Westmore · UDRP DecisionBdo-global-forensics.com
The Panel ordered the transfer of <bdo-global-forensics.com> to Stichting BDO. It found the domain confusingly similar to the BDO trademarks, found no rights or legitimate interests, and found bad-faith registration and use based principally on the domain’s composition and its prior use for a website imitating the Complainant’s branding, content, and services. The domain was inactive by the decision date, but the Panel held that this did not prevent a finding of bad faith.
The timeline behind bdo-global-forensics.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 bdo-global-forensics.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a domain combining a trademark with terms closely corresponding to a complainant’s geographic scope and service offering can support more than confusing similarity. Here, the composition of the domain, together with an imitative website, was relevant to the absence of legitimate interests and to bad faith. It also shows that subsequent inactivity does not neutralize evidence of earlier deceptive use.
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 Stichting BDO v. Anthony Burger Case No. D2026-3002 1. The Parties The Complainant is Stichting BDO, Netherlands (Kingdom of the), represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is anthony burger, South Africa. 2. The Domain Name and Registrar The disputed domain name <bdo-global-forensics.com> (the “Disputed Domain Name”) is registered with Spaceship, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 8, 2026. On July 8, 2026, the Center sent an email to the Registrar, requesting for verification in connection with the Disputed Domain Name. On July 9, 2026, the Registrar replied to the Center via email, disclosing the registrant’s information which differed from the named Respondent (Redacted for Privacy Purposes, Privacy Service Provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email to the Complainant on July 12, 2026, providing the registrant’s information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on July 14, 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 21, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 10, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 15, 2026. page 2 The Center appointed Duy Khanh Nguyen as the sole panelist in this matter on August 21, 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 the owner of all intellectual property rights to the brand BDO. BDO is an international network of independent public accounting, tax, consulting, and business advisory firms which are members of BDO International Limited and perform professional services under the name and style of BDO. The Complainant has conducted longstanding global promotion of the BDO brand via an active portfolio of more than 260 domain names containing the BDO trademark, as well as various social media platforms including LinkedIn, YouTube and X. The Complainant owns trademark registrations for the BDO brand name and logo “ ” (the “BDO Trademarks”) across various jurisdictions, include the following: - European Union Trademark Registration No. 002419778, registered on December 9, 2002, in classes 9, 16, 35, 36, 41, and 42; - United States of America Trademark Registration No. 2699812, registered on March 25, 2003, in classes 9, 16, 35, 36, 41, and 42; and - International Trademark Registration No. 770374, registered on October 30, 2001, in classes 9, 16, 35, 36, 41, and 42. The Complainant also owns the domain names <bdo.global> and <bdoglobal.com>, which were respectively created on August 25, 2014, and July 31, 2003. The Complainant uses these domain names to host its primary website which enables Internet users to access information about the BDO network and its products and services, including forensics and investigations consulting. The Disputed Domain Name was created on June 2, 2026. As of the date of this Decision, the Disputed Domain Name resolves to an inactive page. According to the evidence the Complainant brought before the Panel, the Disputed Domain Name previously resolved to a website featuring a slightly modified BDO logo using the same blue and red colors as used by the Complainant’s for its logo, and claiming to provide “tracing and recovery services for safe crypto transactions and asset protection”. The website generally adopted the same colors as used by the Complainant for its official website and displayed content that attempted to mimic the Complainant’s official website. 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. The Complainant contends that the Disputed Domain Name is confusingly similar to the Complainant’s BDO Trademarks. The Disputed Domain Name incorporates the mark in its entirety with the addition of the descriptive terms “global forensics” and hyphens. According to the Complainant, the added terms do not prevent a finding of confusing similarity, but rather increase it, because “global” directly corresponds to the Complainant’s established global brand and domain names such as <bdo.global> and <bdoglobal.com>, while “forensics” refers to the Complainant’s own forensic services. page 3 The Complainant further alleges that the Respondent has no rights or legitimate interests in the Disputed Domain Name, as it was never authorised to use the BDO Trademarks, is not affiliated with the Complainant, and is not commonly known by the Disputed Domain Name. The Complainant further submits that the Respondent used the Disputed Domain Name to host a website impersonating the Complainant by using a slightly modified version of its logo, and copying its content, which cannot constitute a bona fide or legitimate use. The current inactive status of the Disputed Domain Name likewise does not support any claim of rights or legitimate interests. Finally, the Complainant asserts that the Disputed Domain Name was registered and is being used in bad faith. The Complainant argues that the BDO Trademarks are internationally well known and had been used and registered long before the registration of the Disputed Domain Name, making it implausible that the Respondent was unaware of the Complainant’s rights. The Complainant contends that the composition of the Disputed Domain Name, combining the BDO Trademark with the terms “global forensics”, creates a strong false association with the Complainant and indicates opportunistic bad faith. The Complainant further submits that the Respondent’s prior use of the Disputed Domain Name for a website designed to impersonate the Complainant and mislead Internet users constitutes clear evidence of bad faith, particularly as it involved copying the Complainant’s branding and suggesting a false affiliation. In addition, the Complainant argues that the Respondent’s use of a privacy service supports an inference of bad faith. The Complainant also relies on the doctrine of passive holding, noting that the current inactive status of the Disputed Domain Name which does not prevent a finding of bad faith in the circumstances. 