Westmore · UDRP DecisionRoche-ag.com
The Panel ordered transfer of <roche-ag.com>. It found the domain confusingly similar to the Complainant’s ROCHE mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith to impersonate the Complainant through purchase-order emails seeking products on deferred payment terms. The Respondent’s name was redacted because the registration appeared to use the identity of a Complainant employee.
The timeline behind roche-ag.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 roche-ag.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates a strong impersonation pattern in which a famous mark was paired with the trademark owner’s corporate-form abbreviation, while employee and corporate-address information was used in the registration and the resulting domain supported deceptive purchase-order emails. The decision shows how domain composition, identity misuse, and email evidence can operate together across the rights-or-legitimate-interests and bad-faith analyses.
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 F. Hoffmann-La Roche AG v. Name Redacted Case No. D2026-2383 1. The Parties The Complainant is F. Hoffmann-La Roche AG, Switzerland, internally represented. The Respondent is Name Redacted. 1 2. The Domain Name and Registrar The disputed domain name <roche-ag.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 2, 2026. On June 3, 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 (Privacy service provided by Withheld for Privacy ehf, Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 5, 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 amendment to the Complaint on June 9, 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”). 1 The Respondent appears to have used the name of a Complainant’s employee when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this Decision. 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 the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in these proceedings and has indicated that 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 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 11, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 2, 2026. The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on July 7, 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 multinational Swiss healthcare company and, together with its affiliated companies, operates internationally in the fields of pharmaceuticals and diagnostics. The Complainant has operations in more than 100 countries and uses the ROCHE trademark as a house mark in connection with its business. The Complainant owns a large international trademark portfolio for the ROCHE trademark, including International Registration No. 340483 for the word mark ROCHE, registered on November 14, 1967, and International Registration No. 346223 for the word mark ROCHE, registered on June 19, 1968. The Complainant also owns and uses the domain name <roche.com> for its official corporate website. The disputed domain name <roche-ag.com> was registered on April 12, 2026. According to the registrant information disclosed by the Registrar and the Complainant’s confirmation, the disputed domain name was registered using the name of a legitimate employee of the Complainant, together with the physical address of the Complainant’s corporate office in United States of America. The evidence submitted by the Complainant includes copies of emails displaying sender addresses incorporating the disputed domain name. The emails purported to originate from the Complainant in connection with purchase orders and reproduced the Complainant’s name, address, and corporate information. 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 is confusingly similar to its ROCHE trademark, as it incorporates the trademark in its entirety. The addition of the term “ag”, a common abbreviation for “Aktiengesellschaft” and part of the Complainant’s corporate name, together with a hyphen, does not prevent a finding of confusing similarity. The Complainant further contends that the generic Top- Level Domain “.com” should be disregarded for purposes of the comparison. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant has not licensed, authorized, or otherwise permitted the Respondent to use the ROCHE trademark or to register a domain name incorporating that trademark. The Respondent is not affiliated with the Complainant and has not been commonly known by the disputed domain name. The Complainant further contends that the use of the disputed domain name in connection with emails impersonating the Complainant and concerning purported purchase orders does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use. The Respondent did not reply to the Complainant’s cease-and-desist communication. page 3 The Complainant also contends that the disputed domain name was registered and is being used in bad faith. Given the longstanding use and reputation of the ROCHE trademark, and the combination of that trademark with “ag”, which corresponds to the Complainant’s corporate form, the Respondent must have been aware of the Complainant and its trademark when registering the disputed domain name. The Complainant further contends that the disputed domain name was used as part of an email scheme impersonating the Complainant in connection with purported purchase orders. The emails displayed sender addresses associated with the disputed domain name and reproduced the Complainant’s name, address, and corporate information. According to the Complainant, such conduct demonstrates an intentional attempt to create confusion with the Complainant and to mislead recipients for commercial gain. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 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 another term here, “-ag”, 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 page 4 demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Further, based on the evidence provided, the Panel notes that the Respondent is not connected with or licensed by the Complainant in any way and is not commonly known by the disputed domain name and that there are no elements in this case that point to the Respondent having made any reasonable and demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services. Panels have held that the use of a domain name for illegal activity here, claimed phishing, passing off, or other types of fraud can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. Finally, the Panel observes that the disputed domain name, being confusingly similar to the Complainant’s longstanding and well-known ROCHE trademark and consisting only of such trademark together with the term “-ag”, which is a common abbreviation for the Complainant’s corporate form, namely “Aktiengesellschaft”, carries a risk of implied affiliation and cannot constitute fair use, as it effectively impersonates the Complainant and its corporate form. WIPO Overview 3.1, section 2.5.1. 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. In the present case, the Panel notes that the Respondent registered the disputed domain name many years after the Complainant obtained its trademark rights in the ROCHE mark, as the Complainant’s earliest trademark registrations relied upon in these proceedings date from 1967 and 1968, whereas the disputed domain name was registered on April 12, 2026. Additionally, previous UDRP panels have recognized the Complainant’s ROCHE mark as well known, see for instance F. Hoffmann-La Roche AG v. Linda Puckette, Linda Puckette, WIPO Case No. D2026-1133. While each case must be assessed on its own facts, in the Panel’s view, the longstanding and well-known nature of the ROCHE mark supports the inference that the Respondent was aware of the Complainant and its trademark when registering the disputed domain name. Moreover, the disputed domain name incorporates the Complainant’s ROCHE mark in its entirety together with the term “ag”, an abbreviation for the German-language corporate form “Aktiengesellschaft” and an element of the Complainant’s corporate name. In light of the longstanding and well-known nature of the ROCHE mark, its registration many years before the registration of the disputed domain name, the fact that the Complainant and its trademark could readily have been identified through a basic Internet search or a search of publicly available trademark databases and the Respondent’s identity theft of the Complainant’s employee, the Panel finds that the Respondent knew or should have known of the Complainant and its prior trademarks when registering the disputed domain name. The Panel therefore finds that the disputed domain name was registered 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. As to use in bad faith, the evidence submitted by the Complainant includes copies of emails displaying sender addresses incorporating the disputed domain name, which purported to originate from the Complainant in connection with purchase orders and reproduced the Complainant’s name, address, and corporate information. This means that the disputed domain name was used to impersonate the Complainant and create the false impression that the emails originated from, or were authorized by, the Complainant. In the circumstances of the case, the Panel finds that the use of the disputed domain name in page 5 connection with purported purchase orders and requests for the supply of products on deferred payment terms constituted an intentional attempt to attract, for commercial gain, third parties by creating a likelihood of confusion with the Complainant’s ROCHE trademark as to the source, sponsorship, affiliation, or endorsement of the communications, which constitutes evidence of bad faith within the meaning of paragraph 4(b)(iv) of 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 <roche-ag.com> be transferred to the Complainant. /Deanna Wong Wai Man/ Deanna Wong Wai Man Sole Panelist Date: July 14, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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