Skyscanner Limited v John Parker, John Technologies

WIPO Case No. D2025-1774

ARBITRATION

AND

MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Skyscanner Limited v. John Parker, John Technologies

Case No. D2025-1774

1. The Parties

The Complainant is Skyscanner Limited, United Kingdom, represented by Lewis Silkin LLP, United Kingdom.

The Respondent is John Parker, John Technologies, United States of America (“United States”).

2. The Domain Names and Registrar

The disputed domain names <fastskyscan.com>, <hotskyscan.com>, and <skyscantrip.com> (the “Disputed

Domain Names”) are registered with GMO Internet, Inc. (the “Registrar”).

3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on May 2, 2025. On May 2, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Names. On May 7, 2025, the Registrar transmitted by email to the Center its verif ication response disclosing registrant and contact information for the Disputed Domain Names which dif fered from the named Respondent (Redacted) and contact information in the Complaint. The Center sent an email communication to the Complainant on May 8, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amendment to the Complaint on May 12, 2025.

The Center verif ied that the Complaint together with the amendment to the Complaint satisf ied 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 notif ied the Respondent of the Complaint, and the proceedings commenced on May 14, 2025. In accordance with the Rules, paragraph 5, the due date for Response was June 3, 2025. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s default on June 16, 2025.

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The Center appointed Flip Jan Claude Petillion as the sole panelist in this matter on June 19, 2025. The Panel f inds 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, Skyscanner Limited, of fers travel search and arrangement services. The Complainant holds numerous trademarks, including the following:

- International trademark registration No. 900393 for SKYSCANNER, registered on March 3, 2006 in classes 35, 38, and 39, and

- International trademark registration No. 1030086 for SKYSCANNER, registered December 1, 2009 in classes 35, 39, and 42.

Both trademarks are registered in several countries including the European Union. The f irst one covers the
United States, where the Respondent is located.

The Disputed Domain Names were all registered on April 4, 2025 and resolve to websites appearing to of fer travel services similar to the Complainant’s services.

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 Names.

First, the Complainant contends that the Disputed Domain Names are confusingly similar to a trademark in

which it claims to have rights. 

Second, the Complainant claims that the Respondent has no rights or legitimate interests in respect of the

Disputed Domain Names as, in summary, according to the Complainant: 

- so far as the Complainant is aware, the Respondent does not own any registered rights in any

trademarks which comprise part or all of the Disputed Domain Names; legitimate interest or a bona f ide, noncommercial use of the Disputed Domain Names.

- the terms “Skyscanner” and “Skyscan” are not descriptive in any way, nor do they have any generic,
dictionary meaning. The Complainant has not given its consent for the Respondent to use confusingly
similar variations of its registered trademarks in domain name registrations;
- the Disputed Domain Names resolve to websites that offer travel arrangement services to consumers
who wish to search for flights and cars for hire, in direct competition with the Complainant’s services in which
it enjoys a global reputation. The Respondent capitalises on the misleading association with the
Finally, the Complainant claims that the Disputed Domain Names were registered and are being used in bad

faith.  In summary, according to the Complainant: 

- the Disputed Domain Names were registered over twenty years after the Complainant f irst applied to register its SKYSCANNER trademark;

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- the Respondent was aware of the reputation of the Complainant’s business under its SKYSCANNER trademark at the time the Disputed Domain Names were registered, by which point the Complainant already enjoyed global fame in its trademarks;

- the Respondent (a) registered the Disputed Domain Names that are similar to the SKYSCANNER trademark and (b) pointed those Disputed Domain Names to websites that offer identical services to those supplied under the SKYSCANNER trademark, in a deliberate attempt to mislead consumers in to believing that its services originate f rom, or are associated with the Complainant, for illegitimate gain.

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 f irst 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 Names. While each case is judged on its own merits, in cases where at least a dominant feature of the relevant mark is recognizable in a disputed domain name, the domain name will normally be considered confusingly similar to that mark for purposes of UDRP standing. 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 trademarks or service marks for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1.

The Disputed Domain Names all contain a signif icant portion of the Complainant’s SKYSCANNER mark, namely the element “skyscan”. Therefore, the Panel finds that the Complainant’s mark remains recognizable in the Disputed Domain Names.

