GKN Holdings Limited v Satyendra Singh

WIPO Case No. D2025-2768

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

GKN Holdings Limited v. Satyendra Singh

Case No. D2025-2768

1. The Parties

The Complainant is GKN Holdings Limited, United Kingdom, represented by Demys Limited, United

Kingdom.

The Respondent is Satyendra Singh, India.

2. The Domain Name and Registrar

The disputed domain name <gknaerospaces.com> is registered with Hostinger Operations, UAB (the

“Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 14, 2025.
On July 15, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On July 16, 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 (Domain Admin, Privacy Protect, LLC (PrivacyProtect.org)) and
contact information in the Complaint. The Center sent an email communication to the Complainant on July
16, 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

July 17, 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 the Respondent of the
Complaint, and the proceedings commenced on July 22, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was August 11, 2025. The Respondent sent email communications to the
Center on July 16, 17, 21, 22, and 25, 2025. In the Respondent’s email communications of July 17 and 21,
2025, the Respondent stated that the Respondent does not wish to contest the Complaint and is willing to

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transfer the disputed domain name to the Complainant. On July 21, 2025, the Complainant indicated that it does not wish to explore settlement options. In the Respondent’s email communications of July 22 and 25, 2025, the Respondent completed the Standard Settlement Form confirming the Respondent’s consent to the transfer of the disputed domain name to the Complainant. On August 14, 2025, the Center informed the Parties that it will proceed to Panel Appointment.

The Center appointed Daniel Peña as the sole panelist in this matter on August 20, 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 part of the global GKN Aerospace group of companies (collectively referred to as “GKN
Aerospace”).

GKN Aerospace traces its origins to the year 1759. As of today, it operates 32 manufacturing facilities across 12 countries and employs approximately 16,000 people. It provides aero structures and engine systems for both civil and defense sectors, supporting a wide range of aircraft including helicopters, business jets, commercial airliners, advanced air mobility vehicles, and fighter jets.

The Complainant supplies products and services to more than 90% of global aircraft and engine manufacturers. In 2023, GKN Aerospace reported sales totaling GBP 3.47 billion.

The Complainant is the entity within GKN Aerospace that owns the relevant corporate trademarks:

- United Kingdom Registration No. UK00000960174 for GKN (Design), registered on May 26, 1970, for

International class 20.

- United States Registration No. 1183680 for GKN, registered on December 29, 1981, for International

class 12.

- United States Registration No. 1412236 for GKN (Design), registered on October 7, 1986, for International

class 12.

- European Union Intellectual Property Office (“EUIPO”) Registration No. 000218081for GKN, registered on

October 21, 1998, for Internacional classes 1, 2, 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 20, 35, 37, 39, 41.

- Australian Registration No. 722066 for GKN (Design), registered on November 15, 1996, for International

classes 1, 2, 6, 7, 9, 10, 11, 12, 13, 17, 20, 37, 41, 42.

The disputed domain name was registered on May 25, 2025, and resolves to a website featuring the

Complainant’s trademarks and similar content from the Complainant’s 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.

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Notably, the Complainant contends that the disputed domain name incorporates the Complainant’s GKN mark in its entirety, and only differs by the addition of the term “aerospace” and the single letter “s”. The Complainant notes that it and its group companies are collectively referred to and operate as “GKN

Aerospace”. Thus, the term “aerospace” is one closely connected to the Complainant.

The fact of adding the letter “s” within the disputed domain name (resulting into the plural version of the term
“space”) can be seen as a typographical variant of the Complainant’s name (GKN Aerospace).

The Complainant asserts that the Top-Level Domain “.com” is required solely for technical purposes and, as is customary in UDRP proceedings, may be disregarded when comparing the disputed domain name to the Complainant’s trademarks.

The Complainant contends that the disputed domain name is confusingly similar to GKN registered trademark

The Complainant contends that the Respondent does not have any rights or legitimate interests in the disputed domain name.

The Complainant has found no evidence that the Respondent has been commonly known as GKN or GKN
AEROSPACES prior to or after the registration of the disputed domain name.

The Complainant notes that the oldest of their example marks pre-dates the registration of the disputed domain name by more than 55 years.

The Respondent is not a licensee of the Complainant and has not received any permission or consent from the Complainant to use its GKN mark.

The Complainant has found no evidence that the Respondent owns any trademarks incorporating the term
GKN or GKN AEROSPACES.

The Complainant contends that the Respondent is not making legitimate noncommercial or fair use of the disputed domain name.

The Complainant states that the disputed domain name is configured for email use through active MX records, and closely imitates its own email format. This setup increases the risk of confusion, misrepresentation, and potential impersonation among employees, partners, and clients. The use of a typographical variant of the Complainant’s mark further supports the claim of bad faith.

The Complainant asserts that the Respondent’s website falsely suggested an affiliation with the Complainant by displaying the GKN mark, using a similar blue and white color scheme, presenting information related to the Complainant’s aerospace business, and identifying itself as “GKN Aerospace” in its “About us” section.

