Westmore · UDRP DecisionAlstomgrouqs.com
The Panel ordered transfer of <alstomgrouqs.com> to Alstom. It found the domain confusingly similar to the ALSTOM trademark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. The decision relied particularly on the deliberate typographical variation of Alstom's <alstomgroup.com> domain, apparent impersonation of an Alstom employee, and use of the disputed domain for fraudulent emails seeking to redirect payments to different bank accounts.
The timeline behind alstomgrouqs.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 alstomgrouqs.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates how a domain that combines a recognizable trademark with a visually subtle alteration of a corporate-group term can satisfy all three UDRP elements when tied to employee impersonation and payment-redirection emails. The case also demonstrates the procedural handling of potential identity theft: the apparent victim's name was redacted, while a non-public annex supplied the Registrar with the information needed to implement the 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 Alstom v. Name Redacted, alstomgrouqs Case No. D2026-3079 1. The Parties The Complainant is Alstom, France, represented by Lynde & Associes, France. The Respondent is Name Redacted, alstomgrouqs. 1 2. The Domain Name and Registrar The disputed domain name <alstomgrouqs.com> is registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 13, 2026. On July 14, 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 (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 16, 2026, p roviding 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 July 21, 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”). 1 The Respondent appears to have used the name of a Complainant’s employee when registering the disputed domain name. In light of the potential identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding, and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788. page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on July 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 16, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on August 18, 2026. The Center appointed Anita Gerewal as the sole panelist in this matter on August 20, 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 company founded in 1928 and a global leader in transport infrastructure, with approximately 34,000 employees across more than 60 countries. For the financial year 2024-2025, the Complainant recorded EUR 19.8 billion in orders and EUR 18.5 billion in sales. It has an established international presence and significant commercial reputation in the transport sector. The Complainant owns numerous companies including Alstom Transport Technologies, Alstom Power Systems, Alstom Holdings, Alstom Shipworks, and Alstom APTIS and the designation “A lstom Group” is widely used by the Complainant to refer to the Complainant’s group and its various subsidiaries. The Complainant owns numerous trademark registrations for the word “ALSTOM” in many jurisdictions throughout the world, including the following: • United States Trademark Registration No. 85507365 for in class 12, filed on November 6, 2012, and registered on January 13, 2012; • European Union Trademark Registration No. 948729 for ALSTOM in classes 6, 7, 9, 11, 12, 16, 19, 24, 35, 37, 38, 39, 40, 41 and 42, filed on September 30, 1998, and registered on August 8, 2001; • International Registration No. 706292 for ALSTOM in classes 1, 2, 4, 6, 7, 9, 11, 12, 13, 16, 17, 19, 24, 35, 36, 37, 38, 39, 40, 41 and 42, registered on August 28, 1998 The Complainant is also the registrant of numerous domain names under various generic and country code Top Level Domains that comprise its ALSTOM trademark, such as <alstom.com> registered since January 20, 1998, and <alstomgroup.com> registered on November 14, 2000, both redirecting to the ALSTOM group’s website. The disputed domain name was registered on July 8, 2026, and as at the date of filing of the Complaint, resolved to an inaccessible page with a security warning. The Complainant has submitted evidence that the disputed domain name was used to send fraudulent emails impersonating one of the Complainant’s actual employees. 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 that that the disputed domain name is confusingly similar to its ALSTOM trademarks, as it reproduces the ALSTOM mark with a minor spelling alteration by replacing “p” with “q” and adding “s,” making the difference visually difficult to notice. The disputed domain name closely resembles the domain name <alstomgroup.com>, used by the Complainant, and therefore constitutes typo-squatting. page 3 The Complainant’s ALSTOM mark is clearly recognizable at the beginning of the disputed domain name, while “group” is descriptive when used alongside a company name. Given the worldwide reputation of the Complainant and its activities, Internet users are likely to perceive the disputed domain name as belonging to or being associated with the Complainant and may believe it was registered by the Complainant. Accordingly, the Complainant argues that the disputed domain name is confusingly similar to its prior ALSTOM trademarks. