Westmore · UDRP decision
WIPO · Case No. D2026-1940

Microsoftcn.work

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <microsoftcn.work> after finding that it was confusingly similar to Microsoft Corporation’s MICROSOFT marks, that the Respondent lacked rights or legitimate interests, and that the domain name was registered and used in bad faith. The Panel relied on the incorporation of the world-famous MICROSOFT mark, the apparent unauthorized use of another party’s identity in the registration details, and evidence that MX records enabled email use consistent with the Complainant’s impersonation allegation.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-22
Panelist(s)
Dernbach, Peter J.
Complainant
Microsoft Corporation
Respondent
Name Redacted
Disputed domain(s)
microsoftcn.work
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind microsoftcn.work

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 microsoftcn.work — 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 microsoftcn.work.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that a domain need not host an active website to support a bad-faith-use finding where technical email configuration and the surrounding evidence make impersonation plausible. It also shows how apparent identity theft in registration data can independently reinforce bad-faith registration and justify exceptional redaction measures.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-06-22
Panel
Dernbach, Peter J.
Full decision
13 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Microsoft Corporation v. Name Redacted Case No. D2026-1940 1. The Parties The Complainant is Microsoft Corporation, United States of America, represented by Edward Nathan Sonnenbergs Inc., South Africa. The Respondent is Name Redacted. 1 2. The Domain Name and Registrar The disputed domain name <microsoftcn.work> (the “Disputed Domain Name”) is registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (“www.net.cn”) (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on May 5, 2026. On May 6, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On May 7, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 7, 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 in English on May 12, 2026. On May 7, 2026, the Center informed the parties in Chinese and English, that the language of the registration agreement for the disputed domain name is Chinese. On May 12, 2026, the Complainant requested English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. 1 The Respondent’s name is redacted here as it appears to have engaged in identity theft by using the name and address of another individual/entity when registering the Disputed Domain Name. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the Disputed Domain Name, which includes the name of Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding, and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 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 in Chinese and English of the Complaint, and the proceedings commenced on May 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 2, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 3, 2026. The Center appointed Peter J. Dernbach as the sole panelist in this matter on June 8, 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 Washington-based company that serves as one of the world’s major developers and providers of software systems, applications, and cloud computing services. The Complainant is the owner of the well-known MICROSOFT trademarks (the “MICROSOFT Mark(s)”) around the world, including without limitation: - International Registration (word & design) No. 1142097, registered on August 22, 2012, designating Australia, Switzerland, China, Egypt, European Union, Croatia, Israel, Japan, Kenya, Republic of Korea, Morocco, Norway, Oman, Russian Federation, Singapore, Türkiye, Ukraine, and Viet Nam; - United States of America Registration MICROSOFT (word) No. 1256083, registered on November 1, 1983; and - European Union Registration MICROSOFT (word) No. 000330910, registered on May 7, 1999. The Complainant also owns the official domain names <microsoft.com> and <microsoft.net>. The Disputed Domain Name was registered on April 1, 2025. It does not resolve to an active website as of the time of this decision. The Respondent’s name is redacted here as it appears to have engaged in identity theft by using the name and address of another individual/entity when registering the Disputed Domain Name. According to the Registrar's verification response, the Respondent is reportedly an individual/entity located in the United States of America. 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. (i) The Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights. page 3 The Complainant contends that the Disputed Domain Name wholly incorporates the Complainant’s MICROSOFT Mark and is therefore confusingly similar to the MICROSOFT Mark. The inclusion of “cn” in the Disputed Domain Name is insufficient to avoid the confusing similarity since “cn” is a common country code for China and is descriptive and non-distinctive in nature. The generic Top-Level Domain (“gTLD”) “.work” should also be disregarded under the first element test. (ii) The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name. The Complainant asserts that it has not licensed or otherwise permitted the Respondent to use any of its trademarks or to register a domain name incorporating its well-known and registered MICROSOFT Mark (or a domain name which will be associated with this trademark). The Complainant also contends that the Respondent is not making a legitimate noncommercial or fair use of the Disputed Domain Name. The Complainant points out that there is no evidence showing the Respondent has ever used, or made demonstrable preparations to use, the Disputed Domain Name in connection with a bona fide offering of goods or services; nor is there evidence that the Respondent is commonly known by the Disputed Domain Name or any corresponding name. Therefore, the Complainant believes it has made a prima facie case that the Respondent lacks any right or legitimate interest in the Disputed Domain Name. (iii) The Disputed Domain Name has been registered and is being used in bad faith. The Complainant argues that, given the well-known and famous status of the MICROSOFT Marks, the Respondent surely knew of the MICROSOFT Marks when registering the Disputed Domain Name. The term MICROSOFT is so unique that the Respondent couldn’t have chosen the Disputed Domain Name out of coincidence without the intention of invoking a misleading association with the Complainant. While claiming that the Disputed Domain Name is passively held by the Respondent, the Complainant also states that the Disputed Domain Name has been used in an email address to send an email and statement to a third party, which statement falsely claimed that an enterprise-verified