Westmore · UDRP DecisionAlsttomgroup.com
The Panel ordered transfer of <alsttomgroup.com>. It found the domain confusingly similar to Alstom’s ALSTOM mark because the mark remained recognizable despite the duplicated letter “t” and the addition of “group.” The Respondent lacked rights or legitimate interests because Alstom had not authorized the registration, the domain resolved only to the Registrar’s parking page, and the Respondent did not rebut Alstom’s prima facie case. Bad faith was established from the mark’s prior registration and international reputation, the domain’s typosquatting composition and close resemblance to Alstom’s <alstomgroup.com>, its passive holding, and the absence of a Response.
The timeline behind alsttomgroup.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 alsttomgroup.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a one-letter duplication combined with a company-associated term can support findings across all three UDRP elements, particularly where the resulting domain closely imitates the complainant’s established corporate domain. It also demonstrates that registrar parking and lack of material use do not prevent a bad-faith finding when the mark is distinctive and reputable, the domain composition points toward targeting, and the respondent provides no 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 Alstom v. Maureen Sombe Case No. D2026-1183 1. The Parties The Complainant is Alstom, France, represented by Lynde & Associes, France. The Respondent is Maureen Sombe, United States of America (“United States” or “US”). 2. The Domain Name and Registrar The disputed domain name <alsttomgroup.com> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 19, 2026. On March 19, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On the same date, 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 (UNKNOWN) 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 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 26, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 15, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 16, 2026. The Center appointed Rodrigo Velasco Santelices as the sole panelist in this matter on April 22, 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 The Complainant, Alstom, is a French company created in 1928. It globally operates 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 and sales reached EUR 18.5 billion. The Complainant operates worldwide and plays a significant role in the manufacture and overhaul of rolling stock. The goods and services the Complainant produces are well known throughout the world. United States is notably a key country for the Complainant. The Complainant has been present in the United States for over 160 years in the areas of rail and airport transport and delivers new or renovated vehicles for its US customers. The Complainant holds registrations that comprise the word “Alstom” in numerous jurisdictions around the world, including the following trademark registrations: - United Kingdom Trademark Registration No. UK00900948802 ALSTOM, registered on June 6, 2002, for goods and services in classes 6, 7, 9, 11, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42; - United Kingdom Trademark Registration No. UK00900948729 ALSTOM, registered on August 8, 2001, for goods and services in classes 6, 7, 9, 11, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42; - United States Trademark Registration No. 4236513 ALSTOM, registered on November 6, 2012, for goods and services in class 12; - European Union Trade Mark Registration No. 000948729 ALSTOM, registered on August 8, 2001, for goods and services in classes 6, 7, 9, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42; - International Registration No. 706292 ALSTOM, registered on August 28, 1998, for goods and services in classes 1, 2, 4, 6, 7, 9, 11, 12, 13, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42; and - International Registration No. 706360 ALSTOM, registered on August 28, 1998, for goods and services in classes 1, 2, 4, 6, 7, 9, 11, 12, 13, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42. The Complainant is also the registrant of numerous domain names under various generic and country code Top-Level Domains that comprise its trademark, such as <alstom.com> registered since January 20, 1998, and <alstomgroup.com> registered on November 14, 2000. Additionally, the Complainant is the owner of the following domain names: - <alstomgroup.com> registered since November 14, 2000; - <alstomgroup.net> registered since June 1, 2017; - <alstomgroup.fr> registered since June 2, 2017; and - <alstomgroup.eu> registered since November 24, 2018. Finally, the Complainant owns a great number of companies and trade name rights with the denomination “Alstom”, such as: “Alstom Transport Technologies”, “Alstom Power Systems”, “Alstom Holdings”, “Alstom Shipworks”, “Alstom Aptis”, etc. In particular, the denomination “Alstom Group” is widely used by the Complainant to designate the company Alstom and its subsidiaries. This expression appears in all the email addresses of the Complainant’s employees. The disputed domain name <alsttomgroup.com> was registered on November 20, 2025, and the Respondent has not made material use of it so far as it has been resolving to the Registrar’s parking page. page 3 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 is the owner of the registered trademark ALSTOM, so it cannot be questioned that the disputed domain name is confusingly similar to the Complainant’s trademark since the disputed domain name reproduces the ALSTOM trademark in its entirety with the duplication of the letter “t”. Moreover, the disputed domain name associates the Complainant’s prior mark ALSTOM with the descriptive word “group”, which is commonly used. Therefore, the disputed domain name clearly imitates the Complainant’s earlier ALSTOM trademark by reproducing this sign with a spelling error (“alsttom”). The double letter “tt” is barely noticeable visually. This may lead Internet users to read the disputed domain name as <alstomgroup.com>, which is the domain name used by the Complainant, particularly in their email addresses. Therefore, the disputed domain name will lead users to believe that it is related to the Complainant. For the reasons set out above, and pursuant to paragraph 4(a)(i) of the Policy, the Complainant has rights in the well-known ALSTOM trademark, and the disputed domain name is confusingly similar to it. The Complainant further states that the Respondent clearly had the Complainant’s trademark in mind when registering the disputed domain name in order to exploit and profit from its trademark rights, that the Respondent has no rights or legitimate interests in respect of the disputed domain name, and the disputed domain name was registered and is being used in bad faith. 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 ALSTOM mark is recognizable within the disputed domain name despite the duplication of the letter “t”. 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”, 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 First, the Complainant has never authorized the Respondent to register a domain name composed of the mark ALSTOM or the denomination “Alstom Group” or “Alsttom Group”. Second, the disputed domain name resolves to the Registrar’s parking page and is consequently not used by the Respondent. In this context, the Respondent has not made use of or preparations to use the disputed domain name in connection with a bona fide offering of goods or services. 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. Moreover, the disputed domain name incorporates a misspelling of the Complainant’s ALSTOM trademark by duplicating the letter “t”, together with a term closely related to the Complainant. The Panel considers there is a risk that Internet users will not notice the subtle misspelling of the ALSTOM trademark, the Panel therefore finds that the composition of the disputed domain name carries a risk of implied affiliation with the Complainant as it may mistakenly be seen as effectively impersonating or suggesting some connection to the Complainant. WIPO Overview 3.1, section 2.5.1. 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 Complainant’s trademark ALSTOM was registered many years prior to the registration of the disputed domain name. Further, the Complainant’s trademark ALSTOM is well known internationally. Therefore, the Respondent knew or should have known of the Complainant’s trademark when registering the disputed domain name. The Panel finds that the choice of the disputed domain name, incorporating a misspelling of the ALSTOM trademark together with a term closely related to the Complainant, cannot be a simple coincidence. 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. The Panel notes that the disputed domain name does not resolve to an active website but is simply parked at the Registrar’s page and is not materially used. The non-use of the disputed domain name does not affect the Panel’s finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy, given page 5 the distinctiveness and reputation of the ALSTOM trademark and the Complainant’s activities worldwide, the composition of the disputed domain name, and the lack of the Response. Moreover, the disputed domain name is almost identical to the Complainant’s domain name <alstomgroup.com, and it may be mistakenly considered by the public as belonging to the Complainant. Therefore, 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 <alsttomgroup.com> be transferred to the Complainant. /Rodrigo Velasco Santelices/ Rodrigo Velasco Santelices Sole Panelist Date: May 1, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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