Saudi Arabian Oil Co. v Muhammad Shoaib, XMart Solutions Limited

WIPO Case No. D2025-3483

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Saudi Arabian Oil Co. v. Muhammad Shoaib, XMart Solutions Limited

Case No. D2025-3483

1. The Parties

The Complainant is Saudi Arabian Oil Co., Saudi Arabia, represented by Fish & Richardson P.C., United

States of America (“United States”).

The Respondent is Muhammad Shoaib, XMart Solutions Limited, United Kingdom.

2. The Domain Name and Registrar

The disputed domain name <aramcooilandgassaudi.com> is registered with GMO Internet Group, Inc. d/b/a

Onamae.com (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 27, 2025.
On August 28, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On August 29, 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 (Whois Privacy Protection Service by onamae.com) and contact
information in the Complaint. The Center sent an email communication to the Complainant on August 29,
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

August 30, 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 September 2, 2025. In accordance with the Rules, paragraph 5, the due date for Response was September 22, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on September 30, 2025.

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The Center appointed Peter Burgstaller as the sole panelist in this matter on October 6, 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 was founded in 1933 and is one of the largest oil companies worldwide; it maintains operations in the United States and internationally, with subsidiaries and affiliates in various countries around the world (Annex 7 to the Complaint).

The Complainant owns several trademark registrations in various jurisdictions around the world consisting of the mark ARAMCO, inter alia;

- European Union trademark registration, Reg. No. 012676045, registered on August 15, 2014;

- United States trademark registrations, Reg. No. 7,555,405, registered on November 5, 2024 and Reg. No. 7,029,421, registered on April 18, 2023; and

- United Kingdom trademark registration (figurative), Reg. No. UK00003982026, registered on February 23, 2024 (Annex 4 to the Complaint).

Under its principal business website, available under the domain name <aramco.com>, the Complainant provides information about its business (Annex 7 to the Complaint); the domain name <aramco.com> was registered on January 27, 1994 (Annex 6 to the Complaint).

The Complainant’s former name was “Arabian American Oil Company”; ARAMCO is an acronym for this former name (Annex 5 to the Complaint).

The disputed domain name was registered on June 2, 2025 (Annex 1 to the Complaint); at the time of filing of the Complaint, the disputed domain name resolved to a website presenting the Respondent as “Aramco Oil and Gas Saudi Arabia” (Annex 8 to the Complaint) and offering the same services as the Complainant.

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 it owns several trademark registrations containing the famous and globally well-known mark ARAMCO. The disputed domain name contains this trademark in its entirety, simply adding the descriptive terms “oil”, “and”, “gas” and “saudi”. Hence, the Complainant notes that the disputed domain name is confusingly similar to the Complainant’s ARAMCO mark since the inclusion of descriptive terms as well as the generic Top-Level Domain (“gTLD”) “.com” does not prevent a finding of confusing similarity between a domain name and a protected trademark.

Further, the Complainant asserts, that it has never licensed or in any way authorized the Respondent to register or use the ARAMCO trademark in any manner; moreover, the disputed domain name resolves to a website purporting to be “Aramco Oil and Gas Saudi Arabia”, repeatedly displaying the Complainant’s famous ARAMCO mark, listing the Complainant’s address, falsely claiming to be a “trusted partner of Saudi Aramco”, and claiming to offer identical services to the Complainant.

This impersonation of the Complainant does not constitute a bona fide offering of goods or services, nor a legitimate noncommercial or fair use and therefore does not create any rights or legitimate interests in the disputed domain name for the Respondent.

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The Complainant also notes that the disputed domain name was registered decades after the Complainant had established rights in the mark ARAMCO and especially because of the fame of the mark ARAMCO the Respondent was aware of the Complainant and its rights in the ARAMCO mark when registering the

disputed domain name.

Given that the disputed domain is being used to impersonate the Complainant, it is clear that the domain name was only chosen to exploit the popularity of the ARAMCO trademark which constitutes bad faith use.

Finally, the Respondent has been engaged in a pattern of such bad faith practices which also constitutes evidence of the Respondent’s bad faith.