The Complainant contends that the disputed domain name was registered and used in bad faith to mislead users by imitating its brand. The disputed domain name closely resembles the Complainant’s official site, incorporates its mark, and includes deceptive elements such as similar design, business descriptions, and false identification as “GKN Aerospace,” without any disclaimer. These factors collectively support the claim of intentional brand exploitation and bad-faith registration.

B. Respondent

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

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6. Discussion and Findings

To succeed, the Complainant must demonstrate that all of the elements listed in paragraph 4(a) of the Policy have been satisfied: (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 in respect of the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad faith. Considering these requirements, the Panel rules as follows:

A. Identical or Confusingly Similar

Paragraph 4(a)(i) of the Policy requires the Complainant to show that the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights.

The Complainant has provided evidence of its rights in the trademarks GKN on the basis of its multiple trademark registrations in the United Kingdom, United States, European Union, and Australia. A trademark registration provides a clear indication that the rights in the trademark belong to the complainant (see WIPO Overview 3.0, section 1.2.1). Mere addition of the term “aerospace” and the letter “s” does not prevent a finding of confusing similarity with the Complainant’s GKN marks. As noted in 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) does not prevent a finding of confusing similarity under the first element”.

Similarly, the generic Top-Level Domain (“gTLD”) “.com” is viewed as a standard registration requirement and as such is disregarded for the purpose of determining whether a domain name is identical or confusingly similar to a trademark (see also WIPO Overview 3.0, section 1.11.1).

Accordingly, the Panel finds that the disputed domain name is confusingly similar to the trademark in which the Complainant has rights, meaning that the Complainant has satisfied the requirement under paragraph 4(a)(i) of the Policy.

B. Rights or Legitimate Interests

While 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 often impossible 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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element (see WIPO Overview 3.0, section 2.1).

The Complainant has made a prima facie showing that the Respondent does not have any rights or legitimate interests in the disputed domain name, particularly by asserting that the Respondent is not affiliated with it in any way and that it never authorized the Respondent to use its trademarks as part of the disputed domain name.

Furthermore, the nature of the disputed domain name - comprising the Complainant’s trademarks and additionally incorporating the term “aerospace” and the letter “s”, which corresponds to the name by which the group of companies affiliated with the Complainant is commonly known and reflects their commercial activities - demonstrates a clear awareness of the Complainant and its trademarks. The inclusion of the final “s” appears to be a deliberate attempt by the Respondent to exploit a typographical variation or common misspelling of the group’s name, thereby misleading users and unfairly capitalizing on the Complainant’s reputation. Such circumstances do not support a finding of rights or legitimate interests on the part of the Respondent. The Respondent is not known under the disputed domain name.

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The Panel notes that the Respondent has not replied to the Complainant’s contentions and thus did not deny the Complainant’s assertions, nor brought any information or evidence for demonstrating any rights or legitimate interests.

Accordingly, the Panel finds that the Complainant satisfied the requirements of paragraph 4(a)(ii) of the

Policy.

C. Registered and Used in Bad Faith

Paragraph 4(b) of the Policy stipulates that any of the following circumstances, inter alia, shall be considered as evidence of the registration and use of a domain name in bad faith: (i) circumstances indicating that a respondent registered or acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent’s

documented out-of-pocket costs directly related to the domain name; or (ii) circumstances indicating that the respondent registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or (iii) circumstances indicating that the respondent registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) circumstances indicating that the respondent is using the domain name to intentionally attempt to attract, for commercial gain, Internet users to its website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on its website or location.

With regard to the bad faith at the time of registration, the Panel notes that it is not likely that the Respondent was not aware of the Complainant and its trademarks. On the contrary, the Panel finds that it is likely that the Respondent was aware of the Complainant and its rights and reputation in the GKN trademarks at the time the disputed domain name was registered. Bad faith can be presumed based on the widely evidenced recognition of the Complainant’s trademarks and the use made of the disputed domain name.

The Panel finds that the fact that the Respondent has registered the disputed domain name that contains the Complainant’s trademarks GKN, merely including “aerospace” and the letter “s” at the end reinforces the Respondent’s bad faith.

The Panel notes that the disputed domain name directs to a website that contains the Complainant’s logo and content similar to Complainant’s website. The Panel is satisfied that 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 trademarks as to the source, sponsorship, affiliation, or endorsement of its website or of the products on its website (see WIPO Overview 3.0, section 3.1.4).

Moreover, the Complainant has submitted evidence, including MX record printouts, demonstrating that the disputed domain name is configured for email use. This configuration enables the Respondent to send and receive emails using an address that closely mimics the Complainant’s own format, thereby increasing the risk of confusion, misrepresentation, and potential impersonation among employees, partners, and clients. The use of a typographical variant of the Complainant’s mark further reinforces this concern. In light of these circumstances, the Panel considers the disputed domain name’s email functionality to be an additional factor supporting a finding of bad faith.

Under paragraph 4(b)(iv) of the Policy, the Panel finds that the disputed domain name was registered and used in bad faith.

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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 <gknaerospaces.com> be transferred to the Complainant.

/Daniel Peña/ Daniel Peña Sole Panelist Date: September 3, 2025