Westmore · UDRP DecisionSanofibiopharma.com
The Panel ordered cancellation of <sanofibiopharma.com>. It found the domain confusingly similar to the Complainant’s SANOFI mark because it reproduced the mark in full, with the additional terms “bio” and “pharma” not preventing confusing similarity. The Complainant established a prima facie case that the Respondent lacked rights or legitimate interests, which the defaulting Respondent did not rebut. Bad faith was established based on the SANOFI mark’s longstanding registration, distinctiveness and reputation, the domain’s composition targeting the Complainant’s pharmaceutical sector, and passive holding of the inactive domain.
The timeline behind sanofibiopharma.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 sanofibiopharma.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a widely known mark with a term closely connected to the trademark owner’s industry can support both confusing similarity and an inference of deliberate targeting. It also confirms that an inactive website does not preclude bad faith where the mark’s reputation, the domain’s composition, the age of the trademark rights, and the absence of a credible explanation collectively support passive holding.
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. Lyte Hosting, LyteHosting LLC Case No. D2026-2765 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Lyte Hosting, LyteHosting LLC, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <sanofibiopharma.com> is registered with TuringSign Inc. d/b/a Cosmotown (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 24, 2026. On June 25, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 27, 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 (unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 29, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Center verified that 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 July 13, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 2, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 6, 2026. page 2 The Center appointed Levan Nanobashvili as the sole panelist in this matter on August 14, 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 French multinational pharmaceutical company headquartered in Paris, France. The Complainant was originally formed as Sanofi-Aventis in 2004 by the merger of Aventis and Sanofi- Synthélabo and changed its name to Sanofi in 2011. The Complainant is settled in more than 100 countries on five continents employing 100,000 people. The Complainant’s group manages a large portfolio of high-growth drugs and is a major player in the worldwide pharmaceutical market. The Complainant’s consolidated net sales reached EUR 43.63 billion in 2025. The Complainant owns numerous registrations worldwide for SANOFI, including the following: 1) French Trademark SANOFI (word), registration No. 1482708, registered on August 11, 1988, duly renewed, in International Classes 1, 3, 4, 5, 10, 16, 25, 28, and 31; 2) French Trademark SANOFI (word), registration No. 96655339, registered on December 11, 1996, duly renewed, in International Classes 1, 3, 5, 9, 10, 35, 40, and 42; 3) European Union Trade Mark SANOFI (word), registration No. 010167351, registered on January 7, 2012, duly renewed, in International Classes 3 and 5; and 4) International Trademark SANOFI (word), registration No. 1092811, registered on August 11, 2011, duly renewed, in International Classes 1, 9, 10, 16, 38, 41, 42, and 44, designating multiple jurisdictions. The Complainant holds various domain names incorporating the SANOFI mark, including <sanofi.com>, <sanofi.eu>, <sanofi.us>, and <sanofi.org>. The Respondent is reportedly located in the United States. The disputed domain name was registered on June 22, 2026. At the time of filing the Complaint and as of the date of this Decision, the disputed domain name resolves to an inactive webpage. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for the cancellation of the disputed domain name. Notably, the Complainant contends that: (i) the Complainant is one of the world's leading pharmaceutical companies; (ii) the word “sanofi” does not have any particular meaning, and, therefore, it is highly distinctive; (iii) the disputed domain name is confusingly similar to the Complainant’s mark, as it incorporates the SANOFI mark as its dominant element; page 3 (iv) the Respondent has no affiliation with the Complainant and lacks any authorization, license, or consent to use the Complainant's registered mark or to register the disputed domain name incorporating it; (v) the Respondent has registered and is using the disputed domain name in bad faith; (vi) the Respondent was aware of the Complainant’s mark prior to registering the disputed domain name, as the Complainant’s websites were fully operational and publicly accessible at that time; and (vii) the disputed domain name was registered with the intention of creating a likelihood of confusion with the Complainant’s mark. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving 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 Respondent’s default in the case at hand does not automatically result in a decision in favor of the Complainant. However, paragraph 5(f) of the Rules provides that if the Respondent does not submit a Response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel shall draw such inferences from the Respondent’s failure to submit a Response as it considers appropriate. 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 the 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 other terms, in the present case the “bio” and “pharma”, may bear on assessment of the second and third elements, the Panel finds the addition of this 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 addition of the generic Top-Level Domain “.com” is a standard registration requirement and, as such, is disregarded under the first element confusing similarity test. WIPO Overview 3.1, section 1.11.1. page 4 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. The Respondent provided no evidence that it has been commonly known by the disputed domain name, or has made a legitimate noncommercial use thereof. The Respondent has not rebutted the Complainant’s contention that it has not authorized the Respondent to use the Complainant’s mark, or that there is no relationship between them that could justify the Respondent’s use of the Complainant’s mark in the disputed domain name. 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. The Panel notes that the Complainant’s trademark registration significantly predates the registration of the disputed domain name. The evidence on file shows that the Complainant registered the SANOFI mark in 1988. The disputed domain name was registered in 2026. A gap of more than thirty years between registration of the Complainant’s coined mark and the Respondent’s registration of the disputed domain name containing the mark at issue can indicate the bad faith registration. See Hunza G Limited v. Nikos Kalouris, WIPO Case No. D2025-3956 and Hi-TEC Sports International Holdings B.V. v. Thomas Birch, Finlay Nolan, Anna Akhtar, Tyler Reynolds, Keira Donnelly, WIPO Case No. D2024-1891. A significant number of panels have consistently found that the Complainant’s SANOFI mark is widely known. See Sanofi v. Bryan Garrison, WIPO Case No. D2025-5287: “the Complainant has rights and is the owner of the distinctive and globally well-known mark SANOFI”; Sanofi v. xiao xing, WIPO Case No. D2022- 4529: “the Panel agrees with past panels that the SANOFI trademark is well known”; Sanofi v. Svetlana Guseva, WIPO Case No. D2019-2815: “the Panel is convinced that the Complainant’s trademark is well established through long and widespread use.” page 5 Panels have consistently found that the mere registration of a domain name that is confusingly similar to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith. WIPO Overview 3.1, section 3.1.4. Noting the near instantaneous and global reach of the Internet and search engines, and particularly in circumstances where the complainant’s mark is widely known (including in its sector) or highly specific and a respondent cannot credibly claim to have been unaware of the mark, panels have been prepared to infer that the respondent knew, or have found that the respondent should have known, that its registration would be identical or confusingly similar to a complainant’s mark. WIPO Overview 3.1, section 3.2.2. In the present case, the composition of the disputed domain name (differing from the Complainant’s mark only by the addition of the “biopharma” term) suggests that the Respondent was aware of and intended to target the Complainant’s mark. 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, 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 and reputation 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. 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 <sanofibiopharma.com> be cancelled. /Levan Nanobashvili/ Levan Nanobashvili Sole Panelist Date: August 26, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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