Global Loan Agency Services Limited v BEVIN BICHAGE

WIPO Case No. D2025-2542

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Global Loan Agency Services Limited v. BEVIN BICHAGE

Case No. D2025-2542

1. The Parties

Complainant is Global Loan Agency Services Limited, United Kingdom, internally represented.

Respondent is BEVIN BICHAGE, France.

2. The Domain Name and Registrar

The disputed domain name <gles.agency> (hereinafter “Disputed Domain Name”) 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 June 30, 2025.
On June 30, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the Disputed Domain Name. On July 1, 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 (Privacy Protect, LLC) and contact information in the Complaint[1].
The Center sent an email communication to Complainant on July 1, 2025, providing the registrant and
contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the

[1]The Registrar also advised that the Disputed Domain Name expired June 20, 2025. On July 9, 2025, Complainant paid the fee to

Complaint. Complainant filed an amended Complaint on July 4, 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 July 8, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 28, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on July 29, 2025.

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The Center appointed Lawrence K. Nodine as the sole panelist in this matter on August 5, 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, Global Loan Agency Services Limited, uses GLAS (hereinafter the “Mark”) as a trademark for financial services in connection with agency, trustee, and fiduciary services.

Complainant alleges that the Mark is “used extensively in the financial services sector in connection with

the domain name <glas.agency>, which represents that it has USD 600 billion assets under administration, and offices in 12 locations worldwide, including New York, London, Paris, Madrid,	agency, trustee and fiduciary services.” This allegation is supported by Complainant’s website located at recognizing its success and global reputation[2].
Complainant owns several trademark registrations for the Mark, including:
-	United Kingdom Trademark registration number UK00003962388 (registered on December 29, 2023)
-	French Trademark registration number 1791165 (registered on March 12, 2024)

[2]These awards include: IJInvestor Awards 2024 (“2024 Restructure of the Year, North America”); Hedgeweek and Private Equity Wire-

The Disputed Domain Name was registered on June 20, 2024. It does not resolve to an active website.

5. Parties’ Contentions

A. Complainant

Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the

Disputed Domain Name.

B. Respondent

Respondent did not reply to Complainant’s contentions.

6. Discussion and Findings

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
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.

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.

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The Panel finds 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.

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 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.

Having reviewed the available record, the Panel finds Complainant has established a prima facie case that 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 Panel finds the second element of the Policy has been established.

C. Registered and Used in Bad Faith

The Panel finds that Respondent registered the Disputed Domain Name in bad faith. Respondent does not deny Complainant’s alleges that the Mark is “used extensively in the financial services sector in connection

with agency, trustee and fiduciary services,” which allegation is supported by facts published on

Complainant’s website and third-party awards.

The Panel finds, based on the balance of probabilities, that Respondent was aware of and targeted
Complainant and its rights when it registered the Disputed Domain Name.

Respondent’s selection of the “.agency” Top-Level Domain is additional evidence that Respondent was aware of and targeted Complainant, whose primary website is built on the <glas.agency> domain name. See WIPO Overview 3.0, section 3.2.1 (choice of Top-Level Domain may evidence bad faith: particularly where corresponding to the complainant’s area of business activity). Complainant also uses the

<glas.agency> domain for email communications. The Disputed Domain Name mimics Complainant's email structure and creates the risk that the Disputed Domain Name could be used for fraudulent email communications.

The Panel also finds that Respondent has used the Disputed Domain Name in bad faith. Panels have

found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of does not prevent a finding of bad faith under the Policy.

passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes
the distinctiveness and reputation of Complainant’s trademark, and the composition of the Disputed Domain
The Panel finds that Complainant has established the third element of the Policy.

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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 <gles.agency> be transferred to Complainant.

/Lawrence K. Nodine/
Lawrence K. Nodine
Sole Panelist
Date: August 19, 2025

renew the Disputed Domain Name. Accordingly, the Disputed Domain Name will expire June 20, 2026.

European Credit Awards 2023 (“Best Debt/Loan Administrator”); “2021 Financial Times Europe’s 1000 fastest growing companies”;
“The Sunday Times International Track 200” (ranked 50th).