Decision for dispute CAC-UDRP-107975

The Panel is not aware of any other legal proceedings which are pending or decided and which relate to the disputed domain names.

Complainants, QlikTech International AB and TALEND S.A.S., are the owners, among others, of the following registrations for the trademarks:

International trademark: TALEND®

Reg. No. 1345814

Registration Date: March 7, 2017

International trademark: TALEND®

Reg. No. 1310047

Registration Date: March 25, 2016

EU trademark: TALEND®

Reg No. 014226989

Registration Date: September 23, 2015

US trademark: TALEND®

Reg. No. 5304787

Registration Date: October 10, 2017

Complainants have submitted evidence of these registrations by means of copies from the online databases of WIPO, US Patent and Trademark Office and EUIPO.

Complainants are QlikTech International AB and TALEND S.A.S.. QlikTech International AB and Talend S.A.S. form part of the QlikTech Group.

Talend S.A.S. was previously trading on the Nasdaq stock market from 2016 to 2021. The company was valued at $2.4 billion at the time it stopped trading on the stock market. Moreover, the TALEND® platform is a data integration platform that utilizes a graphical interface to generate Java code. Therefore, it is considered a code generator, which translates graphical design into Java code. In addition, the TALEND® platform is a comprehensive data management platform that includes tools for app integration.

 The QlikTech Group is a global leader in artificial intelligence, data analytics and business intelligence solutions, offering software to businesses worldwide. Through its innovative platform, the QlikTech Group enables businesses to transform raw data into actionable insights, enabling them to gain a deeper understanding of their operations, customers, and market trends. QlikTech International AB was founded in Sweden in 1993, and forms part of the QlikTech Group.

Complainants assert that, as of 2025, the QlikTech Group serves more than 40,000 global customers and has more than 235,000 community members. The QlikTech Group also maintains a robust network of international partners, including Amazon, Google and Microsoft. Moreover, the QlikTech Group has a global presence, with offices and associated companies in North America, Canada, Latin America, Europe, the Middle East, Asia and Africa, including in the United States, where it has an active presence through associated companies. Evidence of these facts are submitted and the Panel could verify those statements.

Complainants own numerous domain names composed of the TALEND® trademark alone, including <talend.com> (created on 8 April 2005) or in combination with other terms, such as <talendcloud.com> (created on 19 August 2014). Both domain name registrations are submitted to the Complaint. Complainants further add that they use <talend.com> to resolve to their official website, through which they inform Internet users and potential consumers about the TALEND® mark and its related services.

Complainants also enjoy a strong presence online via their official social media platforms  and evidence of this is submitted to the Complaint, with respect to TALEND this evidence is based on YouTube (13.1 k subscribers) and Linkedin (85 K followers) presence.

Complainants state and submit evidence that they found out about the registration of the disputed domain names, on June 23, 2025. Consequently, they sent a Cease-and-Desist letter to the Registrant, via the Registrar’s email, and informed the Registrant that the disputed domain names are infringing trademark regulations. Complainants sent further reminders on July 3, 2025, and July 8, 2025, but there was no response

Respondents are Joseph Lee,  Anil Kumar Reddy Tokala and Victor Morris. No-one, except Victor Morris, has replied to this Complaint. Victor Morris response was that he is not using the disputed domain name <talendapp.com> and that it should expire with GoDaddy.

Respondents registered their disputed domain names:

<talendmarket.com> on 31 December 2017;

<talendcode.com> on 15 August 2020;

<talendapp.com> on 2 April 2022.

Response has been filed by one of three Respondents but this is not a substantial Response.

Complainants contend that the requirements of the Policy have been met and that the disputed domain name should be transferred to them.

No administratively compliant Response has been filed.

According to the Policy paragraph 4(a)(i) it needs first to be established that:

(i)The domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights;

Complainants assert that:

<talendmarket.com> - In its second level-portion, the Complainants’ trademark TALEND®, is followed by the relevant term “market”. It is important to underline that Talend S.A.S. was previously trading on the Nasdaq stock market from 2016 to 2021. The company was valued at $2.4 billion at the time it stopped trading on the stock market. Evidence of the facts is enclosed in the Complaint.

 <talendcode.com> - In its second level-portion, the Complainants’ trademark TALEND®, is followed by the relevant term “code”. It is important to underline that the TALEND® platform is a data integration platform that utilizes a graphical interface to generate Java code. Therefore, it is considered a code generator, which translates graphical design into Java code. Evidence of the facts is enclosed in the Complaint.

