Westmore · UDRP DecisionAlstom-ng.com
The Panel ordered transfer of <alstom-ng.com>. It found the domain confusingly similar to the ALSTOM mark because the mark remained recognizable despite the addition of “-ng”. The Respondent lacked rights or legitimate interests, and the domain’s prior use for a login interface displaying the ALSTOM logo and the title “Alstom - Smart Investment Platform” supported findings of impersonation, attempted collection of personal data, attraction for potential commercial gain, and bad-faith registration and use.
The timeline behind alstom-ng.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 alstom-ng.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining a well-known mark with a geographic abbreviation can support transfer when it is used for a branded login interface. The strongest evidence extended beyond the domain string itself: the copied logo, investment-platform title, apparent attempt to collect personal data, and false contact details collectively supported targeting, impersonation, 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. ss sd Case No. D2026-1359 1. The Parties The Complainant is ALSTOM, France, represented by Lynde & Associes, France. The Respondent is ss sd, Hong Kong, China. 2. The Domain Name and Registrar The disputed domain name <alstom-ng.com> is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 30, 2026. On March 31, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 1, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on the same date, 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 3, 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. page 2 The Center appointed Ugur G. Yalçiner as the sole panelist in this matter on May 7, 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, Alstom, is a French company founded in 1928 and globally operating in the railway and transport infrastructure sector. It operates in more than 60 countries with approximately 80,000 employees, providing a wide range of rail systems, equipment, and related services worldwide. The Complainant is the owner of numerous trademark registrations consisting of the term “ALSTOM”, some of which are listed below: - Hong Kong, China trademark registration ALSTOM with registration No. 199916331AA, registered on December 16, 1999 in classes 7, 9, 12, 37, 39, and 42; - International trademark registration ALSTOM with registration No. 706360, registered on August 28, 1998, 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 - European Union Trade Mark registration ALSTOM with registration No. 000948729, registered on August 8, 2001, in classes 6, 7, 9, 11, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42. The Complainant further owns the domain name <alstom.com>, registered on January 20, 1998, which resolves to its official website, to which its other domain names incorporating the ALSTOM mark redirect. The disputed domain name was registered on March 12, 2026 and does not currently resolve to an active website. However, according to the Complaint, it previously resolved to a website displaying a login page featuring the Complainant’s ALSTOM logo. 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. The Complaint includes the following contentions: (i) Identical or Confusingly Similar The Complainant contends that the disputed domain name is confusingly similar to its ALSTOM trademarks, as it wholly reproduces the mark with the addition of the letters “ng”, which may refer to Nigeria, and the “.com” generic Top-Level Domain (“TLD”). The Complainant submits that the letters “ng” will be perceived by Internet users as a reference to Nigeria, “ng” being the country’s country code TLD, and that the addition of such geographical term does not prevent a finding of confusing similarity. The Complainant further states that the ALSTOM mark is entirely contained in the disputed domain name and that, in light of its well-known character, Internet users are likely to recognize the Complainant’s mark within the disputed domain name and assume that it is associated with the Complainant. page 3 (ii) Rights or Legitimate Interests The Complainant submits that the Respondent has failed to prove any rights or legitimate interests in respect of the disputed domain name. The Respondent is not affiliated with the Complainant and has not been authorized, licensed or otherwise permitted to use the ALSTOM trademark, has not applied for or obtained any trademark rights in the sign “ALSTOM”, and is not commonly known by that name. The Complainant further asserts that the Respondent did not reply to its communications and therefore has no rights or legitimate interests in the disputed domain name. (iii) Registration and Use in Bad Faith The Complainant submits that the disputed domain name was registered and is being used in bad faith. It argues that the disputed domain name wholly incorporates its well-known ALSTOM trademark and was registered long after such mark became well known, making it unlikely that the Respondent was unaware of the Complainant’s rights. The Complainant further states that the Respondent remained silent and did not reply to its communications, reproduced the Complainant’s logo on a website displaying a login page, and provided incomplete or inconsistent contact information, indicating an attempt to conceal its identity. In light of these circumstances, the Complainant contends that 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 