Sanofi v Christine Leonardich

WIPO Case No. D2025-2113

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Sanofi v. Christine Leonardich

Case No. D2025-2113

1. The Parties

The Complainant is Sanofi, France, represented by Selarl Marchais & Associés, France.

The Respondent is Christine Leonardich, United States of America.

2. The Domain Name and Registrar

The disputed domain name <sanofineuroscience.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 May 28, 2025. connection with the disputed domain name. On May 30, 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 (Registration Private, Domains By Proxy, LLC, DomainsByProxy.com) and contact information in the Complaint. The Center sent an email communication to the Complainant on June 2, 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 amendment to the Complaint on June 2, 2025.

The Center verified that the Complaint together with the amendment to the 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 4, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was June 24, 2025. The Respondent did not submit any response.
Accordingly, the Center notified the Respondent’s default on June 25, 2025.

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The Center appointed Zineb Naciri Bennani as the sole panelist in this matter on July 1, 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.

After the Panel appointment, the Respondent sent emails from a different email address than the one disclosed the Registrar claiming that they have never used or tried to use the disputed domain name and that they have no idea about <sanofineuroscience.com>. However, some emails were an answer from the Center’s communications.

4. Factual Background

The Complainant is a French multinational pharmaceutical company operating in development, manufacturing, distribution and selling of a wide variety of pharmaceutical products and vaccines.

The Complainant shows consolidated sales of EUR 43 billion in 2022 and presence in more than 100 countries, employing around 100,000 people.

The Complainant holds rights in trademark registrations for the SANOFI mark in many jurisdictions around the world since 1988, among which:

- French Trademark registration No 3831592 (figurative) registered on December 9, 2011 for various goods

and services including pharmaceutical products;

- French Trademark registration No 96655339 registered on December 11, 1996 for various goods and

services including pharmaceutical products;

- European Union Trademark Registration No 010167351 registered on January 7, 2012 for various goods

including pharmaceutical products;

- International Trademark Registration No 1091805 registered on August 18, 2011 for various goods and
services including pharmaceutical products designating multiple jurisdictions.

The Complainant is also the owner of multiple domain names all of them registered prior to the disputed domain name, including the following:

- <sanofi.com> registered on October 13, 1995;

- <sanofi.eu> registered on March 12, 2006; and

- <sanofi.fr> registered on October 10, 2006.

The disputed domain name was registered on May 26, 2025 and directs to a parked page with an option to buy the disputed domain name.

The Respondent is an individual that claimed that she has no idea about 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.

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Notably, the Complainant contends that it owns and uses trademarks and domain names in connection with its activity containing the distinctive word “SANOFI” which are prior to the registration of the disputed domain name.

According to the Complainant the disputed domain name reproduces SANOFI trademarks that do not have any particular meaning and are therefore highly distinctive.

The Complainant contends that the use of SANOFI trademark makes the disputed domain name confusingly similar to the trademarks regardless the addition of the descriptive term “neuroscience” or the generic Top- Level Domain (“gTLD”) “.com”.

The Complainant asserts that this confusing similarity will merely suggest to Internet users that the disputed domain name leads to a website that gives information on or sells SANOFI’s activities in the field of neuroscience, especially, considering that the Complainant’s trademarks are well-known in many jurisdictions.

The Complainant asserts that the Respondent has neither prior rights nor legitimate interests to justify the use of the already well-known and worldwide trademarks and domain names of the Complainant.

The Complainant has never authorized the Respondent to use its trademarks or register any domain name including the trademarks and the Respondent is not making any legitimate noncommercial or fair use of the domain name, especially that the disputed domain name website is used as a bait and switch.

The disputed domain name is leading to a parking website and has been registered only for the purpose unfairly attracting Complainant’s consumers and misleadingly diverting consumers into thinking that the Respondent is, in some way or another, connected to, sponsored by or affiliated with the Complainant and its business, or that the Respondent’s activities are approved or endorsed by the Complainant.

The Complainant considers that given the famous and distinctive nature of its trademarks, the Respondent is likely to have had knowledge of the existence of the Complainant’s marks and registered the disputed domain name as an act of bad faith.

Moreover, the name of the Respondent was registered as “Registration private” that has no resemblance with the word “SANOFI”. Passive holding falls within the concept of the domain name being used in bad faith.

The Complainant asserts that the disputed domain name is leading to a parking website and has been registered only for the purpose unfairly attracting Complainant’s consumers.

B. Respondent

Before the Panel appointment, the Respondent did not reply to the Complainant’s contentions.

After the Panel appointment, the Respondent filed a respond declaring that they have never used or tried to use the disputed domain name and that they have no idea about <sanofineuroscience.com>.

On July 5, 2025, the Respondent sent: “While I did inquire as to the ownership of sanofineuroscience.com, I have never made an attempt to procure or use this domain.”

6. Discussion and Findings

The Panel should decide a complaint based on the statements and documents submitted and in accordance with the Policy and Rules, and any rules and principles of law that it deems applicable.

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Paragraph 4(a) of the Policy directs that the Complainant must establish each of the following:

(i) that the disputed domain name is identical or confusingly similar to a trademark or service mark in which

the Complainant has rights; and

(ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain name; and

(iii) that the disputed domain name has been 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 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.

The entirety of the SANOFI mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

In cases where a domain name incorporates the entirety of a trademark, the disputed domain name will
normally be considered confusingly similar to that mark for purposes of UDRP standing. Rockwool
International A/S v. usrockwool.com / US Rockwool LLC, formerly US Fireproofing LLC, WIPO Case No.
D2013-1022, <usrockwool.com>.

Although the addition of other terms here, “neuroscience” 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 mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8.

Furthermore, the addition of a gTLD in a domain name is viewed as a standard registration requirement and is disregarded under the confusing similarity test.

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

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demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the
Policy or otherwise.

The Panel notes that there is no evidence use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services.

The Respondent, as an individual, is not commonly known by the domain name and is not making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

Therefore, the Respondent lacks rights or legitimate interests in the disputed domain name and did not show a use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering or legitimate noncommercial or fair use.

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.

In the present case, the Panel notes that the Respondent registered the disputed domain name reproducing the Complainant’s distinctive and internationally reputed trademark with the addition the term “neuroscience”, which is associated with one of the Complainant’s areas of commercial activity. This addition may give Internet users the impression that the disputed domain name is connected to the Complainant’s trademark (The American Automobile Association, Inc. v. Cameron Jackson / PrivacyDotLink Customer 2440314, WIPO Case No. D2016-1671).

Noting the Complainant’s presence in the neurology field, its reputation and goodwill, it is more likely than not that the Respondent knew the Complainant’s rights in the mark when registering the disputed domain name (Compagnie Générale des Etablissements Michelin v. Cameron Jackson, WIPO Case No. D2016-2392).

Therefore, the Panel considers that the Respondent has likely registered the disputed domain name that they have no idea about <sanofineuroscience.com>.

primarily for the purpose of selling, renting, or otherwise transferring the disputed domain name to the
Complainant who is the owner of the trademark or service mark or to a competitor of the Complainant.

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 <sanofineuroscience.com> be cancelled.

/Zineb Naciri Bennani/
Zineb Naciri Bennani
Sole Panelist
Date: July 11, 2025