Synopsys, Inc. v Name Redacted
WIPO Case No. D2025-1509
•29-05-2025
ARBITRATION
AND
| MEDIATION CENTER |
ADMINISTRATIVE PANEL DECISION
Synopsys, Inc. v. Name Redacted
Case No. D2025-1509
1. The Parties
The Complainant is Synopsys, Inc., United States of America (“United States”), represented by
Hogan Lovells (Paris) LLP, France.
The Respondent is Name Redacted[1].
[1] The Respondent appears to have used the name of a third party when registering the disputed domain name. In light of the potential
2. The Domain Name and Registrar
The disputed domain name <synopssys.com> is registered with NameCheap, Inc. (the “Registrar”).
3. Procedural History
The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on April 14, 2025.
On April 14, 2025, the Center transmitted by email to the Registrar a request for registrar verification in
connection with the disputed domain name. On the same day, the Registrar transmitted by email to the
Center its verification response disclosing registrant and contact information for the disputed domain name
that differed from the named Respondent (Redacted for Privacy, Privacy service provided by Withheld for
Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the
Complainant on April 15, 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 April 16, 2025.
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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 April 17, 2025. In accordance with the Rules, paragraph 5, the due date for Response was May 7, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on May 8, 2025.
The Center appointed Steven Auvil as the sole panelist in this matter on May 14, 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
According to the Complaint, the Complainant is a United States-based electronic design automation company founded in 1986. It is one of the leading providers of solutions for designing and verifying advanced silicon chips, as well as for developing next-generation processes and models required for
manufacturing silicon chips. The Complainant has over 20,000 employees and reported revenue of more
than USD 6.1 billion in 2024. The Complainant also has a large online presence with over 773,000 followers
on LinkedIn, 26,000 followers on Facebook, and over 22,000 followers on ����.
The Complainant owns numerous trademarks for its SYNOPSYS brand including: Australian Trademark Registration No. 607361 for SYNOPSYS, registered on July 22, 1993; Canadian Trademark Registration No. TMA458822 for SYNOPSYS, registered on June 7, 1996; European Union Trade Mark No. 000181172
| SYNOPSYS, registered on August 12, 1993; Israeli Trademark Registration No. 240586 for SYNOPSYS, | for SYNOPSYS, registered on February 1, 1999; Indian Trademark Registration No. 603839 for including <synopsys.com>. |
| The disputed domain name was registered on March 17, 2025. According to the Complaint, the disputed domain name is being used by the Respondent in connection with a phishing scheme to (1) create a fake email address incorporating an actual employee name associated with Complainant to impersonate the | |
| Complainant and (2) contact one of the Complainant’s vendors. The website associated with the disputed domain name previously resolved to a Registrar parking page featuring pay-per-click links. The Complainant filed a request with the Registrar to suspend the disputed domain name. The website associated with the disputed domain name currently resolved to an inactive page. | |
| 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. |
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First, the Complainant contends that the disputed domain name is confusingly similar to the Complainant’s SYNOPSYS mark. The Complainant alleges that the dispute domain name consists of a misspelling of the Complainant’s SYNOPSYS mark adding only an additional letter “s” in between the letter “s” and “y”.
The Complainant claims that the additional letter “s” creates a high degree of visual and aural similarity between the Complainant’s SYNOPSYS mark and the disputed domain name.
Second, the Complainant alleges that the Respondent has no rights or legitimate interests in the disputed domain name. The Complainant contends that the Respondent is not commonly known by the disputed domain name, nor is it using the disputed domain name in connection with a bona fide offering of goods or services. Complainant further alleges that the Respondent is not affiliated with the Complainant and that it has not granted the Respondent a license to use the SYNOPSYS mark for any reason, including in a domain name.
Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The Complainant alleges that the Respondent is using the disputed domain name in connection with a phishing scheme using an email address incorporating the name of an employee of the Complainant to impersonate the Complainant, including in communications with the Complainant’s vendors.
The Complainant requests that the disputed domain name be transferred to the Complainant.
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 to obtain relief:
(i) that the disputed domain name is identical or confusingly similar to a trademark or a 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.
In view of the Respondent’s failure to submit a Response, the Panel is entitled to accept as true the allegations set forth in the Complaint (unless the evidence is clearly contradictory), and to derive reasonable inferences from the evidence presented. See Talk City, Inc. v. Michael Robertson, WIPO Case No. D2000-0009.