<talendapp.com> - In its second level-portion, the Complainants’ trademark TALEND®, is followed by the relevant term “app”. It is important to underline that the TALEND® platform is a comprehensive data management platform that includes tools for app integration. Evidence of the facts is enclosed in the Complaint.

Complainants continue to state that the TALEND® trademark is clearly recognizable in the disputed domain names. WIPO Jurisprudential Overview 3.0 section 1.8 states:

Where the relevant trademark is recognizable within the disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) would not prevent a finding of confusing similarity under the first element. The nature of such additional term(s) may however bear on assessment of the second and third elements”.

Moreover, Complainants state, that in a similar case involving Complainants, regarding the domain names <talendsolutions.life>, <talendsolutions.org>, <talendsolutions.store> and <talendsolutions.tech> the Panel held that:

The Panel finds the mark is recognizable within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. The addition of the word “solutions” in the disputed domain names does not prevent this finding. The Panel finds the first element of the Policy has been established” (see Talend S.A.S. v. TimesPro, WIPO Case No. D2024-2418).

Further, Complainants add that the presence of the generic Top-Level Domain (“gTLD”) extension “.com” in the first level portion of the disputed domain names is a standard registration requirement and may be disregarded when assessing whether the disputed domain names are confusingly similar to the trademark in which the Complainant has rights (see Rollerblade, Inc. v. Chris McCrady, WIPO Case No. D2000-0429; Can Pro Pet Products LTD. v. Matthew Dweck, WIPO Case No. D2020-0615; Sanofi v. Aamir Hitawala, WIPO Case No. D2021-1781).

The Disputed Domain Names are therefore confusingly similar to the Complainants’ TALEND® trademarks according to Complainants.

The Panel agrees with the assertions of Complainants with respect to the similarity of trademark and the disputed domain names. They have sufficiently shown that disputed domain names consist of the trademark of Complainants intertwined with -for Complainants’ business- relevant descriptive terms. Therefore the disputed domain names as the whole are confusingly similar to the trademark of Complainants.

Further, the trademark registrations predate the registration of the disputed domain names and thus the trademark rights prevail.

Complainants have, to the satisfaction of the Panel, shown that the disputed domain names are identical or confusingly similar to a trademark in which Complainants have rights (within the meaning of paragraph 4(a)(i) of the Policy).

According to the Policy paragraph 4(a)(ii) it needs further to be established that:

(ii) Respondent has no rights or legitimate interests in respect of the domain name.

Paragraph 4 (c) of the Policy provides circumstances that could demonstrate that Respondent has no rights to and legitimate interests in the Domain Name. These circumstances are not exclusive. Circumstances that provide rights or legitimate interests to the domain name are:

(i) before any notice to the Respondent of the dispute, the use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or

(ii) Respondent (as an individual, business, or other organization) has been commonly known by the domain name, even if though it has acquired no trademark or service mark rights; or

(iii) 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.

Further, according to the WIPO Case No. D2003-0455, Croatia Airlines d. d. v. Modern Empire Internet Ltd., Complainant is required to make out a prima facie case that Respondent lacks rights or legitimate interests. Once such prima facie case is made, Respondent carries the burden of demonstrating rights or legitimate interests in the domain name. If Respondent fails to do so, Complainant is deemed to have satisfied paragraph 4(a) (ii) of the UDRP.

According to Complainants Respondents have no rights on the disputed domain names. They motivate with the following statements:

• Complainants have never granted Respondents with any rights to use the TALEND® trademarks in any form, including in the disputed domain names;
• Complainants have not found that the Respondent is known by the disputed domain names. Indeed, when searching for the Disputed Domain Names terms “talendmarket”, “talend market”, “talendcode”, “talend code”, “talendapp” or “talend app” in the Google search engine, all of the results directly relate to the Complainants, as well as their websites, products or related topics. This is substantiated with evidence;
• When searching for any trademarks incorporating the disputed domain names terms “talendmarket”, “talend market”, “talendcode”, “talend code”, “talendapp” or “talend app” on online trademark search platforms, no trademarks are to be found. This is substantiated with evidence;
• When searching for any trademarks in the names of the alleged Respondents “Joseph Lee”, “Anil Kumar Reddy Tokala”, and “Victor Morris” along with the aforementioned disputed domain names terms, there are no results to be found. This is substantiated with evidence;
• At the time Complainants found out about the disputed domain names on June 20, 2025, they resolved to parking pages with relevant “pay per click” (“PPC”) links. At the time of filing of the Complaint, the disputed domain names resolved to parking pages with relevant PPC links. The PPC pages associated to the disputed domain names displayed relevant sponsored links which clearly refer to the Complainants and their business activities, such as “Market Data Platform”. Upon clicking these links, Internet users are invited to visit other websites related to “Data Platforms”, among others.

