Westmore · UDRP DecisionSanofivn.com
The Panel ordered cancellation of <sanofivn.com>. It found the domain confusingly similar to Sanofi’s SANOFI trademark because it reproduced the mark in full with the additional letters “vn.” The Respondent lacked rights or legitimate interests, and the mark-plus-country-code composition carried a risk of implied affiliation. Registration and use in bad faith were established because the composition indicated actual knowledge of Sanofi, no credible explanation for the domain choice appeared in the record, and the domain resolved to a PPC-link website that took advantage of the trademark for commercial gain.
The timeline behind sanofivn.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 sanofivn.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain composed of an entire trademark plus a country-code abbreviation can satisfy all three UDRP elements where the composition implies a localized official presence and the domain is monetized through PPC links. The result also shows that a complainant may request and obtain cancellation rather than transfer.
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. nguyễn thị phương thanh Case No. D2026-2722 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is nguyễn thị phương thanh, Viet Nam. 2. The Domain Name and Registrar The disputed domain name <sanofivn.com> is registered with Global Domain Group LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 23, 2026. On the same day, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 25, 2026, the Registrar sent to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. On June 26, 2026, the Center sent an email to the Complainant, 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 29, 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 July 1, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 21, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 24, 2026. The Center appointed Simone Lahorgue Nunes as the sole panelist in this matter on July 28, 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 is headquartered in France. The Complainant is a French multinational pharmaceutical company. The Complainant operates its website at “www.sanofi.com”. The Complainant has provided evidence of being the right holder of the trademark SANOFI. For instance: French trademark registration No. 3831592, registered on May 16, 2011; European Union trademark registration No. 010167351, registered on January 7, 2012; and International trademark registration No. 1091805, registered on August 18, 2011. The disputed domain name was registered by the Respondent on May 22, 2026, and resolves to a website displaying Pay-Per-Click (“PPC”) links. The Respondent did not reply to the Complainant’s contentions. 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 affirms that it owns several domain names incorporating the SANOFI trademark. The Complainant argues that “the contested domain name <sanofivn.com> is confusingly similar to” the Complainant’s trademarks. In this sense, the Complainant affirms that the disputed domain name: (a) comprises an exact reproduction of the Complainant’s trademark, (b) combined with the geographical acronym “vn”, and (c) followed by a Top-Level Domain suffix “.com”. Furthermore, the Complainant contends that it (a) “is well established that the generic top-level designation used as part of a domain name should be disregarded as it does not serve to distinguish domain names” and (b) “is also well established that where a domain name wholly incorporates a Complainant’s distinctive trademarks in its entirety, it is confusingly similar to that mark despite the addition of a word or, in this case, of a descriptive term”. The Complainant asserts that “the Panel has already considered that Sanofi’s trademarks are ‘well-known’ in many jurisdictions”. The Complainant contends that “the Registrant does not have any legitimate interest in using the litigious domain names since the name of the Respondent ‘nguyễn thị phương thanh’ has no resemblance with the word ‘sanofi’”. In addition, the Complainant submits the fact that “the word ‘sanofi’ has no particular meaning and is therefore highly distinctive”. The Complainant argues that it “has never licensed or otherwise authorized the Respondent to use its trademarks or to register any domain name including the above-mentioned trademarks”. Furthermore, the Complainant submits that “the Respondent is not using the litigious domain name in connection with a bona fide offering of goods or services, so as to confer a right or legitimate interest in it in accordance with paragraph 4(c)(i) of the Policy given that the litigious domain websites are clearly used as a bait and switch”. The Complainant also affirms that “the litigious domain <sanofivn.com> is leading to a parking website and has been registered only for the purpose unfairly attracting Complainant’s consumers, as it is clearly revealed on the Respondent’s webpage”. page 3 The Complainant argues that the “Respondent is more than likely generating click-through revenue from such links, which does not account for a noncommercial or fair use of the disputed domain name in any respect. Therefore, the Respondent has no rights or legitimate interests in the disputed domain name, under the Policy paragraph 4(a)(ii)”. In addition, the Complainant affirms that “given the famous and distinctive nature of the mark ‘SANOFI’, Respondent is likely to have had, at least, constructive, if not actual notice, as to the existence of Complainant’s marks at the time he registered the [disputed] domain name. This suggests that the Respondent acted with opportunistic bad faith in registering the [disputed] domain name in order to make an illegitimate use of it”. The Complainant submits that “the advertisements and links proposed on the parking websites provide without doubt income to the Respondent depending on the number of hits that are generated on the domain name, on a pay per click basis”. Finally, the Complainant requests that the disputed domain name be cancelled. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The analysis of the Complainant’s arguments and of the presented evidence leads to the conclusion that the Complaint should be upheld, based on the following grounds. 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 the letters “v” and “n” may bear on assessment of the second and third elements, the Panel finds that this addition 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 page 4 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. Furthermore, the Panel finds that the disputed domain name, which combines the Complainant’s trademark with the country code “vn” for Viet Nam, carries a risk of implied affiliation with the Complainant. Accordingly, the Respondent has no legitimate interest in the disputed domain name. 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 the Respondent’s bad faith registration and use of the disputed domain name for the following reasons. First, the use of the SANOFI trademark in the disputed domain name with the addition of the letters “v” and “n”, which, according to the Complainant, refer to the geographical acronym “vn” of Viet Nam, suggests that the Respondent has registered the disputed domain name with the actual knowledge of the Complainant and its trademarks, and has done so in an attempt to create a likelihood of confusion with the Complainant. Second, it is clear that the Respondent lacks rights or legitimate interests in the disputed domain name, and this is reinforced by the fact that there is no credible explanation for the Respondent’s choice of the disputed domain name, and the Respondent did not reply to the Complainant’s contentions. WIPO Overview 3.1, section 3.2.1. Third, the disputed domain name resolves to a website, displaying PPC links, thereby taking advantage of the Complainant’s trademark to attract Internet users for commercial gain. Accordingly, the Panel finds that the Respondent registered and used the disputed domain name in 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 <sanofivn.com> be cancelled. /Simone Lahorgue Nunes/ Simone Lahorgue Nunes Sole Panelist Date: August 11, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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