Haleon UK IP Limited v Flex Chen

WIPO Case No. D2025-2531

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Haleon UK IP Limited v. Flex Chen

Case No. D2025-2531

1. The Parties

The Complainant is Haleon UK IP Limited, United Kingdom, represented by SafeNames Ltd., United

Kingdom.

The Respondent is Flex Chen, India.

2. The Domain Name and Registrar

The disputed domain name <haleonhk.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 June 27, 2025. On June 30, 2025, the Center transmitted by email to the Registrar a request for registrar verif ication in connection with the disputed domain name. On July 1, 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 (Domain Admin Privacy Protect, LLC, (PrivacyProtect.org)) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 1, 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 2, 2025.

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 July 3, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 23, 2025. The Respondent did not submit any response.

Accordingly, the Center notif ied the Respondent’s default on July 24, 2025.

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The Center appointed Daniel Peña as the sole panelist in this matter on July 29, 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 in this administrative proceeding, Haleon UK IP Limited, formerly GlaxoSmithKline
Consumer Healthcare (UK) IP Limited, is a British multinational consumer healthcare company established in
July 2022 as a corporate spin-of f f rom GSK plc.

The Complainant is one of the world’s largest consumer healthcare companies. The Complainant reported revenues of GBP 11.3 billion in 2023, and its products are available to individuals in more than 100 countries, covering both developed and emerging markets.

The Complainant has more than 25,000 employees. GSK plc publicly announced the launch of the Complainant, under the “Haleon” name, on February 22, 2022. The completion of the demerger and listing of the Complainant’s shares on the London Stock Exchange took place in July 2022. Worldwide media thoroughly covered the announcement of the HALEON brand on its launch date, including internationally renowned publications.

The Complainant has a number of registrations for the HALEON trademark around the world. The

Complainant is, inter alia, the owner of the following:

- United Kingdom trademark registration number UK00003726732 for the HALEON (word) trademark
registered on March 11, 2022, covering goods and services in classes 3, 5, 9, 10, 21, 29, 30, 32, 35, 36, 41,
42, and 44;

- International trademark registration number 1674572 for the HALEON (word) trademark registered on November 29, 2021, covering goods and services in classes 3, 5, 9, 10, 21, 29, 30, 32, 35, 36, 41, 42, and 44;

- United Arab Emirates trademark registration number 365656 for the HALEON (word) trademark registered

on March 16, 2022, covering services in class 41.

The Complainant also has a brand presence online and operates f rom its primary website at

“

The disputed domain name was registered on April 8, 2025.	The disputed domain name currently resolves
to an inactive parking site.
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 cites its trademark registrations in numerous countries for the mark HALEON, as prima facie evidence of ownership.

The Complainant submits that its rights in the trademark HALEON predate the Respondent’s registration of the disputed domain name.

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It submits that the disputed domain name is confusingly similar to its trademark, because the disputed domain name is comprised of the HALEON trademark and that the addition of the geographical term “hk” is not suf f icient to avoid the confusing similarity to its trademark.

The Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name and that “there is no evidence showing that the Respondent has been using, or preparing to use, the disputed domain dame in connection with a bona fide offering of goods and services since its registration” and claims, in summary, that none of the circumstances set out in paragraph 4(c) of the Policy apply.

The Complainant submits that the passive holding of the disputed domain name would not prevent a f inding of bad faith.

B. Respondent

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

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 HALEON on the basis of its multiple trademark registrations. The Panel f inds that the Complainant has shown rights in respect of the trademarks for the purposes of the Policy (see WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.2.1).

The Panel f inds that the disputed domain name is confusingly similar to the Complainant’s HALEON marks. The Respondent’s incorporation of the Complainant’s mark in full in the disputed domain name is evidence that the disputed domain name is confusingly similar to the Complainant’s marks. WIPO Overview 3.0, section 1.7.

Although the addition of other term here, “hk” may bear on assessment of the second and third elements, the Panel f inds the addition of such 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.

Furthermore, the generic Top-Level Domain “(gTLD”) “.com” is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. WIPO Overview 3.0, section 1.11.1. The Panel is satisfied that the disputed domain name is confusingly similar to the Complainant’s mark and the Complainant has satisf ied the f irst requirement of the Policy.

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

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legitimate interests in a domain name may result in the dif f icult 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 satisf ied the second element. WIPO Overview 3.0, section 2.1.

The Panel f inds 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 composition of the disputed domain name carries a risk of implied af f iliation with the Complainant.
WIPO Overview 3.0, section 2.5.1. Based on the information submitted by the Complainant, the
Complainant has not granted the Respondent authorization to use the disputed domain name. Moreover,
there is no evidence indicating that the Respondent is commonly known by the disputed domain name.
Finally, the Respondent did not file a Response to the Complaint. The Panel may draw f rom the lack of a

Response the inferences that it considers appropriate, according to the Rules, paragraph 14(b).

The Panel f inds 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 disputed domain name reproduces the Complainant’s mark

HALEON in its entirety. Therefore, the Panel f inds it likely that the Respondent was aware of the

Complainant’s mark at the time of registration of the disputed domain name. On this subject, section 3.1.4

of the WIPO Overview 3.0 provides: “Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar […] to a famous or widely-known trademark by an unaf f iliated entity can by itself create a presumption of bad faith.” The Panel therefore holds that the disputed domain name was registered in bad faith.

As to the requirement of use in bad faith, the Panel notes that the Complainant considers the matter to be a case of passive holding, i.e. a case where the disputed domain name was not connected to an active website. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) would not prevent a finding of bad faith under the doctrine of passive holding. Although panelists will look at the totality of the circumstances in each case, factors that have been considered relevant in applying the passive holding doctrine include: (i) the degree of distinctiveness or reputation of the complainant’s mark, (ii) the failure of the respondent to submit a response or to provide any evidence of actual or contemplated good-faith use, (iii) the respondent’s concealing its identity or use of false contact details (noted to be in breach of its registration agreement), and (iv) the implausibility of any good faith use to which the domain name may be put. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes that the Complainant has provided evidence regarding the reputation of its trademark. The

Respondent did not f ile a Response to the Complaint. Considering the degree of distinctiveness or reputation of the Complainant’s trademark, the composition of the disputed domain name, the Panel f inds the non-use of the disputed domain name does not prevent a f inding of bad faith in the circumstances of this proceeding.

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

/Daniel Peña/ Daniel Peña Sole Panelist Date: August 12, 2025