General Electric Company v HUB Team
WIPO Case No. D2025-1216
•09-05-2025
| ARBITRATION AND MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
General Electric Company v. HUB Team
Case No. D2025-1216
1. The Parties
The Complainant is General Electric Company, United States of America, represented by Saba & Co. IP,
Egypt.
The Respondent is HUB Team, Egypt.
2. The Domain Name and Registrar
The disputed domain name <generalelectriceg.com> is registered with Network Solutions, LLC
(the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 24, 2025. On March 25, 2025, the Center transmitted by email to the Registrar a request for registrar verif ication in connection with the disputed domain name. On the same day, 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 (None, None) and contact information in the Complaint. The Center sent an email communication to the Complainant on March 26, 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 amended Complaint on the same day.
The Center verif ied that the Complaint together with the amended 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 March 26, 2025. In accordance with the Rules,
paragraph 5, the due date for Response was April 15, 2025. The Respondent did not submit any response.
Accordingly, the Center notif ied the Respondent’s default on April 16, 2025.
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The Center appointed Andrew D. S. Lothian as the sole panelist in this matter on April 28, 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
According to the Complaint, the Complainant is an award-winning multinational technology, aerospace, and industrial company with approximately 52,000 employees operating in approximately 170 countries worldwide. The Complainant claims a 150-year legacy of innovation, having been formed by the merger of predecessor companies in 1892 by Thomas Alva Edison, the famed American inventor of the f irst commercially viable electric light bulb.
The Complainant made various substantive claims to its history and fame, and that of its trademarks, in a document described as “Fame affidavit”, which was provided in its annexes to the Complaint. This document took the form of an incomplete template of an af f idavit intended to demonstrate the Complainant’s fame (specifically, headed “GE ‘AFFIDAVIT OF FAME’ TEMPLATE”). As far as its claim to be an af f idavit is concerned, the document was not granted by any named person with authority to speak to its terms, was unsworn and unsigned, and notably contained an uncompleted placeholder section where the Complainant’s reputation in a specific country was to be inserted. The document also referenced screenshots allegedly demonstrating the reach of the Complainant’s social media sites which were not attached.
The Panel has accepted this incomplete document as a series of largely unsupported assertions,[1] based on the fact that the Complaint is accompanied by the usual certif ication of completeness and accuracy. It cannot be accorded the status of an aff idavit. Consequently, were it not for the fact that the Panel is independently aware of the Complainant’s substantial worldwide fame, and the fact that this has been accepted by numerous previous panels under the Policy (an example of which is given below), the Panel might have found it necessary to reject the present Complaint for want of supporting evidence. At the risk of stating the obvious, the Panel notes that it is good practice not to file incomplete documentation with a Complaint under the Policy and trusts that the Complainant and its representative will take steps to ensure that this does not happen again.
| Case No. D2016-0553, a previous case under the Policy involving among others the domain name | It has been noted in General Electric Company v. Islam Gamal and Begad Negad, YourServ.CoM, WIPO the Complainant’s trademark registrations in Egypt date back to the 1940’s. |
| For example, the Panel has identified that the Complainant is the owner of Egyptian Registered Trademark Number 2255 for the combined mark GENERAL ELECTRIC COMPANY, registered on July 29, 1944, in Class 9, and the owner of Egyptian Registered Trademark Number 57795 for the combined mark GENERAL ELECTRIC, registered on June 2, 1982, in Class 10. | |
| While the Complainant did not cite any specific registered trademarks in the Complaint, it laid claim to both the GENERAL ELECTRIC and GE marks, and on the strength of the panel’s remarks concerning the Complainant’s Egyptian trademarks in the previous case of General Electric Company v. Islam Gamal and Begad Negad, YourServ.CoM, supra, the Panel was content to review the marks noted above via an online |
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public database. On the subject of the Panel performing its own research of this nature, see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 4.8. The Panel notes in passing that it is good practice for a complainant to include specific examples of its registered trademarks in its documentary annexes, such as printouts or extracts f rom of f icial sources, rather than merely referring to their existence in general as the Complainant has done here.