Based on the foregoing guidance, the Panel makes the following findings and conclusions based on the allegations and evidence contained in the Complaint, as amended, and reasonable inferences drawn from the evidence presented.
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.
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The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy as the Complainant owns at least one trademark for SYNOPSYS. WIPO Overview 3.0, section 1.2.1.
As set forth in WIPO Overview 3.0, section 1.9, a “domain name which consists of a common,
obvious, or intentional misspelling of a trademark is considered by panels to be confusingly similar”.
WIPO Overview 3.0, section 1.9.
The disputed domain name consists of the entirety of the Complainant’s SYNOPSYS mark with the additional letter “s” in between the letter “s” and “y”. The Complainant argues that this is an obvious or intentional misspelling of its mark and thus constitutes typosquatting. Typosquatted domain names are intended to be confusing so that Internet users, who unwittingly make common type errors, will enter the typosquatted domain name instead of the correctly spelled trademark. See Muitas Ltd v. Domain Administrator, Sugarcane Internet Nigeria Limited and Milen Radumilo, WIPO Case No. D2022-4978; Synopsys, Inc. v. Jay Athey, WIPO Case No. D2024-0972. Under the circumstances, the Panel finds that the misspelling was obvious and/or intentional on the part of the Respondent and does not prevent a finding of confusing similarity.
Additionally, as set forth in section 1.11.1 of the WIPO Overview 3.0, the applicable generic Top-Level Domain (“gTLD”) (e.g., “.com”, “.site”, “.info”, “.shop”) is viewed as a standard registration requirement and as such is typically disregarded under the first element confusing similarity test. As such, the use of “.com” gTLD in the disputed domain name has no bearing on the confusing similarity analysis.
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. Such circumstances include:
(i) before any notice of the dispute, the respondent used, or prepared to use, the disputed domain name or a
name corresponding to the disputed domain name in connection with a bona fide offering of goods or
services;
(ii) the respondent (as an individual, business, or other organization) is commonly known by the disputed
domain name, even if the respondent has acquired no trademark or service mark rights; or
(iii) the respondent is making a legitimate noncommercial or fair use of the domain name, without intent for
commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.
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 the production of 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 with the
second element. WIPO Overview 3.0, section 2.1.
Having reviewed the evidence and arguments of record, the Panel finds that the Complainant has domain name to pass itself off or impersonate the Complainant. Panels have held that the use of domain names for illegitimate activity, such as impersonation/passing off, can never confer rights or legitimate
established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain
name. In addition to the confusing similarity between the disputed domain name and the Complainant’s
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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 that are evidence of 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 if found by the Panel to be present may indicate that a domain name was registered and used in bad faith. WIPO Overview 3.0, section 3.2.1.
In the present case, the Panel concludes that the Respondent has registered and used the disputed domain name in bad faith. First, the disputed domain name incorporates the Complainant’s registered and well- known SYNOPSYS mark in its entirety, with only a minor variation— the insertion of an additional letter “s” between the letter “s” and “y”. The disputed domain name currently resolves to an inactive webpage.
The Panel finds that the Respondent has engaged in using the disputed domain name to impersonate the Complainant and mislead its vendors into believing it is affiliated or doing business with the Complainant. Panels have held that the use of a domain name for illegal activity, here impersonation/passing off
constitutes bad faith. WIPO Overview 3.0, section 3.4.
Considering this and other circumstances, including the failure of the Respondent to respond to the
Complaint, the Panel finds that the Respondent knew of the Complainant’s SYNOPSYS mark at the time of
registering the disputed domain name and endeavored to unfairly capitalize on the mark for commercial gain.
The Panel therefore concludes that the disputed domain name was registered and is being used in bad faith.
The Panel therefore 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 <synopssys.com> be transferred to the Complainant.
/Steven Auvil/ Steven Auvil Sole Panelist Date: May 29, 2025
identity theft, the Panel has redacted the Respondent’s name from this decision. However, the Panel has attached as Annex 1 to this
decision an instruction to the Registrar regarding transfer of the disputed domain name, which includes the name of the Respondent.
The Panel has authorized the Center to transmit Annex 1 to the Registrar as part of the order in this proceeding and has instructed that
Annex 1 to this decision shall not be published due to the exceptional circumstances of this case. See Banco Bradesco S.A. v.
FAST-12785241 Attn. Bradescourgente.net / Name Redacted, WIPO Case No. D2009-1788.
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