ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Microsoft Corporation v. Raj Uni, International Institute of e learning and William Seguine Case No. D2025-1914 1. The Parties The Complainant is Microsoft Corporation, United States of America, represented by D.M. Kisch Inc., South Africa. The Respondents are Raj Uni, International Institute of e learning, India and William Seguine. 1 For the reasons given below, the Respondents are hereinafter referred to as “the Respondent”. 2. The Domain Name and Registrar The disputed domain name is registered with GoDaddy.com, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 13, 2025. On May 14, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On May 15, 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 (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 20, 2025, 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 May 27, 2025. 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”). 1Based on the available case record, it is not clear where the Respondent William Seguine is located.
page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on June 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 22, 2025. The Respondent sent email communications to the Center between May 21, 2025 and September 24, 2025. On June 25, 2025, the Center informed the Parties that it would proceed with panel appointment. On July 2, 2025, the Complainant requested a suspension of the proceedings to allow the Parties sufficient time to explore a settlement. On July 3, 2025, the Center issued a notification of suspension until August 4, 2025, for the purpose of settlement discussions concerning the disputed domain name. On August 14, 2025, the Complainant requested a further suspension of the proceedings for an additional 30 days. On August 19, 2025, the Center confirmed that the proceedings were further suspended until September 4, 2025. On August 27, 2025, the Complainant requested a further suspension for an additional 30 days. On September 2, 2025, the Center confirmed that the administrative proceedings were further suspended until October 4, 2025. On September 19, 2025, the Complainant advised the Center that the Parties had been unable to reach a settlement and requested that the proceedings be reinstituted. On September 24, 2025, the Center confirmed that the proceedings were reinstituted as of that date and that it would proceed to the appointment of a panel. The Center appointed Alissia Shchichka as the sole panelist in this matter on September 26, 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. On September 30, 2025, the Complainant sent an email communication to the Center stating that the certificate provided by the Respondent appears to be a completion certificate for the “Direct Partner Onboarding” course dated April 14, 2022, not a professional license or regulatory certification. 4. Factual Background The Complainant, Microsoft Corporation, is an American multinational technology company, recognized as a leading developer of personal-computer software systems, applications, cloud services, video games, and other online services, operating globally through subsidiaries, affiliates, and licensees. Since its founding in 1975, the Complainant has adapted to technological shifts to enable digital transformation worldwide, offering AI-powered platforms and tools to support business competitiveness, education, healthcare, public-sector efficiency, and human creativity. As part of its AI vision, the Complainant acquired Nuance Communications, Inc. (“Nuance”), a leader in conversational AI and ambient intelligence solutions, particularly in healthcare, financial services, retail, and telecommunications. The Complainant’s portfolio includes AI-driven productivity and dictation solutions, such as Dragon Professional, Dragon Legal, Dragon Law, and Dragon Anywhere, distributed through official stores, websites, and authorized distributors. As of 2024, these offerings are used by approximately 1.4 billion consumers in around 190 countries. The Complainant has evidenced to be the registered owner of numerous trademark registrations for NUANCE and DRAGON, including, but not limited to: - International Trademark Registration No. 906390, registered on February 7, 2006, for the word mark NUANCE in classes 9, 41, and 42;
page 3 - United Kingdom Trademark Registration No. UK00900254615, registered on February 24, 1999 for the word mark NUANCE in classes 9, 16, and 42; and - European Union Trademark Registration No. 000524538, registered on March 9, 1999, for the word mark DRAGON in classes 9 and 16. The Complainant also operates the official domain name . The aforementioned trademarks and domain name were registered prior to the disputed domain name, which was registered on June 17, 2019. At the time of the issuance of the decision, the disputed domain name resolves to the Registrar’s parking page indicating that it “is parked free, courtesy of GoDaddy.com,” with an option to click “to get it.” Clicking this button redirects Internet users to the Registrar’s Domain Brokerage Service, which informs that the disputed domain name is already registered but may still be acquired for a third party through the Registrar’s brokerage service for a fee. At the time of filing of the Complaint, the disputed domain name was also parked at the Registrar’s website with a message “This domain is registered, but may still be available. If you’re interested, try our Domain Broker service.” 