Westmore · UDRP DecisionSanoficampaign.com
The Panel ordered transfer of <sanoficampaign.com> to Sanofi. It found the domain confusingly similar to the SANOFI mark because it incorporated the mark in its entirety with the additional term “campaign.” The Respondent did not rebut Sanofi’s prima facie case on rights or legitimate interests. Considering the mark’s distinctiveness and reputation, the domain’s composition, the error page, the absence of a response, and the lack of any plausible good-faith use, the Panel found registration and use in bad faith under the passive-holding doctrine.
The timeline behind sanoficampaign.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 sanoficampaign.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a domain that merely displays a server error can still satisfy the UDRP bad-faith requirement. The outcome rested not on affirmative website misuse but on the combined weight of the mark’s distinctiveness and reputation, full incorporation of the mark, the suggestive term “campaign,” the absence of authorization, the lack of any plausible good-faith use, and the Respondent’s default.
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 Sanofi v. Wei Ying Wang, 賽諾菲股份有限公司 Case No. D2026-2374 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Wei Ying Wang, 賽諾菲股份有限公司, Taiwan Province of China. 2. The Domain Name and Registrar The disputed domain name <sanoficampaign.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 June 2, 2026. On June 2, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 4, 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 June 4, 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 8, 2026. The Center verified that the Complaint together with the amendment to the 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 9, 2026. In accordance with the Rules, paragraph 5, the due date for Response was June 29, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on June 30, 2026. The Center appointed Paula Bezerra de Menezes as the sole panelist in this matter on July 3, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is Sanofi, a French multinational pharmaceutical company headquartered in Paris, France. The company was originally formed as Sanofi-Aventis in 2004 by the merger of Aventis and Sanofi- Synthélabo and changed its name to Sanofi in May 2011. Sanofi is settled in more than 100 countries on all 5 continents employing 100.000 people. This group benefits from a large portfolio of high-growth drugs and is a major player on the worldwide pharmaceutical market. Sanofi owns many trademark registrations worldwide, a few of which are detailed below: • International Trademark , number 591490, registered on September 25, 1992, in class 5, covering “pharmaceutical products”, and designating China among others; • European Union Trademark SANOFI, number 000596023, filed on July 15, 1997 and registered on February 1, 1999, in classes 3 and 5, covering inter alia “pharmaceutical, veterinary and sanitary preparations”. Additionally, the Complainant owns a series of domain names bearing “sanofi”, such as <sanofi.com>, <sanofi.eu>, <sanofi.fr>, <sanofi.us>, and many others, registered within a period that dates back to 1995 until 2011. The disputed domain name <sanoficampaign.com> was registered on June 30, 2022. When the Complaint was filed the disputed domain name did not resolve to an active and regular website, but to a website displaying the message “Web server is returning an unknown error”. Until the date of this decision, the contents of the website remained unchanged. The Respondent was identified by the Registrar as Wei Ying Wang. The information about the Respondent, reportedly an individual with an address in Taiwan Province of China, is limited to the contact details that the Registrar disclosed to the Center through this proceeding. The Respondent’s email address has no relation to the disputed domain name. 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: 1) SANOFI is a fanciful trademark, with no particular meaning, highly distinctive and well-known. The Complainant has registered several trademarks and domain names that bear the distinctive element “sanofi” before the disputed domain name. The Complainant ranks among the world’s ten largest pharmaceutical companies by prescription sales and has invested substantial financial resources in advertising and promoting the company and its trademarks worldwide; page 3 2) the Respondent has wrongly registered and used the disputed domain name, which reproduces its trademark with the addition of the term “campaign” followed by the generic Top-Level Domain (“gTLD”) “.com”, and could not ignore the Complainant’s trademarks; 3) the disputed domain name is confusingly similar to the Complainant’s prior trademarks and its coexistence with the Complainant’s marks and domain names is likely to cause confusion in the market, especially given the renown of the Complainant’s marks; 4) the Respondent does not have a legitimate interest in using the disputed domain name and cannot justify the use of SANOFI trademarks and domain names; 5) there is no relationship whatsoever between the parties. The Complainant has never licensed or otherwise authorized the Respondent to use its trademarks or to register the disputed domain name bearing the Complainant’s marks; 6) the registration of the disputed domain name cannot be a coincidence, and was an act of bad faith, because it is inconceivable that the Respondent was unaware of the Complainant’s rights and reputation. Moreover, the Respondent used the disputed domain name by keeping an inactive website, characterizing passive holding. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, for the transfer of the disputed domain name the Complainant must establish that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (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 Rules provide that if the Respondent does not comply with the time periods established, or with any provision or requirement under paragraph 14 of the Rules, the panel shall proceed to a decision on the complaint and draw such inferences as it considers appropriate. Pursuant to paragraph 15(a) of the Rules, a panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. The Panel has reviewed the case and found the following: 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 Complainant’s registered trademark is SANOFI. page 4 The entirety of the mark is reproduced 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. Although the addition of other terms here, “campaign”, may bear on assessment of the second and third elements, the Panel finds the addition of such 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. 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. There is no evidence that the Respondent used the disputed domain name with a bona fide offering, was commonly known by the disputed domain name or that the disputed domain name was being used with a legitimate noncommercial or fair use purpose. On the contrary, given the worldwide reputation and renown of the Complainant’s mark the evidence appears to indicate that the disputed domain name was created to generate a likelihood of confusion with the Complainant’s mark, therefore, it appears more likely than not that the Respondent has no legitimate interest in the disputed domain name. WIPO Overview 3.1, section 2.1. 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. 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 (including a blank or “coming soon” page, and, by analogy, a page showing the message of error) 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. See Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003. page 5 Having reviewed the available record, the Panel considered the following factors to apply the passive holding doctrine and additional bad faith consideration factors: a) the Complainant’s mark is fanciful, highly distinctive and well-known worldwide; b) the reproduction of the Complainant’s well-reputed mark in its entirety in the disputed domain name with an additional term that is common and descriptive suggests that the Complainant itself is promoting a campaign, which has not been authorized; c) the webpage reflecting the disputed domain name that bears a well-known mark and presenting an error message can be confusing and lead Internet users to believe that the Complainant is not on the Internet; d) the failure of the Respondent to come forward to rebut the Complainant’s evidence and provide any evidence of actual or contemplated good-faith use; e) it is not plausible to assume that the Respondent was unaware of the Complainant’s mark. Therefore, it appears more probable than not that the disputed domain name was registered and is being held in bad faith. Given the above, the Panel 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, as already decided in previous cases brought before the Center. Thus, 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 <sanoficampaign.com> be transferred to the Complainant. /Paula Bezerra de Menezes/ Paula Bezerra de Menezes Sole Panelist Date: July 17, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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