ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Snowflake Inc. v. Roselle Black Case No. D2025-2911 1. The Parties The Complainant is Snowflake Inc., United States of America (“United States” or “US”), represented by Schwegman Lundberg & Woessner, P.A., United States. The Respondent is Roselle Black, 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 July 22, 2025. On July 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 24, 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 (“Unknown Registrant”) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 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 July 29, 2025. The Center verified that the Complaint 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 30, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 19, 2025. The Respondent did not submit any
response. Accordingly, the Center notified the Respondent’s default on August 20, 2025. The Center appointed Andrew J. Park as the sole panelist in this matter on August 25, 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 Complainant, Snowflake Inc., is a leading US corporation headquartered in Bozeman, Montana, engaged globally in the provision of cloud-based computing and data solutions. Snowflake operates a widely recognized data cloud platform relied upon by over 11,000 organizations worldwide, processing billions of queries daily. Through extensive commercial operations and substantial investment in marketing and promotion, the Complainant has achieved significant international recognition and goodwill in its corporate name and marks. In particular, the Complainant owns numerous trademark registrations worldwide for the mark SNOWFLAKE, covering software-as-a-service and platform-as-a-service offerings, including data storage, data management, data processing, data migration, data analytics, and related services. The Complainant has expended considerable resources to promote and protect its SNOWFLAKE marks, which have been used continuously and extensively in commerce. Such longstanding and widespread use has caused the marks to serve as distinctive indicators of source, and the relevant public associates the marks exclusively with the Complainant’s goods and services. The Complainant also maintains a significant presence on the Internet, operating its official website under a domain name registered as early as July 8, 1995, further reinforcing its rights and reputation in the marketplace. The Complainant owns numerous trademark registrations, including the following: Country Trademark Registration Number Registration Date Classes European Union SNOWFLAKE 17736083 May 25, 2018 9 Hong Kong, China SNOWFLAKE 302614798AA January 30, 2014 9 and 42 Japan SNOWFLAKE 5675532 June 6, 2014 9 and 42 Mexico SNOWFLAKE 1398350 September 23, 2013 9 New Zealand SNOWFLAKE 977650 December 3, 2013 9, 38 and 42 Norway SNOWFLAKE 1434694 September 20, 2018 42 Russian Federation SNOWFLAKE 1434694 September 20, 2018 42 Republic of Korea SNOWFLAKE 450050643 August 11, 2014 9 and 42 Switzerland SNOWFLAKE 650153/651996 October 24, 2013/ December 9, 2013 9 and 42 United Kingdom SNOWFLAKE UK00917736083 May 25, 2018 9 United States SNOWFLAKE 5610829 November 20, 2018 42 The disputed domain name was registered on June 17, 2025, by the Respondent. On July 11, 2025, the Complainant submitted a takedown request concerning the disputed domain name to the legal and abuse department of the registrar because the Respondent’s identity was
shielded by privacy protections. The disputed domain name does not resolve to an active website, and its only use has been related to a fraudulent email scheme which will be explored in detail below. 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. (1) The disputed domain name is identical or confusingly similar to the Complainant’s SNOWFLAKE mark in which it has established prior rights. The Complainant states that it has used the SNOWFLAKE mark for more than a decade in connection with computer services, cloud hosting provider services, software as a service, and platform as a service, including data warehousing, data management, data migration, data mining, and database analytics. According to the Complainant, these longstanding and widespread uses resulted in significant goodwill and global recognition, such that the SNOWFLAKE mark serves as a distinctive indicator of source exclusively associated with the Complainant. The Complainant further contends that the disputed domain name incorporates the SNOWFLAKE mark in its entirety, with only a minor transposition of the letters “N” and “O”. The Complainant argues that such a trivial modification does not avoid a finding of confusing similarity, and that this type of alteration constitutes an example of typo squatting, in which a domain name registrant seeks to exploit the likelihood of typographical errors made by Internet users in order to divert traffic from the trademark holder. (2) The Complainant asserts that the Respondent has no rights or legitimate interests in the disputed domain name, . The Complainant has never authorized or licensed the Respondent to use the SNOWFLAKE trademark, and the Respondent is not affiliated with the Complainant in any way. The disputed domain name is not being used for a bona fide offering of goods or services, nor is it being used for legitimate noncommercial or fair purposes. Instead, the Respondent has used the disputed domain name to impersonate the Complainant’s employees in emails requesting payment of fake invoices, as if the Complainant itself were requesting payment for services it had rendered. The Respondent has presented no evidence of being commonly known by the disputed domain name, nor of any legitimate purpose for using it. The Complainant has developed significant rights to the SNOWFLAKE marks over the past ten years. Therefore, there is no apparent reason for the Respondent to have registered the disputed domain name other than to take advantage of the goodwill and reputation associated with the Complainant’s SNOWFLAKE marks. These facts support the conclusion that the Respondent lacks any rights or legitimate interests in the disputed domain name. (3) The Respondent’s registration and use of the disputed domain name constitutes bad faith under the UDRP. The sole purpose of the Respondent’s registration of the disputed domain name appears to be the impersonation of the Complainant, using the disputed domain name to contact the Complainant’s employees and clients under false pretenses, particularly to obtain payments from the Complainant’s clients. This conduct, together with the fact that the disputed domain name was registered on June 17, 2025—almost ten years after the Complainant had established its well-known SNOWFLAKE marks, which have gained substantial international recognition and goodwill—demonstrates a deliberate attempt to mislead and deceive Internet users by creating confusion as to the source and affiliation of communications, constituting clear evidence of bad-faith registration.