PPC pages generate revenue when Internet users click on the links displayed therein. The Respondents likely obtained a financial benefit when Internet users clicked on the aforementioned links. Such use of the disputed domain names aims at attracting Internet users for commercial gain by creating a likelihood of confusion with the Complainants’ TALEND® trademarks as to the sources, sponsorship, affiliation, or endorsement of the aforementioned PPC pages.

Complainants cite in this respect:

 [e]xploitation of the reputation of a trademark to obtain click-through commissions from the diversion of Internet users is a common example of use in bad faith as referred to in paragraph 4(b)(iv) of the Policy and identified in many previous UDRP decisions” (see Renault SAS v. Domain Administrator, See PrivacyGuardian.org / Simon Pan, WIPO Case No. D2019-3208).

Moreover, Complainants cite:

when the use of the disputed domain name was in connection with “a parking page displaying PPC links, from which Respondent derived click-through revenue”, the UDRP Panel considered that such use “signals a further attempt on the part of Respondent to take unauthorized commercial advantage of Complainant’s trademarks in bad faith” (see Amazon Technologies, Inc. and Amazon Europe Core S.à.r.l. v. Hei Ze Shang Zi, WIPO Case No. D2020-3012).

Moreover, the structure of the disputed domain names – incorporating in their second level portion the Complainants’ TALEND® trademark, followed by the relevant terms “market”, “code” and “app” respectively – reflect the Respondent’s intention to create an association, and a subsequent likelihood of confusion, in internet users’ mind.

It therefore appears that Respondents deliberately chose to use the TALEND® trademark in the disputed domain names to confuse Internet users as to the source of the disputed domain names, as Complainants state.

 Respondents did not submit any substantial Response.

The Panel agrees that Complainant has sufficiently demonstrated that Respondents have no right or legitimate interest and as Respondents did not file a Response demonstrating a prima facie case on lack of rights and legitimate interest is sufficient to conclude.

Complainant has, to the satisfaction of the Panel, shown Respondent to have no rights or legitimate interests in respect of the disputed domain name (within the meaning of paragraph 4(a)(ii) of the Policy).

According to the Policy paragraph 4(a)(iii) it finally needs to be established that:

(iii) the domain name has been registered and is being used in bad faith.

Paragraph 4 (b) of the Policy provides circumstances on that demonstrate that Respondent has registered and used the domain name in bad faith. These circumstances are not exclusive. Those circumstances are for example:

(i) circumstances indicating that Respondent has registered or has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the domain name; or

(ii) Respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or

(iii) Respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

(iv) by using the domain name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to it’s web site or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of your web site or location or of a product or service on your web site or location.

Registration in bad faith according ot Complainants

As Complainants allege and substantiate with evidence, the TALEND® trademark is a widely known trademark registered in many countries and Complainants enjoy a strong online presence with their websites and social media.

Therefore, by conducting a simple online search, Respondent would have inevitably learnt about Complainants, their TALEND® trademarks and business. According to Complainants it is clear that Respondents had the intention to create an association, and a subsequent likelihood of confusion, with Complainants’ trademarks in Internet users’ minds.

Complainants cite in this respect WIPO Overview 3.0, section 3.1.4.:

Bad faith is apparent from the coupling of the Mark with a lack of an alternative explanation for the disputed domain name’s registration. The Respondent has presented no evidence suggesting that the disputed domain name was derived from any source other than the Complainant’s Mark. “Panels have consistently found that the mere registration of a domain name that is identical or confusingly similar (particularly domain names comprising typos or incorporating the mark plus a descriptive term) to a famous or widely-known trademark by an unaffiliated entity can by itself create a presumption of bad faith.”

Therefore, the disputed domain names shall be deemed as registered in bad faith according to Complainants.

Use in bad faith according to Complainants

The disputed domain names resolve to parking pages of GoDaddy.com with relevant pay-per-click (“PPC”) links. The PPC links display relevant sponsored links which could be associated with Complainants and their business activities, such as “Market Data Platform”. Upon clicking these links, Internet users are invited to visit other websites related to “Data Platforms”, among others.

PPC pages generate revenue when Internet users click on the links displayed therein. According to Complainant, Respondent likely obtained a financial benefit when Internet users clicked on the aforementioned links. Such use of the disputed domain names aims at attracting Internet users for commercial gain by creating a likelihood of confusion with the Complainants’ TALEND® trademarks as to the sources, sponsorship, affiliation, or endorsement of the aforementioned PPC pages.

Complainant has submitted print screens of the webpages on which it can be seen that the pages are parking pages of GoDaddy.com with pay-per-click-links.

