ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION General Electric Company v. Daniel Stanley, GeAerosapceGroup Case No. D2025-1754 1. The Parties Complainant is General Electric Company, United States of America (“United States”), represented by Faegre Drinker Biddle & Reath, United States. Respondent is Daniel Stanley, GeAerosapceGroup, United States. 2. The Domain Name and Registrar The disputed domain name is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 1, 2025. On May 1, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 2, 2025, 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, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to Complainant on May 5, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amendment to the Complaint on May 8, 2025. 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 Respondent of the Complaint, and the proceedings commenced on May 12, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 1, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on June 2, 2025.
page 2 The Center appointed Scott R. Austin as the sole panelist in this matter on June 17, 2025. 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 following facts appear from the Complaint and its Annexes, which facts have not been contested by Respondent. Organized in 1892 under the name General Electric Company, following the merger of Thomas-Houston Electric Company and light bulb inventor Thomas Edison’s Edison General Electric Company, Complainant is a multinational business incorporated in the United States state of New York and headquartered in Evendale, Ohio. Since its founding, Complainant has expanded its business into new and widely varying industries, including aerospace, lighting, appliances, renewable energy, and more, all under the trademarks GE, the GE “monogram”, as well as the more recent GE AEROSPACE trademarks. (collectively “the GE Marks”). Complainant claims statutory trademark rights through over 3,300 active applications and registrations for the GE Marks around the world for a range of products and services, including the following: United States Registration No. 35,089, GE (figurative), registered on September 18, 1900, for a range of electric devices and wiring devices in International Class 21; United Kingdom Trade Mark No. 2271563, GE, registered on February 8, 2002, for a range of goods and services in International Classes 1-4, 6-12, 14, 16-19, 25, 28, and 35-42; China Trademark Registration No. 3049561, GE, registered on February 21, 2005, for a range of machines and household appliances in International Class 7; European Union Trade Mark No. 018919099, GE AEROSPACE (figurative), registered on March 27, 2024, for a range of goods in International Classes 1, 7, 9, 35, 37, 40-42. Complainant also shows it has a substantial Internet presence and wholly incorporates the GE Mark into its official domain name, , which it registered on August 5, 1986, making it the 20th domain name ever registered. The official domain name provides access to its primary website used in service of three separate, stand-alone going-forward companies that operate under the GE Marks, namely Complainant which goes to market as “GE Aerospace”, and the licensees GE Vernova, LLC, and GE HealthCare Technologies Inc. GE Aerospace is now a publicly traded multinational aerospace technology and industrial company with approximately 53,000 employees operating in approximately 170 countries worldwide and is a leading provider of jet and turboprop engines, components, and integrated systems for commercial, military, business, and general aerospace crafts. Complainant’s GE Aerospace business official domain name, was registered by Complainant and in use since January 9, 2012. The disputed domain name was registered on March 28, 2025, and as of the filing of the Complaint, the disputed domain name resolved to a copycat website being used to host content that mirrors Complainant’s legitimate “careers” website located at and redirects users to Complainant’s own site once the domain has loaded.
page 3 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Complainant contends that the disputed domain name is identical or confusingly similar to Complainant’s GE Marks, that Respondent has no rights or legitimate interests in respect of the disputed domain name, and that the disputed domain name was registered and is being used in bad faith. Notably, Complainant cites numerous trademark registrations in the United States dating back to its first registration in 1900, and numerous other registrations around the world, for its GE Marks as prima facie evidence of ownership. Complainant submits that the GE Marks are famous and that its rights in that mark predate the Respondent’s registration of the disputed domain name by over 124 years. It submits that the disputed domain name is confusingly similar to its trademark because the disputed domain name incorporates in its entirety the GE and GE AEROSPACE Marks and that the similarity is not removed by the additional term “careers” or the addition of the generic Top-Level Domain (“gTLD”) “.org”. Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name because they resolve to a website that mimics or resembles its own. Finally, Complainant alleges that the registration and use of the disputed domain name was, and currently is, in bad faith, contrary to the Policy and Rules having regard to the fame and long standing prior use of Complainant’s GE Marks. Complainant cites a number of previous UDRP decisions involving Complainant and also submits evidence showing that the Respondent’s website creates a false impression that it is somehow connected with Complainant. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules provides that the Panel is to decide the Complaint on the basis of the statements and documents submitted in accordance with the Policy, the Rules, and any rules and principles of law that it deems applicable. The onus is on Complainant to make out its case and it is apparent from the terms of the Policy that Complainant must show that all three elements set out in paragraph 4(a) of the Policy have been established before any order can be made to transfer a domain name. As the proceedings are administrative, the standard of proof under the Policy is often expressed as the “balance of the probabilities” or “preponderance of the evidence” standard. Under this standard, an asserting party needs to establish that it is more likely than not that the claimed fact is true. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.2. Thus, for Complainant to succeed it must prove within the meaning of paragraph 4(a) of the Policy and on the balance of the probabilities that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) 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 finds that Complainant has met its burden in all three elements of the Policy and will deal with each of these elements in more detail below.
