Westmore · UDRP DecisionCitiusgenpal.com
The Panel ordered transfer of <citiusgenpal.com>. It found the domain confusingly similar to the registered CITIUSTECH mark, found no rebuttal to the Complainant’s prima facie case on rights or legitimate interests, and concluded on the balance of probabilities that the Respondent targeted the Complainant when registering the domain shortly after the Complainant applied for CITIUS GENPAL. The domain was offered for sale through Atom.com. Although the Panel criticized the Complaint as insufficiently tailored and potentially misleading regarding the status and notoriety of CITIUS GENPAL, it was not sufficiently convinced that the Complaint had been filed with bad intentions and did not find Reverse Domain Name Hijacking.
The timeline behind citiusgenpal.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 citiusgenpal.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how the timing of a domain registration immediately after a trademark application can support an inference of targeting when combined with an established related mark, an exact domain match to the newly applied-for designation, a sale listing, and no respondent rebuttal. It also demonstrates that a successful complainant may receive strong procedural criticism where its pleading conflates registered rights with a pending application or reuses material not tailored to the disputed domain.
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 CitiusTech Healthcare Technology Private Limited v. web master, Expired domain caught by auction winner.***Maybe for sale on Dynadot Marketplace*** Case No. D2026-2777 1. The Parties The Complainant is CitiusTech Healthcare Technology Private Limited, India, represented by Vutts & Associates LLP, India. The Respondent is web master, Expired domain caught by auction winner.***Maybe for sale on Dynadot Marketplace***, Hong Kong, China. 2. The Domain Name and Registrar The disputed domain name <citiusgenpal.com> is registered with Realtime Register B.V. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 25, 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 29, 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 (Not Available) 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 Complainant filed an amended Complaint on June 30, 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 2, 2026. In accordance with the Rules, paragraph 5, the due date for Response was July 22, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 24, 2026. page 2 The Center appointed Willem J. H. Leppink as the sole panelist in this matter on July 29, 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 following facts are undisputed. The Complainant is an Indian company. It operates in India, the United States of America (“United States”), the United Kingdom, the United Arab Emirates, and Singapore, and is a provider of consulting and digital technology to healthcare and life sciences companies. CITIUSTECH is the registered trademark of the Complainant and features in its corporate name. The CITIUSTECH mark was first adopted by the Complainant as its brand name and logo in 2005 when the Complainant was established under the name Citius IT Solutions Private Limited. The CITIUSTECH mark was also used as the name of the Complainant’s subsidiary in the United States, CitiusTech, Inc., which was established on July 11, 2005. The Complainant changed its name to CitiusTech Healthcare Technology Private Limited on October 10, 2015. The Complainant has been using the CITIUSTECH mark continuously and exclusively since 2005. The sales figures of the Complainant in the year 2024-2025 are the equivalent of approximately USD 437,549,000. Its advertising and marketing expenditure is approximately 10% of this figure. The Complainant has won a number of awards in recognition of its contribution to the healthcare industry. The Complainant (and its subsidiary, CitiusTech, Inc.), own various trademark registrations for CITIUSTECH in India and the United States, including United States Trademark Registration No. 86239450 (in the name of CitiusTech, Inc), with a registration date of October 28, 2014 for goods and services in classes 9 and 42, and Indian Trademark Registration No. 2700671 with a registration date of October 4, 2018, for goods in class 9. The Complainant has filed the Indian Trademark Application No. 7700952, for CITIUS GENPAL, with an application date of May 1, 2026, for services in class 42. The Complainant operates its main website which can be reached via <citiustech.com>, which became active in 2005, and which prominently features the CITIUSTECH mark and provides information about the Complainant. The disputed domain name has been registered on May 12, 2026 and at the time filing this Complaint and at the time of handing down its decision, resolves to a page operated by Atom.com where the disputed domain name is offered for sale. 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 the following. The disputed domain name is deceptively similar to the Complainant’s prior, invented and well-known mark and trade name CITIUSTECH. The Complainant’s adoption, use and registration of this mark predates the registration of the disputed domain name. The Complainant’s mark has achieved global recognition prior to page 3 the registration of the disputed domain name and is immediately associated with the Complainant’s commercial activities and businesses in India as well as the United States. The disputed domain is deceptively similar to the well-known mark of the Complainant. The disputed domain name effectively incorporates a substantial part of the registered trademark CITIUSTECH of the Complainant. Moreover, the disputed domain name is exactly identical to one of the Complainant’s CitiusTech formative trademarks, i.e., CITIUS GENPAL. The mark CITIUSTECH is an invented word. The use of this mark either by itself or with slight variations or in conjunction with any other word does not serve any purpose for the Respondent, rather causes deception. In addition, because the mark is a well-known