Westmore · UDRP decision
WIPO · Case No. D2026-3549

Hem0farm.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <hem0farm.com> to Hemofarm A.D. The Domain Name replaced the letter “o” in the HEMOFARM trademark with the numeral “0”. The Panel found confusing similarity, no rights or legitimate interests, and bad-faith registration and use based principally on the Domain Name’s use for emails impersonating the Complainant and seeking to induce fraudulent transactions.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-22
Panelist(s)
Nicholas Smith
Complainant
Hemofarm A.D., Serbia
Respondent
Tyler Hall
Disputed domain(s)
hem0farm.com
Domain history UDRP Intelligence

The timeline behind hem0farm.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 hem0farm.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of hem0farm.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates that a domain need not host an active website to support transfer where it is used as infrastructure for deceptive email. It also applies the established treatment of a visually similar letter-to-numeral substitution as confusingly similar typosquatting and treats phishing, impersonation, and fraud as incompatible with rights or legitimate interests and as evidence of bad faith.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registered and used in bad faithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-09-22
Panel
Nicholas Smith
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Hemofarm A.D. v. Tyler Hall Case No. D2026-3549 1. The Parties The Complainant is Hemofarm A.D., Serbia, represented by The GigaLaw Firm, Douglas M. Isenberg, Attorney at Law, LLC, United States of America (“United States”). The Respondent is Tyler Hall, United States. 2. The Domain Name and Registrar The disputed domain name <hem0farm.com> (the “Domain Name”) is registered with Wild West Domains, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 11, 2026. On August 11, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On August 26, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 26, 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 August 26, 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 August 27, 2026. In accordance with the Rules, paragraph 5, the due date for Response was September 16, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 17, 2026. page 2 The Center appointed Nicholas Smith as the sole panelist in this matter on September 21, 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 Serbian company that since 1960 has supplied a range of generic pharmaceuticals. The Complainant manufactures about 6.6 billion tablets and capsules annually, operates in 34 markets on four continents and has a team of more than 3,600 employees. The Complainant offers its products under a trademark consisting of the term “Hemofarm” (the “HEMOFARM Mark”) (as well as other marks containing the term “Hemofarm”), including from its primary website at “www.hemofarm.com” which provides information on the Complainant’s products. The Complainant has held trademark registrations for the HEMOFARM Mark in various jurisdictions, including United Kingdom Registration Number UK00904504049, registered June 5, 2014, for goods and services in classes 5 and 35. The Domain Name was registered on February 24, 2026. The Domain Name does not resolve to an active website. The Complaint contains evidence that the Respondent has sent emails from an email account in the address format “[...]@hem0farm.com” where the Respondent impersonates the Complainant and seeks to engage in fraudulent transactions. 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 Domain Name. Notably, the Complainant contends that: a) It is the owner of the HEMOFARM Mark, having registered the HEMOFARM Mark in the United Kingdom and other jurisdictions. The Domain Name is confusingly similar to the HEMOFARM Mark as it merely replaces the letter “o” in the HEMOFARM Mark with the number “0” to create a minor misspelling. b) There are no rights or legitimate interests held by the Respondent in respect of the Domain Name. The Complainant has not granted any license or authorization for the Respondent to use the HEMOFARM Mark. The Respondent is not commonly known by the HEMOFARM Mark, nor does it use the Domain Name for a bona fide purpose or legitimate noncommercial purpose. Rather, the Domain Name is used for emails impersonating the Complainant, which does not provide the Respondent with rights or legitimate interests in the Domain Name. c) The Domain Name was registered and is being used in bad faith. The Domain Name is being used for emails that impersonate the Complainant in order to perpetuate fraud. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 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 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 mark is recognizable within the Domain Name. Accordingly, the Domain Name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.1, section 1.7. A domain name which consists of a misspelling of a trademark is considered by panels to be confusingly similar to the relevant mark for the purpose of the first element. Here the replacement of the letter “o” with the number “0” creates such a minor misspelling of the Complainant’s trademark. WIPO Overview 3.1, section 1.9. 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 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 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 Domain Name such as those enumerated in the Policy or otherwise. The Panel considers that the record of this case reflects that: • Before any notice to the Respondent of the dispute, the Respondent did not use, nor has it made demonstrable preparations to use, the Domain Name or a name corresponding to the Domain Name in connection with a bona fide offering of goods or services. Paragraph 4(c)(i) of the Policy, and WIPO Overview 3.1, section 2.2. • The Respondent (as an individual, business, or other organization) has not been commonly known by the Domain Name. Paragraph 4(c)(ii) of the Policy, and WIPO Overview 3.1, section 2.3. • The Respondent is not making a legitimate noncommercial or fair use of the Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Paragraph 4(c)(iii) of the Policy, and WIPO Overview 3.1, section 2.4. page 4 • The record contains no other factors demonstrating rights or legitimate interests of the Respondent in the Domain Name. Furthermore, the Respondent’s use of the Domain Name is in connection with a phishing scheme, namely to send emails passing itself off as the Complainant to third parties for the likely purpose of engaging in fraudulent transactions. Panels have held that the use of a domain name for illegitimate activity (here claimed to be phishing and impersonation/passing off) can never confer rights or legitimate interests on a 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. Panels have held that the use of a domain name for illegitimate activity (here claimed to be phishing and impersonation/passing off) 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 Domain Name constitute bad faith under the Policy. The Domain Name has been used to create an email account where the Respondent sends emails purporting to be emails from the Complainant seeking to induce the other party to enter into a fraudulent transaction by creating the mistaken impression that they are dealing with the Complainant. This amounts to the commission of fraud. 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 Domain Name <hem0farm.com> be transferred to the Complainant. /Nicholas Smith/ Nicholas Smith Sole Panelist Date: September 22, 2026

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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