official email address under the Disputed Domain Name is the sole channel of communication on behalf of Microsoft. For the foregoing reasons, the Complainant requests a finding that the Disputed Domain Name has been registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1 Language of the Proceeding Notwithstanding Chinese being the language of the registration agreement for the Disputed Domain Name, the Panel, in exercising its discretion under paragraph 11(a) of the Rules, determines that the language of the proceeding should be English, as requested by the Complainant, in consideration of the following factors. First, according to the Registrar, the Respondent is reportedly an entity or individual located in United States of America, where English is the primary language. The Panel therefore reasonably supposes the Respondent is capable of communicating in English. Second, the Center issued procedural notifications in both Chinese and English, ensuring that the Respondent was fully informed and had a fair opportunity to object to the Complainant’s request that English be the language of proceeding, yet the Respondent chose not to participate. page 4 Finally, the Complainant, as an American entity, has filed the Complaint in English and claims to have no knowledge of the Chinese language. The Panel believes requiring translation of the Complaint and all supporting annexes into Chinese would impose an undue financial and administrative burden on the Complainant, cause unwanted delay, and incur unnecessary additional costs to the proceeding. Accordingly, the Panel determines that English should be the language of the proceeding. 6.2 Substantive Issues In accordance with paragraph 4(a) of the Policy, in order to succeed in this administrative proceeding and obtain the requested remedy (in this case, transfer of the Disputed Domain Name), the Complainant must prove that each of the three following elements are present: (i) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has right; (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 Panel finds the Complainant has established that it has rights in the MICROSOFT Marks. The Panel finds the Disputed Domain Name confusingly similar to the Complainant’s trademarks, as the Disputed Domain Name <microsoftcn.work> incorporates the Complainant’s MICROSOFT Mark in its entirety. The addition of the element “cn” is a standard geographic abbreviation for China and does not prevent a finding of confusing similarity under the first element according to UDRP panels’ well-established practice, since the well-known MICROSOFT Mark remains readily recognizable within the Disputed Domain Name. WIPO Overview 3.1, section 1.8. The gTLD “.work” is viewed as a standard functional requirement of domain registration and should be disregarded for the purpose of assessing confusing similarity. WIPO Overview 3.1, section 1.11.1. Accordingly, the Panel finds that the Complainant has satisfied the first element of the Policy. 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. page 5 In this case, the Complainant has asserted that it has never licensed or otherwise permitted the Respondent to use any of the Complainant’s trademarks or to register a domain name incorporating the MICROSOFT Mark. As the Complainant has claimed, the Panel finds no evidence from the records showing that the Respondent is making a legitimate noncommercial or fair use of the Disputed Domain Name; nor is there any proof that the Respondent has ever used, or made demonstrable preparations to use, the Disputed Domain Name in connection with a bona fide offering of goods or services. There is also no credible evidence showing that the Respondent has been commonly known by the Disputed Domain Name or MICROSOFT. The Complainant has confirmed that the Respondent is not known to, or affiliated with the Complainant. Given the above, 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. Therefore, the Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Under the third element of the Policy, the complainant must demonstrate that the disputed domain name has been registered and is being used in bad faith. 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. Regarding registration in bad faith, given the world-famous status of the MICROSOFT Marks, the Panel finds it inconceivable that the Respondent was unaware of the Complainant's pre-existing MICROSOFT Marks when registering the Disputed Domain Name, which reproduces the “microsoft” element in its entirety, on April 1, 2025. More importantly, from the Registrar’s reply, it appears to the Panel that the Respondent may have, without authorization, deliberately used the name and address of another individual/entity when registering the Disputed Domain Name—apparently an act of identity theft. Accordingly, the Panel finds it beyond reasonable doubt that the Disputed Domain Name has been registered in bad faith. As to use in bad faith, albeit the Complainant’s passive holding claim, the Panel finds that the Respondent has actively used the Disputed Domain Name. In particular, the Panel notes the Complainant’s contention that the Disputed Domain Name has been used to send an email and statement to a third party, impersonating the Complainant. Although the Complainant does not provide the said email and statement in their original language but only a translation (see Annex 9 to the Complaint) to support this contention, the Panel, after conducting independent research (WIPO Overview 3.1, section 4.8), finds that mail exchange (MX) records have been set up for the Disputed Domain Name, meaning the domain name can already be used for email services. Therefore, the Panel finds the Complainant’s contention plausible. Moreover, the Panel believes such emails sent from the Disputed Domain Name could easily deceive Internet users into the misbelief that they originate from the Complainant, which is highly likely a prelude to a range of bad-faith activities or scams such as phishing, identity theft, or malware distribution (WIPO Overview 3.1, section 3.4). Therefore, the Panel reaches the finding of bad-faith use. Considering the above, the Panel finds the Complainant has satisfied the third element of the Policy. page 6 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 <microsoftcn.work> be transferred to the Complainant. For purposes of properly executing this order, the Panel also directs the Registrar's attention to Annex 1 hereto that identifies the registrant of the Disputed Domain Name in the formal record of registration, and orders that the Disputed Domain Name, <microsoftcn.work>, be transferred from that registrant to the Complainant. The Panel directs the Center that Annex 1 shall not be published along with this decision. /Peter J. Dernbach/ Peter J. Dernbach Sole Panelist Date: June 22, 2026

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

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