mark, it is likely that Internet consumers would believe that the disputed domain name belongs to the Complainant. In fact, it is apparent that the Respondent banked on the likelihood of such consumer confusion and deception to profit from the disputed domain name. The Respondent was well aware of the Complainant’s Mark CITIUSTECH as the disputed domain has been registered post trademark registrations and applications for the mark CITIUSTECH. This clearly shows that the Respondent was aware of the commercial value of the name and proceeded to adopt it. The Respondent registered the disputed domain name when the Complainant has been running its websites and business under the marks for almost twenty one years. Search results for the Respondent’s webpage leads to a page where the disputed domain name has been listed for sale. This shows the mala fide intent of the Respondent to merely acquire the disputed domain name and squat on the same, with a mala fide intent of selling it to the rightful owner and/or to seek commercial gain from misleading consumers about a non- existent connection between the disputed domain name and the Complainant and furthermore tarnish the trademark of the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Before the Panel comes to its findings under the three elements below, the Panel finds it relevant to comment on the Complaint in general. The Complainant in its Complaint, has referred to fifteen earlier domain name disputes in which the disputed domain names were transferred to the Complainant. These all, unlike the disputed domain name in current dispute, related to domain names including the exact element “citiustech”. The Complaint contains substantial material that appears to have been adapted from earlier complaints involving different domain names. As a result, certain submissions are not fully tailored to the specific circumstances of the present case and include information of limited relevance.. The Panel wishes to express that the Policy is intended to offer fast, affordable, and streamlined administrative process to resolve abusive domain name registrations like cybersquatting. The Complainant focusses in its Complaint, as it must have done in the other fifteen complaints, on extensively explaining the notoriety of the CITIUSTECH mark, but failing to explicitly mention that the CITIUS GENPAL mark is a pending application rather than a registered trademark. The Complainant also did not assert any common law rights in relation to this latter mark. Moreover, the Complainant has chosen in its Complaint to make certain contentions in relation to CITIUSTECH, after first defining that the CITIUSTECH mark and the CITIUS GENPAL mark were being page 4 collectively being referred to as CITIUSTECH, whilst there is a clearly a difference in relation to the notoriety of both marks. The Complainant also contended that the mark CITIUSTECH is an invented word. Whilst the Panel is willing to assume that CITIUSTECH in the combination of “citius” and “tech” is an invented word, the disputed domain name and the CITIUSTECH mark only have in common the element “citius”, which means “faster” in Latin and is being used by other companies as well. As such a wrong impression is created. The Panel reminds the Complainant that in the last paragraph before its signature, in accordance with the model complaint, it has inter alia certified that the information contained in the Complaint is to the best of the Complainant’s knowledge complete and accurate. Based on the record before the Panel, the Panel is, nonetheless, insufficiently convinced that the Complainant drafted the Complaint with bad intentions, which could result in a denial and a finding of Reverse Domain Name Hijacking (RDNH). The Panel will, also in light of the fact that the Respondent did not reply to the contentions, give the Complainant the benefit of the doubt, and will render its decision based on the relevant contentions as it could distill from the Complaint. The Panel trusts that Complainant (and its representative) will take the above observations into account when filing future complaints. 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 in relation to CITIUSTECH 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 Panel finds the mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy as “citius” is a distinctive element of both the CITIUSTECH mark and the disputed domain name. WIPO Overview 3.1, section 1.7. Although the addition of “genpal” may bear on assessment of the second and third elements, the Panel finds the 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 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. page 5 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 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. Having reviewed the available record, the Panel is sufficiently convinced that the CITIUSTECH mark, given its extensive use, as evidenced by the information provided by the Complainant and not rebutted by the Respondent, enjoys a reputation in the market and that the Complainant under its name is well-known. On balance of probabilities, it is unlikely that the Respondent, when registering the disputed domain name, did not have the Complainant and its marks in mind when registering the disputed domain name. In particular, the Panel observes that the Complainant had applied for the Indian trademark CITIUS GENPAL shortly before the disputed domain name was registered. In the circumstances of this case, and considering the reputation of the CITIUSTECH mark, the Panel finds on the balance of probabilities that the registration was not coincidental. Rather, the Respondent appears to have registered the disputed domain name with the intention of targeting the Complainant. Therefore, the use of the disputed domain name offering it for sale 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 <citiusgenpal.com> be transferred to the Complainant. Willem J. H. Leppink Sole Panelist Date: August 5, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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