Screening Eagle Technologies AG v Reema Walker, screenigeagle.com

WIPO Case No. D2025-1052

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Screening Eagle Technologies AG v. Reema Walker, screenigeagle.com

Case No. D2025-1052

1. The Parties

The Complainant is Screening Eagle Technologies AG, Switzerland, represented by Hepp Wenger Ryffel

AG, Switzerland.

The Respondent is Reema Walker, screenigeagle.com, United States of America (“United States”).

2. The Domain Name and Registrar

The disputed domain name <screenigeagle.com> (the “Disputed Domain Name”) is registered with Tucows

Domains Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on March 14, 2025.
On March 14, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the Disputed Domain Name. On March 14, 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 (Redacted for privacy) and contact information in the Complaint.
The Center sent an email communication to the Complainant on March 18, 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 March 19, 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 March 20, 2025. In accordance with the Rules, paragraph
5, the due date for Response was April 9, 2025. The Respondent did not submit any response. Accordingly,
the Center notified the Respondent’s default on April 11, 2025.

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The Center appointed Kar Liang Soh as the sole panelist in this matter on April 16, 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 Swiss company. It owns trademark registrations for the SCREENING EAGLE in various countries and regions, including:

Jurisdiction	Trademark No	Registration Date
International Trademark	1385881	August 11, 2017
International Trademark	1703894	September 6, 2022
Switzerland	705938	August 11, 2017
Switzerland	786239	September 6, 2022
Hong Kong, China	304171383	June 13, 2017
Hong Kong, China	306012044	July 15, 2022

International Trademark registration no. 1385881 has been granted protection in many jurisdictions including Kingdom, and United States. International Trademark registration no. 1703894 has similarly been granted protection in many jurisdictions including Australia, China, European Union, Russia Federation, Singapore, and United Kingdom.

The Complainant uses the SCREENING EAGLE trademark in relation to its products and services including apparatus for recording, transmission or reproduction of sound and images, sensors and software in infrastructure inspection and management, automotive, metal, telecommunication, scientific and technological services industries. The Complainant is the holder of the domain name <screeningeagle.com> registered on December 13, 2016.

The Respondent appears to be an individual. Very little is known about the Respondent beyond the details provided by the Registrar. The Respondent purported address is in Kansas City in the state of Montana of the United States .

The Disputed Domain Name was registered on December 18, 2024. On or before the date of the Complaint, the Disputed Domain Name resolved to a webpage displaying a file system directory containing a single root folder. At the time of this Decision, the Disputed Domain Name no longer resolves to a valid webpage.

On March 6, 2025, the Complainant’s customer received an email sent from an email address under the
Disputed Domain Name with the following content:

“[…] Reattaching the order conformation with bank details as earlier informed. Please ignore the bank details on the proforma as the invoice system is yet to be updated, Proceed to pay to our […]. Please acknowledge this mail at your earliest […]”.

The email content was signed off under Proceq SA as “A Screening Eagle Technologies Company,” and cited the website under the <screeningeagle.com> domain name.

The Complainant appears to be related to Proceq AG which owns International Trademark registration no.
618696 (registered on May 9, 1994) for the PROCEQ trademark. The International registration has been
granted protection in many jurisdictions including Australia, China, European Union, Japan, Singapore,
United Kingdom and United States.

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5. Parties’ Contentions

A. Complainant

The Complainant contends that:

a) The Disputed Domain Name is identical or confusingly similar to the Complainant’s SCREENING

EAGLE trademark. The Disputed Domain Name entirely adopts the SCREENING EAGLE trademark but adapted it by leaving out a letter “n” in the word “screening” to form “screenig”. The difference is barely noticeable;

b) The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name. The

Complainant could not find any useful information online about the Respondent. The information provided by the Respondent for registration of the Disputed Domain Name is false and the Disputed Domain Name was used for dishonest phishing attack only. Such use for a fraudulent purpose cannot constitute a bona fide use of the Disputed Domain Name. The Complainant could not find the Respondent having used or made demonstrable preparations to use the Disputed Domain Name in connection with a bona fide offering of goods or services; and

c) The Disputed Domain Name was registered and is being used in bad faith. The phishing email sent to

payment from the Complainant’s customer. The Disputed Domain Name was registered shortly before the
phishing attack and the registration of the Disputed Domain Name was for the sole purpose of the phishing
attack. The Disputed Domain Name is an abusive registration, having been used for phishing with the
wrongful use of others’ trademarks. The information used by the Respondent to register the Disputed

the Complainant’s customer on March 6, 2025, was for the purpose of dishonest activity, namely, to redirect not resolve to an existing address in Kansas City according to Google Maps. The Respondent masked its identity with an obviously wrong address.

