AXA SA v Sall Domains, ICT fry

WIPO Case No. D2025-1953

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

AXA SA v. Sall Domains, ICT fry

Case No. D2025-1953

1. The Parties

The Complainant is AXA SA, France, represented by Plasseraud IPAvocats, France.

The Respondent is Sall Domains, ICT f ry, United Arab Emirates (“UAE”).

2. The Domain Name and Registrar

The disputed domain name <axatrades.com> is registered with NameCheap, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 15, 2025. On connection with the disputed domain name. On May 15, 2025, the Registrar transmitted by email to the Center its verif ication response, disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 19, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on May 20, 2025.

The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied 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 notif ied the Respondent of the Complaint, and the proceedings commenced on May 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 12, 2025. The Response was filed with the Center on June 12, 2025. In addition, the Respondent sent email communications to the Center on May 21 and 23, 2025. The

Complainant f iled supplemental f ilings on May 26, 2025, and June 13, 2025.

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The Center appointed W. Scott Blackmer as the sole panelist in this matter on June 19, 2025. The Panel f inds 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 a French limited company traded on the Paris and New York stock exchanges that serves as the holding company for the AXA Group, a multinational f inancial services group active in 50 countries, including Europe, North and South America, the Middle East and Africa, and the Asia-Pacif ic region. The group employs 154,000 people and serves 94 million customers. It has been doing business under the AXA mark since 1985. In addition to insurance and savings, the group offers investment and asset management services, including digital assets such as cryptocurrencies. In 2023, group affiliate AXA IM was designated a digital services asset provider by the French Market Authority, enabling it to carry out

cryptocurrency transactions.

The Complainant operates multiple “AXA” websites, including “ (in English and French) and

“” r”.

The Complainant holds relevant trademark registrations, including the following:

Mark Jurisdiction Registration Registration Date Goods and

Number Services

AXA (word)	International	490030	December 5, 1984	IC 35, 36, and 39
(multiple designations)
AXA (word)	European Union	008772766	September 7, 2012	IC 35 and 36

The worldwide reputation of the AXA brand has been recognized in prior UDRP decisions such as AXA SA v. Frank Van, WIPO Case No. D2014-0863. In 2024, the AXA mark was ranked 48th among the 100 best global brands according to Interbrand.

The disputed domain name was registered on January 17, 2025, and is registered to the Respondent “Sall Domains” of the organization “ICT f ry”, listing a postal address in “dubai silicon oasis” UAE. The Response and email communications to the Center were sent by a person identif ied only as “Sami”, on behalf of unnamed persons he referred to only as “we”.

The disputed domain name resolves to an English-language website (the “Respondent’s website”) headed “AXA Trades Trading Platform” that appears to be a trading platform for a variety of cryptocurrencies, with linked social media accounts. Site visitors are encouraged to set up and fund a trading account and may furnish their email address to subscribe to a daily informational newsletter. Despite featuring tabs and links with headings such as “About”, “Contact”, “Company”, “Legal”, “Terms of Service”, and “Privacy Policy”, the Respondent’s website never actually identifies the website operator. The copyright notice is simply in the name of “Axa Trades”, but this is nowhere identif ied as a legal entity in any jurisdiction, and no postal address is given for “Axa Trades”, nor is there a reference to any supervisory authority. The Panel notes that a contact telephone number is given with an area code comporting to the State of New Mexico in the United States of America, but the online database of the New Mexico Secretary of State has no listing for an “Axa Trades” as an entity registered to do business in that state. 1

1Noting the general powers of a panel articulated in paragraphs 10 and 12 of the Rules, it is commonly accepted that a panel may

undertake limited factual research into matters of public record, as the Panel has done in these proceedings. WIPO Overview of WIPO
Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 4.8.

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The Complainant sent three cease-and-desist letters to the Respondent in February 2025, through the

Respondent’s domain privacy service, and received no reply.

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 identical to its registered AXA mark, which it reproduces in its entirety. The Complainant has not given the Respondent permission to use the mark, and there is no evidence that the Respondent is actually an entity known by a corresponding name. It is likely that the Respondent’s website represents a phishing scheme rather than a bona f ide of fering of goods or services. There is no actual legal notice or information about the supposed company “Axa Trades” on the Respondent’s website, as would be expected for a genuine f inancial trading platform. Moreover, the site demonstrates bad faith by offering services (cryptocurrency investments) provided by the Complainant, on a site with a predominantly blue color scheme like the Complainant’s. The Respondent’s use of an anonymizing registration service further supports the inference of bad faith, along with adding the word “trades” to the sign AXA in composing the disputed domain name, as the Complainant of fers

investment services as well.

