Westmore · UDRP DecisionSlidedownloaders.com
The Panel ordered transfer of <slidedownloaders.com> to Scribd, Inc. It found the domain confusingly similar to the Complainant’s SLIDESHARE mark because the recognizable term “slide” appeared at the beginning of the domain, the added term “downloaders” did not avoid confusing similarity, and the associated website expressly targeted SLIDESHARE. The Respondent lacked rights or legitimate interests because the use was unauthorized, the Respondent was not shown to be commonly known by the domain, and the website’s tool for circumventing the Complainant’s subscription fee was illegitimate for purposes of the Policy. Bad faith was established from the targeted use, the prominent display of the mark, the unauthorized access offered through the site, the Respondent’s evident knowledge of SLIDESHARE, and the absence of any response or good-faith explanation. The website disclaimer did not cure the illegitimate use or bad faith.
The timeline behind slidedownloaders.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 slidedownloaders.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that confusing similarity may be established even where a domain reproduces only a recognizable portion of a mark, particularly when the associated website clearly targets the trademark owner and displays the complete mark. It also shows that a non-affiliation disclaimer will not legitimize a service that the panel finds illegitimate or cure bad faith where the surrounding content demonstrates deliberate targeting.
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 Scribd, Inc. v. Đào Ngọc Case No. D2026-3441 1. The Parties The Complainant is Scribd, Inc., United States of America (“United States” or “U.S.”), represented by IPLA, LLP, United States. The Respondent is Đào Ngọc, Viet Nam. 2. The Domain Name and Registrar The disputed domain name <slidedownloaders.com> 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 August 3, 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 August 4, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that 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 August 7, 2026. In accordance with the Rules, paragraph 5, the due date for Response was August 27, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 3, 2026. The Center appointed Tobias Malte Müller as the sole panelist in this matter on September 10, 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 It results from the Complainant’s documented allegations, which remained undisputed, that it is the owner of a portfolio of trademarks for SLIDESHARE. In particular, it bases its Complaint on U.S. trademark registration no. 4212895 for SLIDESHARE (verbal) filed on November 3, 2011 and registered on September 25, 2012, for goods and services in classes 9, 35, and 42 (with first use dating back to October 4, 2006 for classes 9, and 42). Complainant owns and operates the website at the domain name <slideshare.net>. The Respondent registered the disputed domain name on August 17, 2025. The disputed domain name resolves to an active website, which calls itself “SLIDESHARE DOWNLOADER”. This website prominently displays the Complainant’s SLIDESHARE trademark and openly offers a tool to download copyrighted content from the Complainant’s platform by circumventing the subscription fee that the Complainant charges for its products and services. This website further includes a disclaimer at the bottom of the website stating amongst others that “...[w]e are not affiliated with, endorsed by, or connected to SlideShare or its parent company in any official capacity”. 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: (1) the disputed domain name incorporates the dominant first word “slide” from the Complainant’s SLIDESHARE trademark combined with the descriptive term “downloader”. The corresponding website prominently depicts the Complainant’s SLIDESHARE trademark and targets the Complainant. Therefore, Internet users encountering the disputed domain name will reasonably and mistakenly believe that the Respondent and its services originate from, are associated with, or are endorsed by the Complainant. Accordingly, the disputed domain name is confusingly similar to the Complainant’s SLIDESHARE trademark; (2) the disputed domain name provides the possibility to download copyrighted content from the Complainant’s platform without subscribing to the Complainant’s services by acting as a proxy and manipulating the URL link. Use of a domain name for illegal activity, such as to provide unauthorized access to a third-party platform’s subscription-only content, does not amount to a bona fide offering of goods or services to confer any right or legitimate interest in the disputed domain name. Further, the Complainant is not aware of any trademark rights, domain name rights, or other rights that the Respondent has relating to the SLIDESHARE marks, nor has the Complainant ever authorized the Respondent to use its SLIDESHARE marks in connection with any goods or services. Finally, nothing in the Respondent’s WhoIs information or any other publicly available source suggests the Respondent is commonly known by the disputed domain name; (3) The Respondent is using the disputed domain name to confuse Internet users and enable them to bypass the Complainant’s platform access controls and misleading users that such downloading activity is legal. This amounts to fraudulent and therefore illegal activity. In addition, the Complainant’s trademark rights in the SLIDESHARE marks date back to at least as early as 2006 so that the disputed domain name was registered many years after the Complainant’s common law use rights and/or registration of the SLIDESHARE marks. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 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”. Paragraph 4(a) of the Policy requires a complainant to prove each of the following three elements in order to obtain an order that each disputed domain name be transferred or cancelled: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and (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 Panel will therefore proceed to analyze whether the three elements of paragraph 4(a) of the Policy are satisfied. 