Complainants cite in this respect:

[e]xploitation of the reputation of a trademark to obtain click-through commissions from the diversion of Internet users is a common example of use in bad faith as referred to in paragraph 4(b)(iv) of the Policy and identified in many previous UDRP decisions” (see Renault SAS v. Domain Administrator, See PrivacyGuardian.org / Simon Pan, WIPO Case No. D2019-3208).

Moreover, Complainants cite:

a parking page displaying PPC links, from which Respondent derived click-through revenue”, ….“signals a further attempt on the part of Respondent to take unauthorized commercial advantage of Complainant’s trademarks in bad faith” (see Amazon Technologies, Inc. and Amazon Europe Core S.à.r.l. v. Hei Ze Shang Zi, WIPO Case No. D2020-3012).

And further:

 […] The disputed domain name resolved to a parking page with pay-per-click links some of which compete with the Complainant’s mark. WIPO Overview 3.0, section 3.

And concludes that Respondents have been using the disputed domain names in bad faith.

Panel findings

Based on the above the Panel has the following findings.

Reputation of Complainants

Bad faith circumstances occur mainly when a Respondent sees financial gain on riding on the coat tails of Complainants’ success. This is mostly profitable when Complainants have a reputation. Therefore, first it needs to be established whether Complainants have such a reputation.

To substantiate its reputation Complainants submit evidence on their online presence which is highly relevant as Complainants are companies in artificial intelligence, data analytics and business intelligence solutions. The evidence is sufficiently convincing that Complainants have a global presence and reputation in the specific field of data. It is therefore likely that Respondents have registered the disputed domain names in order to attract, for commercial gain, the internet user. Moreover, this is not denied at Respondents end.

Registration in bad faith

The Panel follows the reasoning of Complainants and together with the evidence submitted, and the fact that a Response was not filed, concludes that reasoning of Complainant is true.

From that it follows that the disputed domain names are registered in bad faith.

Use in bad faith

•  Resolving to a parking website with pay-per-click-links: is that use by Respondent according to the Policy? Control is essential!

The disputed domain names resolve to parking websites of the Registrar GoDaddy.com which websites contain pay per click links.

The Panel firstly has to decide whether a domain name resolving to a parking website with pay per click links is use of the domain name by the Respondent according to the Policy.

The Panel finds that use of a domain name by a Registrar (in casu: GoDaddy.com) in order to inform the internet user that the domain name is for sale is not use of the domain name by the Registrant or owner of the domain name. This is use by the Registrar as only the Registrar has control about the information given on the website.

However, in this particular case the websites to which the disputed domain names resolve also show pay per click links. These links aim to attract internet users to click and be forwarded to other websites with, as it seems by the links, relevant information on the trademark owner, but most of the time the links forward the internet user to competitive or irrelevant websites. As the Panels know, adding those pay-per-click links to the parking webpage is a specific service that GoDaddy.com offers to Registrants: the CashParking Ad Revenue service. It entails a monetizing service of unused domain names by setting up an account with GoDaddy.com. Consequently, pay-per-click links are added to the parking webpage of the unused domain name and once an internet user clicks on such link, the Registrant earns money. In such case the Registrant or domain name owner has chosen that the parking webpage comprises pay-per-click-links, and thus has a certain control over the use of the domain name, resolving into a website and benefiting from it.

Therefore,  the Panel considers that the use of parking pages of Registrars with pay-per-click links that are created on demand of the domain name owner is the use of the domain name by the domain name owner in light of the Policy.

•  Resolving to a parking website with pay-per-click-links: is that use in bad faith by Respondents according to the Policy with respect to the disputed domain names?

Through the Registrar Verification Email as submitted in this UDRP Procedure the Panel learnt that, although registering the disputed domain names in 2017, 2020 and 2022, Respondents, started the use of the disputed domain names, all three, on the almost exact time, namely 19 September 2025,1:54:16 pm (first two disputed domain names ) and 1:54:17 pm (talendapp.com) when the domain names were transferred to and registered with GoDaddy.com. This Registrar parked the disputed domain names at a parking webpage with pay-per-click links.

It is likely that Respondents had become aware of this Cash Parking Ad Revenue Service of GoDaddy.com and decided to monetize the -before that date unused- disputed domain names, as the reputation of the TALEND mark could lead to clicks by the public expecting that they would land on the webpages of Complainants. This is profitable for Respondents as the clicks lead to the earning of money.

The Panel therefore concludes that the use of the disputed domain names on parking websites with pay-per-click links is use of the disputed domain names by Respondents and that this use is use in bad faith as through the pay-per-click-links Respondents aim to attract, for commercial gain, internet users, to their websites or other on-line locations, by creating a likelihood of confusion with Complainants’ mark.

