Westmore · UDRP DecisionVfs-biometric.online
The Panel ordered the transfer of <vfs-biometric.online> to VFS Global Services PLC. It found the domain confusingly similar to the Complainant’s VFS-formative marks, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The findings relied particularly on the incorporation of VFS with the business-related term “biometric” and evidence that the domain was used for deceptive emails impersonating the Complainant. The Respondent did not file a response.
The timeline behind vfs-biometric.online
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
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The case illustrates how a domain combining a recognizable mark with a term closely tied to the trademark owner’s operations can support both targeting and bad-faith findings when coupled with impersonation emails. The email use was especially significant because it independently defeated any claim to bona fide or fair use and corroborated the Panel’s finding that the Respondent knew of the Complainant when registering the 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 VFS Global Services PLC v. noush JOSHUA Case No. D2026-3070 1. The Parties The Complainant is VFS Global Services PLC, United Kingdom (the “UK”), represented by Aditya & Associates, India. The Respondent is noush JOSHUA, Nigeria. 2. The Domain Name and Registrar The disputed domain name <vfs-biometric.online> (the “Disputed Domain Name”) is registered with PDR Ltd. d/b/a PublicDomainRegistry.com (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 13, 2026. On July 13, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On July 14, 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 and contact information in the Complaint. The Center sent an email communication to the Complainant on July 15, 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 amendment to the Complaint on July 15, 2026. The Center verified that the Complaint together with the amendment to 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 30, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 19, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 24, 2026. page 2 The Center appointed Marilena Comanescu as the sole panelist in this matter on August 31, 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, established in 2010 in the UK, provides outsourcing and technology services in connection with the provision of visa application services for various countries, including operating visa application centers under the VFS brand at which individuals can file visa applications. Currently, the Complainant and its group affiliates serve the interests of the diplomatic missions of 71 sovereign governments in 168 countries across 5 continents. The Complainant has successfully processed over 552.07 million transactions since its inception in 2001 and over 237.3 million biometric enrolments since 2007, and operates out of 4180 visa application centers located in Asia, Africa, the Middle East, and Europe. The Complainant and its affiliates hold trademark rights for or including VFS / VFS GLOBAL, such as the following: - the European Union Trademark registration number 006923569 for VFS GLOBAL (figurative), filed on May 7, 2008, registered on June 29, 2009, covering goods in International Classes 9, 35, and 38; and - the International Trademark registration number 1250991 for VFS.GLOBAL EST.2001 (figurative), registered on September 5, 2014, designating numerous jurisdictions worldwide, and covering goods and services in International Classes 9, 16, 35, 38, 39, and 42. The Complainant holds and operates the domain name <vfsglobal.com>, registered on February 23, 2005. The Disputed Domain Name was registered on August 22, 2025, and, at the time of filing the Complaint, it was used in connection with a website purporting to promote a Canadian petroleum association. However, the Complainant provided evidence that indicates the Disputed Domain Name was used to send emails to commit fraud impersonating the Complainant. 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: - VFS / VFS GLOBAL forms an essential and integral part of the Complainant’s corporate name and trading name and the Complainant enjoys enormous goodwill and reputation for the services provided; - the Disputed Domain Name is identical and/or confusingly and deceptively similar to the Complainant’s domain name <vfsglobal.com> and/or trademarks; - the Respondent has no rights or legitimate interests in the Disputed Domain Name mainly because: (i) the Disputed Domain Name does not, in any way, reflect the Respondent’s name; the Respondent does not own any trademark registration, nor has acquired any reputation and/or goodwill in the term “vfs”; (ii) the Complainant never granted the Respondent any right, license, authorisation or consent to use its trademark; (iii) the Respondent has no justification for adopting “vfs” as a primary name and this fact clearly portrays the page 3 Respondent’s dishonest and malicious intention in adopting the Complainant’s registered trademark without authorisation; and (iv) the use of the Disputed Domain Name to deceive consumers by misrepresenting the origin of the services offered does not qualify as a bona fide offering of goods or services; - the Respondent registered and is using the Disputed Domain Name in bad faith mainly because: (i) the Complainant’s trademarks and domain name significantly predate the date of the registration of the Disputed Domain Name; (ii) the Disputed Domain Name reproduces the Complainant’s trademark with the addition of the dictionary term “biometric”, which relates to services very closely associated with the Complainant’s visa application services, thereby creating a highly deceptive impression of legitimacy and official association with the Complainant; (iii) the Respondent sent a fraudulent email from an email address associated with the Disputed Domain Name, representing itself as “VFS GLOBAL LAGOS” thereby deliberately impersonating the Complainant and its personnel; and (iv) the Respondent’s registration and use of the Disputed Domain Name constitutes active and egregious bad faith use, as the corresponding website and email correspondence have been deliberately used to impersonate the Complainant and create a false impression of an association with the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under the Policy, the Complainant is required to prove on the balance of probabilities 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 the Disputed Domain Name; and (iii) the Disputed Domain Name has been registered and is being used in bad faith. 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 Panel finds the dominant element of the mark, VFS, is recognizable 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. While the addition of other term, here “biometric”, and the removal of the term “global” from the VFS GLOBAL mark, may bear on assessment of the second and third elements, the Panel finds such alterations do 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. page 4 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 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 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 has provided evidence indicating that the Disputed Domain Name was used in connection with fraudulent emails sent to the Complainant’s clients impersonating the Complainant. Therefore, the Respondent is not using the Disputed Domain Name in connection with any bona fide offering of goods or services, nor is the Respondent making a legitimate noncommercial or fair use of the Disputed Domain Name. Rather, it appears that the Disputed Domain Name has been used for illegal purposes, which can never confer rights or legitimate interests upon the Respondent. WIPO Overview 3.1, section 2.13.1. 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 that the Disputed Domain Name was registered in bad faith, with knowledge of the Complainant and its trademark, particularly because it incorporates the Complainant’s mark with a term related to the Complainant’s business and is very similar to the Complainant’s domain name. Also, the Complainant’s mark and domain name predate the registration of the Disputed Domain Name with about two decades. Furthermore, the use of the Disputed Domain Name corroborates this finding. 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 Complainant provides evidence that the Disputed Domain Name has been used to send deceptive emails impersonating the Complainant. The use of a domain name for illegitimate activity is considered as manifest evidence of bad faith. WIPO Overview 3.1, section 3.4. The Panel finds that the Complainant has established the third element of the Policy. page 5 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, <vfs-biometric.online>, be transferred to the Complainant. /Marilena Comanescu/ Marilena Comanescu Sole Panelist Date: September 14, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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