Westmore · UDRP DecisionAlstomnet.com
The Panel ordered transfer of <alstomnet.com> to ALSTOM. It found the domain confusingly similar because it incorporated the ALSTOM mark in full and the added term “net” did not prevent confusing similarity. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests. Bad faith was established from the mark’s distinctiveness and well-known status, the domain’s composition, the likelihood that it was selected for its association with ALSTOM, the Respondent’s registration details and inconsistent statement regarding suspension, and passive holding under the totality of the circumstances.
The timeline behind alstomnet.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 alstomnet.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that an inactive domain incorporating a distinctive, well-known mark can satisfy the bad-faith requirement when the surrounding circumstances indicate likely awareness and targeting. It also shows that automated registration, non-use, and unsupported claims of generic meaning do not themselves create rights or legitimate interests.
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. comalstomnet comalstomnet Case No. D2026-2433 1. The Parties The Complainant is ALSTOM, France, represented by Lynde & Associes, France. The Respondent is comalstomnet comalstomnet, comalstomnet, United States of America (“United States” or “U.S.”). 2. The Domain Name and Registrar The disputed domain name <alstomnet.com> 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 June 4, 2026. On June 5, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 5, 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 (On behalf of alstomnet.com OWNER, c/o whoisproxy.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 10, 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 11, 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 16, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 6, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 10, 2026. page 2 The Center appointed Meera Chature Sankhari as the sole panelist in this matter on July 16, 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, ALSTOM, is a French limited company created in 1928. It is one of the global leaders in the world of transport infrastructures, employing 34,000 professionals in more than 60 countries. The Complainant has been present in the United States for over 160 years in the areas of rail and airport transport. The Complainant has delivered more than 12,000 new or renovated vehicles for their U.S. customers, including the first high-speed trains made in the United States. The Complainant is also one of the first private operators in the United States, serving more than 20 rail and airport customers and moving millions of passengers daily. The Complainant owns a great number of companies and trade name rights on the denomination “ALSTOM”, such as: ALSTOM Transport Technologies, etc. The Complainant holds trademark registrations that comprise the word ALSTOM in numerous jurisdictions around the world, including the U.S. Trademark Registration no. 4570546 for ALSTOM (device) dated July 22, 2014, European Union Trade Mark Registration no. 948729 for ALSTOM (word) dated August 08, 2001, and International Registration no. 706292 for ALSTOM (word) dated August 28, 1998. The Complainant is the registrant of various domain names, including <alstom.com> dated January 20, 1998, <alstom.net> dated April 1, 2000, <alstom.fr> dated May 10, 2000, and <alstom.us> dated May 16, 2002. The disputed domain name <alstomnet.com> was registered by the Respondent, comalstomnet comalstomnet comalstomnet on March 10, 2026. The disputed domain name is presently inactive. The Complainant initially approached the Registrar, asserting its prior rights in the trademark ALSTOM and requesting disclosure of the Respondent’s (Registrant’s) contact details as well as suspension of the disputed domain name. By email dated March 17, 2026, the Registrar responded that the content identified as infringing appeared to have been removed. On the same date, the Complainant clarified that although the website had become inactive, the disputed domain name remained registered and continued to incorporate the Complainant’s well-known trademark ALSTOM without authorization. The Registrar subsequently clarified that it was not the registrant of the disputed domain name and provided the relevant contact details through email correspondence. On March 16, 2026, the Complainant contacted the Respondent, requesting: (a) an explanation for the registration of the disputed domain name; and (b) transfer of the disputed domain name to the Complainant. The Respondent acknowledged receipt of the communication on March 19, 2026. As no substantive response was received, the Complainant sent a follow-up email on March 27, 2026. By email dated March 28, 2026, the Respondent stated that the disputed domain name had been registered through “standard automated processes” and “did not have knowledge of any third-party rights that may be associated with the name”. Further on, the Respondent stated that the disputed domain name “has not been actively used in a manner that targets” the Complainant. The Respondent further informed the Complainant that it was internally reviewing the matter. On April 8, 2026, the Complainant sent a further follow-up communication requesting that the Respondent provide the authorization code to facilitate the transfer of the disputed domain name and resolve the matter amicably. The Complainant also notified the Respondent that, failing a satisfactory response, it would proceed with filing a Complaint under the UDRP before the Center. page 3 On April 9, 2026, the Respondent responded that it had no intention of referencing or targeting the Complainant or creating any association with it. The Respondent further asserted that “the domain name has not been utilized in any manner that could cause confusion or be misleading”. It also contended that the structure of the disputed domain name was open to various interpretations, including combinations of generic terms or abbreviations. Finally, the Respondent requested that the Complainant provide concrete evidence of actual confusion or misuse, if any. By email dated April 15, 2026, the Complainant explained that, under the UDRP, it is only required to establish a likelihood of confusion and is not required to demonstrate actual confusion. On April 16, 2026, the Respondent informed the Complainant that the disputed domain name had been suspended. However, on April 24, 2026, the Complainant informed the Respondent that the publicly available WhoIs records continued to reflect the disputed domain name as registered, rather than suspended, and once again requested that the Respondent provide the authorization code to enable transfer of the disputed domain name and facilitate an amicable resolution of the dispute. Lastly, the Complainant did not receive any response and has filed the present Complaint. 