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. According to the Complainant, the disputed domain name is confusingly similar to the Complainant’s NUANCE and DRAGON trademarks, as it reproduces both trademarks in their entirety. The addition of the term “support” does not prevent a finding of confusing similarity. The generic Top-Level Domain (“.com”) should also be disregarded under the first element as it is a standard registration requirement. The Complainant further asserts that the Respondent has no rights or legitimate interests in the disputed domain name, as (i) the Complainant is not affiliated with the Respondent, and has never licensed or otherwise authorized the Respondent to register the disputed domain name; (ii) the Respondent registered the disputed domain name to exploit the reputation of the Complainant’s NUANCE and DRAGON trademarks for commercial gain, as the disputed domain name resolves to the Registrar’s parking page offering the disputed domain name for sale via the Registrar’s Domain Brokerage Service. The Respondent therefore fails to satisfy the criteria of fair use as established by “Oki Data test”; and (iii) the disputed domain name is not used in connection with a bona fide offering of goods or services. Instead, the actual use of the disputed domain name does not in itself represent a use of the disputed domain name that legitimizes registration by establishing a legitimate noncommercial or fair use nor does it establish preparations for a bona fide offering of goods or services. Moreover, on January 22, 2024, an email communication was sent from an email address using the disputed domain name to a consumer of the Complainant’s products offering to create a “new acc” for a one-time cost. This email was signed off by William S. Finally, the Complainant argues that the Respondent registered and is using the disputed domain name in bad faith. In particular: (i) Taking into account the Respondent’s use of the disputed domain name, it is clear that the Respondent knew of the Complainant’s business and trademarks; (ii) the Respondent uses the disputed domain name for the parking page which explicitly offers the disputed domain name for sale while prominently displaying the Complainant’s trademarks, thereby attempting to attract Internet users for commercial gain by creating a likelihood of confusion as to source, affiliation, or endorsement with the Complainant.
page 4 In addition, the Complainant in its email of September 30, 2025 pointed out that the certificate provided by the Respondent is a training or onboarding course completion certificate – and not a professional license or regulatory certification nor does it contain permission from the Complainant authorizing the Respondent to use the NUANCE and DRAGON trademarks in the disputed domain name. The Complainant requests that the disputed domain name be transferred to the Complainant. B. Respondent The record shows that the Respondent submitted several communications during the course of the proceeding. On May 21, 2025, the Respondent, Raj Uni, International Institute of e learning, sent several emails asserting that the disputed domain name “belongs to us,” that it had been purchased “a long time ago,” and that it was their “legal property.” A submission received on the same date reiterated that the Respondent was the legal owner of the disputed domain name. On June 2, 2025, the Center received two emails from a Mr. William Seguine, identifying himself as a “certified reseller.” Mr. Seguine stated that the disputed domain name had previously been approved by Nuance for the sale of Dragon software, and that he held a reseller certification with eDist for Dragon Medical One products. He offered to provide supporting documents, including his reseller certificate and eDist’s approval. Following a request for clarification from the Center, Mr. Seguine replied on June 5, 2025, explaining that Raj Uni, International Institute of e learning had acted as his “web developers” and had initially purchased and built the website several years earlier for affiliate marketing purposes. He further claimed that this activity had been approved by Nuance, and reiterated his status as a certified reseller of Dragon products. He also indicated that he “currently collaborate directly with other major Dragon partners”, therefore, he does “not have an immediate need for the nuancedragonsupport.com domain at this time”. Upon receipt of the Center’s Notification of Suspension email dated July 3, 2025, Mr. Seguine asked for elaboration on the offer and indicated that he was reviewing the details of the suspended proceeding and were keen to understand the proposed terms for settlement. On August 12, 2025, an email signed by Raj Uni stated that he had originally acquired the disputed domain name but had subsequently sold it to Mr. Seguine, described as an “authorized reseller for Dragon products.” He further indicated that Mr. Seguine should now be the primary point of contact for the matter. Finally, on September 24, 2025, the Center received an email from Mr. Seguine attaching a reseller certificate, which shows “This certification is awarded to [XXX Gatlin] for successfully completing the course Direct Partner Onboarding” issued by eDist on April 14, 2022 – notably with no expiration date. 6. Discussion and Findings 6.1. Procedural issue: Identity of the Respondent The Registrar confirmed that the registrant of the disputed domain names is Raj Uni, International Institute of e-Learning. The Complaint was filed against the Respondent, Raj Uni, International Institute of e-Learning. Paragraph 1 of the Rules provides that “Respondent means the holder of a domain-name registration against which a complaint is initiated”. Therefore, Raj Uni, International Institute of e-Learning is the Respondent in this proceeding. However, during the proceedings, the Center received several communications from both Raj Uni, International Institute of e-Learning and William Seguine, for which Raj Uni, International Institute of
