Westmore · UDRP DecisionAirbusglobals.pro
The Panel ordered the transfer of <airbusglobals.pro> to Airbus SAS. It found the domain confusingly similar to the AIRBUS trademark, concluded that the Respondent lacked rights or legitimate interests, and found bad-faith registration and use based principally on the Respondent's targeting of the widely known AIRBUS mark to attract users to a purported bitcoin investment website for commercial gain. The Respondent sent informal communications but filed no formal response.
The timeline behind airbusglobals.pro
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 airbusglobals.pro — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how a domain combining a widely known mark with a term suggestive of the trademark owner's international presence can support findings of deliberate targeting. It also shows that using such a domain for unrelated investment or bitcoin services, particularly through apparently replicated website content, may defeat any claim to a bona fide offering and support commercial-confusion bad faith. Post-complaint removal of content did not cure the prior conduct.
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 Airbus SAS v. Emmanuel Akam Case No. D2026-3408 1. The Parties The Complainant is Airbus SAS, France, represented by CSC Digital Brand Services Group AB, Sweden. The Respondent is Emmanuel Akam, Nigeria. 2. The Domain Name and Registrar The disputed domain name <airbusglobals.pro> is registered with Hostinger Operations, UAB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 31, 2026. On August 4, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On the same day, 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 Disclosed) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 5, 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 6, 2026. The Respondent sent several emails to the Center on August 6, 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 18, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 7, 2026. The Respondent did not submit any formal response. The Center appointed Mihaela Maravela as the sole panelist in this matter on September 11, 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. page 2 4. Factual Background According to information in the Complaint, the Complainant is an international reference in the aerospace sector. The Complainant has designed, manufactured and delivered industry-leading commercial aircraft, helicopters, military transports, satellites and launch vehicles for over 50 years. Its history dates back to the formation of the Airbus Industrie GIE consortium in 1970. Since then, the Complainant has delivered over 13,500 aircrafts to airlines worldwide, as of September 2021, and 12,000 helicopters operated by over 3,000 customers. The Complainant has a wide global presence, through roughly 180 locations across Europe, the Americas, Africa & Middle East and Asia. More than 157,000 employees make up the Complainant’s workforce. The Complainant communicates with its range of customers through its primary domain name <airbus.com>, registered since May 23, 1995. The Complainant has provided evidence that it is the registered owner of various trademarks relating to its brand AIRBUS, including, but not limited to the following: - International trademark AIRBUS (word), No. 1112012, registered on June 24, 2011, in classes 3, 6-9, 12- 14, 16-18, 21, 24-25, 28, 35-43, 45; and - International trademark AIRBUS (word), No. 1247403, registered on June 18, 2014, for goods and services in classes 3-4, 6-9, 11-14, 16-19, 21, 24-25, 28-43, 45. The disputed domain name was registered on March 10, 2026 and does not currently resolve to an active website. According to evidence furnished with the Complaint, the disputed domain name resolved previously (at least on June 24, 2026) to a website claiming to offer investment services. The Respondent is (presumably) an individual reportedly located in Nigeria. No information is available on the Respondent except for the information made available by the Registrar. 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 captures in its entirety the Complainant’s AIRBUS trademark and simply adds the generic term “globals” at the end of the trademark. The mere addition of this generic term to the Complainant’s trademark does not negate the confusing similarity between the disputed domain name and the Complainant’s trademark. As regards the second element of the Policy, the Complainant contends that Respondent is not sponsored by or affiliated with the Complainant in any way and that the Complainant has not given the Respondent permission to use the Complainant’s trademarks in any manner, including in domain names. Further, the Complainant contends that the Respondent is not making a bona fide offering of goods or services or legitimate, noncommercial fair use of the disputed domain name. Specifically, the Respondent has taken unfair commercial advantage of the Complainant’s trademark by using the confusingly similar disputed domain name to redirect users to a website claiming to offer investment services. Further, the “Terms of Use” page directly refers to a different website, that hosts near-identical content as the disputed domain name but for the replacement of AIRBUS with “Silverstones”. With respect to the third element of the Policy, the Complainant contends that it and its AIRBUS trademark are known internationally, with trademark registrations across numerous countries. The Complainant has marketed and sold its goods and services using this trademark since 1970, which is well before the Respondent’s registration of the disputed domain name on March 10, 2026. Prior panels have recognized the fame and notoriety of the AIRBUS trademark. In this sense, the Complainant cites previous decisions under the UDRP, such as Airbus SAS v. Cho-lin Yang, WIPO Case No. D2025-4854. Therefore, at the time page 3 of registration of the disputed domain name, the Respondent knew, or at least should have known, of the existence of the Complainant's trademarks and that the registration of domain names containing well-known trademarks constitutes bad faith per se. As regards the use, the Complainant argues that the disputed domain name promotes investment services unrelated to the Complainant and its services. This sort of tactic – labeled “bait-and switch” for its propensity to confuse Internet users into believing that they are visiting a Complainant’s site only to discover that the disputed domain name is completely unconnected to that Complainant – has been held to be evidence of bad faith registration and use by previous panels. B. Respondent The Respondent did not formally reply to the Complainant’s contentions. By an informal communication dated August 6, 2026, the Respondent mentioned that the disputed domain name and its contents had been taken down. No submissions were received from the Parties on any possible settlement. