ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION CitiusTech Healthcare Technology Private Limited v. Web Master Case No. D2025-3710 1. The Parties Complainant is CitiusTech Healthcare Technology Private Limited, India, represented by Vutts & Associates LLP, India. Respondent is Web Master, Hong Kong, China. 2. The Domain Name and Registrar The disputed domain name (the “Domain Name”) is registered with Dynadot Inc (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on September 12, 2025. On September 12, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On September 16, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from named Respondent (Private Registration) and contact information in the Complaint. The Center sent an email communication to Complainant on September 17, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on September 22, 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 Respondent of the Complaint, and the proceedings commenced on September 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 13, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on October 17, 2025.
page 2 The Center appointed Clive L. Elliott, K.C., as the sole panelist in this matter on October 23, 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 Complainant is a provider of consulting and digital technology to healthcare and life sciences companies. Originally established in 2005 under the name Citius IT Solutions Private Limited, Complainant then changed its name in 2015 to CitiusTech Healthcare Technology Private Limited. Complainant builds applications, deploys enterprise-level software and is a pioneer in healthcare analytics in the international market. It is a well-established company in the United States of America (“United States”) market and is expanding its business to other countries. Complainant first adopted the mark CITIUSTECH in 2005 as its brand name and logo and has been using it continuously and exclusively since then. Complainant is the registered owner of the following marks in both United States and India (collectively and individually referred to as the “Complainant’s Mark”). Mark Jurisdiction Registration No. Registration Date Class India 2700671 March 18, 2014 9 United States 4628676 October 28, 2014 9, 42 India 3382199 October 5, 2016 42 In addition to the above trademarks, Complainant has also applied for the mark CITIUSTECH KNEWRON on May 16, 2025, which is pending registration in India. Complainant is also the registered owner of the domain name since 2005, which is its main website featuring Complainant’s Mark and is accessible to people worldwide. According to the publicly available WhoIs, the Domain Name was registered on July 10, 2025, and does not resolve to an active webpage (it resolves to a registrar parking page where the Domain Name is offered for sale for USD 1,999). 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Domain Name. Notably, Complainant contends that the Domain Name is deceptively similar to Complainant’s Mark as it incorporates Complainant’s CITIUSTECH and CITIUSTECH KNEWRON Marks in their entirety, and there is a high likelihood of confusion and deception since the public would mistakenly assume that Respondent originates from the same source as, or is associated with, Complainant. Complainant states that Respondent has not been licensed or authorized either to use Complainant’s Mark or to apply for the registration of a domain name including or deriving from it. Complainant submits that the Domain Name resolves to a webpage where the Domain Name has been listed for sale for USD 1,999. Complainant believes that because Respondent is not running any website under the Domain Name, Respondent is not making a bona fide offering of goods or services, and it
page 3 therefore appears not to be a fair use of the Domain Name. Complainant contends that the Domain Name was registered only because of its recognition as Complainant’s Mark. Complainant points out that the Mark CITIUSTECH is an invented word that it is using in relation to its various services in India and the United States. Complainant goes on to say that it has expended significant amounts in advertising and marketing in order to promote Complainant’s Mark and it believes that Complainant’s Mark is synonymous with Complainant and its business across the globe and has become well known. In terms of bad faith, Complainant submits that Respondent has registered the Domain Name, being aware of the commercial value of Complainant’s Mark and with the sole purpose of squatting on the Mark. Complainant further asserts that the facts support the conclusion that the primary purpose of registering and using the Domain Name is to capitalise upon the goodwill and reputation of Complainant’s Mark. Finally, Complainant asserts that Respondent is not running any website under the Domain Name and that this, along with the attempt to sell the Domain Name, shows the mala fide intent of Respondent is to merely earn profits from i.e. monetise the Domain Name with no purpose or intention of using the same. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The first element of the Policy functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between Complainant’s Mark and the Domain Name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. Complainant has shown rights in respect of a trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The Domain Name incorporates Complainant’s CITIUSTECH Mark in its entirety. Accordingly, the Domain Name is confusingly similar to Complainant’s 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. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which Respondent may demonstrate rights or legitimate interests in the 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 respondent lacks rights or legitimate interests, the burden of production on this element shifts to respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the Domain Name (although the burden of proof always remains on complainant). If respondent fails to come forward with such relevant evidence, complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1.
page 4 The Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Domain Name. Respondent has made no effort to rebut Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the Domain Name, such as those enumerated in the Policy or otherwise. It is asserted that Respondent is not making a bona fide offering of goods or services and the sole purpose of the use of the Domain Name is to offer it for sale. Such activity on its own is not indicative of any rights or legitimate interests. Complainant argues that the Domain Name is likely to mislead or deceive members of the public since the public would mistakenly assume that Respondent originates from the same source as, or is associated with, Complainant. The Panel agrees and finds that the Domain Name, and its use in this manner, carries a risk of implied affiliation. WIPO Overview 3.0, section 2.5.1. In addition, there is no evidence that Respondent is actually commonly known by the Domain Name. 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. The Panel notes that the composition of the Domain Name, incorporating Complainant’s Mark in its entirety suggests Respondent knew of and sought to take advantage of Complainant’s Mark when registering the Domain Name. As noted above, Respondent has not put forward any credible explanation for the choice of the Domain Name. Absent such explanation the Panel considers that there is a significant risk that dealings in or with the Domain Name are likely to lead to members of the public being misled or deceived. Furthermore, UDRP panels have long found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. 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. In particular, 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. WIPO Overview 3.0, section 3.3. The Panel regards the mere offer for sale of the Domain Name, without any other use of the Domain Name, as analogous. Having reviewed the available record, the Panel notes the distinctiveness or reputation of Complainant’s Mark, and the composition of the Domain Name, and finds that in the circumstances of this case, the holding and offer for sale of the Domain Name, but without more, does not prevent a finding of bad faith under the Policy. The Panel finds that 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 Domain Name be transferred to Complainant. /Clive L. Elliott, K.C./ Clive L. Elliott, K.C. Sole Panelist Date: November 10, 2025
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