Westmore · UDRP decision
WIPO · Case No. D2026-1212

Techcombankvietnam.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <techcombankvietnam.com>. It found the domain confusingly similar to the Complainant’s TECHCOMBANK mark, that the Respondent had no rights or legitimate interests, and that the domain was registered and used in bad faith. The bad-faith finding rested on the reputation of the mark, the domain’s incorporation of the mark with the geographically relevant term “vietnam,” the Respondent’s default, and passive holding of the inactive domain.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-04-30
Panelist(s)
Fano, Edoardo
Complainant
Vietnam Technological and Commercial Joint Stock Bank (TECHCOMBANK)
Respondent
Domain Service
Disputed domain(s)
techcombankvietnam.com
Domain history UDRP Intelligence

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

The case illustrates how an inactive domain can still satisfy the UDRP bad-faith requirement where it combines a reputed mark with a geographically meaningful term that suggests an official local presence. The same composition influenced all three elements: the complete mark established confusing similarity, the geographic addition created an affiliation risk, and the resulting misleading impression supported targeting and passive-holding bad faith.

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
2026-04-30
Panel
Fano, Edoardo
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Vietnam Technological and Commercial Joint Stock Bank (TECHCOMBANK) v. Domain Service Case No. D2026-1212 1. The Parties The Complainant is Vietnam Technological and Commercial Joint Stock Bank (TECHCOMBANK), Viet Nam, represented by IPMAX Law Firm, Viet Nam. The Respondent is Domain Service, Viet Nam. 2. The Domain Name and Registrar The disputed domain name <techcombankvietnam.com> is registered with Dominet (HK) Limited (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 20, 2026. On March 20, 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 (Dominet (HK) Limited / Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 24, 2026, providing the registrant and contact information disclosed by the Registrar, and requesting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on March 26, 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 19, 2026. page 2 The Center appointed Edoardo Fano 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. The Panel has not received any requests from the Complainant or the Respondent regarding further submissions, waivers, or extensions of deadlines, and the Panel has not found it necessary to request any further information from the Parties. Having reviewed the communication records in the case file provided by the Center, the Panel finds that the Center has discharged its responsibility under the Rules, paragraph 2(a), “to employ reasonably available means calculated to achieve actual notice to [the] Respondent”. Therefore, the Panel shall issue its Decision based upon the Complaint, the Policy, the Rules, and the Supplemental Rules and without the benefit of a response from the Respondent. The language of the proceeding is English, being the language of the Registration Agreement, as per paragraph 11(a) of the Rules. 4. Factual Background The Complainant is Vietnam Technological and Commercial Joint Stock Bank (TECHCOMBANK), a joint stock commercial bank of Viet Nam, established in 1993 and owning several trademark registrations worldwide for TECHCOMBANK, among which: - Vietnamese Trademark Registration No. 55953 TECHCOMBANK and design, registered on July 29, 2004; - International Trademark Registration No. 1124762 TECHCOMBANK and design, registered on February 3, 2012; and - United States of America Trademark Registration No. 6801947 TECHCOMBANK and design, registered on July 26, 2022. The Complainant also operates on the Internet with its official website being “www.techcombank.com”. According to the WhoIs records, the disputed domain name was registered on April 5, 2025, and it is inactive. 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 states that the disputed domain name is confusingly similar to its trademark TECHCOMBANK, as the disputed domain name wholly incorporates the Complainant’s trademark. Moreover, the Complainant asserts that the Respondent has no rights or legitimate interests in respect of the disputed domain name since it has not been authorized by the Complainant to register the disputed domain name or to use its trademark within the disputed domain name, it is not commonly known by the disputed domain name, and it is not making either a bona fide offering of goods or services or a legitimate noncommercial or fair use of the disputed domain name. page 3 The Complainant submits that the Respondent has registered the disputed domain name in bad faith, since the Complainant’s trademark TECHCOMBANK is well known in the banking and financial field. Therefore, the Respondent targeted the Complainant’s trademark at the time of registration of the disputed domain name and the Complainant contends that the passive holding of the disputed domain name qualifies as bad faith registration and use. B. Respondent The Respondent has made no reply to the Complainant’s contentions and is in default. In reference to paragraphs 5(f) and 14 of the Rules, no exceptional circumstances explaining the default have been put forward or are apparent from the record. A respondent is not obliged to participate in a proceeding under the Policy, but if it fails to do so, reasonable facts asserted by a complainant may be taken as true, and appropriate inferences, in accordance with paragraph 14(b) of the Rules, may be drawn. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 4.3. 6. Discussion and Findings Paragraph 4(a) of the Policy lists three elements, which the Complainant must satisfy in order to succeed: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. 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 3.1, section 1.7. Based on the available record, the Panel finds 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 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. While the addition of other terms, here “vietnam” (namely the country in which the Complainant is based), 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 Complainant’s trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. It is also well-accepted that a generic Top-Level Domain (“gTLD”), in this case “.com”, is typically ignored when assessing the similarity between a trademark and a domain name. WIPO Overview 3.1, section 1.11.1. Based on the available record, 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. While 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 often impossible 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. 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. The Complainant in its Complaint, and as set out above, has established a prima facie case that the Respondent has no rights or legitimate interests in the disputed domain name. It asserts that the Respondent, who is not currently associated with the Complainant in any way, is not using the disputed domain name for a legitimate noncommercial or fair use or in connection with a bona fide offering of goods or services. The prima facie case presented by the Complainant is enough to shift the burden of production to the Respondent to demonstrate that it has rights or legitimate interests in the disputed domain name. However, the Respondent has not presented any evidence of any rights or legitimate interests it may have in the disputed domain name. Finally, the Panel finds that the composition of the disputed domain name (incorporating the Complainant’s trademark in its entirety with the addition of the term “vietnam”, namely the country in which the Complainant is based) carries a risk of implied affiliation as it effectively impersonates or suggests sponsorship or endorsement by the Complainant. WIPO Overview 3.1, section 2.5.1. Based on the available record, 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, regarding the registration in bad faith of the disputed domain name, the reputation of the Complainant’s trademark TECHCOMBANK in the banking and financial field is clearly established, and the Panel finds that the Respondent more likely than not knew of the Complainant, and deliberately registered the disputed domain name in bad faith, especially because the disputed domain name incorporates the Complainant’s trademark in its entirety with the addition of the term “vietnam”, namely the country in which the Complainant is based, and where the Respondent is also supposedly based. As regards the use of the disputed domain name, being inactive, panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.1, section 3.3. Having reviewed the record, the Panel notes the reputation of the Complainant’s trademark in the banking and financial field, the nature of the disputed domain name (wholly incorporating the Complainant’s trademark, with the addition of the term “vietnam”, namely the country in which the Complainant is based), and the failure of the Respondent to submit a response, 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 5 Furthermore, the Panel considers that the nature of the inherently misleading disputed domain name, which incorporates the Complainant’s trademark in its entirety with the addition of the term “vietnam” (namely the country in which the Complainant is based), further supports a finding of bad faith. WIPO Overview 3.1, section 3.2.1. Based on the available record, 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, <techcombankvietnam.com>, be transferred to the Complainant. /Edoardo Fano/ Edoardo Fano Sole Panelist Date: April 30, 2026

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

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