Westmore · UDRP DecisionAlstomvd.com
The Panel ordered transfer of <alstomvd.com>. It found the domain confusingly similar to the Complainant’s ALSTOM mark because it reproduced the mark in its entirety with the addition of “vd”. The Respondent lacked rights or legitimate interests because it was not authorized or affiliated, was not shown to be commonly known by the domain, and used the domain for a Vietnamese-language webpage reproducing an earlier ALSTOM logo, displaying a train image, and requesting users to create an account. The Panel found bad-faith registration and use based on the Complainant’s prior rights, the distinctive character of ALSTOM, the website content, and the resulting phishing, passing-off, and implied-affiliation concerns.
The timeline behind alstomvd.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 alstomvd.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a targeted-impersonation pattern in which a distinctive mark is combined with a short letter string and supported by website content that reproduces the complainant’s branding and industry imagery. The account-creation request was particularly significant because it moved the case beyond domain composition alone and supported phishing, passing-off, and implied-affiliation concerns.
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. alstomvd, alstomvd Case No. D2026-1275 1. The Parties The Complainant is Alstom, France, represented by Lynde & Associes, France. The Respondent is alstomvd, alstomvd, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <alstomvd.com> is registered with Amazon Registrar, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 25, 2026. On March 25, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On March 26, 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 (Identity Protection Service) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 30, 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 April 2, 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 April 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 27, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 28, 2026. The Center appointed Delia-Mihaela Belciu as the sole panelist in this matter on May 15, 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 page 2 Rules, paragraph 7. 4. Factual Background The Complainant is a French company created in 1928, currently a global leader in the world of transport infrastructures, employing 84,000 professionals in more than 60 countries. Between April 1, 2024, and March 31, 2025, the Complainant’s order intake reached EUR 19,8 billion, while its sales reached EUR 18,5 billion. The Complainant operates worldwide and plays a significant role in the manufacture and overhaul of rolling stock. The Complainant is present in the United States in the areas of rail and airport transport, delivering more than 12,000 new or renovated vehicles for its United States customers, including the first high-speed trains made in the United States. The Complainant is also the first private operator in the United States, serving more than 20 rail and airport customers and moving millions of passengers daily. To date, the Complainant employs around 4,500 people in the United States on 10 main sites across the country. The Complainant is in particular the owner of the following ALSTOM trademark registrations: - the United States Trademark No. 4570546, for ALSTOM, registered on July 22, 2014, for goods and services in classes 1, 6, 7, 8, 9, 11, 12, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41, 42, 43, 45; - the European Union Trademark No. 000948729 for 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, 42; - International Trademark Registration No. 706292 for 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, 42, designating several territories for protection, including Viet Nam. The Complainant also owns numerous domain names under various generic and country code To p-Level Domains that comprise its ALSTOM trademark, such as <alstom.com> registered since January 20, 1998, used in relation to ALSTOM group’s website. Moreover, within the Complainant’s group of companies, there are several companies under Alstom corporate name such as: ALSTOM Power Systems, ALSTOM Holdings, ALSTOM Shipworks, ALSTOM APTIS, ALSTOM Transport SA, etc. The disputed domain name <alstomvd.com> was registered on January 16, 2026, and resolved, at the date when the Complaint was filed, to a webpage, in Vietnamese language, reproducing a prior version of the ALSTOM trademark, requesting Internet users to create an account to access the content of the 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. page 3 Notably, the Complainant contends that: (i) the disputed domain name is confusingly similar to the Complainant’s ALSTOM trademark , as it incorporates it in its entirety, with the addition of the term “vd”, which corresponds to one of Viet Nam’s alpha codes, followed by the generic Top-Level Domain (“gTLD”) “.com”; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name for a number of reasons, among which that: (1) the Complainant has not authorized the Respondent to register the disputed domain name, (2) the Respondent is not affiliated in any way to the Complainant, (3) to the best of the Complainant’s knowledge, the Respondent did not apply for or obtained any trademark registrations related to the terms “alstom” or “alstomvd”, (4) the disputed domain name redirects to a webpage, in Vietnamese language, reproducing a prior version of the ALSTOM trademark, without