G4S Limited v Name Redacted

Case

WIPO Case No. D2025-1090

16-05-2025

No judgment structure available for this case.

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

G4S Limited v. Name Redacted

Case No. D2025-1090

1. The Parties

The Complainant is G4S Limited, United Kingdom, represented by SafeNames Ltd., United Kingdom.

The Respondent is Name Redacted.[1]

[1]The Respondent appears to have used the name of a Complainant’s employee when registering the disputed domain name. In light

2. The Domain Name and Registrar

The disputed domain name <g4sindiasecurity.com> is registered with GoDaddy.com, LLC (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 17, 2025.
On March 17, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On March 18, 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 (Registration Private, Domains By Proxy, LLC) and contact
information in the Complaint. The Center sent an email communication to the Complainant on March 21,
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 amended Complaint on

March 26, 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”).

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In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the
Complaint, and the proceedings commenced on March 27, 2025. In accordance with the Rules, paragraph
5, the due date for Response was April 16, 2025. The Respondent did not submit any response.

Accordingly, the Center notified the Respondent’s default on April 22, 2025.

The Center appointed Delia-Mihaela Belciu as the sole panelist in this matter on May 2, 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 a London-based global security company which provides security and facility services in around 90 countries across the world. Initially founded in 1901, the Complainant has been operating under its current name, G4S (or Group 4 Securicor) since 2004, when Group 4 Falck and Securicor merged. In

2021, the Complainant was acquired by Allied Universal and presently has a network of more than 800,000
employees globally.

The Complainant offers a diverse range of services, broadly divided into the categories of “Security Solutions”, “Cash Solutions”, “Consulting Services”, “Care and Justice Services” and the “G4S Academy”, as well as tailored country-specific services across different industry sectors which include, for example, courier-related services, as well as offerings for the sectors of retail and financial institutions.

The Complainant has a number of subsidiaries operating across numerous countries, including but not
limited to Colombia, Finland, Japan, and particularly in India. Specifically, G4S Security Services (India)
Private Limited oversees the Complainant’s India-based operations. Launched in 1989, the Complainant’s
presence in India is significant with 128 hubs, branches, and offices and over 130,000 employees. The
Complainant’s India services can be found by accessing the website “

The Complainant has acquired widespread consumer goodwill, having operated for over a century and under the G4S brand for more than 20 years.

The Complainant is in particular the owner of the following G4S trademark registrations:

- the International trademark registration No. 885912 for G4S, registered on October 11, 2005, for goods and
services in classes 1, 5, 6, 9, 16, 35, 36, 37, 38, 39, 41, 42, 44, and 45, in various jurisdictions;
- the United States of America trademark No. 3378800 for G4S, registered on February 5, 2008, for goods
and services in classes 9, 39, and 45;
- the European Union trademark No. 015263064 for G4S, registered on September 20, 2016, for goods and
services in classes 6, 36, and 37.

In addition, the Complainant uses its main website “ corresponding to its domain name <g4s.com> registered on December 1, 1999, to market its global offerings. This website is available in multiple languages and includes many country-specific pages. These enable the Complainant to provide its tailored services to users in different countries.

The Complainant has also registered its G4S mark across a number of country code Top-Level Domains

(“ccTLDs”), such as:

- <g4s.cz>, registered on January 27, 2003,
- <g4s.us>, registered on November 17, 2004,
- <g4s.cn>, registered on March 1, 2005,
- <g4s.in>, registered on March 2, 2005.

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Moreover, the Complainant has an established presence on different social media platforms through its social pages.

The disputed domain name was registered on January 15, 2025, and resolves to a parked webpage
provided by the Registrar. According to the evidence available in the file, a Mail Exchange (“MX”) record for

the disputed domain name was configured.

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:

;

(i) the disputed domain name is confusingly similar to the Complainant’s G4S mark as it contains the G4S and goodwill in the G4S mark

mark in its entirety, with the addition of the geographical term “India” and an industry-specific term “security”.

of reasons, among which that, (1) the Respondent does not have any trademark rights regarding the term
“g4s” or any other term used in the disputed domain name nor a license from the Complainant in order to
use the G4S trademark, (2) the disputed domain name resolves to a parked webpage provided by the

(ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name for a number known by the disputed domain name or the Complainant’s mark G4S nor any other similar denomination;

which that, (1) the Complainant’s trademark registrations predate the registration date of the disputed
domain name, (2) the “g4s” term is a distinctive term used to represent the Complainant’s services, in which
it has accrued substantial goodwill since 2004, (3) conducting searches for the term “g4s” on search engines
such as Google, lists the Complainant’s brand and goods as the first result, (4) the disputed domain name
reproduces the G4S mark in its entirety with the only additions being the geographic term “India” and the
industry specific term “security”, both of which only add an affiliation to the Complainant’s operations, (5)
the disputed domain name does not resolve to a functional website, (6) cease and desist letters were sent
out to the Respondent on February 10, and 17, 2025 to which no response was received, (7) the

(iii) the disputed domain name was registered and is being used in bad faith for a number of reasons, among activity through email distribution, particularly given the implied affiliation of the disputed domain name with the Complainant, (8) the Respondent used the name of one of the Complainant’s employees when registering the disputed domain name in an attempt to conceal its true identity and frustrate legal proceedings against them. In the Complainant’s view, the presence of identity theft reaffirms the bad faith nature of the Respondent’s conduct.

B. Respondent
The Respondent did not reply to the Complainant’s contentions.

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6. Discussion and Findings

In order for the Complainant to succeed, such must prove, according to paragraph 4(a) of the Policy, that:

(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the

Complainant has rights;

(ii) the Respondent has no rights or legitimate interests with respect to the disputed domain name; and

(iii) the disputed domain name has been registered and is being used in bad faith.

In case all three elements above have been fulfilled, the Panel is able to grant the remedy requested by the

Complainant. Thus, the Panel will deal with each of the requirements in turn.

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 panel finds that the entirety of the G4S mark is reproduced within the disputed domain name with the
addition of the geographical term “India” and of the descriptive term “security”, which is not sufficient to
prevent the finding that the disputed domain name is confusingly similar to the Complainant’s trademark
G4S. 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 “India” and “security”, may bear on assessment of the second and third elements, the Panel finds the addition of such terms 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.

In what concerns the addition of the generic Top-Level Domain (“gTLD”) “.com” in relation to the disputed domain name, such is viewed as a standard registration requirement, and is disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11.1.

Based on the available record, the Panel finds that 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
evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section
2.1.

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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.

Thus, based on the available evidence, the Respondent does not appear to be commonly known by the name “g4s”, does not appear to have any trademark rights regarding the term “g4s” or any other term used in the disputed domain name nor a license from the Complainant in order to use the G4S mark.

Moreover, the disputed domain name resolves to a parked webpage provided by the Registrar, with minimum content, while a MX record was configured in relation to this disputed domain name which could lead to a possible risk of a fraudulent activity.

Furthermore, the composition of the disputed domain name, incorporating the Complainant’s G4S mark with the addition of the geographical term “India” and of the descriptive term “security”, might lead to confusion for Internet users and as such, carries a risk of implied affiliation with the Complainant. WIPO Overview 3.0,

section 2.5.1.

All the above does not amount to a bona fide offering of goods or services, or to a legitimate noncommercial or fair use of the disputed domain name.

Based on the available record, the Panel finds that 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.

In the present case, the Panel notes that the Complainant’s rights in the G4S mark predate the registration date of the disputed domain name.

In light of the above as well as of the distinctive character of the G4S mark, the Panel finds that it is not
conceivable that the Respondent registered the disputed domain name without knowledge of the
Complainant’s G4S mark, which supports a finding of bad faith registration. WIPO Overview 3.0, section
3.2.2.

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 the present case, the Panel notes that, the disputed domain name resolves to a parked webpage provided by the Registrar, with minimum content, while a MX record was configured in relation to this disputed domain name, aspect which could lead to a possible risk of a fraudulent activity. Moreover, the disputed domain

name incorporates in its entirety the Complainant’s distinctive G4S mark with the addition of the
geographical term “India” and of the term “security” which is descriptive for the Complainant’s activity,
leading thus to confusion and misleading Internet users including into believing that any email which might
be sent using the disputed domain name is sent by the Complainant or by an affiliated entity with the
Complainant’s consent.

In addition, cease and desist letters were sent out to the Respondent to which no response was received. Furthermore, the Respondent used the name of one of the Complainant’s employees when registering the disputed domain name in an attempt to conceal its true identity, being thus a possible case of identity theft.

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Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy and 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 <g4sindiasecurity.com> be transferred to the Complainant.

/Delia-Mihaela Belciu/
Delia-Mihaela Belciu
Sole Panelist
Date: May 16, 2025

of the potential identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent. The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding, and has indicated Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v. FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788.

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