The disputed domain name was registered on June 23, 2024. Little is known of the Respondent, other than that it appears to be based in Egypt. The screenshot of the website associated with the disputed domain name provided by the Complainant was captured on July 1, 2024, and contains a “Coming Soon!” page provided on WordPress via the Hostgator hosting service. This screenshot was considerably out of date by the time of the filing of the Complaint, and the Panel notes that it would have been good practice for the Complainant to have updated this. Nevertheless, the Complainant does note in the Complaint that the website associated with the disputed domain name had begun to of fer repair services for domestic
appliances by the time of f iling of the Complaint, and in light of the aged nature of the Complainant’s screenshot, the Panel chose to validate this submission by visiting the website associated with the disputed domain name on April 28, 2025. As of that date, the website associated with the disputed domain name bore to be operated by an entity allegedly named “General Electric” which claimed to be the “authorized agent for the largest electrical appliance companies in Egypt” for the repair and maintenance of electrical appliances, noting specifically the third party brands “Crazy, LG, Sharp, Samsung”. The website was in the Arabic language but readily translated into the language of the proceeding by way of a machine translation. Consequently, the Panel notes that the disputed domain name is being used in a very similar manner to the disputed domain names in General Electric Company v. Islam Gamal and Begad Negad, YourServ.CoM, supra.
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 incorporates the entirety of its GENERAL ELECTRIC trademark, appending only the nondistinctive term “eg”, which it asserts is an abbreviation of the country Egypt, adding that the addition of a common term to a complainant’s recognizable mark does not prevent a f inding of confusing similarity under the Policy.
The Complainant submits that the use of the website associated with the disputed domain name to of fer repair services for appliances is likely to mislead consumers to believe that the Respondent or its business is, or is affiliated or connected with, or authorized by, the Complainant, adding that the Respondent has neither used, nor made any demonstrable preparations to use, the disputed domain name or a
corresponding name in connection with a bona fide offering of goods or services. The Complainant states that the Respondent is not an authorized or certif ied service provider for the Complainant’s appliances, submitting that even an authorized provider does not have the right to use the Complainant’s trademark as a domain name. The Complainant adds that it has not licensed or otherwise permitted the Respondent to use any mark owned by the Complainant, and that the Respondent’s inclusion of “generalelectric” is not a nominative fair use but falsely conveys that the services concerned are of fered by the Complainant.
The Complainant contends that the use of a domain name that is confusingly similar to the Complainant’s famous GENERAL ELECTRIC mark is evidence of bad faith. It asserts that the Respondent knew of such mark based on its incorporation in the website associated with the disputed domain name, which attempts to deceive consumers into thinking that the Respondent or its business is associated with the Complainant. The Complainant states that by using the disputed domain name for such website, the Respondent has intentionally attempted to attract, for commercial gain, Internet users thereto by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, af f iliation, or endorsement thereof .
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Finally, the Complainant asserts that, through its use of the disputed domain name, the Respondent diverts consumers f rom the Complainant’s business to the Respondent’s business.
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 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 for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.
The Panel f inds the mark is recognizable 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, “eg” may bear on assessment of the second and third elements, the Panel f inds the addition of such term does not prevent a f inding 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 Top-Level Domain suffix in respect of the disputed domain name, here, “.com”, is typically disregarded under the f irst element test. WIPO Overview 3.0, section 1.11.1.
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.
Noting that the disputed domain name is used for a website which of fers repair services, potentially to the Complainant’s equipment or appliances, the Panel must consider whether the Respondent is making fair use
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of the Complainant’s mark in referential terms. This involves consideration of the nature of the disputed domain name itself, circumstances beyond the disputed domain name including website content, and any commercial activity operated by way of the disputed domain name. WIPO Overview 3.0, sections 2.5.1, 2.5.2 and 2.5.3.
Considering the disputed domain name on its own, the Panel first notes that a respondent’s use of a domain name will not be considered “fair” if it falsely suggests aff iliation with the trademark owner; the correlation between a domain name and the complainant’s mark being central to this inquiry. WIPO Overview 3.0, section 2.5. Here, the disputed domain name replicates the Complainant’s GENERAL ELECTRIC mark with the addition of the letters “eg”, being the two-character country code for Egypt. Given the famous nature of the GENERAL ELECTRIC mark, the composition of the disputed domain name suggests to the Panel that the Respondent is making a representation thereby that the Respondent has some form of of f icial status or af f iliation with the Complainant’s business in respect of the country of Egypt when it does not. This cannot confer rights and legitimate interests upon the Respondent.
