ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Reliance Industries Limited v. 吴彬兴 (Wu Bin Xing) Case No. D2025-3134 1. The Parties The Complainant is Reliance Industries Limited, India, represented by Ajay Sahni & Associates, India. The Respondent is 吴彬兴 (Wu Bin Xing), China, self-represented. 2. The Domain Name and Registrar The disputed domain name is registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on August 6, 2025. On the same day, 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 (John Doe) and contact information in the Complaint. The Center sent an email communication to the Complainant on August 13, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Center sent another email communication to the Complainant on the same day advising that the total size of the Complaint exceeded the maximum permitted by Annex E to the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). The Complainant filed an amended Complaint in English on August 14, 2025. On August 13, 2025, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On August 14, 2025, the Complainant confirmed its request that English be the language of the proceeding. On August 15 and August 27, 2025, the Respondent objected to the Complainant’s request and requested a copy of the Complaint in Chinese. 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 Supplemental Rules.
page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in Chinese and English of the Complaint, and the proceedings commenced on August 15, 2025. In accordance with the Rules, paragraph 5, the original due date for Response was September 4, 2025. However, on August 27, 2025, the Respondent requested an extension of the due date for Response. On August 29, 2025, the Respondent was granted the automatic four calendar day extension for Response under paragraph 5(b) of the Rules. The due date for Response was then September 8, 2025. The Response was filed in Chinese with the Center on September 8, 2025. The Center appointed Matthew Kennedy as the sole panelist in this matter on September 9, 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 16, 2025, pursuant to paragraphs 10 and 12 of the Rules, the Panel issued Administrative Panel Procedural Order No. 1 (“Panel Order No. 1”) inviting (i) the Complainant to provide evidence to substantiate its assertion regarding the launch of flagship telecom services under the JIO brand on September 5, 2016, on or before September 21, 2025; and (ii) the Respondent to provide comments on the Complainant’s submissions, if any, on or before September 26, 2025. The Decision due date was extended to October 6, 2025. The Complainant and the Respondent submitted their responses to Panel Order No. 1 on September 21, 2025, and September 25, 2025, respectively. 4. Factual Background The Complainant is part of Reliance Industries Limited Group, one of India’s largest private sector conglomerates, which operates a wide range of businesses ranging from energy, petrochemicals, textiles, and retail to telecommunications. The group’s JIO brand 4G telecom network was launched across India on September 5, 2016 and now carries 55 per cent of data traffic in that country. The Complainant holds multiple registrations for trademarks consisting of, or commencing with, JIO, including the following: − Indian trademark registration number 2247460 for JIO, entered on the register on February 25, 2013 (applied for December 9, 2011), specifying goods in class 9; and − Indian trademark registrations numbers 2702350 and 2702351 for JIO WE COIN and JIOWE COIN, respectively, both entered on the register on April 30, 2018 (applied for March 20, 2014) and specifying services in class 36. The above trademark registrations are current. An Indian court recognized that JIO is a well-known mark in 2021. 1 The Complainant uses the domain names and in connection with websites where it provides information about itself and its services. In March 2023, JIO crossed the mark of 439 million customers. In January 2025, the Complainant publicly activated “JioCoin”, a blockchain-based reward token for users of the Complainant’s JioSphere Internet-browsing platform at “www.jiosphere.com”. The Respondent is an individual based in China. The disputed domain name was registered on October 15, 2016. At the time when the Complaint was filed, the disputed domain name resolved to a webpage where it was offered for sale with a button to “去购买” (meaning “go buy”). No asking price was displayed. At the time of this Decision, the disputed domain name no longer resolves to an active webpage; rather, it is passively held. 1See Bombay High Court, Reliance Industries Limited & Anr. vs Ashok Kumar, Commercial IP Suit (L) NO. 14473 of 2021 (August 23, 2021).
