Principal Financial Services, Inc. v Cong Truong
WIPO Case No. D2025-0648
•11-04-2025
| ARBITRATION AND MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
Principal Financial Services, Inc. v. Cong Truong
Case No. D2025-0648
1. The Parties
The Complainant is Principal Financial Services, Inc., United States of America (“United States”), represented by Neal & McDevitt, United States.
The Respondent is Cong Truong, Viet Nam.
2. The Domain Name and Registrar
The disputed domain name <principalfinancialgroupincp.shop> is registered with NameCheap, Inc. (the
“Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 19, to the Complainant on February 23, 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 February 24, 2025.
2025. On February 19, 2025, the Center transmitted by email to the Registrar a request for registrar
verification in connection with the disputed domain name. On the same day, 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 (Redacted for Privacy, Privacy service provided by
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 February 27, 2025. In accordance with the Rules, paragraph 5, the due date for Response was March 19, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 23, 2025.
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The Center appointed Deanna Wong Wai Man as the sole panelist in this matter on March 28, 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 publicly traded, multinational financial services company incorporated in the State of Iowa, United States, and headquartered in Des Moines, Iowa. The Complainant’s group offers global investment management, insurance, and other financial services to businesses and individuals, as described on its websites at “ and “ According to the Complainant’s website at “ the group employs some 19,000 people in 27 nations and territories and reported net income of USD 1.571 billion in 2024.
The Complainant owns an international portfolio of trademark registrations. These include, but are not
limited to, United States Trademark Registration Number 1562541 (registered on October 24, 1989) for the
word PRINCIPAL in stylized letters in International Class 36, and United States Trademark Registration
Number 4483644 (registered on February 18, 2014) for PRINCIPAL FINANCIAL GROUP in International
Class 36. The Complainant has a strong online presence and also owns a portfolio of domain name
registrations, including <principal.com>, <principalbank.com>, <principalfinancial.com>, and
<principalfinancialgroup.com>.
The disputed domain name was registered on September 28, 2024, and is therefore of a later date than the abovementioned registered trademarks owned by the Complainant. The disputed domain name is not linked to an active website. However, the Complainant provides evidence that the Respondent has configured MX (“Mail Exchange”) records for the disputed domain name.
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 its trademarks for PRINCIPAL FINANCIAL GROUP, since it incorporates these marks in their entirety, adding only the letters “inc” and “p”. The Complainant argues that its trademarks for PRINCIPAL FINANCIAL GROUP are well known and intensely used and refers to a number of prior decisions under the Policy recognizing such well- known status. The Complainant contends that the Respondent is not a licensee of the Complainant, nor is the Respondent otherwise entitled or authorized in any way to use the Complainant’s PRINCIPAL FINANCIAL GROUP mark for any purpose. The Complainant further states that it has not given the Respondent permission to use the mark and that the Respondent is not commonly known under the disputed domain name. Furthermore, the Complainant argues that the Respondent is holding the disputed domain name passively in bad faith. Additionally, the Complainant contends that the Respondent has configured MX records for the disputed domain name, enabling the Respondent to send and receive email with addresses that use the disputed domain name, creating a risk of phishing, fraud, or other deceptive practices designed to mislead consumers, business partners, or employees of the Complainant into believing that communications originating from the disputed domain name are legitimate. The Complainant essentially argues that in these circumstances, the Respondent has no rights or legitimate interests in the disputed domain name and the registration and use of the disputed domain name are made in bad faith.
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B. Respondent
The Respondent did not reply to the 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 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 rights in respect of a trademark or service mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.
WIPO Overview 3.0, section 1.8.
The entirety of the PRINCIPAL FINANCIAL GROUP mark is reproduced within the disputed domain name. assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy.
Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy.
Further, the Panel finds that the disputed domain name is also confusingly similar to the Complainant’s
PRINCIPAL mark as this mark is entirely incorporated in the disputed domain name.
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 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 Panel notes that the disputed domain name directs to an inactive or blank webpage. Under the circumstances of this case, the Panel finds that merely holding a domain name passively, without making any use of it, also does not confer any rights or legitimate interests in the disputed domain name on the Respondent (see in this regard earlier UDRP decisions such as Bollore SE v. 赵竹飞 (Zhao Zhu Fei), WIPO
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Case No. D2020-0691; and Vente-Privee.Com and Vente-Privee.com IP S.à.r.l. v. 崔郡 (jun cui), WIPO
Case No. D2021-1685).
Finally, the Panel also finds that the disputed domain name incorporates the Complainant’s well-known mark Complainant is a publicly traded company, although “incp” is not a standard abbreviation for “incorporated”, which is “Inc.”, Internet users may not notice the subtle difference between “incp” and “inc” and therefore may think that the disputed domain name is somewhat related to the Complainant.
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.
| similar to the Complainant’s well-known and intensely used PRINCIPAL and PRINCIPAL FINANCIAL | In the present case, the Panel notes that the Respondent has registered a domain name which is confusingly of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith”. Furthermore, the Panel also notes that the Complainant’s trademarks were registered many years before the registration date of the disputed domain name. The Panel deducts from these elements that the Respondent knew, or at least should have known, of the existence of the Complainant’s trademarks at the time of registering the disputed domain name. In the Panel’s view, these elements indicate bad faith on the part of the Respondent, and the Panel therefore finds that it has been demonstrated that the Respondent registered the disputed domain name in bad faith. |
| As to use of the disputed domain name in bad faith, 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. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the strong reputation of the Complainant’s trademark, the composition of the disputed domain name and the lack of a response from the Respondent and 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. | |
| Furthermore, the Panel has also reviewed the Complainant’s evidence containing the MX records for the disputed domain name, which indicate that the Respondent has connected the disputed domain name to email servers. The Panel finds that this creates a risk that the Respondent may be using the disputed | |
| domain name, which is confusingly similar to the Complainant’s well-known marks, for misrepresentations and/or phishing or spamming activities (see in this sense also previous UDRP decisions such as Carrefour v. WhoisGuard, Inc., WhoisGuard Protected / Robert Jurek, Katrin Kafut, Purchasing clerk, Starship Tapes & Records, WIPO Case No. D2017-2533). The preceding elements lead the Panel to conclude that the Respondent is using the disputed domain name in bad faith. | |
| The Panel therefore finds that it has been demonstrated that the Respondent has registered, and is using the disputed domain name in bad faith. | |
| The Panel finds 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 <principalfinancialgroupincp.shop> be transferred to the Complainant.
/Deanna Wong Wai Man/
Deanna Wong Wai Man
Sole Panelist
Date: April 11, 2025
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