Westmore · UDRP DecisionAltsormgroup.com
The Panel ordered transfer of <altsormgroup.com> to ALSTOM. It found the domain confusingly similar to the ALSTOM mark because the mark remained recognizable despite altered letters and the addition of “group,” characterizing the domain as an instance of typosquatting. The Respondent did not rebut ALSTOM’s prima facie showing on rights or legitimate interests. Considering the reputation or distinctiveness of ALSTOM, the domain’s composition, its passive holding, the Respondent’s lack of engagement, and the Panel’s finding concerning identity concealment, the Panel found registration and use in bad faith.
The timeline behind altsormgroup.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 altsormgroup.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain containing transposed or additional letters can remain confusingly similar where the underlying mark is recognizable, especially when paired with a term already used in the complainant’s domain portfolio. It also demonstrates that inactivity does not insulate a registrant from a bad-faith finding when the domain’s composition, prior trademark rights, lack of a credible explanation, and other circumstances support passive holding.
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. Simon Taylor Case No. D2026-1372 1. The Parties The Complainant is ALSTOM, France, represented by Lynde & Associes, France. The Respondent is Simon Taylor, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <altsormgroup.com> is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 31, 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 March 31, 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 April 1, 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 8, 2026. In accordance with the Rules, paragraph 5, the due date for Response was April 28, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on April 29, 2026. page 2 The Center appointed Ahmet Akgüloğlu as the sole panelist in this matter on May 5, 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 a French company established in 1928 that operates in the transport infrastructure field, focusing on the manufacture and overhaul of rolling stock, and is active around the globe. The Complainant, is the owner of several trademark registrations, such as the ALSTOM (logo) United States trademark with the registration number 4236513, registered in international classes 1, 6, 7, 8, 9, 12, 13, 17, 19, and 24 on November 6, 2012; ALSTOM United States trademark with the registration number 4570546, registered in international classes 1, 6, 7, 8, 9, 11, 12, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41, 42, 43, and 45 on July 22, 2014; ALSTOM (logo) United States trademark with the registration number 2898433, registered in international classes 1, 6, 7, 9, 11, 12, 13, 16, 17, 19, 21, 24, 35, 36, 37, 38, 39, 40, 41, and 42 on November 2, 2024; ALSTOM International trademark with registration number 706292, registered in international classes 1, 2, 4, 6, 7, 9, 11, 12, 13, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42 on August 28, 1998. The Complainant also owns several domain names, inter alia, <alstom.com>, which was registered on January 20, 1998; <alstomgroup.net> which was registered on June 2, 2017; <alstomgroup.com> which was registered on November 14, 2000; and <alstomgroup.fr> which was registered on June 2, 2017. The disputed domain name was registered on October 21, 2025, and consists of the terms “altsorm” and “group”. As the Complainant notes, the disputed domain name resolves to an inactive website. As the Respondent failed to submit their response, there is no concrete information regarding the Respondent. 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 Complainant asserts that the disputed domain name <altsormgroup.com> is confusingly similar to their trademark ALSTOM, as outlined in paragraph 4(a)(i) of the Policy. The Complainant argues that the disputed domain name mimics their earlier trademarks by containing a spelling error (“altsorm”) and reversing the letters “s” and “t” at the beginning. The addition of the letter “r” at the end of the name is not visually noticeable. The Complainant also points out that the first letters “al” and the ending of the disputed domain name <altsormgroup.com> closely resemble those of the Complainant’s ALSTOM trademark. This similarity could lead Internet users to mistakenly read the disputed domain name as <alstomgroup.com>. Furthermore, the Complainant argues that it constitutes typosquatting. The Complainant contends that their prior trademark ALSTOM is clearly recognizable within the disputed domain name, particularly given its position at the beginning and its association with the descriptive term “group” that appears next to company names. page 3 Furthermore, the Complainant highlights that, due to the reputation and well-known status of its trademark ALSTOM, the public is likely to perceive the domain name <altsormgroup.com> as being associated with ALSTOM. The Complainant also claims that the Respondent has no affiliation with them. Additionally, the disputed domain name has been inactive since its registration date, indicating it has not been used by the Respondent. The Complainant attempted to contact the Respondent through the Registrar’s online form but received no response. The Complainant argues that the lack of identifiable information about the Respondent in the WhoIs extract suggests an effort to conceal their identity. The Complainant contends that the Respondent has not demonstrated any intention to use the disputed domain name in connection with a legitimate offering of goods and services. In conclusion, the Complainant argues that the Respondent acquired the disputed domain name long after the ALSTOM marks became well-known, attempts to hide their identity, and has kept the disputed domain name inactive. All these factors indicate that the Respondent is acting in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs the Panel to “decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. Paragraph 4(a) of the Policy requires that the complainant prove each of the following three elements to obtain an order that the disputed domain name should be transferred or cancelled: (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 in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. The Panel will proceed to analyze whether the three elements of paragraph 4(a) of the Policy are satisfied in this proceeding. 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 information provided in the Complainant's Complaint and accompanying documents demonstrates that the Complainant holds rights to the trademark ALSTOM due to its prior trademark registrations, trade name, and domain name registrations, which date earlier than the registration date of the disputed domain name, October 21, 2025. Based on the details in the Complaint, it is understood that the Complainant has been using the term “ALSTOM” in the manufacture and overhaul of rolling stock. 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. page 4 Aside from the generic Top-Level Domain (“gLTD”) “com” the disputed domain name is composed of phrases “altsorm” and “group”. The disputed domain name shares the same initial letters “a” and “l”, and ends with the identical letter “m”, similar to the Complainant’s trademarks ALSTOM. The additional letters and their different placements in the middle part of the disputed domain name do not prevent confusing similarity. The disputed domain name appears to be an instance of typosquatting. WIPO Overview 3.1. section 1.9. Although the addition of the term “group” may bear on the assessment of the second and third elements, the Panel finds that the addition of such a 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. Thus, the Panel finds 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. The Respondent did not submit a response to the Complainant’s Complaint. The Panel observed that the disputed domain name is currently inactive. Evidence provided by the Complainant in Annex 8 shows screenshots taken at various times, indicating that the disputed domain name is not being used for any bona fide goods and services but it has been inactive at such times. There is no indication that the Respondent is known by the disputed domain name, nor is there any evidence of legitimate noncommercial or fair use related to the disputed domain name. 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 has not been using the disputed domain name for any commercial activities that promote bona fide goods or services. Despite the Complainant's efforts to resolve the matter amicably, the Respondent has shown no willingness to reach an agreement. Additionally, the Respondent has concealed its identity in the disputed domain name registration, which may indicate an intention to engage in cybersquatting. It is evident that by making minor alterations to the Complainant's prior trademark, ALSTOM, the Respondent is attempting to create an association with the Complainant. page 5 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. 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 or reputation of the Complainant’s trademark, and the composition of the disputed domain name, 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 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 <altsormgroup.com> be transferred to the Complainant. /Ahmet Akgüloğlu/ Ahmet Akgüloğlu Sole Panelist Date: May 19, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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