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs this Panel to “decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable”. Likewise, paragraph 10(d) of the Rules, provides that “the Panel shall determine the admissibility, relevance, materiality and weight of the evidence”. No substantive response has been received from the Respondent in this case. Even if the Respondent has not substantively replied to the Complainant’s contentions, the Complainant still bears the burden of proving that all requirements are fulfilled. To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (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 has been registered and is being used in bad faith. The applicable standard of proof in UDRP cases is the “balance of probabilities” or “preponderance of the evidence”, and the Panel can draw certain inferences in light of the particular facts and circumstances of the case. WIPO Overview of WIPO Panel Views on Select UDRP Questions, (“WIPO Overview 3.1”), section 4.2. Concerning the uncontested information provided by the Complainant, the Panel may, where relevant, accept the reasonable factual allegations in the Complaint as true. WIPO Overview 3.1, section 4.3. 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 3.1, section 1.7. The Complainant has shown rights in respect of the trademark AIRBUS for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The entirety of the mark is reproduced 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. Although the addition of other terms (here, “globals”) 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. It is the settled view of panels applying the Policy that the generic Top-Level Domains (“gTLDs”) (here “.pro”) may be disregarded under the first element test. See WIPO Overview 3.1, section 1.11. 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 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. According to the record, the Respondent has no connection or affiliation with the Complainant, and the Complainant has not licensed or otherwise authorized the Respondent to use or register any domain name incorporating the Complainant’s trademarks. Further, the Respondent does not appear to make any legitimate noncommercial or fair use of the disputed domain name, nor any use in connection with a bona fide offering of goods or services. Rather, the Respondent has used the disputed domain name to resolve to a website purporting to offer financial services unrelated to the Complainant. Also, according to the unrebutted evidence with the Complaint, the Respondent’s website refers to a different website, that hosts near-identical content as the disputed domain name but for the replacement of AIRBUS with “Silverstones”. Therefore, on the available record, the Panel is not persuaded that this represents a bona fide business for the purposes of the Policy. Furthermore, the Panel finds that the composition of the disputed domain name (incorporating the Complainant’s trademark AIRBUS in its entirety with the addition of the term “globals”), signals the Respondent’s intention of taking unfair advantage of the likelihood of confusion between the disputed domain name and the Complainant as to the origin or affiliation of the website. The Respondent is reportedly called “Emmanuel Akam” and there is no evidence that the Respondent is commonly known by the disputed domain name within the meaning of paragraph 4(c)(ii) of the Policy. Also, the Respondent has not formally replied to the Complainant’s contentions, claiming any rights or legitimate interests in the disputed domain name. Instead, he asked that the case is closed and mentioned that “The domain and it’s contents has been taken down”. 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. page 5 The disputed domain name reproduces, without any authorization or approval, the Complainant’s registered AIRBUS trademark with the addition of the dictionary word “globals”, which presumably alludes to the global presence of the Complainant’s products and services. The Panel finds the Complainant’s AIRBUS trademark to be distinctive and widely known and to have established a worldwide reputation in the aerospace sector. In the light of these factors, the Panel’s findings above and the fact that the Respondent provided no explanation for why he registered the disputed domain name and did not deny in his informal communication his knowledge of the Complainant and its trademarks, the Panel deems that the Respondent’s registration of the disputed domain name was not merely coincidental. Rather, under the circumstances of this case, the Panel finds that the Respondent registered the disputed domain name with knowledge of the Complainant and its AIRBUS trademark and with the intention of taking unfair commercial advantage of the goodwill attaching to that trademark. As regards the use, as described above, the Panel deems that the Respondent has used the disputed domain name containing the AIRBUS mark to attract and confuse Internet users into thinking that there is some affiliation between the website at the disputed domain name and the Complainant when that is not the case. The Respondent’s website is ostensibly for commercial purposes, as it purportedly invites Internet users to invest in bitcoin. Further, the Complainant provided evidence of another website at a different domain name that displays practically identical information to the website at the disputed domain name. Although there is no evidence to suggest that such domain name and website is necessarily owned by the Respondent, this evidence does suggest that the Respondent is not running a bona fide business with a differentiated website and business offering, but is rather using the disputed domain name incorporating the Complainant’s reputed AIRBUS mark to divert Internet users and attract traffic to its website at the disputed domain name for its own purposes. By doing so, it is clear that the Respondent was intentionally seeking to attract Internet users for commercial gain through the creation of a likelihood of confusion with the Complainant’s trademark. See WIPO Overview 3.1, section 3.1.4. The Respondent’s use of a privacy service in an attempt to hide its identity only reinforces the Panel’s view of the Respondent’s bad faith. Further, not only did the Respondent fail to explain its conduct both before and during these proceedings, but he has taken action to remove the content at the disputed domain name, which further reinforces the above findings. 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 <airbusglobals.pro> be transferred to the Complainant. /Mihaela Maravela/ Mihaela Maravela Sole Panelist Date: September 25, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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