page 5 e-Learning claimed to have initially registered the disputed domain name and had then sold to William Seguine and William Seguine claimed Raj Uni, International Institute of e-Learning was his “web developer” and that he is a certified reseller of Dragon products. Considering the circumstances of the case, the Panel finds that William Seguine has demonstrated a sufficient interest in the disputed domain name and in these proceedings to justify his participation. In particular, Raj Uni, International Institute of e-Learning stated that the disputed domain name was initially “acquired and maintained” by him and subsequently transferred to William Seguine, who would therefore appear to be the current holder of the disputed domain name. Accordingly, the Panel finds that both Raj Uni, International Institute of e-Learning and William Seguine should be considered as the Respondent in these proceedings, and will take into account all submissions made by them in rendering its decision. 6.2. Substantive Issues Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving: (i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) that the disputed domain name has been registered and is being used in bad faith. Paragraph 15(a) of the Rules directs the Panel to decide the complaint on the basis of the statements and documents submitted and in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. 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 Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the NUANCE and DRAGON marks is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the marks for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms here, “support”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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
page 6 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, section 2.1. The Complainant argues that the Respondent holds no trademark registrations for NUANCE or DRAGON, and has not been authorized or licensed to use those marks. The Panel finds in the circumstances of this case that this suffices to establish a prima facie case. The burden of production on this element therefore shifts to the Respondent to come forward with relevant evidence demonstrating its rights or legitimate interests in the disputed domain name. The Panel notes that at the time of filing of the Complaint, the disputed domain name was parked at the Registrar’s website and therefore, there is no evidence on record showing that the Respondent is using or has demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services nor is the Respondent making a legitimate noncommercial or fair use of the disputed domain name. There is also no evidence on record showing that the Respondent has been commonly known by the disputed domain name. The Panel further notes inconsistencies regarding the identity of the Respondent. The disputed domain name was registered in the name of “Raj Uni, International Institute of eLearning.” However, multiple communications in these proceedings have been submitted by “William Seguine,” who claims to have acquired the disputed domain name from Raj Uni, International Institute of eLearning and to be its current holder. In an email dated August 12, 2025, Raj Uni confirmed that he had initially registered the disputed domain name but subsequently transferred it to Mr. Seguine. The precise timing of this alleged transfer remains unclear. William Seguine identifies himself as a certified reseller through eDist. He contends that the disputed domain name had been previously approved by Nuance for the purpose of selling Dragon software. Mr. Seguine further asserts that he holds valid reseller certification from eDist for Dragon products. A presumed copy of Mr. Seguine’s reseller certification has been submitted into the record. The Panel also observes that the name “William Seguine” corresponds to the sender of an email dated January 22, 2024, submitted by the Complainant. That email, signed “William S, Dragon Support Team,” offered the creation of a new account for Dragon Medical software at a one-time cost of USD 2,650 for five years. The Panel has considered whether the Respondent could be regarded as a reseller or service provider that may have legitimate interests in a disputed domain name e.g., under the criteria set out in Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. At present, the disputed domain name resolves to a registrar parking page indicating it is “parked free, courtesy of GoDaddy.com” with an option to “get it” through the registrar’s brokerage service. The page with this placeholder content plainly does not support any claimed fair use. As to the history of the disputed domain name, the record shows that it was registered in 2019, i.e., before Microsoft’s acquisition of Nuance in 2022. This is largely beside the point (i.e., it seems to imply that prior to such acquisition, the Respondent’s conduct vis a vis the predecessor company would somehow be different from the same calculus applied here towards the present Complainant), and the Complainant contends that the Respondent has no rights or legitimate interests in the disputed domain name. In response, the Respondent asserts that the disputed domain name was previously approved by Nuance for the purpose of selling Dragon software and it has been authorized as a reseller of Dragon products. In this regard, the Respondent provides a certification, which shows “This certification is awarded to [XXX Gatlin] for
