ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Sanofi v. Ei Poler Case No. D2025-3659 1. The Parties The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France. The Respondent is Ei Poler, United States of America (the “US”). 2. The Domain Name and Registrar The disputed domain name (the “Disputed Domain Name”) is registered with NameSilo, LLC (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 9, 2025. On September 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On September 10, 2025, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center sent an email communication to the Complainant on September 10, 2025, providing the registrant and contact information disclosed by the Registrar, which corresponded to those included in the Complaint. The Center verified that 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on September 19, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 9, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 14, 2025.
page 2 The Center appointed Monica Novac as the sole panelist in this matter on October 22, 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 Sanofi, a French multinational pharmaceutical company, ranked as the fourth world’s largest multinational pharmaceutical company by prescription sales. The company was established in 2004 under the name Sanofi-Aventis, and then changed its name to Sanofi in 2011. The Complainant has a presence in more than 100 countries around the world, employing around 100,000 people. The Complainant owns several SANOFI trademarks in various jurisdictions, including the following: - European Union Trademark Registration No. 010167351 SANOFI (word), registered on January 7, 2012, in classes 3 and 5; - European Union Trademark Registration No. 004182325 SANOFI (word), registered on February 9, 2006, in classes 1, 9, 10, 16, 38, 41, 42 and 44; - International Trademark Registration No. 1092811 SANOFI (word), registered on August 11, 2011, in classes 1, 9, 10, 16, 38, 41, 42 and 44, designating numerous jurisdictions; - International Trademark Registration No. 1094854 SANOFI (word), registered on August 11, 2011, in classes 3 and 5, designating numerous jurisdictions; - International Trademark Registration No. 674936 SANOFI (word), registered on June 11, 1997, in classes 3 and 5, designating numerous jurisdictions; and - US Trademark Registration No. 4178199 SANOFI (word), registered on July 24, 2012, in, among others, class 5. Previous UDRP panels have already recognized the well-known character of the SANOFI trademarks in various jurisdictions. The Complainant also owns several domain names corresponding to its SANOFI trademark, including, but not limited to , , , , , , and , all these being registered before the date of registration of the Disputed Domain Name. Most of these domain names are used by the Complainant in connection with its business activities. The Respondent is Ei Poler, apparently located in the US. The Respondent registered the Disputed Domain Name on August 28, 2025. As of the date of this Decision, when accessed by the Panel, the Disputed Domain Name resolves to an inactive website. 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.
page 3 Notably, the Complainant contends that: - the Disputed Domain Name is confusingly similar to the Complainant’s SANOFI trademarks; - the Respondent has no rights or legitimate interests in the Disputed Domain Name; and - the Disputed Domain Name has been registered and it is being used in bad faith. B. Respondent 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 a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the SANOFI trademark is reproduced within the Disputed Domain Name. The Panel finds that the SANOFI trademark is recognizable within the Disputed Domain Name. Accordingly, the Disputed Domain Name is confusingly similar to the Complainant’s trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The Disputed Domain Name also contains the term “global” preceded by a hyphen, however the Panel finds that the addition of this element does not prevent finding a confusing similarity between the Disputed Domain Name and the Complainant’s trademark for the purposes of the Policy. According to the WIPO Overview 3.0, section 1.8, where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. According to the WIPO Overview 3.0, section 1.11.1, the generic Top-Level Domain (“gTLD”) “.com” in the Disputed Domain Name is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. Further to all the above, 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 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
page 4 evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. It is accepted by the Panel that the Respondent has no relationship whatsoever with the Complainant, and that the Complainant has never licensed or authorized the use of its trademarks or the registration of the Disputed Domain Name by the Respondent. There is no evidence that the Respondent holds any rights over SANOFI, including those that are earlier than the Complainant’s rights in the SANOFI trademarks. Moreover, there is no evidence that the Respondent is commonly known by the Disputed Domain Name or by a similar name. The Panel is of the opinion that the composition of the Disputed Domain Name carries a risk of implied affiliation with the Complainant. WIPO Overview 3.0, section 2.5.1. As noted above, the Disputed Domain Name resolves to an inactive webpage. The Respondent has not brought any evidence that it has engaged in any demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services as per the Policy. In view of the composition of the Disputed Domain Name and the reputation of the Complainant’s trademark, the Panel is of the opinion that the Disputed Domain Name is likely to mislead Internet users, and there is no evidence that the Respondent has been making legitimate noncommercial or fair use of the Disputed Domain Name. 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. 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. Further to all the above, 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. 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. According to the WIPO Overview 3.0, section 3.1.4, panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith. In the present case, the Panel notes that the Respondent registered the Disputed Domain Name long after the Complainant registered and used its SANOFI trademark. In view of the global fame of the Complainant, the well-known character of its SANOFI trademark and the composition of the Disputed Domain Name, it is unlikely that the Respondent was not aware of the Complainant’s trademark and business when registering the Disputed Domain Name. In view of the above, the Panel considers that the Respondent targeted the Complainant when registering the Disputed Domain Name. The Disputed Domain Name contains the Complainant’s well-known SANOFI trademark in its entirety, which is followed by a hyphen, the descriptive term “global” and the gTLD “.com”. Such composition of the Disputed Domain Name falsely suggests to Internet users that they will be directed to a website affiliated with the Complainant and related to the Complainant’s worldwide presence and activities. The Respondent’s
page 5 registration of the Disputed Domain Name, creating a false association or affiliation with the Complainant, is clear proof of the Respondent’s bad faith. Regarding the use of the Disputed Domain Name, 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. Having reviewed the available record, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, the composition of the Disputed Domain Name, as well as the Respondent’s failure to submit a response, and finds that in the circumstances of this case the passive holding of the Disputed Domain Name does not prevent a finding of bad faith under the Policy. Further to all the above, 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. /Monica Novac/ Monica Novac Sole Panelist Date: November 5, 2025
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