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. In addition, the Panel notes that the Complainant is not required to register its marks within the country of the Respondent in order to establish standing under the first element of the Policy. WIPO Overview 3.1, section 1.1.2. The Panel finds that the Disputed Domain Name fully incorporates the Complainant’s BDO Trademarks and is combined with the terms “global forensics” and the addition of hyphens in the Disputed Domain Name. The Panel finds that the addition of the terms “global forensics” and the hyphens in the Disputed Domain Name does not prevent a finding of confusing similarity for the purpose of the Policy. WIPO Overview 3.1, section 1.8. In addition, it is well-established that the Top-Level Domain “.com” may be disregarded for this purpose. 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. page 4 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 Complainant’s BDO Trademarks are well known and their registration and use precedes the date of the Respondent’s registration of the Disputed Domain Name by many years. The Complainant has never assigned, granted, licensed, sold, transferred or in any way authorized the Respondent to register or use the BDO Trademarks in any manner. The Panel also notes that the Disputed Domain Name was also registered after the registration of the Complainant’s primary domain names <bdo.global> and <bdoglobal.com>. The Respondent has not provided any evidence of a legitimate noncommercial or fair use of the Disputed Domain Name or reasons to justify its choice of the Disputed Domain Name that is confusingly similar to the Complainant’s BDO Trademarks. The fact that the Disputed Domain Name now resolves to an inactive page does not assist the Respondent, as such passive use does not amount to a bona fide offering of goods or services or a legitimate noncommercial or fair use. Further, the Panel finds no indication showing that the Respondent is commonly known by the Disputed Domain Name or otherwise has rights or legitimate interests in the Disputed Domain Name. The Complainant notes that the Respondent’s name, as identified in the WhoIs information, bears no resemblance to the Disputed Domain Name. The Panel further finds that before the Complainant’s takedown request, the Respondent used the Disputed Domain Name for a website that attempted to imitate the Complainant’s official website, including the use of a slightly modified version of the Complainant’s logo and same color scheme, in order to mislead Internet users into believing that the website was associated with the Complainant. In addition, the Panel notes that the terms “global forensics” in the Disputed Domain Name are closely related to the Complainant’s global business including forensics. Panels have held that the use of a domain name for attempted passing off or other deceptive activity can never confer rights or legitimate interests on a Respondent. WIPO Overview 3.1, section 2.13.1. For these reasons, the Panel finds that the Respondent has no rights or legitimate interests in the Disputed Domain Name. The Panel finds the second element of the Policy has been established. C. Registered and Used 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. In the present case, the Panel notes that the Disputed Domain Name was registered on June 2, 2026, long after the Complainant first registered the BDO Trademarks. Given that the distinctive and well-known page 5 character of the BDO Trademarks has been established under numerous UDRP decisions (See: Stichting BDO v. Tarren Adriaanse, Tarren Adriaanse, Noor Brenner, Itay Rogers, WIPO Case No. D2025-4900; Stichting BDO v. Name Redacted, WIPO Case No. D2023-1380; Stichting BDO v. neil neil., WIPO Case No. D2025-3243), it is implausible that the registration of the Disputed Domain Name, which incorporates the BDO Trademark in its entirety, was coincidental. In addition, the Panel finds that the bad faith registration and use of the Disputed Domain Name is also affirmed by the Respondent’s conduct under paragraph 4(b)(iv) of the Policy. In particular, the Respondent has used the Disputed Domain Name to attempt to imitate the Complainant’s official website by using a slightly modified version of the Complainant’s logo, copying the same color scheme as used by the Complainant, and mimicking the content of the Complainant’s official website. Notably, the Disputed Domain Name itself includes the descriptive terms “global forensics”, which are closely related to the Complainant’s services, and the associated website previously promoted similar services to those of the Complainant. In addition, the Panel also finds that the Respondent’s use of a privacy service, as found by past panels, may further support a finding of bad faith (WIPO Overview 3.1, section 3.6) and the current inactive status of the Disputed Domain Name does not prevent a finding of bad faith in this context (WIPO Overview 3.1, section 3.3). Having reviewed the available record, the Panel finds that the Respondent has registered and used the Disputed Domain Name in bad faith. 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 <bdo-global-forensics.com> be transferred to the Complainant. /Duy Khanh Nguyen/ Duy Khanh Nguyen Sole Panelist Date: September 4, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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