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 <alstomnet.com> is confusingly similar to its trademark ALSTOM. The Complainant argues that in the disputed domain name, “net” is a descriptive element and the generic Top-Level Domain “.com” only indicates that the disputed domain name is registered with a generic Top- Level Domain. Moreover, the Complainant alleges that Internet users will directly recognize their ALSTOM trademarks in the disputed domain name and are likely to believe that it has been registered by the Complainant. The Complainant contends that the Respondent does not have any rights or legitimate interests in the disputed domain name, nor has the Respondent been authorized by or is affiliated with the Complainant in any manner. The Complainant further argues that the reply received from the Respondent on March 28, 2026, in which the Respondent states that the disputed domain name was registered automatically, has not been used and that the Respondent would suspended it, further proves that the Respondent has no rights and legitimate interests in the disputed domain name. Furthermore, the Complainant contends that the first name and last name “comalstomnet comalstomnet” do not correspond to the names of real people and are merely a reproduction of the disputed domain name. Thus, the Respondent is trying to hide its real identity. The Respondent’s actions are made in violation of the Complainant’s trademark rights in ALSTOM and are likely to be very detrimental. The Complainant contends that the disputed domain name was registered and used in bad faith due to the following reasons: (a) that the disputed domain name was acquired long after the Complainant’s ALSTOM marks became well-known; (b) that the Respondent is trying to hide its real identity; and c) that the disputed domain name is inactive. The Complainant explains further that given the well-known character of the name ALSTOM, it is virtually impossible that the Respondent was not aware of the Complainant’s activities at the time of registration. Further, the Complainant emphasizes that the disputed domain name is registered in the name of “on behalf of alstomnet.com OWNER”. Moreover, the Complainant argues that the post address of the Respondent does not exist and the nearest available address is a shoe shop named “ovpybm”, which has no connection with the disputed domain name and the Respondent. Lastly, the email address of the Respondent page 4 “[...]@gmail.com” does not match with its name “comalstomnet comalstomnet” which is a simple reproduction of the disputed domain name. With regards to the disputed domain name, the Complainant highlights that the Respondent in its email dated March 28, 2026, confirms that the disputed domain is registered under standard automated process and is not being used. For these reasons, the Complainant alleges that the registration and use of the disputed domain name amount to taking unfair advantage of the significant reputation of the Complainant’s trademark ALSTOM. B. Respondent The Respondent did not reply to the Complainant’s contentions after the formal UDRP proceedings were initiated. While the Respondent did not file a formal Response, in pre-Complaint correspondence it stated that the disputed domain name had been registered through “standard automated processes”, that it was unaware of any third-party rights associated with the name, that it had no intention of targeting the Complainant, and that the disputed domain name had never been used in a manner likely to cause confusion. The Respondent further asserted that the structure of the disputed domain name could be interpreted in different ways, including as a combination of generic terms or abbreviations, and requested evidence of actual confusion or misuse. The Respondent subsequently stated that the disputed domain name had been suspended. 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 ALSTOM for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark ALSTOM 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. The Panel notes that the term “net” does not prevent a finding of confusing similarity between the disputed domain name and the Complainant’s ALSTOM trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.8. The generic Top-Level Domain “.com” is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. 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 page 5 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. The Respondent’s assertions that the registration occurred through an automated process, that it lacked knowledge of the Complainant, or that the disputed domain name had not yet been used do not by themselves establish rights or legitimate interests under paragraph 4(c) of the Policy. The Panel notes that the Respondent has not only failed to submit relevant evidence demonstrating preparations to use the disputed domain name in connection with a bona fide offering of goods or services, it has also not provided evidence that it has been commonly known by the disputed domain name, or evidence of legitimate noncommercial or fair use. 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. The Panel notes that the Respondent asserted that it was unaware of any third-party rights associated with the disputed domain name and that it did not intend to target the Complainant. The Panel is not persuaded by these assertions. In the present case, the Panel notes that given the wide popularity and presence of the Complainant, it is highly unlikely that the Respondent was unaware of the Complainant and its trademark ALSTOM when registering the disputed domain name. The disputed domain name reproduces the Complainant’s ALSTOM mark in its entirety, followed only by the term “net”, which is commonly understood as an abbreviation for “network” or “Internet”. In the circumstances of this case, the Panel finds that the disputed domain name is more likely than not to have been chosen because of its association with the Complainant’s mark. As per the records, Respondent also tried to hide its identity firstly by registering the disputed domain name as “On behalf of alstomnet.com OWNER” and secondly as “comalstomnet comalstomnet comalstomnet”. The Panel further notes that, in its email dated April 16, 2026, the Respondent stated that the disputed domain name had been suspended, whereas the WhoIs records continued to reflect the disputed domain name as registered. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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. Having reviewed the available record, the Panel notes the distinctiveness as well as the well-known status of the Complainant’s trademark, and the composition of the disputed domain name, and 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. The Panel finds that the Complainant has established 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 <alstomnet.com> be transferred to the Complainant. /Meera Chature Sankhari/ Meera Chature Sankhari Sole Panelist Date: July 30, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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