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name, as the Respondent is not affiliated with ALSTOM and was never authorized to use the ALSTOM mark, the Alstom Group name, or the disputed domain name. The disputed domain name resolves to a security warning indicating that the site may be attempting to steal users’ information, while the Respondent’s identity and contact details are not properly disclosed in the WhoIs record. The Complainant further alleges that the Respondent used the name of an actual Complainant’s employee without consent, together with a fictitious address and a non-existent organization name, indicating impersonation and awareness of the Complainant at the time of registration. In light of these circumstances, the Complainant argues that the disputed domain name is being used fraudulently to obtain confidential banking information and that the Respondent therefore lacks any rights or legitimate interests and is not acting in good faith. The Complainant further contends that the disputed domain name was registered and is being used in bad faith, as the ALSTOM mark is well known and the Respondent must reasonably have been aware of the Complainant and its activities. The Respondent allegedly concealed its identity through an anonymization service and invalid contact information, while deliberately using the letter “q” to visually mimic “p” and make the disputed domain name resemble the Complainant’s legitimate domain names. The Respondent used an email address associated with the disputed domain name to impersonate an employee of the Complainant and contact the company’s providers and clients, requesting that future payments be redirected to fraudulent bank accounts. The disputed domain name is also reportedly unsafe and associated with attempts to obtain confidential information. Taken together, the well-known ALSTOM trademark, deceptive typo-squatting, identity concealment, fraudulent communications, and unsafe use of the disputed domain name are presented as clear evidence of registration and use in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 4(a) of the Policy, in order to succeed, the Complainant must establish each of the following elements: (i) the disputed domain name is identical or confusingly similar to the 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. 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 ALSTOM trademark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. page 4 The Panel finds the mark is recognizable within the disputed domain name. The disputed domain name incorporates the Complainant’s trademark and the word “group” with a minor spelling alteration by replacing the letter “p” with the letter “q” and adding the letter “s” at the end. The misspelling and addition do not prevent a finding of confusing similarity. 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 other term here, “grouqs”, a misspelling of the term “groups”, may bear on assessment of the second and third elements, t he Panel finds the addition of such 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 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. The Panel finds that there is no evidence before the Panel that the Respondent is affiliated with, licensed by, or otherwise authorized by the Complainant to use the ALSTOM trademark, nor is there any evidence that the Respondent is commonly known by the disputed domain name. The disputed domain name resolves to an inaccessible page with a security warning indicating that the associated website may be unsafe. Moreover, the Respondent appears to have provided inaccurate or concealed contact information, including a fictitious or inaccurate address and the non-existent organisation name “alstomgrouqs”. The Respondent also allegedly impersonated an employee of the Complainant by using the name in the registration details and in fraudulent email communications. In addition, the disputed domain name was used to send fraudulent emails to the Complainant’s clients, requesting changes to bank details and payment of invoices. In the Panel’s view, such circumstances demonstrate that the Respondent was aware of the Complainant and its ALSTOM mark and that the disputed domain name was not used in connection with any bona fide offering of goods or services, but rather for fraudulent and deceptive purposes. Such unauthorized and fraudulent use cannot confer rights or legitimate interests upon the Respondent. 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. Panels have held that the use of a domain name for illegitimate activities/illegal activities such as phishing/identity theft, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. page 5 C. Registered and Used in Bad Faith The Panel notes that, fo r 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. In the present case, the Panel notes that the Complainant’s ALSTOM trademark has a longstanding presence and reputation, and the disputed domain name constitutes a deliberate typographical variation of the Complainant’s domain name <alstomgroup.com>, replacing the letter “p” with the visually similar letter “q” and adding the letter “s” at the end of the word “group”, such that it is highly unlikely that the Respondent registered the disputed domain name without knowledge of the Complainant or its trademark. The Respondent’s apparent impersonation, including through the use the name of a Complainant’s employee, and the fictitious organisation name together with the alleged impersonation of the Complainant’s employee in its fraudulent emails, further supports a finding of bad faith. The Panel also notes that the use of the disputed domain name in fraudulent email communications directed at the Complainant’s clients and providers, requesting changes to bank account details and redirecting payments, which demonstrates an intent to impersonate the Complainant and facilitate fraud. Taken together, these circumstances demonstrate that the Respondent registered and used the disputed domain name with knowledge of the Complainant and its ALSTOM trademark, with the intention of misleading Internet users and exploiting the Complainant’s reputation for fraudulent purposes. Panels have held that the use of a domain name for illegitimate activity/illegal activity such as phishing/identity theft constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes 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 <alstomgrouqs.com> be transferred to the Complainant. /Anita Gerewal/ Anita Gerewal Sole Panelist Date: September 3, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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