page 3 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 Complainant’s JIO mark. The Respondent has no rights or legitimate interests in respect of the disputed domain name. The disputed domain name is offered for sale on the associated website. It is not being used for any bona fide purpose. The Respondent is not affiliated or connected in any manner whatsoever with the Complainant or its group entities. The disputed domain name has been registered and is being used in bad faith. The Respondent has acquired and registered the disputed domain name primarily for the unlawful purpose of diluting the reputation and goodwill of the Complainant’s JIO mark. The Respondent might try to sell, rent, or otherwise transfer the disputed domain name registration to the Complainant which is the owner of the JIO trademark along with several jio-based domain names, or to a competitor of the Complainant, for valuable consideration in excess of the documented out-of-pocket costs incurred by the Respondent in relation to the disputed domain name. The disputed domain name has been acquired by the Respondent with the sole objective of misappropriating and capitalizing on the vast goodwill and reputation subsisting in favor of the Complainant, and to prevent the Complainant as the owner of the JIO trademarks from exercising its legal rights and conducting business using a corresponding domain name that reflects its trademark. The bad faith conduct of the Respondent is evident from the fact that the Respondent deliberately chose to acquire the disputed domain name whilst having no association with either the Complainant or any of its group companies, or with the word “jio”. The Respondent, by intentionally creating a likelihood of confusion and deception as to the source, affiliation, patronage, and/or endorsement of its website, has attempted to attract unsuspecting visitors to its website accessible through the disputed domain name resulting in unjust enrichment of the Respondent on the back of the Complainant’s hard-earned goodwill and reputation. B. Respondent The Respondent contends that the Complainant has not satisfied any of the three elements required under the Policy for a transfer of the disputed domain name. The disputed domain name is not identical or confusingly similar to a trademark in which the Complainant has rights. First, “jio” is the common south-western Chinese dialectal pronunciation of “脚” (standard pronunciation “jiǎo”, meaning “foot”). The disputed domain name is based on this dialect, with “jiocoin” (脚币) registered as a blockchain token project. A search on any Chinese Internet search engine shows that “jio” refers to “脚”. It is a freely available generic word. Second, the Complainant holds no valid registered trademark rights - especially in areas directly relevant to the disputed domain name’s use, such as cryptocurrency and blockchain technology. The Complainant’s Chinese trademark applications for JIO and JIO and device in classes 9, 38, and 42 are still pending. Third, the disputed domain name is composed of the dialectal pronunciation “jio” and the generic word “coin” (commonly used in the cryptocurrency field), which has no connection to the Complainant’s telecommunications services and causes no confusion. The Complainant provides no evidence of the fame or reputation of its JIO brand in China in 2016. The Complainant has obtained no recognition as a well-known trademark in China and has no business operations in the Chinese market. Therefore, there is no basis for confusion. In the Chinese context, “jio” lacks distinctiveness as a trademark as the public overwhelmingly understands it to refer to foot. The Respondent has rights and legitimate interests in respect of the disputed domain name. The disputed domain name was initially registered in October 2016 with another registrar and transferred to the current Registrar in 2022 for use in a blockchain-related blog project. In contrast, the Complainant's “JioCoin”
page 4 project was not publicly announced until January 2025, over nine years later. There is no possibility of bad faith registration targeting a project that did not exist at the time. The Respondent has continuously held the disputed domain name since its initial registration. As business activities related to cryptocurrencies were expressly banned in 2017, the Respondent temporarily suspended active use of the disputed domain name. This decision was made in good faith. Passive holding of a domain name, especially with a plausible plan for future use and no evidence of bad faith, does not disqualify the registrant from having legitimate rights or interests. The disputed domain name has not been registered, and is not being used, in bad faith. The use of “jio” in everyday speech follows a long-standing convention. In 2016, the Complainant had not entered the Chinese market; no branch or entity was listed in China’s National Enterprise Credit Information Publicity System. The Complainant had no products in China, nor trademarks, nor brand information in the marketplace, in daily life, or online. The Respondent did not actively offer the disputed domain name for sale. Most English-language purchase inquiries were left unanswered. On a few occasions, third parties contacted the Respondent in Chinese to inquire about the disputed domain name but he consistently replied that it was “reserved for personal use.” The Respondent has never set a high price for the disputed domain name. Among the enquiries that he declined, the highest offer was only CNY 5,000, far below any threshold that could reasonably indicate bad faith profit-seeking. All inquiries were passive and unsolicited, and the Respondent explicitly refused to sell. The Complainant asserts prior rights in Indian trademarks such as JIO WE COIN. However, the text of the disputed domain name differs significantly from those marks. While JIO WE COIN was registered in respect of financial and other services in class 36, the Complainant did not launch its digital asset project until 2025. The Respondent is not infringing any trademark; he is displaying the disputed domain name but not using it as a trademark. There is no possibility of confusion. The Respondent questions whether the Complainant has engaged in Reverse Domain Name Hijacking. The Complainant never contacted the registrant. The associated webpage does not display a price and sells nothing. The Complainant provided no evidence of infringement of its rights or interests. The Complainant admits that it did not launch its “JioCoin” project until nine years after the registration of the disputed domain name. The Complainant had no legitimate grounds to file the Complaint. The Respondent submits that the evidence submitted by the Complainant in response to Panel Order No. 1 fails to address the core rights underlying this case as it fails to mention any business operations, brand promotion, or public awareness of the company’s brand in China, which is the market associated with the disputed domain name. The Respondent’s registration of the disputed domain name in October 2016 was legal and without bad faith, as demonstrated by clear factual evidence. 6. Discussion and Findings 6.1 Language of the Proceeding The language of the Registration Agreement for the disputed domain name is Chinese. Pursuant to the Rules, paragraph 11(a), in the absence of an agreement between the parties, or unless specified otherwise in the registration agreement, the language of the administrative proceeding shall be the language of the registration agreement. The Complaint and amended Complaint were filed in English. The Complainant requested that the language of the proceeding be English, noting that the Respondent registered the disputed domain name using letters and an English word, and arguing that this implies that he understands English. The Response was submitted in Chinese. The Respondent objected to the Complainant’s language request, submitting that he does not understand English, and that Chinese is a globally respected language. He requests a Chinese version of the Complaint.
