Westmore · UDRP DecisionQlik-quotes.com
The Panel ordered transfer of <qlik-quotes.com>. It found the domain confusingly similar to the Complainant’s QLIK trademark, found no rights or legitimate interests because the inactive domain was neither used for a bona fide offering nor supported by any explanation or evidence from the Respondent, and found bad-faith registration and use under the passive-holding doctrine. The domain combined the distinctive QLIK mark with “quotes,” a term associated with resources in the Complainant’s technical documentation.
The timeline behind qlik-quotes.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 qlik-quotes.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining an invented trademark with a term specifically associated with the trademark owner’s technical resources can support findings of targeting and bad faith even when the domain has never hosted an active website. The result rested on the cumulative force of the mark’s distinctiveness and reputation, the domain’s composition, passive holding, and the absence of any respondent explanation.
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 QlikTech International AB v. TechTorch Admin, TechTorch Case No. D2026-2280 1. The Parties The Complainant is QlikTech International AB, Sweden, represented by Abion AB, Sweden. The Respondent is TechTorch Admin, TechTorch, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <qlik-quotes.com> (the “Domain Name”) 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 May 27, 2026. On May 28, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On June 1, 2026, the Registrar transmitted by email to the Center its verification response, disclosing registrant and contact information for the Domain Name which differed from the named Respondent (On behalf of qlik-quotes.com OWNER, c/o whoisproxy.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 3, 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 June 12, 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 June 15, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 5, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 6, 2026. The Center appointed Ian Lowe as the sole panelist in this matter on July 9, 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 was founded in Sweden in 1993, and forms part of the QlikTech Group, one of the leading providers worldwide of artificial intelligence, data analytics, and business intelligence solutions. As of 2026, the QlikTech Group serves more than 40,000 global customers and has more than 235,000 community members. The QlikTech Group also maintains a robust network of international partners, including Amazon, Google, and Microsoft. Among the resources provided by the Complainant are materials concerning “Quotes” and quotation mark handling within Qlik scripting and data-loading syntax, which are used by developers and business users worldwide in connection with the Complainant’s software products and services. The Complainant is the proprietor of a number of registered trademarks for QLIK (the “Mark”), including European Union trademark number 001115948 registered on May 16, 2000; International Trademark number 839118 QLIK registered on May 14, 2004; and United States trademark number 2657563 registered on December 10, 2002. The Complainant is also the owner of a number of domain names comprising QLIK, including its official website at “www.qlik.com.” The Domain Name was registered on March 24, 2026. It does not resolve to an active website. 5. Parties’ Contentions A. Complainant The Complainant contends that the Domain Name is confusingly similar to the Mark, that the Respondent has no rights or legitimate interests in respect of the Domain Name, and that the Respondent registered and is using the Domain Name in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 4(a) of the Policy, for this Complaint to succeed in relation to the Domain Name the Complainant must prove that: (i) the 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 Domain Name; and (iii) the 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 or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. page 3 Ignoring the generic Top-Level Domain “.com”, the Domain Name comprises the entirety of the Mark together with a hyphen and the term “quotes”. The Panel finds that this addition does not prevent a finding of confusing similarity between the Domain Name and the Mark. WIPO Overview 3.1, section1.8. Accordingly, the Panel finds that the Domain Name is confusingly similar to a trademark in which the Complainant has rights, and 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 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. Accordingly, 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. The Respondent has not used the Domain Name for a bona fide offering of goods or services. There is no question of the Respondent being commonly known by the Domain Name or of the Complainant having given permission to the Respondent to register or use the Domain Name. In the circumstances of this case, the inactive Domain Name cannot in the Panel’s view indicate rights or legitimate interests. Having reviewed the available evidence, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the Domain Name. The Respondent did not reply to the Complaint and has given no explanation for having registered a domain name comprising QLIK, an invented neologism, combined with the term “quotes” used by the Complainant in its own technical documentation as a file specifier within its data-loading and scripting environments. 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 Domain Name such as those enumerated in the Policy or otherwise. The Panel finds the second element of the Policy has been established C. Registered and Used in Bad Faith The Domain Name comprises the entirety of the Mark together with a reference to one of the resources provided by the Complainant. The Panel is therefore satisfied that the Respondent most likely had the Complainant and its rights in the Mark in mind when it registered the Domain Name. 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, UDRP panels have found that the registration and non-use of a domain name can still constitute bad faith for purposes of the Policy. Having reviewed the available evidence, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, the composition of the Domain Name, the failure of the Respondent to submit a response, and finds that in the circumstances of this case the passive holding of the Domain Name does not prevent a finding of bad faith under the Policy. WIPO Overview 3.1, section 3.3. page 4 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 Domain Name <qlik-quotes.com> be transferred to the Complainant. /Ian Lowe/ Ian Lowe Sole Panelist Date: July 21, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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