Each Disputed Domain Name combines the “skyscan” element with a descriptive term, respectively “fast”, “hot”, and “trip”. Although the addition of other terms may bear on assessment of the second and third elements, the Panel f inds the addition of such terms does not prevent a f inding of confusing similarity between the Disputed Domain Names and the marks under the first element of the Policy. WIPO Overview 3.0, section 1.8.

Additionally, it is well established that generic Top-Level Domains (“gTLDs”), here “.com”, may be disregarded when considering whether a disputed domain name is confusingly similar to a trademark in which a complainant has rights.

The Panel f inds the f irst 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 of ten 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

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proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisf ied 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 Names. 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 Names such as those

enumerated in the Policy or otherwise.

The Panel notes that the Respondent has not apparently been commonly known by the Disputed Domain
Names, and that the Respondent does not seem to have acquired trademark or service mark rights. 
According to the information provided by the Registrar, the Respondent is named “John Parker, John
Technologies”.

Where a domain name consists of a trademark plus an additional term, UDRP panels have largely held that such composition cannot constitute fair use if it ef fectively impersonates or suggests sponsorship or endorsement by the trademark owner. WIPO Overview 3.0, section 2.5.1. In the present case, the Disputed Domain Names do not incorporate the Complainant’s SKYSCANNER mark in its entirety. However, the Complainant provides evidence showing that its SKYSCANNER trademark enjoys a considerable reputation among potential customers, which is also confirmed by previous UDRP panels. See Skyscanner Limited v. Basit Ali, WIPO Case No. D2012-1983; Skyscanner Limited v. Contact Privacy Inc. Customer 1244355693 / Mrs. K Ananthan, WIPO Case No. D2019-0988.

Therefore, the Panel finds that the Disputed Domain Names, each combining a signif icant portion of the Complainant’s SKYSCANNER mark with a laudatory and/or descriptive term, carry a risk of implied affiliation with the Complainant.

Beyond looking at the domain name and the nature of any additional terms appended to it, UDRP panels assess whether the overall facts and circumstances of the case, such as the content of the website linked to a disputed domain name and the absence of a response, support a fair use or not. WIPO Overview 3.0,

sections 2.5.2 and 2.5.3. 

The Panel observes that the Disputed Domain Names each refer to a different website which share the same structure and similar content. All these websites appear to offer an aggregator platform and travel services similar to the Complainant’s platform and services. In the Panel’s view, this neither amounts to a bona f ide of fering of goods or services nor a legitimate noncommercial or fair use of the Disputed Domain Names in the circumstances of this case.

The Respondent had the opportunity to demonstrate its rights or legitimate interests but did not do so.  In the

absence of a Response from the Respondent, the prima facie case established by the Complainant has not

been rebutted. 

The Panel f inds 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. Among these factors demonstrating bad faith registration and use is the use of a domain name to intentionally attempt to attract, for commercial gain, Internet users to a website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the website or location or of a product or service on the website or location.

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In the present case, the Panel finds that the Respondent must have been aware of the Complainant and its trademark rights when it registered the Disputed Domain Names:

- the Complainant’s SKYSCANNER marks predate the registration of the Disputed Domain Names by at least 15 years, including in the United States where the Respondent appears to be located;

- the Complainant’s evidence shows that its SKYSCANNER mark enjoys a not negligible reputation in the relevant sector;

- all three Disputed Domain Names incorporate the same significant portion of the Complainant’s mark with the addition of a laudatory and/or descriptive term;

- the websites linked to the Disputed Domain Names appear to of fer services similar to the

Complainant’s services.

In the Panel’s view, the circumstances of this case indicate that the Respondent has intentionally attempted to attract Internet users to its websites for commercial gain by creating a likelihood of confusion with the Complainant’s trademark. WIPO Overview 3.0, section 3.1.4.

By failing to respond to the Complaint, the Respondent did not take any initiative to contest the foregoing.

Pursuant to paragraph 14 of the Rules, the Panel may draw the conclusions it considers appropriate.

The Panel f inds 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 Names <fastskyscan.com>, <hotskyscan.com> and <skyscantrip.com> be transferred to the Complainant.

/Flip Jan Claude Petillion/
Flip Jan Claude Petillion
Sole Panelist
Date: July 3, 2025