page 5 The Panel notes that both Parties have taken the opportunity to present their respective cases in this proceeding. The Response replies in detail to statements in the Complaint showing that the Respondent has in fact understood the Complaint. In exercising its discretion to use a language other than that of the registration agreement, the Panel has to exercise such discretion judicially in the spirit of fairness and justice to both parties, taking into account all relevant circumstances of the case, including matters such as the parties’ ability to understand and use the proposed language, time, and costs. See WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.5.1. Having considered all the matters above, the Panel determines under paragraph 11(a) of the Rules that the language of the proceeding shall be English but that the Panel will accept all submissions as filed in their original language, without translation. 6.2 Substantive Issues Paragraph 4(a) of the Policy provides that a complainant must prove each of the following elements: (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 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. 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. See WIPO Overview 3.0, section 1.7. The Complainant has shown rights in respect of the JIO trademark for the purposes of the Policy. Given the global nature of the Internet and the Domain Name System, the jurisdiction in which that trademark is valid is not considered relevant to the first element of the Policy. The goods and services for which the mark is registered are not considered relevant to the first element test either. See WIPO Overview 3.0, sections 1.1.2 and 1.2.1. The entirety of the JIO mark is reproduced within the disputed domain name as its initial element. Despite the addition of the word “coin”, the mark is clearly recognizable within the disputed domain name. The only additional element in the disputed domain name is a generic Top-Level Domain (“gTLD”) extension (“.com”) which, as a standard requirement of domain name registration, may be disregarded in the assessment of confusing similarity for the purposes of the Policy. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. See WIPO Overview 3.0, sections 1.7, 1.8, and 1.11.1. Therefore, 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 of “proving a negative”, requiring information that is often primarily within the knowledge or control of the
page 6 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. See WIPO Overview 3.0, section 2.1. In the present case, the disputed domain name formerly resolved to a webpage where it was offered for sale. This circumstance does not indicate that the Respondent has been using the disputed domain name in connection with a bona fide offering of goods or services. Nor is this a legitimate noncommercial or fair use of the disputed domain name. At the time of this Decision, the disputed domain name no longer resolves to an active webpage. Further, the Respondent’s name is “吴彬兴 (Wu Bin Xing)”, which does not resemble the disputed domain name. Nothing on the record indicates that the Respondent has been commonly known by the disputed domain name. The Complainant submits that the Respondent is not affiliated or connected in any manner whatsoever with itself or its group entities. 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. Turning to the Respondent, he provides proof of his registration and renewal of the disputed domain name. However, merely holding a domain name cannot confer rights or legitimate interests for the purposes of the Policy, otherwise no complaint could ever succeed, which would be an illogical result. The Respondent alleges that he holds the disputed domain name for use in connection with a blockchain-related project. While there is no requirement in the Policy to make active use of a domain name, the Respondent does not demonstrate any preparations to use the disputed domain name in connection with a bona fide offering of goods or services. He does not substantiate his assertion that it is a registered project. He submits what he describes as preliminary sketches of a blockchain token concept but they are simply two logos showing footprints in circles, with no text and no apparent connection to blockchain. The nature of the project is unclear. In any case, the Respondent does not explain why he was offering the disputed domain name for sale if he intended to use it for a project. The Respondent emphasizes that “jio” is a transliteration of a dialectal pronunciation of the Chinese character “脚” (meaning “foot”). While the Panel does not doubt that “jio” has that meaning, it suffices to note that the Respondent is not using, nor made demonstrable preparations to use, the disputed domain name in connection with any meaning, notwithstanding that the two logos he submitted showed footprints. In sum, the Respondent has not rebutted the Complainant’s prima facie showing. Based on the record, the Panel finds the second element of the Policy has been established. C. Registered and Used 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 be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. See WIPO Overview 3.0, section 3.2.1. In the present case, the disputed domain name was registered in 2016, which was after the registration of the Complainant’s JIO mark in 2013. The disputed domain name incorporates the JIO mark as its initial element. The Complainant alleges that “jio” is an “arbitrary word” and inherently distinctive. The Panel understands that “Jio” is derived from a Hindi word meaning “live life” but there is no suggestion that the Respondent chose it for that reason. The Complainant submits that it chose and used its JIO mark prior to the registration of the disputed domain name. The Complainant submits that it decided to use the JIO brand in 2011 and obtained registration of the JIO mark in India in 2013, but there is no reason to deem the Respondent to have known or should have known of the contents of the Indian trademark register. The Complainant submits that its JIO brand was
