Scribd, Inc. v Abdullah Khan

WIPO Case No. D2025-3299

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Scribd, Inc. v. Abdullah Khan

Case No. D2025-3299

1. The Parties

The Complainant is Scribd, Inc., United States of America (“US”), represented by IPLA, LLP, US.

The Respondent is Abdullah Khan, Pakistan.

2. The Domain Name and Registrar

The disputed domain name <slidessharedownloader.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 August 15, 2025. connection with the disputed domain name. On August 18, 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 (Domains By Proxy, LLC) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 1, 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 September 5, 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 paragraph 5, the due date for Response was September 28, 2025. The Respondent sent an email communication to the Center on September 8, 2025. Accordingly, the Center notified the Parties of the Commencement of Panel Appointment Process on September 29, 2025.

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The Center appointed Rebecca Slater as the sole panelist in this matter on October 3, 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 US corporation headquartered in Delaware. The Complainant provides a hosting service for professional content via its official website at the <slideshare.net> domain name. The hosting service was officially launched in 2006. Since this time, there have been over 28,000,000 uploads by users in 40 content categories. The Complainant serves over 80,000,000 users per month.

The Complainant holds a number of trade mark registrations for the SLIDESHARE word mark, including US Registration No. 4,212,895 (registered September 25, 2012), European Union Registration No. 010853919 (registered November 26, 2012) and United Kingdom Registration No. 00910853919 (registered November 26, 2012) (the “Trade Mark”).

The Complainant is the registrant of the <slideshare.net> domain name (registered April 4, 2006), which it uses to run its hosting service.

The disputed domain name was registered on May 21, 2024.

The Respondent is an individual apparently located in Pakistan. The Respondent made an initial inquiry regarding potential settlement options via email communication but subsequently failed to pursue such discussions further. No formal Response was filed by the response due date, and, consequently, little information is known about the Respondent.

The disputed domain name resolves to a website which offers a “SlideShare Downloader” tool for download.
The website states that “it will guide you through what it is, its features, and how to download the
presentations from SlideShare”. The website content refers to the Complainant and features the Trade

Mark.

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 the Trade Mark. The disputed domain name

incorporates the Trade Mark in its entirety, differing by only one added letter “s” in the middle of the Trade from the Trade Mark, in fact, it creates stronger ties to the Trade Mark as it describes the Complainant’s services.

- The Respondent has no rights or legitimate interests in the disputed domain name. The website at the

disputed domain name enables users to download copyright materials from the Complainant’s platform materials ordinarily available by subscribing to the Complainant’s platform.
without subscribing to the Complainant’s services by acting as a proxy and manipulating the URL link. The
disputed domain name is not being utilized in connection with a bona fide offering of goods or services as the

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- The Trade Mark predates the registration of the disputed domain name by many years. The

Respondent uses the Trade Mark on the website at the disputed domain name and offers users the ability to avoid signing up for the Complainant’s services. The website at the disputed domain name provides explicit instructions in relation to how to copy links from the Complainant’s website. The disputed domain name is

being used for illegal and fraudulent activity, as it allows users to bypass the Complainant’s platform access

controls.

B. Respondent

The Respondent did not formally respond to the Complainant’s contentions.

6. Discussion and Findings

To succeed, the Complainant must demonstrate that all the elements enumerated in paragraph 4(a) of the
Policy have been satisfied, namely:

1. the disputed domain name is identical or confusingly similar to a trade mark or service mark in which the Complainant has rights;

2.        the Respondent has no rights or legitimate interests in respect of the disputed domain name; and

3.        the disputed domain name has been registered and is being used in bad faith.

The onus of proving these elements is on the Complainant.

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 trade mark 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 trade mark or service mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.

The entirety of the Trade Mark is reproduced within the disputed domain name, with the only difference between the Trade Mark and the disputed domain name being the insertion of the letter “s” and the term “downloader”. Accordingly, the disputed domain name is confusingly similar to the Trade Mark for the

purposes of the Policy. WIPO Overview 3.0, section 1.7.

The addition of the letter “s” to the Trade Mark is an example of typosquatting. A domain name which consists of a common, obvious, or intentional misspelling of a trade mark is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.0, section 1.9.

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.

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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 composition of the disputed domain name carries a risk of implied affiliation. name.

WIPO Overview 3.0, section 2.5.1. The Complainant has not authorized the Respondent to use the Trade

Panels have held that the use of a domain name for illegal activity (here, claimed unauthorized access,
copyright infringement and fraud) can never confer rights or legitimate interests on a respondent.

WIPO Overview 3.0, section 2.13.1.

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.

Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0, section 3.2.1.

Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy.

The Panel finds it unlikely that the disputed domain name was registered without knowledge of the
Complainant and its Trade Mark, given the reputation of the Complainant. The Respondent’s goal in
registering and using the disputed domain name appears, on the balance of probabilities, to be to attract
Internet users by taking unfair advantage of the Trade Mark for potential gain. This finding is reinforced by
the Respondent’s use of the disputed domain name to host a website that allows users to bypass the
Complainant’s platform access controls. This amounts to “opportunistic bad faith” under the Policy.

Panels have held that the use of a domain name for illegal activity (here, claimed unauthorized access, copyright infringement and fraud) constitutes bad faith. WIPO Overview 3.0, section 3.4.

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 <slidessharedownloader.com> be transferred to the Complainant.

/Rebecca Slater/
Rebecca Slater
Sole Panelist
Date: October 8, 2025