Zensar Technologies Limited v Naveen Chaubey

WIPO Case No. DAI2025-0034

ARBITRATION
AND
MEDIATION CENTER

ADMINISTRATIVE PANEL DECISION

Zensar Technologies Limited v. Naveen Chaubey

Case No. DAI2025-0034

1. The Parties

The Complainant is Zensar Technologies Limited, India, internally represented.

The Respondent is Naveen Chaubey, India, represented by A to Z Services Pvt. Ltd, India.

2. The Domain Name and Registrar

The disputed domain name <zensar.ai> 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 July 21, 2025. On July 21, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On July 25, 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 July 25, 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 July 29, 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 July 30, 2025. In accordance with the Rules, paragraph 5,
the due date for Response was August 19, 2025. The Respondent sent his response to the Center on

Auguust 14, 2025.

The Center appointed Shwetasree Majumder as the sole panelist in this matter on August 22, 2025. The
Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and

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Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the
Rules, paragraph 7.

On September 1, 2025, the Complainant’s representative requested information regarding a suspension and negotiation period. The Center provided the information requested by the Complainant. No answer or request has been received after said communication.

4. Factual Background

The Complainant is an Indian company in the business of providing services in the field of computer software and information technology under its mark ZENSAR. It is amongst the top 15 software service providers in India. The Complainant is a publicly listed company in India. The Complainant has several registrations for its mark ZENSAR, dating back to the year 2000. The details of some of such registrations are as below:

- – Indian Registration No. 905014, registered on February 21, 2000, in international class 16

- ZENSAR – Indian Registration No. 902474, registered on February 08, 2000, in international class 16.

- ZENSAR – Indian Registration No. 902473, registered on February 08, 2000, in international class 9. The Complainant’s main business website is at “ which has been registered since the year
1999. - ZENSAR – Indian Registration No. 1454727, registered on May 29, 2006, in international class 35.

The disputed domain name <zensar.ai> was registered on November 11, 2024. The disputed domain name redirects to a parked site and does not host a website. However, the Respondent has made the disputed domain name available for sale via Registrar’s auction service and also features pay-per-click (“PPC”) links.

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 identical to the trademark of the gives an unmistakable impression that the disputed domain name has a connection with the Complainant.

The Complainant argues that it has coined, adopted and started using the mark ZENSAR since the year
2001. The Complainant further argues that it is amongst the top 15 software service providers in India and
offers a wide range of services in the field of computer software and information technology, providing IT
solutions, different kinds of software and tools, along with scientific and technological services under the
name and style of Zensar Technologies Limited. The Complainant also has several trademarks registered for
ZENSAR. The Complainant submits that the mark ZENSAR has been held as a well-known trademark in
India. The Complainant contends that the Respondent has registered the disputed domain name in bad
faith, and the website does not contain any content or meaningful business, but redirects to “GoDaddy
Auction” to buy the disputed domain name.

The Complainant argues that the Respondent has no connection with the Complainant and has neither been authorised nor permitted to use or register the disputed domain name. The Complainant further contends that the disputed domain name, being identical to its trademark ZENSAR, is likely to mislead Internet users into believing that there is an association or affiliation between the Complainant and the Respondent.

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B. Respondent

The Respondent argues that the concept of ZENSAR AI originated independently, following his involvement in artificial intelligence and the launch of his startup in 2022. He further claims that the acquisition of the disputed domain name was a natural progression of these efforts.

The Respondent further points out that the use of the disputed domain name was in good faith and he was not aware of any trademark rights on ZENSAR held by the Complainant. The Respondent submits that the disputed domain name was registered in good faith for a genuine business venture in the field of artificial

intelligence and generative speech, which is entirely different from the Complainant’s line of business. The
Respondent contends that the addition of “.ai”, which is both a reference to artificial intelligence and the
country code top-level domain for Anguilla, clearly distinguishes the disputed domain name from the
Complainant’s mark.

The Respondent states that he has been developing the AI-related business idea for several years and registered the disputed domain name in November 2024 to support these bona fide plans, without any knowledge of or intent to exploit the Complainant’s trademark. The Respondent emphasises that there has

been no attempt to mislead consumers, divert clients, or gain commercially from the Complainant’s goodwill,
and the website itself contains no content that could create confusion.

The Respondent further argues that the Complainant does not operate in the AI sector and has not registered its trademark in Anguilla, where the Respondent intends to establish his venture, thereby eliminating any likelihood of confusion. The Respondent has argued reverse domain name hijacking against the Complainant.

6. Discussion and Findings

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.

The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy.
WIPO Overview 3.0, section 1.2.1.

The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7.

WIPO Overview 3.0, section 1.11. Also, the absence of Complainant’s trademark registrations in Anguilla is inconsequential for determining merits in the present case, and does not prevent a finding of confusing similarity under the first element. The first element of the UDRP requires the trademark to be identical or confusingly similar to the disputed domain name, irrespective of where Complainant’s trademark may be registered. WIPO Overview 3.0, sections 1.1.2 and 1.7.

The Respondent has contended lack of confusion, arguing that Complainant does not operate in the AI practice to disregard the Top-Level suffix under the confusing similarity test, except where the applicable Top-Level suffix may itself form part of the relevant trademark, which is not the case here.
sector and has not registered its trademark in Anguilla. The Respondent has also stated that addition of the

“.ai” country code top-level domain (“ccTLD”) distinguishes the disputed domain name from the

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 with the second element. WIPO Overview 3.0, section 2.1.

The Panel finds the Respondent's claim of intending to start a business in Anguilla unconvincing and unsupported by evidence. This is particularly so because the Respondent has offered the disputed domain name for sale via auction. The Respondent has failed to come forward with any evidence of prior use, or demonstrable preparations to use the disputed domain name in connection with a bona fide offering of goods or services. Past UDRP panels have recognized that PPC links can support respondent rights or legitimate interests only where the domain name consists of an actual dictionary words or phrase and is used to host PPC links genuinely related to the dictionary meaning of the words or phrase. WIPO Overview 3.0, section 2.9. However, this is not the case in the present matter. The Complainant’s mark ZENSAR is a coined mark and the Respondent has failed to offer any explanation on adopting an identical domain name.

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, in his response, 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 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.

In the present case, the Panel notes that the Respondent intentionally attempted to attract, for commercial gain, Internet users by creating a likelihood of confusion with the complainant’s mark. The Respondent has failed to give any explanation for registering the disputed domain name which is identical to Complainant’s coined mark ZENSAR. Even if the Respondent argues that his intention was to operate in a field different from the Complainant’s field, the Panel considers it unlikely that the Respondent would have registered a disputed domain name identical at the second level domain to the Complainant’s trademark, without knowing the Complainant's trademark.

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 available record, the Panel notes the distinctiveness of the Complainant’s trademark,
and the composition of the disputed domain name. The Panel observes that the disputed domain name
redirected to a parked site in which the Respondent offered for sale the disputed domain name and also
contained pay-per-click links.

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The Panel 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 <zensar.ai> be transferred to the Complainant.

/Shwetasree Majumder/
Shwetasree Majumder
Sole Panelist
Date: September 5, 2025