page 7 successfully completing the course Direct Partner Onboarding” issued by eDist on April 14, 2022 – notably with no expiration date. The Panel notes that the certification was awarded to a Mr. Gatlin whose name does not match either of the Respondent names. Further, the certification simply shows that Mr. Gatlin completed a course for “Direct Partner Onboarding” presumably offered by eDist. There is no sign of Nuance appearing on the certification. The Complainant above all emphasized that this document does not constitute a professional license or regulatory certification, let alone any authorization or partnership. The Panel’s own research reveals a LinkedIn profile for “William Seguine, BDM at Nuance Dragon Support Team” created before 2022. Putting aside that this name does not match that on the certificate provided by the Respondent, screenshots from the Wayback Machine show that the disputed domain name was used in connection with the Complainant’s software. And while that site did state that “any purchase you initiate through Nuance Dragon Support will be made directly from the official Nuance online store and not through Nuance Dragon Support”. It went on to say that it was “an authorized Nuance partner website created to introduce you to Nuance’s award-winning software products”. While the site also said that it was an independent technical support provider, this does not dispel the fact that it indicated itself to be an authorized partner. Looking at this evidence in the most favorable light to the Respondent (bearing in mind the Complainant’s burden), it is a close call whether a claim could have been made that the Respondent would have been able to show a fair use at the time. However that may be, according to the Panel’s own research, beginning in late 2024, the disputed domain name resolved to a website for “Études Architectural Solutions”, presented as an architectural firm emphasizing innovation and sustainability. The site content was generic, repetitive, and included placeholders such as “Hello world!” and “Just another WordPress site”, with no evidence of actual projects or clients. It now resolves to a Registrar page. Neither use gives any indication whatsoever of a possible fair use defense – even putting aside for a moment the material fact that the Complainant asserts that the certification provided by the Respondent does not stand for what the Respondent claims it does. The Panel also observes that a consumer of the Complainant’s products forwarded an email to the Complainant in which the Respondent offered to create a “new acc” for a one-time cost. Accordingly, the Panel concludes that the Complainant has met its burden under paragraph 4(a)(ii) of the Policy. 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. The NUANCE and DRAGON trademarks were used and registered years before the Respondent’s registration of the disputed domain name in 2019. There is no evidence on record showing that the Respondent was authorized to register any domain name incorporating the NUANCE and DRAGON trademarks. The Respondent claims that it has been authorized as a reseller of Dragon products and that the disputed domain name was approved by Nuance. The only evidence provided by the Respondent is a certification issued by eDist on April 14, 2022 showing someone with a name different from either of the Respondent names completed a course of Direct Partner Onboarding. The Complainant notably rejects the contention that this stands for anything even approaching an authorized relationship. Noting these circumstances and noting the discussion above on the second element, the Panel finds that the Respondent registered the disputed domain name with the NUANCE and DRAGON trademarks in mind.
page 8 The Complainant’s evidence shows that the Respondent is using the disputed domain name for the Registrar’s parking page which indicates the disputed domain name may be available for sale. The disputed domain name at one time resolved to a so-called “Études Architectural Solutions” website, the Panel finds that at least in this instance, such use does not assist the Respondent. The website in question contained largely generic and repetitive content, apparently AI-generated or copied from shared templates, and replicated across multiple other websites with only minimal variations. Such content appears designed to potentially generate traffic for commercial gain, rather than reflect a genuine business. Policy paragraph 4(b)(iv). By using the disputed domain name in this manner followed by the current Registrar page, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website or other on-line location, by creating a likelihood of confusion with the 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. WIPO Overview 3.0. Section 3.1. Therefore, the Panel finds that although the disputed domain name has not been substantively used currently, it does not prevent a finding of bad faith. 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 be transferred to the Complainant. /Alissia Shchichka/ Alissia Shchichka Sole Panelist Date: October 10, 2025
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