Stripe, Inc. v Hua Ren She Tuan Ru Guo Ge Se De Ren Kou Jie Gou

WIPO Case No. D2025-0838

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Stripe, Inc. v. Hua Ren She Tuan Ru Guo Ge Se De Ren Kou Jie Gou

Case No. D2025-0838

1. The Parties

The Complainant is Stripe, Inc., United States of America, represented by Elster & McGrady LLC, United

States of America (the “United States”).

The Respondent is Hua Ren She Tuan Ru Guo Ge Se De Ren Kou Jie Gou, Hong Kong, China.

2. The Domain Name and Registrar

The disputed domain name <stripe.ceo> 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 February 28,
2025. On February 28, 2025, the Center transmitted by email to the Registrar a request for registrar
verification in connection with the disputed domain name. On February 28, 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)
and contact information in the Complaint. The Center sent an email communication to the Complainant on
March 4, 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 6, 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 11, 2025. In accordance with the Rules, paragraph
5, the due date for Response was March 31, 2025. The Respondent did not submit any response.
Accordingly, the Center notified the Respondent’s default on April 4, 2025.

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The Center appointed Luca Barbero as the sole panelist in this matter on April 11, 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 technology company specialized in building economic infrastructure for the Internet and for businesses ranging from new startups to public companies, offering payment exchange software and other services for the management of businesses online.

With headquarters in San Francisco and Dublin, and offices in London, Paris, Tokyo, Singapore and other locations around the world, the Complainant’s STRIPE services are available for businesses in over 40 countries, including the United States and Hong Kong, China.

The Complainant is the owner of numerous trademark registrations for STRIPE, including the following, as per trademark registration certificates submitted as annexed to the Complaint:

- United States trademark registration No. 4451679 for STRIPE (word mark), filed on January 11, 2011, and

registered on December 17, 2013, in international class 36;

- Hong Kong, China trademark registration No. 304025006 for STRIPE (word mark), registered on January
19, 2017, in classes 9, 35, 36, 41, 42, and 45.

The Complainant is also the owner of the domain name <stripe.com>, registered on September 12, 1995, and used by the Complainant to promote its products and services and publish its documentation, libraries, and API resources under the trademark STRIPE.

The disputed domain name was registered on October 21, 2024, and does not currently resolve to an active website. Based on the screenshots submitted as annexed to the Complaint, which have not been challenged by the Respondent, on March 6, 2025, it was redirected to a registrar parking page with pay-per- click links whilst on February 27, 2025, it resolved to a webpage stating that the website had been stopped.

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 trademark addition of the generic Top Level Domain (“gTLD”) “.ceo”.

With reference to rights or legitimate interests in respect of the disputed domain name, the Complainant states that: i) the Respondent was never granted any license, permission or authorization by which the Respondent could own or use any domain name registrations confusingly similar to the STRIPE mark; ii) the

Respondent is not commonly known by the disputed domain name, by the STRIPE mark or any variation thereof; iii) the Respondent has not used the disputed domain name in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use, since the disputed domain name currently resolves to a pay-per-click website containing links to third-party websites and prior to the present proceeding was passively held.

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faith because: i) the Respondent’s redirection of the disputed domain name to a pay-per-click website to
presumably obtain click-through revenue shows that it intentionally attempted to attract users, for commercial
gain, to its website by creating a likelihood of confusion with the Complainant’s mark; ii) the Respondent
previously acted in bad faith by passively holding the disputed domain name; iii) there is no conceivable
reason for the Respondent to have registered the disputed domain name other than to trade off the
reputation and goodwill of the STRIPE mark and to disrupt the Complainant’s business; iv) the Respondent
registered the disputed domain name using a privacy service to conceal its identity; v) even if the
Respondent was to implausibly argue that it was somehow unaware of the Complainant’s rights in the

The Complainant also states that the Respondent registered and is using the disputed domain name in bad search, it would have found the Complainant’s trademark registrations, the websites associated with the mark, and numerous additional references in commerce, on the Internet, and in publications, evidencing the Complainant’s use of the STRIPE mark in connection with its goods and services.

B. Respondent

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

6. Discussion and Findings

According to paragraph 15(a) of the Rules: “A Panel shall decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable.” Paragraph 4(a) of the Policy directs that the Complainant must prove each of the

following:

(i) that the disputed domain name registered by the Respondent is identical or confusingly similar to a

trademark or service mark in which the Complainant has rights;

(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 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. registrations for STRIPE.

The entirety of the mark is reproduced within the disputed domain name without any variation. Accordingly, the disputed domain name is identical to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

The gTLD “.ceo” can be disregarded under the first element confusing similarity test, being a standard registration requirement. WIPO Overview 3.0, section 1.11.1.

Therefore, the Panel finds the first element of the Policy has been established.

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

According to the evidence on record, there is no relationship between the Complainant and the Respondent, and the Complainant has not authorized the Respondent to register or use its trademark or the disputed domain name. Moreover, there is no element from which the Panel could infer the Respondent’s rights over the disputed domain name, or that the Respondent might be commonly known by the disputed domain name.

As mentioned above, the disputed domain name is currently not resolving to an active website, but, according to the Complainant’s submissions – which have not been contested by the Respondent – it was previously redirected to a parking page with pay-per-click links and to a webpage indicating that the website had been shut down. Based on the record, the Panel finds that there is no evidence of use of the disputed domain name by the Respondent in connection with a bona fide offering of goods or services or a legitimate noncommercial or fair use without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s trademark.

The Panel notes that the Complainant’s trademark is widely known in its sector, as also found by Panels in previous cases decided under the Policy. Considering the composition of the disputed domain name, identical to the STRIPE mark and registered in the gTLD “.ceo”, and in the absence of a Response, the Panel finds that, on balance of probabilities, the Respondent was aware of the Complainant and its trademark and registered the disputed domain name due to the potential association of the disputed domain name with the Complainant and/or its Chief Executive Officer. Therefore, the Panel finds that the Respondent does not have any rights or legitimate interests in the disputed domain name.

In view of the foregoing, the Panel finds the second element of the Policy has been established as well.

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.

The Panel finds that, considering the Complainant’s prior registration and use of the STRIPE mark, including online via the Complainant’s website at “ and the Complainant’s widespread reputation in the STRIPE mark with regard to its products and services, also recognized by Panels in previous cases, the

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Respondent knew of should have known of the Complainant’s STRIPE mark at the time of the registration of the disputed domain name. WIPO Overview 3.0, section 3.2.2.

The Respondent has provided no evidence to justify its choice of the term “stripe” in the disputed domain name, which in view of its composition, the Panel finds was likely chosen due to its significance as a trademark owned by the Complainant. Indeed, the selection of a domain name identical to the STRIPE mark and of the gTLD “.ceo” suggests that the Respondent intended to target the Complainant and/or its Chief Executive Officer.

According to the screenshots submitted by the Complainant, the disputed domain name previously resolved to a pay-per-click page. In view of such use of the disputed domain name, the Panel finds that the Respondent intentionally attempted to attract Internet users to its website, for commercial gain, by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of its website according to paragraph 4(b)(iv) of the Policy.

The disputed domain name does not currently resolve to an active website. Panels have found that the non- Complainant’s trademark, and the composition of the disputed domain name, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy.

use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding.

Therefore, the Panel finds that the Complainant has also 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 <stripe.ceo> be transferred to the Complainant.

/Luca Barbero/
Luca Barbero
Sole Panelist
Date: April 28, 2025