In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three elements are present: (i) the disputed domain name registered by the Respondent 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 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 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 for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel is satisfied that the Complainant is the owner of the trademark ALSTOM registered in several jurisdictions. The disputed domain name incorporates the Complainant’s trademark ALSTOM in its entirety, together with a hyphen and the additional letters “ng”, which corresponds to the country code for Nigeria. In this regard, the Panel considers that the mere addition of “-ng” does not prevent a finding of confusing similarity with the Complainant’s trademark, as the Complainant’s ALSTOM trademark remains recognizable within the disputed domain name (WIPO Overview 3.1, section 1.8). page 4 It is an accepted principle that TLDs, in this case “.com”, are to be typically disregarded in the consideration of the issue of whether a domain name is identical or confusingly similar to a Complainant’s trademark. WIPO Overview 3.1, section 1.11.1. In the light of the above, the Panel finds that the disputed domain name is confusingly similar to the Complainant’s registered trademark and that the requirements in paragraph 4(a)(i) of the Policy are fulfilled. 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 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 notes that the Respondent does not have any registered trademarks or trade names, and that no license or authorization of any kind has been granted to the Respondent by the Complainant to use its trademark. Nevertheless, as evidenced by the Complainant’s assertions and supporting documents, the disputed domain name resolved to a website displaying a login interface prominently featuring the Complainant’s ALSTOM logo without its authorization, and in the lack of evidence indicating a noncommercial or fair use. There is also no evidence that the Respondent has been commonly known by the disputed domain name. The Respondent’s use of the disputed domain name therefore does not support a finding of rights or legitimate interests in the disputed domain name on the part of the Respondent. As a result, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name, and the requirements of paragraph 4(a)(ii) of the Policy are therefore fulfilled by the Complainant. 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 is satisfied with the relevant evidence submitted by the Complainant showing that it owns trademark rights in ALSTOM, which have been registered and used for many years prior to the registration of the disputed domain name. page 5 The Panel notes that the Complainant’s trademark is widely known in the railway and transport infrastructure sector, as it has been recognized as such in UDRP decisions, namely ALSTOM v. Daniel Bailey (Registrant I D: tuuROSvPJbZdd2XO), WIPO Case No. D2010-1150; and Alstom S.A. and General Electric Company v. Sichuan Electricity Transmission and Distribution Engineering Co., Ltd, WIPO Case No. DCO2016-0032. Several UDRP panels have held that the mere registration of a domain name that is identical or confusingly similar (e.g., domain names incorporating the mark plus a descriptive term as in this case) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.1, section 3.1.4. The Panel considers that the Respondent could not have been unaware of the Complainant and its trademark at the time of registration of the disputed domain name. The Panel finds that the Respondent’s purpose in registering the disputed domain name was to take unfair advantage of the Complainant’s trademark, as the disputed domain name resolved to a website displaying a login interface prominently featuring the Complainant’s ALSTOM logo and was entitled “Alstom - Smart Investment Platform”. In this regard, the use of a login interface strongly suggests an attempt to collect personal data from Internet users by creating a false impression of affiliation with the Complainant. The Panel is therefore convinced that the Respondent intended to attract Internet users to its website by creating a likelihood of confusion with the Complainant’s trademark for potential commercial gain within the meaning of paragraph 4(b)(iv) of the Policy. Panels have held that the use of a domain name for illegitimate activity, such as impersonation or passing off, constitutes bad faith. WIPO Overview 3.1, section 3.4. In the present case, there is also evidence that the Respondent provided false contact details to conceal its identity when registering the disputed domain name. Previous panel decisions have found that the provision of false WhoIs information may may support a finding of bad faith. WIPO Overview 3.1, section 3.2.1. Having reviewed the record, the Panel finds that the Respondent’s registration and use of the disputed domain name constitute bad faith under the Policy. Having considered all the facts in this case, the Panel finds that the Complainant has sustained its burden of proof in showing that the disputed domain name was registered and used in bad faith. 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 <alstom-ng.com> be transferred to the Complainant. /Ugur G. Yalçiner/ Ugur G. Yalçiner Sole Panelist Date: May 13, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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