Jindal Steel and Power Limited v Jindal Getway

WIPO Case No. D2025-2838

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Jindal Steel and Power Limited v. Jindal Getway

Case No. D2025-2838

1. The Parties

The Complainant is Jindal Steel and Power Limited, India, represented by Sarad Kumar Sunny, India.

The Respondent is Jindal Getway, Canada

2. The Domain Name and Registrar

The disputed domain name <jsplgroup.com> is registered with Ascio Technologies, Inc. Danmark - Filial af

Ascio technologies, Inc. USA (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on July 17, 2025. On July 17, 2025, the Center transmitted by email to the Registrar a request for registrar verif ication in connection with the disputed domain name. On July 18, 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 (“Redacted/Masked in WHOIS detail”) and contact information in the Complaint. The Center sent an email communication to the Complainant on July 21, 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 July 22, 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 23, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 12, 2025. The Respondent did not submit any response.

Accordingly, the Center notif ied the Respondent’s default on August 13, 2025.

The Center appointed William F. Hamilton as the sole panelist in this matter on August 19, 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

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4. Factual Background

The Complainant is a globally recognized company that manufactures steel products, including sponge iron, ferro alloys, and hot-rolled and cold-rolled steel products. It is the third-largest steel producer in India. Since at least 1998, the Complainant has consistently used the trademark JSPL (the “Mark”), an abbreviation of its name. This use has been continuous across its various projects, goods, services, buildings, and on its principal website, “ The Complainant has extensively used the Mark in advertising through various media, such as newspapers, magazines, and sponsored events. It has received numerous industry awards and recognitions. Its Indian sales and distribution network includes 50 distributors, 3793 dealers, and 200 sales teams across 23 Indian states. Indian government agencies refer to the company as JSPL. In sum, the Complainant is widely recognized by the Mark and has built a strong reputation in the steel manufacturing industry.

The Complainant owns Indian trademark registrations that incorporate the Mark, including:

- Registration No. 2563581 for JSPL PANTHER, registered on July 12, 2013,

- Registration No. 2563583 for JSPL TMT, registered on July 12, 2013, and

- Registration No. 2731001 for JSPL QUICKBUILD, registered on May 5, 2014.

These registrations remain valid and subsisting and confirm the Complainant’s statutory rights in the marks.

The disputed domain name was registered on October 14, 2024, and directs to a website that prominently displays the Mark and falsely impersonates the Complainant. The Respondent’s website falsely claims to of fer employment opportunities with the Complainant that require an application fee. Additionally, the Respondent promotes its fraudulent employment scam by sending emails that falsely appear to come f rom the Complainant and use the Mark to targeted audiences, including students seeking employment.

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.

The Complainant asserts that the disputed domain name is confusingly similar to the Mark because the Mark is fully incorporated into the disputed domain name. The Complainant claims that the Respondent has no rights or legitimate interests regarding the disputed domain name, as the Complainant did not authorize the Respondent to use the Mark or the disputed domain name. The Complainant also states that the

Respondent cannot not have any legitimate right, title or interest in the trademark JSPL, nor is it bona f ide of fering goods or services or engaging in legitimate or fair use of the disputed domain name. Additionally, the Complainant contends that the disputed domain name has been f raudulently used to attract

unsuspecting Internet users seeking employment with the Complainant to the Respondent’s website, where they are tricked into paying a bogus employment application fee when no such employment exists or is of fered.

B. Respondent

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

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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 of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0“), section 1.7. The Complainant has shown both unregistered and registered rights in respect to the Mark for the purposes of the Policy. WIPO

Overview 3.0, section 1.2.1.

The entire mark JSPL is included, and the dominant portion of the Complainant’s registered trademarks is recognizable within the disputed domain name. Therefore, 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 the term “group” may influence the assessment of the second and third elements, the Panel f inds that adding such a 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.

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.

Additionally, Panels have held that using a domain name for illegal activities, such as impersonation and falsely soliciting employment opportunities and phishing, can never grant rights or legitimate interests to a respondent. WIPO Overview 3.0, section 2.13.1.

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 utilized the disputed domain name to trick Internet users to pay money and provide personal information by falsely impersonating the Complainant as of fering employment opportunities.

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Panels have held that using a domain name for illegal activities, such as f raudulently impersonating the Complainant to trick people into paying employment application fees and providing personal identif ication information, amounts to bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel f inds that the Respondent’s registration and use of the disputed domain name constitute bad faith under the Policy.

The Panel notes that the Complainant has felt compelled to place a public disclaimer on its genuine website at “ warning job seekers of fraudulent employment offers falsely made in its name and clarifying that it never charges application fees. The Complainant has also received direct inquiries from job seekers attempting to verify such offers. These facts provide concrete evidence of actual confusion and conf irm that the Respondent’s use of the disputed domain name is calculated to deceive the public.

Panels have long held that the use of a domain name to impersonate a complainant for fraudulent purposes constitutes bad faith. The Respondent’s conduct here is of a similar nature.

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 <jsplgroup.com> be transferred to the Complainant.

/William F. Hamilton/
William F. Hamilton
Sole Panelist
Date: September 2, 2025