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 registered trademark or service mark SLIDESHARE for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The Panel notes that this mark is not entirely included in the disputed domain name <slidedownloaders.com>. However, the confusing similarity test typically involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. In the case at hand, the Panel finds that the trademark SLIDESHARE is recognizable in the disputed domain name since the first element “slide”, to which users reading from left to right pay more attention, is identically reproduced in the disputed domain name (cf. Scribd, Inc. v. Webs Pulse and Sohail Habib, WIPO Case D2026-1609, finding domain names <slidesaver.net> and <saveslide.com> confusingly similar to the Complainant’s SLIDESHARE trademark; and Scribd, Inc. v. Jahanzaib khan, JahaSoft, Tahseen Kiani, WIPO Case D2025- 3300, finding domain names <slidedownload.com> and <slidesdownloader.com> confusingly similar to the Complainant’s SLIDESHARE trademark). While the content of the website associated with the domain name is usually disregarded by panels when assessing confusing similarity under the first element, the Panel does, however, take note of the content of the website associated with the disputed domain name. In fact, the Panel finds that the website content supports a finding of confusing similarity with the Complainant’s mark in this case. The website, to which the disputed domain name resolves, prominently shows the Complainant’s trademark SLIDESHARE in its entirety. In the Panel’s view, this confirms confusing similarity between the trademark and the disputed domain name since it appears prima facie that the Respondent seeks to target said trademark through the disputed domain name (WIPO Overview 3.1, section 1.15). Finally, although the addition of other term here, “downloaders”, 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. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. 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. Firstly, the Respondent did not submit any evidence of bona fide pre-Complaint use or preparations to use the disputed domain name pursuant to paragraph 4(c)(i) of the Policy. In particular, the Complainant’s uncontested allegations demonstrate that it has not authorized or licensed the Respondent’s use of its trademark for registering the disputed domain name which is confusingly similar to said trademark. Secondly, the Panel notes that there is no evidence in the records showing that the Respondent may be commonly known by the disputed domain name in the sense of paragraph 4(c)(ii) of the Policy. Finally, the Panel finds that the disputed domain name cannot constitute fair use pursuant to paragraph 4(c)(iii) of the Policy. Panels have held that the use of a domain name for illegitimate activity can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. As detailed above, the disputed domain name resolves to a website, which calls itself “SLIDESHARE DOWNLOADER”. This website prominently displays the Complainant’s SLIDESHARE trademark and openly offers a tool to download copyrighted content from the Complainant’s platform by circumventing the subscription fee that the Complainant charges for its products and services. The Panel considers this activity as described above to be illegitimate for the purposes of the Policy. The disclaimer provided at the bottom of the website does not render this illegitimate activity legitimate. 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. One of these circumstances is that the Respondent by using the disputed domain name, has intentionally attempted to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement page 5 of its website or location or of a product or service on its website or location (paragraph 4(b)(iv) of the Policy). This is the case here. According to the Complainant’s documented allegations the disputed domain name resolves to an active website, which calls itself “SLIDESHARE DOWNLOADER”. This website prominently displays the Complainant’s SLIDESHARE trademark and openly offers a tool to download copyrighted content from the Complainant’s platform by circumventing the subscription fee that the Complainant charges for its products and services. Panels have held that the use of a domain name for such illegitimate activity, here unauthorized access to copyrighted material, constitutes bad faith. WIPO Overview 3.1, section 3.4. As stated above, the disclaimer provided at the bottom of the website does not render this illegitimate activity legitimate nor can it cure the Respondent’s bad faith considering the circumstances of this case. In addition, this finding of bad faith registration and use is further supported by further circumstances resulting from the case at hand and in the absence of any evidence to the contrary. These further circumstances, the Panel considers to be relevant, are the following: (i) the Panel is convinced that the Respondent knew that the disputed domain name was confusingly similar to the Complainant’s trademark when it registered the disputed domain name and uses it for the illegitimate activity as described above. This is confirmed by the website content including the disclaimer provided at the bottom of the website, explicitly referring to Slideshare; (ii) the Respondent’s failure to submit a response or to provide any evidence of actual or contemplated good faith use; and (iii) A clear absence of rights or legitimate interests coupled with the Respondent’s failure to provide any explanation for its choice of the disputed domain name. 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 <slidedownloaders.com> be transferred to the Complainant. /Tobias Malte Müller/ Tobias Malte Müller Sole Panelist Date: September 24, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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