the Complainant’s authorization, along with an image of a train (field in which the Complainant is well known), requesting Internet users to create an account to access the content of the website; (iii) the disputed domain name was registered and is being used in bad faith for a number of reasons, among which that, (1) in view of the well-known character of the denomination ALSTOM belonging to the Complainant, it is not possible that the Respondent was not aware of the Complainant’s activities when such registered the disputed domain name, (2) the Respondent is trying to hide its real identity, as the Respondent did not disclose its identity when it registered the disputed domain name. The Complainant further asserts that the details of the Respondent provided to such during the UDRP procedure are clearly fictive, as “alstomvd” is not a first or a last name (especially when this word appears in a repeated manner), and that, according to its verifications on Google Maps, the Respondent’s address does not exist, (3) the disputed domain name redirects to a webpage making the Internet users believe that it is operated by the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings In order for the Complainant to succeed, such must prove, according to paragraph 4(a) of the Policy, that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests with respect to the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. In case all three elements above have been fulfilled, the Panel is able to grant the remedy requested by the Complainant. Thus, the Panel will deal with each of the requirements in turn. 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. page 4 The Panel finds that the entirety of the ALSTOM mark is reproduced within the disputed domain name with the addition of the term “vd”, which does not prevent a finding that the disputed domain name is confusingly similar to the Complainant’s ALSTOM mark. 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, in this case “vd”, 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. In what concerns the addition of the gTLD “.com” in relation to the disputed domain name, such is viewed as a standard registration requirement, and is disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. Based on the available record, the Panel finds that 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 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. Based on the available evidence, the Respondent is not affiliated with the Complainant, nor has the Complainant’s authorization to use the ALSTOM mark. Also, notwithstanding the Respondent’s name, there is no evidence that the Respondent is commonly known by the disputed domain name. Moreover, the disputed domain name resolved, at the date when the Complaint was filed, to a webpage, in Vietnamese language, reproducing a prior version of the ALSTOM trademark, requesting Internet users to create an account to access the content of the website, which might suggest that, the disputed domain name may have been used for phishing purposes. Panels have held that the use of a domain name for an illegal activity, as in this case phishing, passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Furthermore, the composition of the disputed domain name, incorporating the Complainant’s ALSTOM mark with the addition of the term “vd”, in combination with the content on the webpage, available at the time when the Complaint was filed, namely reproducing a prior version of the ALSTOM trademark, along with an image of a train (field in which the Complainant is well-known) create a risk of Internet user confusion and may give rise to an implied affiliation with the Complainant. page 5 All the above does not amount to a bona fide offering of goods or services, or to a legitimate noncommercial or fair use of the disputed domain name. 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, the Panel notes that the Complainant’s rights in the ALSTOM mark predate the registration date of the disputed domain name. In light of the above as well as of the distinctive character of the ALSTOM mark, the Panel finds that it is not conceivable that the Respondent registered the disputed domain name without knowledge of the Complainant’s ALSTOM mark, which supports a finding of bad faith registration. WIPO Overview 3.1, section 3.2.2. 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 Respondent’s incorporation into the disputed domain name of the Complainant’s distinctive ALSTOM mark in its entirety, with the addition of the term “vd”, the failure of the Respondent to submit a response in this file, as well the fact that, according to the evidence available in this file, the disputed domain name resolved, at the time when the Complaint was filed, to a webpage reproducing a prior version of the ALSTOM trademark, along with an image of a train (field in which the Complainant is well-known), requesting Internet users to create an account to access the content of the website, is clear evidence of bad faith registration and use of a domain name, and all lead to a finding of bad faith. Panels have held that the use of a domain name for an illegal activity, as in this case phishing, passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy and 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 <alstomvd.com> be transferred to the Complainant. /Delia-Mihaela Belciu/ Delia-Mihaela Belciu Sole Panelist Date: May 29, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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