B. Respondent

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

6. Discussion and Findings

According to paragraph 4(a) of the Policy, the Complainant must prove that:

(i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and

(ii)       the Respondent has no rights or legitimate interests with respect to the disputed domain name; and

(iii)      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.

Based on the available record, the Panel finds the Complainant has shown rights in respect of the mark

ARAMCO for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.

In the present case, the disputed domain name is confusingly similar to the ARAMCO mark in which the
Complainant has rights since it incorporates the entirety of the mark ARAMCO and only adds the terms “oil”,
“and”, “gas”, and “saudi”.

It has long been established under UDRP decisions that where the relevant trademark is recognizable within the disputed domain name, the mere addition of other terms does not prevent a finding of confusing similarity under the first element of the Policy. This is the case at present. WIPO Overview 3.0, section 1.8.

Finally, it has also long been held that gTLDs (in this case “.com”) are generally disregarded when evaluating the confusing similarity of a disputed domain name. WIPO Overview 3.0, section 1.11.1.

Based on the available record, 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 the disputed domain name.

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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. WIPO Overview 3.0, section 2.1.

Having reviewed the 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, since it has never assigned, granted, licensed, sold, transferred, or in any way authorized the Respondent to register the disputed domain

name or use its trademark in any manner.

The Respondent is also not commonly known under the disputed domain name and the disputed domain name is not being used for a bona fide offering of goods or services; rather, the composition of the disputed domain name, comprising the Complainant’s mark ARAMCO together with the terms “oil”, “gas” and “saudi” directly refers to the Complainant’s business and primary location, and it appears most likely that the disputed domain name was specifically chosen to falsely suggest an affiliation with the Complainant.

Such conduct does not give rise to rights or legitimate interests.

Finally, the Respondent did not provide any evidence showing its rights or legitimate interests in the disputed domain name – it did not file a Response and has therefore not rebutted the Complainant’s contentions.

Based on the available records, the Panel finds the second element of the Policy has been established.

C. Registered and Used in Bad Faith

Robert Ellenbogen v. Mike Pearson

As stated in many decisions rendered under the Policy (e.g., , WIPO consequently, the Complainant must show that:

- the disputed domain name is registered by the Respondent in bad faith, and

- the disputed domain name is being used by the Respondent in bad faith.

(i) The Complainant has established rights in the distinctive mark ARAMCO many years before the business website.

registration of the disputed domain name, the ARAMCO mark is well known globally. Furthermore, the

Because of the distinctiveness and fame of the ARAMCO mark, it is inconceivable for this Panel that the Respondent has registered the disputed domain name without knowledge of the Complainant’s rights. This conclusion is supported by the fact that the ARAMCO mark was repeatedly used on the website at the disputed domain name.

Furthermore, panels have consistently found that the mere registration of a domain name that is identical or confusingly similar to a well-known trademark by an unaffiliated entity (as it is in the present case) can by itself create a presumption of bad faith. WIPO Overview 3.0, section 3.1.4.

Based on the available record, there is no doubt for this Panel, that the Respondent must have been aware of the ARAMCO mark and the Complainant when registering the disputed domain name; hence, the disputed domain name was registered in bad faith by the Respondent.

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(ii) The Complainant has put forward evidence that the disputed domain name was used by the Respondent prior to filing of the Complaint to resolve to a website presenting itself as “Aramco Oil and Gas Saudi Arabia”, listing the Complainant’s headquarters address and offering the same services as the Complainant itself.

The website under the disputed domain name falsely suggests an affiliation with the Complainant; this is likely to disrupt the Complainant’s business and shows that the Respondent intentionally attempts to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant’s mark, which constitutes bad faith use.

The evidence and documents produced and put forward by the Complainant together with the fact that the Respondent has failed to file a Response and therefore failed to present any evidence of any good faith registration and use with regard to the disputed domain name clearly prove that the disputed domain name was registered and is used by the Respondent in bad faith under paragraph 4(a)(iii) of the Policy.

Based on the available record, 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 <aramcooilandgassaudi.com> be transferred to the Complainant.

/Peter Burgstaller/
Peter Burgstaller
Sole Panelist
Date: October 16, 2025