page 4 A. Identical or Confusingly Similar To prove this element, Complainant must have trade or service mark rights, and the disputed domain name must be identical or confusingly similar to Complainant’s trade or service mark. Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy. WIPO Overview 3.0, section 1.2.1. Based upon the trademark registrations cited by Complainant, as well as supporting documents, the Panel finds that Complainant has established trademark rights in and to its GE Marks. Having met its burden for established trademark rights in the GE Marks, Complainant next contends that the disputed domain name is identical or confusingly similar to Complainant’s GE Marks because the dominant part of the disputed domain name comprises the terms “geareospace”, identical to the GE and GE AEROSPACE Marks. 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. Prior UDRP panels have held the fact that a domain name wholly incorporates a complainant’s registered mark is sufficient to establish identity or confusing similarity for purposes of the Policy despite the addition of other words to such marks. WIPO Overview 3.0, section 1.8 (“Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element”); see also BNP Paribas v. Ronan Laster, WIPO Case No. D2017-2167; Compagnie Gervais Danone v. DomainPark Limited, WIPO Case No. D2008-0587; Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. The disputed domain name incorporates Complainant’s GE Marks in in their entirety and appends the term “careers”. Respondent appending this term to Complainant’s GE Marks does not prevent a finding of confusing similarity for the reasons stated in the UDRP decisions cited above. The addition of the gTLD, “.org” in this case, is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11; see also Research in Motion Limited v. Thamer Ahmed Alfarshooti, WIPO Case No. D2012-1146. Complainant’s GE Mark and GE AEROSPACE Mark each remain fully recognizable as incorporated in its entirety into the disputed domain name. Accordingly, the Panel finds the disputed domain name is confusingly similar to the GE Marks in which Complainant has rights and Complainant has thus satisfied its burden under paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which 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 perplexing 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 3.0,
page 5 section 2.1. See also, Malayan Banking Berhad v. Beauty, Success & Truth International, WIPO Case No. D2008-1393. Respondent here has failed to appear to present any evidence of its rights or legitimate interests in the disputed domain name. The Panel finds that Complainant has established a prima facie case that Respondent has no rights or legitimate interests in the disputed domain name. Paragraph 4(a)(ii) of the Policy also directs an examination of the facts to determine whether a respondent has rights or legitimate interests in a domain name. Paragraph 4(c) lists a number of ways in which a respondent may demonstrate that it does have such rights or legitimate interests. First, Complainant contends that it is not aware of any relationship between it and Respondent that would give rise to any license, permission, or authorization given by Complainant to Respondent, to use the GE Marks in the disputed domain name or otherwise. Complainant also contends Respondent is not commonly known by the disputed domain name or the GE Marks, in accordance with paragraph 4(c)(ii) of the Policy. Respondent used the name “Daniel Stanley, GeAerosapceGroup” when registering the disputed domain name. The Panel notes the registrant name Daniel Stanley does not resemble the disputed domain name or Complainant’s GE Marks in any manner and the registrant organization name which follows it, appears to be a misspelling of Complainant’s business unit, and is wholly unauthorized by Complainant. The Panel finds, therefore, that Respondent is not commonly known by the disputed domain name. Rather, it appears the choice of registrant details is intended to falsely suggest affiliation with Complainant. The Panel finds that Respondent has neither any connection with Complainant, nor has Respondent been authorized or licensed by Complainant to use and register the GE Marks or to register any domain name incorporating Complainant’s GE Marks. Prior UDRP panels under the Policy have found that “[i]n the absence of any license or permission from Complainant to use its trademark, no actual or contemplated bona fide or legitimate use of the disputed domain name could reasonably be claimed”. See Sportswear Company S.P.A. v. Tang Hong, WIPO Case No. D2014-1875. Complainant next contends that Respondent is not using the disputed domain name in connection with a bona fide offer of goods or services in accordance with paragraph 4(c)(i) of the Policy or a legitimate noncommercial or fair use of the disputed domain name anticipated under paragraph 4(c)(iii) of the Policy, but has intentionally chosen a domain name based on a well-known registered trademark in order to generate traffic and income, through a copycat website being used to host content that mirrors Complainant’s legitimate “careers” website (located at ) and redirects users to the same once the domain name has loaded. The Panel notes that the record of evidence submitted in the Annex to the Complaint supports Complainant’s argument that Respondent is juxtaposing Complainant’s widely recognized GE Marks for Complainant’s electric and aerospace products and services with a website created by Respondent to create a false association with Complainant, by which Respondent likely earns income or is being used to phish personal or financial information from Complainants employees or prospective employees. Previous UDRP panels have confirmed that such use is neither a bona fide offer of goods or services in accordance with paragraph 4(c)(i) of the Policy, nor a legitimate noncommercial or fair use of the disputed domain name in accordance with paragraph 4(c)(iii) of the Policy. Here, the disputed domain name combines the famous GE Mark and widely recognized GE AEROSPACE Mark with a term descriptive of Complainant’s job site creating risk of implied affiliation to mislead Internet users expecting to find Complainant to further their career and instead are directed to a website featuring Respondent’s business as a pretext for Respondent’s commercial gain. WIPO Overview 3.0, sections 2.5.1 and 2.5.3. See also
