ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Stripe, Inc. v. Miguel Case No. D2025-2451 1. The Parties The Complainant is Stripe, Inc., United States of America (“Unites States”), represented by Elster & McGrady LLC, United States. The Respondent is Miguel, Spain. 2. The Domain Name and Registrar The disputed domain name is registered with Porkbun LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 20, 2025. On June 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 23, 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 (Whois Privacy / Private by Design, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 24, 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 June 26, 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on July 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 22, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on July 23, 2025. The Center appointed Beatrice Onica Jarka as the sole panelist in this matter on July 28, 2025. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and
page 2 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 technology company that builds economic infrastructure for the Internet. Millions of businesses of every size, from new startups to public companies, use the Complainant’s software to accept payments and manage their businesses online. The Complainant is available for businesses in over 40 countries, including the United States. The Complainant uses its website at “www.stripe.com” to publish its documentation, libraries, and API (“Application Programming Interface”) resources among other things. The Complainant holds trademark registration rights for the STRIPE Mark, as follows: - United States Registration No. 4451679, registered on December 17, 2013, and covering “[f]inancial services, namely online credit card payment and transaction processing and transmission of bills and payments thereof; financial services, namely, electronic funds transfer via electronic communications networks; clearing and reconciling financial transactions via electronic communications networks.” - United States Registration No. 6389493, registered on June 15, 2021, covering “[e]lectronic publishing services, namely, publication of text and graphic works of others online featuring tax accounting and legal information.” - European Union Registration No. 18309744, registered on January 29, 2021, covering “[d]ownloadable computer software for creating, distributing, and managing physical and virtual payment cards and card transactions; [f]inancial services, namely, creating, distributing, and managing physical and virtual payment card programs; [p]roviding temporary use of non-downloadable software for creating, distributing, and managing physical and virtual payment cards and card transactions.” (collectively, the “STRIPE Mark”) The Complainant has been using its STRIPE Mark in connection with financial services and payment processing services throughout the United States and around the world since 2011. The Respondent appears to be Miguel, located in Madrid, Spain. The disputed domain name was registered on May 5, 2025. The disputed domain name has been sent emails impersonating the Complainant’s Chief Legal Officer. 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 is confusingly similar to the STRIPE mark because it consists of the entirety of Complainant’s STRIPE Mark along with the generic Top-Level Domain “.legal”. The Respondent sent an email in an attempt to fraudulently deceive the Complainant’s employees by referencing an account closure and scaring the Complainant’s employees into reinstating the closed account. Specifically, this social engineering attack impersonated the Complainant’s Chief Legal Officer, and the email was sent to one of the Complainant’s employees. Although the MX records have now been removed, the Respondent’s real intention was a fraud attempt. The Respondent’s email to commit fraud
page 3 does not convey any rights or legitimate interests to the Respondent and cannot be considered a bona fide offering of goods or services or legitimate noncommercial use. The Respondent deliberately and fraudulently sent the email impersonating the Complainant’s Chief Legal Officer in an attempt to deceive the Complainant’s employees. Utilising a domain name in this way is representative of clear-cut bad faith registration and use. There is no conceivable reason for the Respondent to have registered the disputed domain other than to trade off the reputation and goodwill of the STRIPE Mark, to attempt to falsely impersonate the Complainant’s employees, and to disrupt the Complainant’s business. The disputed domain was registered and is being used with actual knowledge of the Complainant and the Complainant’s well-known STRIPE Mark. Even if the Respondent were to implausibly argue that it was somehow unaware of the Complainant’s rights in the STRIPE Mark, had the Respondent conducted a preliminary trademark search or even a simple browser search, it would have found the Complainant’s various trademark registrations, the websites associated with the marks, and numerous additional references in commerce, on the Internet, and in publications, evidencing the Complainant’s use of the STRIPE Mark in connection with its goods and services. The Respondent had concealed its identity. Hiding one’s identity while using the STRIPE Mark in the disputed domain name to impersonate the Complainant’s Chief Legal Officer should be considered further evidence of bad faith registration and use. B. Respondent Although, procedurally summoned the Respondent did not reply to the Complainant’s contentions. 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 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 the STRIPE trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the mark is reproduced within the disputed domain name, along with the gTLD “.legal”. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Accordingly, 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 4 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. 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. Despite being procedurally summoned, 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. From the evidence provided by the Complainant, it appears that the Respondent sent an email in an attempt to fraudulently deceive the Complainant’s employees by impersonating the Complainant’s Chief Legal Officer. Such use of the disputed domain name does not convey any rights or legitimate interests to the Respondent and cannot be considered a bona fide offering of goods or services or legitimate noncommercial use. No other bona fide offering of goods or services or legitimate noncommercial use had been identified by the Panel as the Respondent failed to file the Response and rebut the Complainant’s contentions. Panels have held that the use of a domain name for illegitimate activity, here, claimed as applicable to this case: impersonation/passing off, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. Accordingly, 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. In the present case, the Panel notes that the Respondent appears: ⁃ to have registered and used the disputed domain name with actual knowledge of the Complainant and the Complainant’s well-known STRIPE mark. ⁃ to have deliberately and fraudulently sent the email impersonating the Complainant’s Chief Legal Officer in an attempt to deceive the Complainant’s employees. The Panel agrees with the Complainant that the evidence indicates that there could be no conceivable reason for the Respondent to have registered the disputed domain name other than to trade off the reputation and goodwill of the STRIPE Mark, to attempt to falsely impersonate the Complainant’s employees, and to disrupt the Complainant’s business. 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 3.0, section 3.2.1. Panels have held that the use of a domain name for illegitimate activity here, claimed impersonation/passing off, constitutes bad faith. WIPO Overview 3.0, section 3.4.
page 5 Based on such indicative circumstances, the Panel concludes that the Respondent has registered and used the disputed domain name in bad faith targeting the Complainant in order to trade off the reputation and goodwill of the STRIPE Mark, to attempt to falsely impersonate Complainant’s employees, and to disrupt Complainant’s business. Accordingly, 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. /Dr. Beatrice Onica Jarka/ Dr. Beatrice Onica Jarka Sole Panelist Date: August 12, 2025
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