B. Respondent

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

6. Discussion and Findings

The Complainant must establish that the following three elements of paragraph 4(a) of the Policy are present on the facts:

a) The Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the complainant has rights;

b)	The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and
c)	The Disputed Domain Name has been registered and is being used in bad faith.

A. Identical or Confusingly Similar

The Panel accepts that the Complainant has rights in the SCREENING EAGLE trademark based on the identified trademark registrations. According to the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), paragraph 1.7, the threshold test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s

trademark and the Disputed Domain Name. Despite the typographical absence of a letter “n” in the Disputed
Domain Name in comparison to the SCREENING EAGLE trademark, the Panel finds that the SCREENING
EAGLE trademark remains readily recognizable in the Disputed Domain Name. The present circumstances

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is a classic situation of “typosquatting” (see WIPO Overview 3.0 paragraph 1.9). The Panel has no hesitation
in holding that the Disputed Domain Name is confusingly similar to the Complainant’s SCREENING EAGLE

trademark. The first element of paragraph 4(a) of the Policy is therefore established.

B. Rights or Legitimate Interests

Although the Complainant has the overall burden of proof in UDRP proceedings, UDRP panels have found where a complainant makes out a prima facie case that a respondent lacks rights or legitimate interests, the burden of production shifts to the respondent to demonstrate its rights or legitimate interests (see

WIPO Overview 3.0, paragraph 2.1). The Panel is able to readily infer from the Complaint that the Complainant has no prior knowledge or relationship with the Respondent. The Complainant has asserted unequivocally that the Complainant could not find any useful information online about the Respondent. The Panel is persuaded by the evidence that the Disputed Domain Name was used in a phishing attack against the Complainant’s customer. The Complainant clearly did not agree with or condone the use of the Disputed Domain Name for a phishing attack against the Complainant’s customer. Therefore, the Panel is of the view that the Complainant has made out a prima facie case that the Respondent does not have any rights or legitimate interests in the Disputed Domain Name.

The Panel agrees with the view of past panels that the use of a domain name for a phishing attack can never confer rights or legitimate interests on a respondent (see WIPO Overview 3.0, paragraph 2.13.1). Further, there is an abject absence of evidence to even remotely suggest that the Respondent could have any right or legitimate interest in the Disputed Domain Name by having used or made preparations to use the Disputed Domain Name for a bona fide purpose. The Panel accordingly holds that the Complainant’s prima facie case has not been rebutted that the second element of paragraph 4(a) of the Policy is established.

C. Registered and Used in Bad Faith

Paragraph 4(b) of the Policy outlines non-exhaustive circumstances that amounts to the registration and use of a domain name in bad faith. Paragraph 4(b)(iv) of the Policy provides one such circumstance as follows:

“by using the domain, [the respondent has] intentionally attempted to attract, for commercial gain, Internet
users to [the respondent’s] website or other online source, by creating a likelihood of confusion with the
complainant’s mark as to the source, sponsorship, affiliation, or endorsement of [the respondent’s] website or

location or of a product or service on [the respondent’s] website or location.”

The Respondent has clearly used the Disputed Domain Name to attract commercial gain by deploying the EAGLE trademark as to the source, sponsorship, affiliation, or endorsement of the email’s source and legitimacy. The Panel is satisfied that the circumstances fall squarely within the instance of bad faith registration and use outlined by paragraph 4(b)(iv) of the Policy.

phishing attack on the Complainant’s customer with a clear intention to reroute payment from the
Complainant’s customer. The email sign-off in the phishing email which spelt the SCREENING EAGLE
trademark correctly multiple times removes any doubt that the Respondent could have been unaware of the
Complainant or the SCREENING EAGLE trademark. The Respondent was obviously using the Disputed

UDRP panels have often held that the use of a domain name for a phishing attack per se constitutes bad faith (see WIPO Overview 3.0, paragraph 3.4). The Panel does not see any reason to depart from the consensus of UDRP panels especially in the present case. The abuse of the Disputed Domain Name by the Respondent as a weapon of fraudulent phishing against the Complainant’s customer is in the Panel’s view one of extreme bad faith that should not be permitted to persist.

Further, the Panel is also persuaded on the facts that the Respondent has used a fictitious address to register the Disputed Domain Name in furtherance of its fraudulent phishing attack on the Complainant’s customer. This further corroborates the Panel’s finding of bad faith registration and use of the Disputed Domain Name (see Nintendo of America Inc. v Berric Lipson, WIPO Case No. D2000-1121).

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The Panel holds that the third element of paragraph 4(a) of the Policy is established.

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 <screenigeagle.com> be transferred to the Complainant.

/Kar Liang Soh/
Kar Liang Soh
Sole Panelist
Date: May 9, 2025