page 6 GameStop, Inc. v. Above.com Domain Privacy/Protection Domain, WIPO Case No. D2018-1243 and smava GmbH v. Anna Brunner, WIPO Case No. D2021-4089. In view of the above, the Panel finds that Complainant has made out a prima facie case that Respondent has no rights or legitimate interests in the disputed domain name. Respondent has not submitted any argument or evidence to rebut Complainant’s prima facie case. The Panel determines, therefore, that Respondent does not have rights or legitimate interests in the disputed domain name and that Complainant has satisfied the requirements of paragraph 4(a)(ii) of the Policy. C. Registered and Used in Bad Faith Whether a domain name is registered and used in bad faith for purposes of the Policy may be determined by evaluating four (non-exhaustive) factors set forth in the Policy, paragraph 4(b): (i) circumstances indicating that the respondent has registered or the respondent has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registrations to complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or (ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or (iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the disputed domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the respondent’s website or other online location, by creating a likelihood of confusion with complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the respondent’s website or location. The Panel finds that Respondent has registered and used the disputed domain name in bad faith for at least the following reasons. First, Complainant contends and has provided persuasive support that Respondent registered the disputed domain name fully aware of Complainant’s rights, because the submitted record shows the registration date of the disputed domain name is over 124 years subsequent to when Complainant registered the GE Mark and years after Complainant registered the GE AEROSPACE Mark, therefore, Respondent cannot claim to have been using the GE Marks without being aware of Complainant’s rights to them. Complainant’s evidence in support of its allegations is sufficient for the Panel to agree that Respondent could not plausibly argue that it did not have knowledge of Complainant’s world renowned GE Marks, registered in the United States since 1900, when Respondent registered the disputed domain name over a century later in 2025. The Panel finds that given the significant use of Complainant’s GE Marks more than a century prior to Respondent’s registration of the disputed domain name, the worldwide recognition of the GE Marks, and Respondent’s addition of “careers” to the disputed domain name, as well as the nature of Respondent’s copycat website (using the identical characters as Complainant’s official careers website in the disputed domain name) targeting Complainant’s GE Marks, Respondent registered the disputed domain name with actual knowledge of Complainant’s GE Marks in bad faith. See Royds Withy King LLP v. Help Tobuy, WIPO Case No. D2019-0624. See WIPO Overview 3.0, section 3.2.2; see, e.g., eBay Inc. v. Sunho Hong, WIPO Case No. D2000-1633. Moreover, the UDRP panel in Intel Corporation v. The Pentium Group, WIPO Case No. D2009-0273, stated that, “[t]he incorporation of a well-known trademark into a domain name by a registrant having no plausible
page 7 explanation for doing so may be, in and of itself, an indication of bad faith”. See also Veuve Clicquot Ponsardin, Maison Fondée en 1772 v. The Polygenix Group Co., WIPO Case No. D2000-0163; General Electric Company v. CPIC NET and Hussain Syed, WIPO Case No. D2001-0087; Microsoft Corporation v. Montrose Corporation, WIPO Case No. D2000-1568. Respondent has had multiple opportunities to explain and justify how Respondent came to register the disputed domain name but has failed to do so. Indeed, the fact that Respondent has elected not to appear in this proceeding underscores that Respondent likely has no valid explanation for Respondent’s actions, which to this Panel appears on the evidence submitted to have been undertaken in bad faith. See, e.g., Volkswagen Group of America, Inc. v. Super Privacy Service Ltd. c/o Dynadot, WIPO Case No. D2019-2521. Finally, Complainant contends Respondent’s actions constitute use of the disputed domain name in bad faith because Respondent has chosen a trademark, which is world renowned for its electric and aerospace product and services, to attract visitors to a website featuring Complainant’s business for Respondent’s commercial benefit. As mentioned above, the disputed domain name is connected to a website mirroring Complainant’s official website content featuring electric and aerospace products and related services. Previous UDRP panels have consistently held that a respondent’s use of a confusingly similar domain name to direct unsuspecting Internet users to their own business website, as here, is evidence of bad faith registration and use of that domain name. WIPO Overview 3.0, section 3.1.4. This Panel finds the same conclusion should be applied here because Respondent is using the GE Marks within the disputed domain name to attract visitors and then direct them to the website featuring its commercial services before sending them back to Complainant’s website. This use clearly constitutes an intentional attempt by Respondent to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with Complainant’s GE Marks as to the source, affiliation or endorsement of the website to which the disputed domain name resolves in violation of paragraph 4(b)(iv) of the Policy. The Panel finds Complainant’s arguments and evidence persuasive, and Respondent has submitted no arguments or evidence to the contrary. Considering all the circumstances, the Panel concludes that Respondent has registered and used the disputed domain name in bad faith and Complainant has satisfied paragraph 4(a)(iii) 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 be transferred to Complainant. /Scott R. Austin/ Scott R. Austin Sole Panelist Date: July 11, 2025
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