B. Respondent

The Respondent contends that the Complainant has not satisf ied all of the elements required under the Policy for a transfer of the disputed domain name. The Respondent does not deny prior awareness of the Complainant or its AXA mark but asserts that the disputed domain name was registered “with a clear plan to develop a digital asset trading and education platform” that is “not associated with” the Complainant. The Respondent states that it makes no reference to the Complainant and suggests no association with the Complainant. The Respondent acknowledges that in emails with the Center the Respondent suggested an “amicable resolution” as a “standard commercial approach” but denies an intent to “prof it unfairly” f rom the disputed domain name. The Respondent claims that the disputed domain name “was independently

selected based on our business model and not as part of any pattern to target trademark holders”.

6. Discussion and Findings
6a. Preliminary Issues: Supplemental Filings

Paragraph 10 of the Rules gives the Panel “the authority to determine the admissibility, relevance, materiality and weight of the evidence, and also to conduct the proceedings with due expedition”. Paragraph 12 provides that it is in the Panel’s sole discretion to request further statements or documents f rom the parties. Unsolicited f ilings are generally discouraged and tend to be permitted exceptionally where additional

supporting evidence is required, a relevant claim has not been addressed, or fairness calls for an opportunity
to respond to the opposing party. WIPO Overview 3.0, sections 4.6 and 4.7.

Here, the Respondent (not represented by counsel) raised several issues in email communications before f iling the Response, and the Complainant replied to issues raised in either the emails or in the Response, in two supplemental f ilings. The Panel f inds these matters either duplicative or immaterial, and they are, therefore, either addressed below in the context of the pleadings or disregarded.

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6b. Substantive Matters
A. Identical or Confusingly Similar

It is well accepted that the f irst 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 3.0, section 1.7.

The Complainant has shown rights in respect of a trademark or service mark (the registered AXA mark) for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.

The entirety of the mark is reproduced 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.

Although the addition of other terms (here, the word “trades”) may bear on assessment of the second and third elements, the Panel finds the addition of such a term 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 f inds the f irst 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 of ten 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 satisf ied the second element. WIPO Overview 3.0, section 2.1.

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. The Respondent has not shown that it is known by a corresponding name or that it is legitimately offering cryptocurrency trading services on its website; there is no evidence of actual sales or trades, for example, and there are indicia of a f raudulent website, as described above in the Factual

Background section. The actual company operating the website is not identif ied, for example. Thus, the Respondent has not established that it is using the disputed domain name, or has made demonstrable plans to do so, for a bona f ide commercial of fering or that it is commonly known by a corresponding name (paragraphs 4(c)(i) and (ii) of the Policy).

Panels have held that the use of a domain name for illegitimate or illegal activity, here claimed to involve phishing and impersonation, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Respondent’s website appears more likely to ref lect such activity than to be a legitimate trading platform.

The Panel f inds the second element of the Policy has been established.

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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.

In the present case, the Panel notes that the Respondent does not deny prior awareness of the Complainant’s distinctive and well-established AXA mark. The Respondent denies an intent to exploit the mark and argues that the mark is associated with insurance, but the record shows that it is also associated with cryptocurrency investment, as promoted on the Respondent’s website. In any event, it is likely that the Respondent selected the disputed domain name incorporating the Complainant’s mark for the trademark value of the term in attracting Internet users to the Respondent’s website, consistent with the example of bad faith given in the Policy, paragraph 4(b)(iv), misleading Internet users with a likelihood of confusion for commercial gain.

Panels also have held that the use of a domain name for illegitimate or illegal activity such as phishing or impersonation constitutes bad faith. For the reasons set out above, the Respondent’s website appears more likely to ref lect such activity than to be a legitimate trading platform, and, in any case, af f irms the

Respondent’s intention to take unfair advantage of the likelihood of confusion between the disputed domain name and the Complainant as to the origin of the Respondent’s website. WIPO Overview 3.0, section 3.4.

Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy.

The Panel f inds 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 <axatrades.com> be transferred to the Complainant.

/W. Scott Blackmer/
W. Scott Blackmer
Sole Panelist
Date: July 3, 2025