Westmore · UDRP DecisionSareptatx.org
The Panel ordered transfer of <sareptatx.org> to Sarepta Therapeutics, Inc. The domain reproduced the Complainant’s SAREPTA mark and added “tx,” a term sometimes used to refer to “therapeutics.” The Panel found no rights or legitimate interests because the Respondent was unauthorized, was not commonly known by the domain, made no bona fide or legitimate noncommercial use, and used the domain for fraudulent recruitment emails impersonating the Complainant. That phishing activity also demonstrated knowledge and targeting of the Complainant and established bad-faith registration and use.
The timeline behind sareptatx.org
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 sareptatx.org — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates that an inactive website does not prevent a transfer where the domain is actively used through email for impersonation and phishing. The combination of the full SAREPTA mark with “tx,” a term associated with “therapeutics,” supported both confusing similarity and the inference of deliberate targeting when considered alongside the fraudulent recruitment communications.
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 Sarepta Therapeutics, Inc. v. Lucille Goins Case No. D2026-3370 1. The Parties The Complainant is Sarepta Therapeutics, Inc., United States of America (“United States” or “U.S.”), represented by Arnold & Porter Kaye Scholer LLP, United States. The Respondent is Lucille Goins, United States. 2. The Domain Name and Registrar The disputed domain name <sareptatx.org> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 29, 2026. On July 30, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 31, 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 (Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 3, 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 August 4, 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 August 12, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 1, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 2, 2026. page 2 The Center appointed Raj Sachdev as the sole panelist in this matter on September 4, 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, Sarepta Therapeutics, Inc., is a corporation existing under the laws of the State of Delaware, United States, with its principal place of business in Cambridge, Massachusetts, United States. It is a global biotechnology company that develops and sells precision genetic medicines and that develops gene therapy products for the treatment of rare diseases. The Complainant is the owner of various global and U.S. federal trademark registrations for SAREPTA and SAREPTA THERAPEUTICS marks, including, but not limited to: U.S. Trademark Registration No. Mark Class(es) Date of Registration 4,724,239 SAREPTA 1 April 21, 2015 4,653,264 SAREPTA 5, 42 December 9, 2014 6,342,349 SAREPTA 5 May 4, 2021 4,724,240 SAREPTA THERAPEUTICS 1 April 21, 2015 4,653,265 SAREPTA THERAPEUTICS 5, 42 December 9, 2014 The Complainant operates a website under the domain names <sarepta.com> and <sareptatherapeutics.com> (the latter domain name redirects to the former) through which it provides information about itself and its products, programs and services, as well as for employee email addresses. The disputed domain name was registered on June 23, 2026, with registrant information records disclosed by the Registrar indicate the disputed domain name to be registered by Lucille Goins under Privacy service provided by Withheld for Privacy ehf. The disputed domain name resolves to a “can’t reach this page” message. 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 the disputed domain name is confusingly similar to the SAREPTA mark because it contains the SAREPTA mark in its entirety. The Complainant contends that the additional term “tx” is a common abbreviation of “therapeutics”. The Complainant also contends that the Complainant has never authorized the Respondent to use the disputed domain name, that the Respondent is not commonly known by “sarepta” or the disputed domain name, and has never engaged in any bona fide commercial activity in connection with the disputed domain name. The Complainant further contends that the Respondent has no rights or legitimate interests in the Complainant’s trademarks and has registered and used the disputed domain name in bad faith to perpetrate phishing scams and impersonate the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed the Complainant must satisfy the Panel 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 was registered and is being used in bad faith. A. Identical or Confusingly Similar The Complainant has shown rights in respect of the SAREPTA and SAREPTA THERAPEUTICS marks for the purposes of the Policy through its many trademark registrations including the United States registrations referenced in the Factual Background section above (see WIPO Overview 3.1, section 1.2.1). The SAREPTA mark is entirely reproduced within the disputed domain name along with the addition of “tx” which is sometimes used to refer to “therapeutics”. As is the case here, where a domain name incorporates the entirety of a trademark, or where at least a dominant feature of the relevant mark is recognizable in the domain name, the domain name will normally be considered confusingly similar to that mark (see WIPO Overview 3.1, section 1.7). Although the addition of another term, here, “tx,” may bear on assessment of the second and third elements, the 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 (see WIPO Overview 3.1, section 1.8). Further, the added generic Top-Level Domain (“gTLD”), “.org”, is typically disregarded in the confusing similarity test as such is a standard registration requirement (see WIPO Overview 3.1, section 1.11.1). Accordingly, the disputed domain name is confusingly similar to the SAREPTA and SAREPTA THERAPEUTICS marks for the purposes of the Policy. 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 (see 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 submitted a response and accordingly 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. Specifically, the Complainant has not authorized the Respondent to use the SAREPTA or SAREPTA THERAPEUTICS trademarks. There is also no evidence that the Respondent is commonly known by the disputed domain name. Further, there is no evidence of any bona fide offering of goods or services, or legitimate noncommercial use. Panels have held that the use of a domain name for illegitimate or illegal activity, here, claimed phishing activity, can never confer rights or legitimate interests on a respondent (WIPO Overview 3.1, section 2.13.1). The Complainant has submitted evidence showing the disputed domain name was used for a fraudulent recruitment email scheme. The Respondent used the disputed domain name to send phishing emails page 4 impersonating the Complainant and asking recipients to engage in a job recruitment process. Such activity clearly does not confer rights or legitimate interests on a respondent (see Sarepta Therapeutics, Inc. v. My Name, User User, WIPO Case No. D2024-2938; Lonza Ltd v. Geral Gera, SEGLINK, WIPO Case No. D2025-1342). 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 Respondent has registered and used the disputed domain name in bad faith under paragraph 4(b) of the Policy. 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 (see WIPO Overview 3.1, section 3.2.1). Panels have held that the use of a domain name for illegitimate or illegal activity, here, claimed phishing, constitutes bad faith (see WIPO Overview 3.1, section 3.4). Evidence submitted by the Complainant shows that an email address associated with the disputed domain name, specifically “[...]@sareptatx.org”, was used by the Respondent to send phishing emails to solicit job applications online purported to be with the Complainant and falsely holding itself out as the Complainant usings its logo. This activity shows clear knowledge and targeting of the Complainants mark. The Respondent used the disputed domain name to impersonate the Complainant and engage in phishing, an activity considered bad faith (see Sarepta Therapeutics, Inc. v. My Name, User User, WIPO Case No. D2024-2938; Lonza Ltd v. Geral Gera, SEGLINK, WIPO Case No. D2025-1342; and Aspen Insurance Holdings Limited v. Bukayo Ajiboye, WIPO Case No. D2023-0669). Additionally, the Respondent used a privacy service, which by itself does not automatically equate to bad faith, but appears to have been used to remain anonymous to engage in phishing, another indicator of bad faith (see WIPO Overview 3.1, section 3.6). Further, the Respondent also did not respond to the Complaint, further indicating bad faith (see Sarepta Therapeutics, Inc. v. Daniel Nduta, KAGZDO, WIPO Case No. D2023-3058). Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitute 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 <sareptatx.org> be transferred to the Complainant. /Raj Sachdev/ Raj Sachdev Sole Panelist Date: September 14, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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