MHG IP Holding (Singapore) Pte. LTD. v Sarang Thakre

WIPO Case No. D2025-2277

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

MHG IP Holding (Singapore) Pte. LTD. v. Sarang Thakre

Case No. D2025-2277

1. The Parties

The Complainant is MHG IP Holding (Singapore) Pte. LTD., Singapore, represented by Kochhar & Co.,

India.

The Respondent is Sarang Thakre, India.

2. The Domain Name and Registrar

The disputed domain name <anantarahotel.com> (the “Domain Name”) 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 June 11, 2025. On June 12, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On June 13, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Registration Private, Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 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 June 18, 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 June 20, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was July 10, 2025. The Respondent sent an informal email communication to the
Center on June 17, 2025.

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The Center appointed Mathias Lilleengen as the sole panelist in this matter on July 23, 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 to ensure compliance with the Rules, paragraph 7.

The Panel issued on August 11, 2025 a Procedural Order in which the Panel ordered the Respondent to provide evidence and explanation for the choice and timing of the name of its purported business, as well as evidence of its operations. The Respondent did not respond. The Complainant was in the same Procedural Order requested to submit further statements with supporting documents regarding the Respondent’s purported hotel operations and further information about the Complainant’s brand presence and business operations in India. The Complainant filed a reply to the Procedural Order.

4. Factual Background

The Complainant is a subsidiary of Minor International PCL which currently operates over 562 hotels, resorts
and serviced suites and over 2,699 restaurants and 267 retail trading points of sale, that the Complainant
has built and developed over the course of over 50 years of operation, in 66 countries across the Asia
Pacific, the Middle East, Europe, South America, Africa, and the Indian ocean. The Complainant’s chain of
ANANTARA hotels has received several prizes and accolades, e.g. at the World Spa Awards 2020.
ANANTARA resorts and spas attract tourist traffic from all around the world, with a worldwide revenue for

2023 of USD 815.5 million, and more than 40,000 Indian guests that same year.

The Complainant owns trademark registrations of the ANANTARA trademark in numerous countries, such as owns the domain name <anantara.com> and runs its main webpage from there.

The Complainant has an expanding presence in India, including Anantara Jewel Bagh Jaipur Hotel, the Complainant’s Indian subsidiary MHG Management (India) Private Limited, and digital presence through its global website at <anantara.com>. Since 2006, through Global Hotel Alliance Membership, ANANTARA has been featured in directories placed in Indian hotels such as The Leela Group, enhancing brand visibility among Indian guests.

The Domain Name was registered on December 4, 2024. The Domain Name resolves to a webpage that offers hotel services. The webpage uses trademarks and brands used by the Complainant’s business.

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 Domain Name. The Complainant documents registered trademark rights that predate the registration of the Domain Name. The Complainant argues that the trademark qualifies as a well-known trademark. The

Complainant argues that the Domain Name is identical to the Complainant’s trademark as the Domain
Name’s prominent part consists of the Complainant’s trademark.

The Complainant argues that there is no credible or legitimate reason for the Respondent to have chosen to adopt a domain name incorporating an identical term to that of the Complainant’s well-known brand, domain name and trademark. The Complainant finds it apparent that the Respondent has adopted the Domain

Name with the sole intention to usurp the goodwill and reputation associated with the Complainant and deceive unwary customers.

Finally, among other arguments, the Complainant submits that the Respondent’s conduct, adoption and use of an identical/deceptively similar disputed domain name offering identical services under the Complaint’s well-known brand amounts to bad faith.

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B. Respondent

The Respondent did not reply to the Complainant’s contentions but sent an informal email to the Center confirming he is the registrant of the Domain Name.

6. Discussion and Findings

A. Identical or Confusingly Similar

The first element functions primarily as a standing requirement. The 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 established rights in its trademark ANANTARA. The Domain Name incorporates the Complainant’s trademark in its entirety with “hotel” added. The addition of other terms, here “hotel”, does not prevent a finding of confusing similarity as the mark remains recognizable within the disputed domain name, see WIPO Overview 3.0, section 1.8. For the purposes of assessing confusing similarity under paragraph 4(a)(i) of the Policy, it is permissible for the Panel to ignore the generic Top-Level Domain (“gTLD”) as it is viewed as a standard registration requirement, see WIPO Overview 3.0, section 1.11.1.

The Panel finds that the Domain Name is confusingly similar to a trademark in which the Complainant has rights in accordance with paragraph 4(a)(i) 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. 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 Respondent is not affiliated with nor authorized by the Complainant. The Respondent has not filed any evidence suggesting that the Respondent has any rights or legitimate interests in the Domain Name. As the Panel may undertake limited factual research into matters of public record, see WIPO Overview 3.0, section 4.8, the Panel has made a search of the Respondent. It confirms that the Respondent likely operates a hotel

in India under the name “Hotel Anantara”. However, the Respondent has not offered the Panel an
explanation as to when and why the Respondent chose this name. Not even as a reply to the Panel’s direct
question in the Procedural Order. Therefore, based on the case file, the Panel cannot conclude that the
Respondent has bona fide rights in the Domain Name.

The Panel finds that the Complainant has made out a case showing that the Respondent has no rights or legitimate interests in the Domain Name. It has not been rebutted by the Respondent. Accordingly, the Panel finds that the Respondent has no rights or legitimate interests in respect of the Domain Name in accordance with paragraph 4(a)(ii) of the Policy.

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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.

The Complainant’s trademarks were registered before the registration of the Domain Name, including in
India where the Respondent is situated. The Complainant’s ANANTARA trademark is well-known. This, and
the composition of the Domain Name, suggest that the Respondent was or should have been aware of the

Complainant’s trademark when the Respondent registered the Domain Name.

possible that the Respondent did not have the Complainant in mind when the Respondent registered the Domain Name. However, noting the reputation and expansive operations of the Complaint, it appears more likely from the record before the Panel that the Respondent had the Complainant in his mind when he registered the Domian Name, and when the Respondent chose the name of the hotel. In the void of an explanation from the Respondent, it is not for the Panel to speculate in the Respondent’s motivation further than the evidence allows. The evidence of the case suggests that the Respondent had knowledge of the Complainant and its well-known trademark when the Respondent registered the Domain Name. The Respondent has not disputed the Complainant’s assertion that the Respondent has most likely registered the	On the other hand, as explained above, the Respondent appears to run a hotel named “Hotel Anantara”. It is of the Complainant, by creating a likelihood of confusion with the Complainant’s mark and through freeriding on the Complainant’s goodwill.
Even when invited to by the Procedural Order, the Respondent has not provided any evidence of non- infringing use or any reason for the choice of the Domain Name.
The Panel concludes that the Domain Name was registered and is being used in bad faith, within the meaning of paragraph 4(a)(iii) 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 the Domain Name <anantarahotel.com> transferred to the Complainant.
/Mathias Lilleengen/ Mathias Lilleengen Sole Panelist Date: August 21, 2025