ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Infosys Limited v. Bhairav Singh Case No. D2025-3070 1. The Parties The Complainant is Infosys Limited, India, represented by Remfry & Sagar, India. The Respondent is Bhairav Singh, India. 2. The Domain Name and Registrar The disputed domain name is registered with Cosmotown, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 1, 2025. On August 4, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 7, 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 / Private Whois) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 7, 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 amendment to the Complaint on August 7, 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”). On August 16, 2025, the Registrar sent a communication to the Center confirming that the disputed domain name had expired on July 1, 2025, and was restored and placed under registrar lock for the duration of the proceeding. Further noting that the Complainant shall pay the renewal fees, in the event that the Complainant gets a favorable order.
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 August 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 7, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 8, 2025. The Center appointed Harini Narayanswamy as the sole panelist in this matter on September 11, 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 is an Indian company that was established in the year 1981 and is in the business of information technology consulting services. The Complainant uses the trademark INFOSYS and operates its website from the domain name . The Complainant owns a large portfolio of trademark registrations for the INFOSYS mark across many jurisdictions including India. Some of the Complainant’s Indian trademark registrations include: INFOSYS mark Indian trademark registration number 873673, date August 30, 1999, in class 24. INFOSYS mark Indian trademark registration number 873666, date August 30, 1999, in class 17. INFOSYS mark Indian trademark registration number 873680, date August 30, 1999, in class 31. The Respondent registered the disputed domain name on July 1, 2024. At the time of filing the present Complaint, the disputed domain name was inactive. During the proceedings, the disputed domain name briefly resolved to a page with a heading “Index of /” offering users to download a file named “cgi-bin” before becoming inactive again. The disputed domain name has not been used by the Respondent for any activity. 5. Parties’ Contentions A. Complainant The Complainant contends that INFOSYS is its house mark and “Infosys” is a prominent part of its corporate name. The Complainant states that its mark is extensively promoted through sponsorships and advertisements and is well known in India and internationally. The Complainant alleges that it maintains a comprehensive website which it operates from the domain name since 1992 and states that the website is popular as it receives numerous hits from India and around the world. The Complainant contends that its business is well known for its products and innovative solutions and invests extensively in research and product development. The Complainant further states that its services include technology consulting, custom application development, infrastructure management services, maintenance and production support, packaged enabled consulting, implementation of enterprise solutions, product engineering and lifestyle solutions, systems integration, validation solutions, business process management and Software-as-a-Service solutions. The Complainant states its current market capitalization is USD 93.6 billion and has about 279,000 employees in more than 50 countries. The Complainant has provided figures of its revenue for the period 2010 to 2025 and alleges that its increasing revenue indicates not just its growth but also indicates rise in its goodwill and reputation due to the popularity of its products and services.
page 3 The Complainant contends that it is a reputed international company. In 2008 it was selected as an original component member of the “The Global Dow”, a world-wide stock index consisting of 150 leading blue-chip stocks. The Complainant further states that it is the first Indian company to be listed on stock exchange of the United States of America, and the first Indian company to make a public offering without listing in Japan and also the first Indian company to be added to the NASDAQ-100 index. The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name: (i) the disputed domain name is confusingly similar to its INFOSYS mark, (ii) the Respondent lacks rights or legitimate interest in the disputed domain name and is not connected with the Complainant or authorized to use its mark, and (iii) the disputed domain name was registered and is being used in bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings The three elements that need to be established by the Complainant under paragraph 4(a) of the Policy to obtain transfer of the disputed domain name are: (i) The disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent lacks rights or legitimate interests in the disputed domain name; and (iii) The disputed domain name was registered and is being used in bad faith by the Respondent. 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 provided evidence of its registered trademarks for the INFOSYS mark. The Complainant’s trademark registration satisfies the threshold requirement of having rights in the mark. The Complainant has accordingly 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 INFOSYS mark is reproduced within the disputed domain name along with the additional word “groups”. It is well established that where the mark is recognizable in the disputed domain name, any additional terms or words do not prevent a finding of confusing similarity between the disputed domain name and the mark. Although the addition of the term “groups” may bear on assessment of the second and third elements, the Panel finds the addition of the term “groups” 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 mark is recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Panel finds the first element of the Policy has been established.
page 4 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 3.0, section 2.1. The Panel finds the Respondent is not known by the disputed domain name and has not responded or shown any legitimate reasons for use of the INFOSYS mark in the disputed domain name. The Complainant has submitted that the Respondent has no authorization or license to use its mark and the disputed domain name which contains its mark creates a false and misleading impression of implied affiliation with the Complainant’s business. The disputed domain name has not been used by the Respondent, and the passive holding of the disputed domain name incorporating the INFOSYS mark does not constitute a bona fide use of the domain name under the discussed circumstances. This is consistent with UDRP panels views that when circumstances indicate a disputed domain name is registered to capitalize of the reputation or goodwill of the complainant’s mark, passive holding of such a domain name by the respondent does not constitute bona fide use. Having reviewed the available record, the Panel finds the INFOSYS mark was adopted and used by the Complainant much prior to the registration of the disputed domain name. The Panel agrees with the Complainant’s submission that the use of the INFOSYS mark in the disputed domain name is likely to mislead Internet users. An Internet user looking for the Complainant online is likely to assume that the disputed domain name and is affiliated to the Complainant or is endorsed by the Complainant. The disputed domain name which is likely to mislead Internet users is not bona fide use that is indicative of rights or legitimate interests in the disputed domain name as understood under the Policy. The Respondent’s failure to respond also supports a finding of lack of the Respondent’s rights, under the circumstances. It has consistently been found by previous panels that under appropriate circumstances, if a respondent fails to respond it could indicate lack of rights or legitimate interests in the disputed domain name. See for instance Nordstrom, Inc. and NHIC, Inc. v. Inkyu Kim, WIPO Case No. D2003-0269 and AREVA v. St James Robyn Limoges, WIPO Case No. D2010-1017. In the light of the evidence, 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 relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The Panel finds the second element of the Policy has been established.
page 5 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, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. 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 also 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. (i) Circumstances indicate that the respondent has registered or acquired the domain name primarily for 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 complainant, for valuable consideration in excess of 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 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 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. In the present case, the Panel notes that the Complainant’s trademark is a distinctive and known mark. The Respondent has registered the disputed domain name several years after the Complainant’s mark has become an identifier of source. It has been consistently found by UDRP panels that the registration of a disputed domain name that is identical or confusingly similar to a known trademark by a party who is not affiliated with the complainant can itself be an indication of bad faith. Passive holding of a disputed domain name containing a known trademark is typical of cyber-squatting. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. The relevant factors to consider under the passive holding doctrine are (i) degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to respond or provide any evidence of actual or contemplated good-faith use, (iii) respondent concealing identity or use of false contact details, (iv) implausibility of any good faith use to which the domain name may be put. Having reviewed the available record, the Panel finds that the Complainant has established with supporting evidence the distinctiveness and reputation of its trademark. The Respondent’s failure to respond coupled with use of privacy shield, under the circumstances of this case leads the Panel to finds that the passive holding of the disputed domain name constitutes bad faith registration and use as understood under the Policy. The Panel finds that the Complainant has established the third element of the Policy.
page 6 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. /Harini Narayanswamy/ Harini Narayanswamy Sole Panelist Date: September 25, 2025
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