page 7 announced to the public in 2013 but it is not clear what that involved beyond inserting “Jio” in the company name of its group telecom services provider, Reliance Jio Infocomm Limited (“RJIL”). The Complainant does demonstrate that RJIL launched its 4G telecom network under the JIO brand in 2016. The launch of the network was reported in the Indian and international press, including in China, where the Respondent is based. The launch occurred on September 5, 2016 and the network reached 100 million subscribers in 170 days. During that period, one month after the launch, the Respondent registered JIO in the disputed domain name. The disputed domain name adds the word “coin” after the JIO mark, which may imply an awareness of the Complainant’s recently-launched JIO network. The word “coin” is clearly related to payment and financial services. The network launch featured a welcome offer with tariff plans covering the full range of JIO applications and services, including payments. The network was presented to the press as the basis for a digital services business offering solutions across the entire value chain in key domains such as financial services. To this end, the Complainant had applied for multiple trademarks in India combining JIO with financial terms including “pay”, “payments”, “money”, and “currency”, as well as JIOWE COIN and JIO WE COIN, although the Complainant does not allege that any of those trademarks were used prior to the registration of the disputed domain name. The Respondent does not provide a credible alternative explanation for his combination of “jio” and “coin” in the disputed domain name. He acknowledges that they are two terms, not one, and that the second term is the English word “coin”. He alleges that he registered the disputed domain name for use in connection with a blockchain-related project. The Panel recalls its findings in Section 6.2B above that this allegation is unsubstantiated. The draft logos that the Respondent submitted are also undated and do not shed light on his intentions at the time of registration of the disputed domain name. Based on the record, the Panel finds the more plausible explanation for the registration of the disputed domain name to be that the Respondent anticipated that the Complainant would combine the JIO mark for its recently-launched and rapidly-expanding network with the word “coin”. This is not a case of anticipation of trademark rights because the JIO mark was already registered. The Panel acknowledges that the Complainant lacks trademark rights or local business in China. However, in view of all the circumstances, including the timing of events and the availability online of news about the network launch, the Panel finds it more likely than not that the Respondent registered the disputed domain name with the Complainant’s mark in mind. As regards use, the disputed domain name formerly resolved to a webpage where it was offered for sale but it is now passively held. Passive holding does not preclude a finding of use in bad faith. See Telstra Corporation Limited v. Nuclear Marshmallows, WIPO Case No. D2000-0003. The Panel notes that the disputed domain name wholly incorporates the JIO mark as its initial and only distinctive element. The Respondent has held the disputed domain name for 9 years despite having no association with the Complainant. While the Respondent refers to another meaning of “jio” and a regulatory prohibition on business activities related to cryptocurrency in China during most of that period, he has not shown that he intends to use the disputed domain name in a way that would be subject to that prohibition; in particular, he has not shown that the regulatory prohibition prevented him from launching a blog or that the project was of a different nature. In any case, if the Respondent intended to use the disputed domain name for his own project, he does not explain why it formerly resolved to a webpage offering it for sale. The Panel notes that the disputed domain name ceased to resolve to an active webpage after the Respondent received notice of this dispute. It can be inferred that the change in use was engineered to support the submission in the Response that the disputed domain name was intended for use with a project. The evidence presented of that project was trivial, undated, and most likely pretextual. In view of all these circumstances, the Panel considers that the disputed domain name is being used in bad faith. Therefore, the Panel finds the third element of the Policy has been established.
page 8 D. Reverse Domain Name Hijacking The Respondent questions whether the Complainant brought the Complaint in an attempt at Reverse Domain Name Hijacking. As the Panel has upheld the Complaint, it does not find that the Complaint was brought in bad faith. 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. /Matthew Kennedy/ Matthew Kennedy Sole Panelist Date: October 1, 2025
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