the disputed domain name very similar to the Complainant’s trademark, intending to make it very close to the domain names owned and used by the Complainant. Thus, Internet users could be misled by a typing error and believe that the disputed domain name is owned by the Complainant. The practice of typosquatting is, in itself, evidence of bad faith registration. MX servers have been configured on the disputed domain name, which allows the disputed domain name to be used in the form of email addresses. In this way, the disputed domain name could be used to send emails to third parties, usurping the identity of the Complainant, with the aim of collecting potentially sensitive information. This technique corresponds to the definition of phishing. An Internet user looking for information on the Complainant or who receives an email from an address composed of the disputed domain name is likely to think, wrongly, that this name belongs to the Complainant. There is no reason why the Respondent should be allowed to use the Complainant’s well- known trademark in the disputed domain name to configure MX servers on the disputed domain name. The creation of an email address - based on the disputed domain name - that may lead the recipient of a message sent from that address to believe that it is from the Complainant constitutes a bad faith use. There is no legitimate reason for the Respondent to incorporate the Complainant’s well-known trademark into the disputed domain name. The Respondent’s registration and use of the disputed domain name are therefore intended to divert Internet users, initiate fraudulent actions, undermine the Complainant’s business, and operate against its legitimate interests. 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 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. A domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) of a trademark is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.1 section 1.9. Although the addition of other term here, “group”, 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. 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. Furthermore, the Respondent provided no evidence that it holds rights or legitimate interests in the disputed domain name. The available evidence does not confirm that the Respondent is commonly known by the disputed domain name, which could demonstrate its rights or legitimate interests (see, e.g., World Natural Bodybuilding Federation, Inc. v. Daniel Jones, TheDotCafe, WIPO Case No. D2008-0642). 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 notes that the Respondent registered the disputed domain name consisting of an intentional misspelling of the Complainant's widely known trademark and also mimicking the Complainant’s respective domain names. The Panel finds this confirms the Respondent was aware of and targeted the Complainant and its trademark while registering the disputed domain name, which is bad faith. 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, the composition of the disputed domain name mimicking the respective Complainant's domain names, 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 considers that the configuration of MX servers on the disputed domain name may be a further indication of bad faith under the circumstances of this case. The Panel finds that the Complainant has established the third element of the Policy. page 5 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 <safrrangroup.com> be transferred to the Complainant. /Taras Kyslyy/ Taras Kyslyy Sole Panelist Date: May 8, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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