Westmore · UDRP DecisionAlstomcgroup.com
The Panel ordered transfer of <alstomcgroup.com>. It found the domain confusingly similar to the Complainant’s ALSTOM trademark because the mark remained clearly recognizable despite the added letter “c” and term “group.” The Respondent did not rebut the Complainant’s prima facie case concerning rights or legitimate interests. Bad faith was found based on the longstanding and well-known ALSTOM mark, the domain’s close resemblance to the Complainant’s <alstomgroup.com> domain, passive holding through an error page, use of a privacy service, and contact details that did not appear readily verifiable.
The timeline behind alstomcgroup.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 alstomcgroup.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a passive-holding transfer where the disputed domain did more than incorporate a well-known mark: it closely imitated the Complainant’s longstanding <alstomgroup.com> domain by inserting a single letter. The Panel treated that resemblance, the age and reputation of the ALSTOM rights, the lack of any legitimate explanation, privacy-service use, and contact details that did not appear readily verifiable as collectively sufficient for bad faith despite the absence of an active website.
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. Susie Allen Case No. D2026-1860 1. The Parties The Complainant is ALSTOM, France, represented by Lynde & Associes, France. The Respondent is Susie Allen, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <alstomcgroup.com> is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 30, 2026. On April 30, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On April 30, 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 (See PrivacyGuardian.org / Privacy User #917a03f5) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 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 May 4, 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 May 8, 2026. In accordance with the Rules, paragraph 5, the due date for Response was May 28, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 29, 2026. The Center appointed Estela Mariel de Luca as the sole panelist in this matter on June 4, 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 is a French company founded in 1928, active in the fields of power generation, power transmission and rail infrastructure. It develops and markets a comprehensive range of systems, equipment and services for the railway industry and conducts business worldwide, with presence in the United States, Iceland, United Kingdom (the), Ireland, France, Netherlands (Kingdom of the), Sweden, Canada and Germany. The Complainant is the owner of various trademark registrations including: - United States trademark registration No. 4570546 ALSTOM, registered on July 22, 2014, in int ernational classes 7, 9, 12, 35, 37, 39, and 42. - United States trademark registration No. 4236513 , registered on November 6, 2012, in int ernational class 12. - Icelandic trademark registration No. V0033613, registered on July 20, 1999, in international classes 6, 7, 9, 11, 12, 16, 19, 24, 35, 36, 37, 38, 39, 40, 41, and 42; - French trademark registration No. 98727757 , registered on April 10, 1988, in international classes 6, 7, 9, 11, 12, 19, 37, 39, 40, and 42; and - European Union trademark Registration No. 000948729 ALSTOM, registered on August 8, 2001, in int. classes 6, 7, 9, 11, 12, 16, 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 (“TLDs”) that reflect its trademark, such as: <alstomgroup.com> registered since November 14, 2000; <alstom.com> registered since January 20, 1998; <alstomusa.com> registered since August 10, 2020; <alstom.net> registered since April 1, 2000; <alstom.com.uk> registered since June 15, 1998; and <alstom.cn> registered since July 7, 2004. The disputed domain name was registered on March 27, 2026. At the time of the filing of the Complaint it displayed an error message. 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 disputed domain name wholly contains the ALSTOM trademark. The Complainant further submits that the additional letter “c” and the term “group” does not prevent a finding of confusing similarity, arguing that the letter “c” is unlikely to be noticed by Internet users and that the term “group” would be perceived as referring to the Complainant’s group of companies. In this regard, the Complainant notes that it owns and uses the domain name <alstomgroup.com>, which supports the email addresses of employees within the ALSTOM group of companies. page 3 The Complainant also cites several prior UDRP decisions in which the ALSTOM mark was recognized as being well known. Finally, the Complainant submits that the “.com” TLD should be disregarded for purposes of the comparison under the first element of the Policy. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name. According to the Complainant, the Respondent is not affiliated with the Complainant and has not been authorized, licensed, or otherwise permitted to register or use the ALSTOM trademark. The Complainant further submits that the Respondent has not applied for or obtained any trademark registrations corresponding to the ALSTOM mark and that there is no evidence that the Respondent is commonly known by the disputed domain name or by the name “Alstom”. The Complainant submits that the disputed domain name was registered and is being used in bad faith, as it wholly incorporates the well-known ALSTOM trademark and was registered long after the Complainant acquired trademark rights, making it unlikely that the Respondent was not aware of the Complainant ́s activities or its trademark at the time of registration. The Complainant further states that the Respondent remained silent and did not reply to its communications and used a privacy or proxy service when registering the disputed domain name in an attempt to conceal its identity. According to the Complainant, its searches did not reveal any apparent connection between the Respondent and the entity name appearing in the Respondent’s email address, while the address and telephone number provided by the Respondent did not allow the Respondent to be clearly identified or contacted. In addition, the Complainant contends that the disputed domain name has not been used in connection with a bona fide offering of goods or services, noting that the disputed domain name resolves to an error page. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. The Respondent’s default in the case at hand does not automatically result in a decision in favor of the Complainant, however, paragraph 5(f) of the Rules provides that if the Respondent does not submit a Response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel may draw such inferences from the Respondent’s failure to submit a Response as it considers appropriate. page 4 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 Complainant’s mark is reproduced within the disputed domain name. Although the addition of the letter “c” and the term “group”, may bear on the assessment of the second and third elements, the Panel finds that the ALSTOM trademark remains clearly recognizable within the disputed domain name and does not prevent a finding of confusing similarity. WIPO Overview 3.1, sections 1.7 and 1.8. Further, it is well established that the TLD “.com” may be disregarded for the purpose of assessing confusing similarity under the first element of the Policy. WIPO Overview 3.1, section 1.11.1 . 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. In addition, there is no evidence that the Respondent has been commonly known by the disputed domain name, that it has used the disputed domain name in connection with a bona fide offering of goods or services, or that it has made a legitimate noncommercial or fair use of the disputed domain name. Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy. 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. 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. Noting that the Complainant’s trademark was registered decades ago and the disputed domain name is highly similar to the Complainant’s domain name <alstomgroup.com>, the Panel finds that the Respondent registered the disputed domain name in bad faith. Panels have found that the non-use of a domain name, including where it resolves to an error page, does not by itself prevent a finding of bad faith under the doctrine of passive holding. In the present case, such a finding is reinforced by the following factors: (i) the Complainant’s rights in the well-known ALSTOM trademark predate the registration of the disputed domain name by many years; (ii) the disputed domain name was registered by an unaffiliated entity and closely resembles the Complainant’s tr ademarks and domain name <alstomgroup.com>, thereby reinforcing an apparent association with the Complainant; (iii) the Respondent sought to conceal its identity through the use of a privacy service and provided contact details that do not appear readily verifiable. Taking the above factors into consideration, the Panel is unable to conceive of any plausible good-faith use to which the disputed domain name could be put. 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 <alstomcgroup.com> be transferred to the Complainant. /Estela Mariel de Luca/ Estela Mariel de Luca Sole Panelist Date: June 18, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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