Turning to the circumstances beyond the disputed domain name, the Panel notes that the associated website appears to of fer repair services for appliances manufactured under a variety of brands, not specifically including that of the Complainant. Not only does this make a false representation that the Respondent is in some way of f icially authorized to repair appliances branded with the Complainant’s GENERAL ELECTRIC mark, a mark of considerable longstanding in Egypt, but the website also references third party marks which might be seen as those of the Complainant’s competitors. The website in no way makes the position clear that the Respondent has no of f icial connection with the Complainant, as the disputed domain name itself would suggest. Such use could not therefore be regarded as making a fair reference to the Complainant’s mark for the purposes of of fering repair services for the Complainant’s appliances. The Panel notes in passing that this use is largely identical to the use of the very similar domain name <generalelectricegy.com> (where the only difference in composition is an additional letter “y” to the abbreviation for Egypt), as featured in the case of General Electric Company v. Islam Gamal and Begad Negad, YourServ.CoM, supra. In that case, the panel reached a similar conclusion to that reached by the Panel here that such use did not confer rights or legitimate interests upon the respondent.
Finally, on this topic, considering the commercial use of the disputed domain name, it is clear that the Respondent is making commercial gain from its association with the Complainant’s well-known mark via its use in the disputed domain name despite having no authority f rom the Complainant to do so. The Panel accepts the Complainant’s assertion that its GENERAL ELECTRIC mark is suf f iciently famous that a third party such as the Respondent could not adopt and use it in a domain name by arguing that it is making fair use of the term to describe “general electric” services, in other words, an allegedly descriptive use.
Furthermore, no such argument has been made by the Respondent in this case.
Taking all of these elements into consideration, the Panel does not consider that there is any evidence on the present record that the Respondent has rights or legitimate interests in the disputed domain name. The Respondent has not engaged with the present proceeding, and therefore has not taken up the opportunity to assert any such rights and legitimate interests on any basis. In the absence of such, the Panel cannot conceive of any rebuttal to the Complainant’s prima facie case that the Respondent might have made in connection with this element of the Policy.
The Panel f inds 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 Respondent has adopted the Complainant’s famous GENERAL
ELECTRIC registered trademark for use in the disputed domain name along with a country code
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representing the country of Egypt. The fame of the Complainant’s mark, which the Panel accepts based upon the assertions in the Complaint, the linked independent material relating to the Complainant’s awards, and previous cases under the Policy involving the Complainant and its GENERAL ELECTRIC mark
(sometimes abbreviated to “GE”), leads the Panel to the view that the Respondent could not have registered the disputed domain name independently of the Complainant’s mark. In particular, the Respondent claims to be in the business of appliance repair, and the Complainant manufactures appliances of many dif ferent types, whereby it seems inconceivable to the Panel that the Respondent might have been seeking to refer descriptively to its own business as dealing in “general electric” repairs. In any event, the use of the
Complainant’s mark with virtually no adornment does not suggest a descriptive use as, for example, the term “general electrical repairs” might have done. The adornment “eg” itself, coupled to the Complainant’s mark, suggests an official status for the Respondent’s business granted by the Complainant in respect of the country of Egypt when the Respondent has no such status and no entitlement to use such mark.
Consequently, the Panel considers that the Complainant’s mark was deliberately chosen by the Respondent for the disputed domain name in order to convey a misleading impression that the Respondent is in some way af f iliated to the Complainant in order to attract consumers by f ree-riding on the Complainant’s
substantial reputation in the field of electrical equipment manufacturing. Registration and use of the disputed domain name for this purpose could not be considered to be a good faith activity for the purposes of the Policy.
The Respondent has chosen not to engage with the present administrative proceeding, and has therefore failed to address the Complainant’s allegations of registration and use in bad faith. It has failed to assert any potential good faith reason or present any explanation for its registration and use of the disputed domain name.
The Panel f inds that, by using the disputed domain name, the Respondent has intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark as to the source, sponsorship, affiliation, or endorsement of such website or of a service on such website, namely the appliance maintenance and repair service discussed above. This constitutes registration and use in bad faith in terms of paragraph 4(b)(iv) of the Policy.
The Panel takes this opportunity to note that the poor quality of the Complaint in this case brought the Complainant within a hair’s breadth of not making out its case in terms of the Policy. The notably restricted record does the Complainant and its representatives no favors, and the Panel has considered it necessary to describe multiple shortcomings regarding the evidence presented in the factual background section above. The Panel invites the Complainant to take note of these observations should it wish to make future f ilings 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 <generalelectriceg.com> be transferred to the Complainant.
/Andrew D. S. Lothian/
Andrew D. S. Lothian
Sole Panelist
Date: May 9, 2025
accompanying pdf comments, presumably with the intention that the sites concerned would be visited by the drafter of the Complaint, and screenshots provided as an annex to the completed affidavit. As the URLs were provided on the record, the Panel has visited and verified several of these, principally focusing upon those which were independent publications and not the Complainant’s own press releases.
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