The Complainant contends that the Respondent used the disputed domain to send fraudulent emails, including fake invoices, the Complainant’s logo, and the name and contact information of a legitimate Snowflake employee. The emails instructed the customer to transfer payments to a fraudulent bank account, successfully deceiving the customer into making payments. These emails were sent over multiple days following the domain registration, including follow-ups that reinforced the fraudulent scheme. The Complainant asserts that the registration and use of the disputed domain name were carried out solely to mislead the public, exploit the Complainant’s reputation, and divert funds from the customer. Such use constitutes clear evidence of bad faith under paragraph 4(b)(iv) of the Policy, as the disputed domain name facilitated impersonation, phishing, and fraudulent activity targeting the Complainant’s business and customers. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar This element consists of two parts: first, whether the Complainant has rights in a relevant trademark and, second, whether the disputed domain name is identical or confusingly similar to that trademark. The Panel finds that the Complainant has established registered rights in the trademark SNOWFLAKE and that the disputed domain name is confusingly similar to the Complainant’s trademark. The disputed domain name incorporates the SNOWFLAKE mark in its entirety, with only a minor transposition of the letters “N” and “O,” which, in the Panel’s view, is insufficient to avoid a finding of confusing similarity as the Complainant’s trademark remains recognizable within the disputed domain name. The Complainant has used the SNOWFLAKE mark to identify its services, including computer services, cloud hosting, software as a service, and platform as a service, for over a decade prior to the registration of the disputed domain name. In determining whether a domain name is identical or confusingly similar to a trademark, the Top Level Domain is typically disregarded (see Proactiva Medio Ambiente, S.A. v. Proactiva, WIPO Case No. D2012-0182; WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.11.1). For these reasons, pursuant to the Policy, paragraph 4(a)(i), the Panel finds that the disputed domain name is confusingly similar to the Complainant’s trademark and the first element of the Policy has been established. B. Rights or Legitimate Interests Pursuant to paragraph 4(a)(ii) of the Policy, the Complainant is required to make out a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. Once such a prima facie case is made, the Respondent carries the burden of demonstrating its rights or legitimate interests in the disputed domain name. If the Respondent fails to do so, the Complainant is deemed to have satisfied paragraph 4(a)(ii) of the Policy. WIPO Overview 3.0, section 2.1. Pursuant to paragraph 4(c) of the Policy, the Respondent may establish its rights or legitimate interests in the disputed domain name, among other circumstances, by showing any of the following elements:
(i) before any notice to the Respondent of the dispute, the Respondent’s use of, or demonstrable preparations to use, the disputed domain name or a name corresponding to the disputed domain name in connection with a bona fide offering of goods or services; or (ii) the Respondent (as an individual, business, or other organization) has been commonly known by the disputed domain name, even if it has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue. Here, having reviewed the available records, 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 evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name within the meaning of Paragraph 4(a)(ii) of the Policy. The Complainant has not authorized, licensed, or otherwise permitted the Respondent to use its SNOWFLAKE trademark, and there is no evidence of any relationship between the Parties that would give rise to such rights. The Respondent has not been commonly known by the disputed domain name, nor has it made a bona fide offering of goods or services, or legitimate noncommercial or fair use of the disputed domain name. The disputed domain name is confusingly similar to the Complainant’s SNOWFLAKE mark, differing only by the transposition of two letters. This minor alteration is characteristic of typosquatting and demonstrates the Respondent’s intent to exploit the reputation and goodwill associated with the Complainant’s marks, rather than to assert any right or legitimate interest. Moreover, the Respondent’s use of the disputed domain name to impersonate a Complainant employee and conduct a phishing scheme constitutes compelling evidence that the Respondent lacks any legitimate interest. The emails sent from the disputed domain name solicited payments from a Complainant customer using fraudulent invoices and misrepresented the Respondent as the Complainant. Such fraudulent conduct is incompatible with any claim of rights or legitimate interests in the disputed domain name. In the absence of any credible evidence to the contrary, the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain name and these facts may be taken as true in the circumstances of this case in view of the use of the disputed domain name. Accordingly, the Panel holds that the Respondent has no rights or legitimate interests in the disputed domain name pursuant to paragraph 4(a)(ii) of the Policy and the second element of the Policy has been established. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy provides a non-exclusive list of circumstances that evidence registration and use of a domain name in bad faith. Any one of the following is sufficient to support a finding of bad faith: (i) circumstances indicating that the respondent has registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark, or to a competitor of that the 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 a 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 domain name, the respondent 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 of the respondent’s website or location or of a product or service on the respondent’s website or location. The Complainant claims that the Respondent registered and is using the disputed domain name in bad faith satisfying the requirement of paragraph 4(a)(iii) of the Policy. In particular, the Complainant contends that the Respondent’s conduct falls squarely within the scope of paragraph 4(b)(iv) of the Policy, as the Respondent registered the disputed domain name in an attempt to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s trademark. As stated previously, the Respondent did not file any response to the Complaint, failing thereby to rebut the Complainant’s allegations of the Respondent’s bad faith registration and use of the disputed domain name. Nevertheless, the Panel still has the responsibility of determining which of the Complainant’s assertions are established as facts, and whether the conclusions asserted by the Complainant can be drawn from the established facts. The Panel finds that the Complainant has established that the Respondent registered and is using the disputed domain name in bad faith. The disputed domain name incorporates a misspelled version of the Complainant’s well-known SNOWFLAKE mark and was registered in 2025—over ten years after the Complainant first adopted and used its SNOWFLAKE mark in commerce and long after the Complainant had secured extensive trademark registrations worldwide. The SNOWFLAKE mark is distinctive, widely recognized, and strongly associated with the Complainant’s services. It is therefore inconceivable that the Respondent registered the disputed domain name without knowledge of the Complainant’s rights. The fact that the Respondent registered a domain name that is a clear typographical variation (“sonwflake” instead of “snowflake”) strongly indicates that the Respondent intentionally sought to take advantage of typographical errors and trade on the goodwill of the Complainant’s brand, which constitutes bad faith registration of the disputed domain name. In addition, the Complainant has presented compelling evidence that the Respondent has used the disputed domain name in a fraudulent phishing scheme. Specifically, emails were sent from the disputed domain name on June 17, 2025, impersonating an employee of the Complainant and requesting payment of fraudulent invoices. The emails included the Complainant’s logo, the name and legitimate contact details of a Complainant employee, and misleadingly presented themselves as originating from the Complainant’s collections department. Further emails on June 18, 19, and 23, 2025 followed up with fraudulent bank account details and revised invoices, ultimately deceiving the Complainant’s customer into making payments to the Respondent’s fraudulent account. The disputed domain name itself does not resolve to an active website, but it has been used exclusively to perpetrate this fraudulent scheme. The Respondent has not provided any evidence of legitimate interest or use and has remained silent in response to the Complaint. Taken together, these facts support a finding that the Respondent registered and is using the disputed domain name not merely in bad faith, but as part of a deliberate and fraudulent effort to misappropriate funds by creating a false impression of affiliation with the Complainant.
Accordingly, as the conduct described above falls squarely within paragraph 4(b)(iv) of the Policy, the Panel concludes that the third element of the Policy has been satisfied and the Respondent registered and is using the disputed domain name in bad faith pursuant to the Policy, paragraph 4(a)(iii). 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. /Andrew J. Park/ Andrew J. Park Sole Panelist Date: September 8, 2025
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