Ipsos v Majed Almajed

WIPO Case No. D2025-2656

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

IPSOS v. Majed Almajed

Case No. D2025-2656

1. The Parties

The Complainant is IPSOS, France, represented by NOVAGRAAF FRANCE, France.

The Respondent is Majed Almajed, Saudi Arabia.

2. The Domain Name and Registrar

The disputed domain name <ipsos-sa.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 July 7, 2025. connection with the disputed domain name. On July 8, 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 (Unknown – Undisclosed) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 9, 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 9, 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 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 4, 2025. The Respondent did not submit a formal response. The Respondent sent an email communication to the Center on July 30, 2025. The Center sent a possible settlement email communication to the Parties on July 31, 2025. The Complainant did not request the suspension of the Proceedings.

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The Center appointed Mireille Buydens as the sole panelist in this matter on August 11, 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 company headquartered in France a company, which was founded in 1975 and is one of the largest companies in the surveys, market research and marketing fields, operating in 90 countries with more than 17.000 employees. The Complainant had a turnover of more than 2,440 million Euros in 2023

and more than 5 000 clients all over the world.

The Complainant owns many registrations for the trademark IPSOS (“the IPSOS Trademark”), including:

- European Union trademark registration No. 005583621 for IPSOS (word mark), registered on

January 10, 2008;

- European Union trademark registration No. 018161418 for IPSOS (word and device mark), registered

on May 22, 2020;

- United States of America trademark registration No. 1747049 for IPSOS (word mark), registered on

January 19, 1993.

The Complainant also owns and operates a website under the domain name <ipsos.com> created on
May 27, 1998.

The disputed domain name was registered on May 19, 2025. According to the Complaint, the disputed domain name directs to a parking page containing a link to buy this domain at the price of 141.99 USD. At the date of this decision, the disputed domain name still resolves to a parking page with a “buy this domain name” button where the disputed domain name can be acquired for 90,99 USD.

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 is confusingly similar to the IPSOS Trademark, as it includes the word element “ipsos” identically, and only adds a hyphen followed by “sa”, which is the usual abbreviation in French for “Société Anonyme” (joint-stock company), the Complainant being itself a “SA” or Société Anonyme. The applicable generic Top-Level Domain (“gTLD”), in this case “.com”, may be disregarded for the purposes of assessment under the first element, as it is viewed as a standard registration requirement.

Second, the Complainant asserts that the Respondent lacks rights or legitimate interests in the disputed Complainant is present in more than 90 countries all around the world, has more than 17,000 employees and more than 5,000 clients. The Complainant also contends that the Respondent does not own trademark registrations containing the disputed domain name.

domain name. The Respondent is neither affiliated with the Complainant nor has it been authorized by the
Complainant to seek registration of any domain name incorporating its IPSOS Trademark. Furthermore, the

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Third, the Complainant asserts that the disputed domain name was registered and is being used in bad faith. that the Respondent has no interest in holding the disputed domain name. The Complainant also explains that the disputed domain name is proposed for sale at 141.99 USD. The Complainant further contends that MX servers are configurated, creating a risk for the Complainant’s activity. The Complainant also argues that the reproduction of the term “Ipsos”, which has no meaning, is distinctive, and enjoys a certain reputation, clearly demonstrates the Respondent’s bad faith.

B. Respondent

The Respondent did not file a formal response to the Complainant’s contentions.

On July 30, 2025, the Respondent wrote to the Center explaining that he was “working on a personal project”
and registered in this regard three domain names, including the disputed domain name. He explained that
he would agree to transfer the disputed domain name without any compensation or conditions. The Center
sent a possible settlement email communication to the Parties on July 31, 2025, but the Complainant did not

request the suspension of the Proceedings.

6. Discussion and Findings

Paragraph 4(a) of the Policy provides that the Complainant proves each of the following three elements in order to succeed in its Complaint:

(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 was registered and is being used in bad faith.

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 Complainants’ 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 Panel finds the entirety of the IPSOS Trademark is reproduced within the disputed domain name. The only difference between the IPSOS Trademark and the disputed domain name is the addition of the hyphen followed by the letters “sa”. Although the addition of these elements may bear on assessment of the second and third elements, the Panel finds the addition of such term does not prevent a finding of confusing

similarity between the disputed domain name and the IPSOS Trademark for the purposes of the Policy.
WIPO Overview 3.0, section 1.8.

Further, the generic Top-Level Domain “.com” is a standard registration requirement and does not prevent the disputed domain name from being confusingly similar to the IPSOS Trademark. WIPO Overview 3.0, section 1.11.1.

Accordingly, the disputed domain name is confusingly similar to the IPSOS Trademark for the purposes of the Policy.

The Panel finds the first element of the Policy has been established.

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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.

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.

The Respondent is not licensed by, nor affiliated with, the Complainant in any way. There is no evidence
that the Respondent is commonly known by the disputed domain name, nor is there any evidence of use or
demonstrable preparations to use the disputed domain name for a bona fide offering of goods or services.
There is no evidence of legitimate noncommercial or fair use of the disputed domain name, either. On the
contrary, the Panel notes that the disputed domain name reproduces the IPSOS Trademark (which is a
coined and fanciful term) in its entirety with the mere addition of a hyphen followed by the letters “sa”, which
are the French usual abbreviation for “société anonyme”, as translated above as joint-stock company, (the
Complainant, headquartered in France, being itself a “société anonyme”). As a result, the disputed domain
name carries a risk of implied affiliation, which cannot constitute fair use as it suggests sponsorship or
endorsement by the Complainant. On the contrary, the registration of the disputed domain name affirms the
Respondent’s intention of taking unfair advantage of the likelihood of confusion between the disputed
domain name and the Complainant’s IPSOS Trademark. This confirms that there is no use, nor preparations
to use, of the disputed domain name in connection with a bona fide offering of goods or services, and thus
no legitimate interest in the disputed domain name.

The Respondent does not contest, in his Response of July 30, 2025, that he is not a licensee of the Complainant, nor affiliated with the Complainant in any way, nor authorized in any way to register and use the disputed domain name. The Respondent simply asserts, without filing any evidence, that he registered the disputed domain name in the framework of a “personal project”. However based on the record, this does not confer rights or legitimate interests under the Policy.

The Panel finds 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.

Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy.

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Concerning the registration in bad faith, the Panel notes that the Respondent has composed the disputed
domain name by combining the Complainant’s well-known IPSOS Trademark with a hyphen followed by the
letters “sa”, which as explained above, is, the French abbreviation for the company type of the Complainant
headquartered in France. As a result, the disputed domain name, if ever put in use, would likely confuse
Internet users into believing that the Respondent is affiliated with, or endorsed by, the Complainant. The
registration of the disputed domain name creates a likelihood of confusion with the Complainant and its
IPSOS Trademark. It is also worth noting that the disputed domain name is highly similar to the main
domain name used by the Complainant <ipsos.com>. In the circumstances, the Panel can reasonably infer
that the Respondent registered the disputed domain name in the knowledge of the Complainant’s Trademark
and with the intention of taking unfair advantage of the goodwill attached to it by causing confusion among
Internet users. WIPO Overview 3.0 section 3.2.1.

The Panel also notes that a quick search for the term “ipsos” online would have revealed to the Respondent the existence of the Complainant and its IPSOS Trademark, which is well-known and used for decades. As a result, the Panel finds that the Respondent was more likely than not aware of the Complainant’s

Trademark at the time of the registration of the disputed domain name. WIPO Overview 3.0 section 3.2.2.

Panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. 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.

In this respect, the Panel notes the distinctiveness of the IPSOS Trademark (IPSOS is a coined term that is inherently distinctive and is well-known), the composition of the disputed domain name (which includes the IPSOS Trademark in its entirety with the mere addition of a hyphen followed by the letters “sa”) , the failure of the Respondent to submit a response (except a very brief email on July 30, 2025 in which the Respondent

does not challenge the Complainant’s arguments), and the implausibility of any good faith use to which the
disputed domain name may be put. The Panel finds that in the circumstances of this case, the passive

holding of the disputed domain name does not prevent a finding of bad faith under the Policy.

The Panel 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 <ipsos-sa.com> be transferred to the Complainant.

/Mireille Buydens/
Mireille Buydens
Sole Panelist
Date: August 22, 2025