In addition, the Panel would like to mention that this judgement is in line with paragraph 2.9 of the WIPO Overview 3.0 about rights and legitimate interests with respect to parked pages comprising pay-per-click links and paragraph 3.5.of the WIPO Overview ‘Can third party generated material ‘automatically’ appearing on the website associated with a domain name form a basis for finding bad faith?’

Complainants have, to the satisfaction of the Panel, shown the disputed domain names have been registered and are being used in bad faith (within the meaning of paragraph 4(a)(iii) of the Policy).

Preliminary Procedural Issue: Consolidation of multiple domain names request

In this UDRP Procedure Complainants request to issue a decision on three domain names, namely talendmarket.com, talendcode.com, talendapp.com, which domain names are owned by three different individuals. The request is substantiated by informing in the Complaint that previously UDRP Panels stated that:

The consolidation of multiple registrants as Respondents in a single administrative proceeding may in certain circumstances be appropriate under paragraph 3(c) or 10(e) of the Rules provided Complainant can demonstrate that the disputed domain names or the websites to which they resolve are subject to common control, and the Panel, having regard to all of the relevant circumstances, determines that consolidation would be procedurally efficient and fair and equitable to all parties

(See WIPO Case No. D2010-028, Speedo Holdings B.V. v. Programmer, Miss Kathy Beckerson, John Smitt, Matthew Simmons; and WIPO Jurisprudential Overview 3.0, section 4.11.2).

In the present case, Complainants argue that the disputed domain names are under common control of the same person or entity as the disputed domain names show similarity in their structure and spelling. They share a comparable structure, as they all comprise, in their second level portions, Complainants’ trademark TALEND along with relevant terms connected to Complainant’s business and services such as the terms “market”, “code”, “app”, followed by the same gTLD “.com.

In addition, while the registrations of the disputed domain names did not occur at the same time, they have all been registered before the same Registrar and Hosting Provider as well as the WHOIS data redacted with the same privacy service and pointing identical IP addresses and name severs 

Moreover, all the email addresses of the alleged Respondents are Gmail and are composed of name of the Respondent + generic term. All of the alleged Respondents are based in the United States

All the provided details for the Respondents show that they are allegedly based in the United States. Lastly, all the disputed domain names resolve to similar content and do not show ever being used in relation to any bona fide service, as they resolve to pay-per-click pages despite being registered at least three years ago.

These similarities strongly suggest that the disputed domain names are likely under common control.

Complainant continues by citing WIPO Jurisprudential Overview 3.0 section 4.11.2 which states:

“Panels have considered a range of factors, typically present in some combination, as useful to determining whether such consolidation is appropriate, such as similarities in or relevant aspects of

• the registrants’ identity(ies) including pseudonyms,
• the registrants’ contact information including email address(es), postal address(es), or phone number(s), including any pattern of irregularities,
• relevant IP addresses, name servers, or webhost(s),
• the content or layout of websites corresponding to the disputed domain names,
• the nature of the marks at issue (e.g., where a registrant targets a specific sector), (vi) any naming patterns in the disputed domain names (e.g., <mark-country> or <mark-goods>),
• any naming patterns in the disputed domain names (e.g., <mark-country> or <mark-goods>),
• the relevant language/scripts of the disputed domain names particularly where they are the same as the mark(s) at issue,
• any changes by the respondent relating to any of the above items following communications regarding the disputed domain name(s),
• any evidence of respondent affiliation with respect to the ability to control the disputed domain name(s),
• any (prior) pattern of similar respondent behavior, or
• other arguments made by the complainant and/or disclosures by the respondent(s).”.

Summarizing it Complainant mentioned several factors to be applicable in the present case:

• the content hosted on the disputed domain names is exactly the same or extremely similar (pay-per-click pages);
• The domain names are all registered with the same Registrar;
• The domain names are all registered with the same Hosting Provider;
• The domain names point to the same IP address and name servers;
• The nature of the marks involved is the same;
• The naming pattern of the disputed domain names is the same: Talend + terms connected to the Complainant’s business and services, such as “market”, “code”, “app” + generic TLD “.com”;
• All the alleged Respondents are based in the US, and their email addresses show a similar structure.

By consolidating these Respondents into a single proceeding, Complainants aim to address the collective harm caused by their actions and seek an equitable resolution to this dispute.

In accordance with the rules and procedures governing UDRP proceedings, Complainants request the consolidation of multiple Respondents in this case. 

The Panel has the following findings.

The structure of the disputed domain names is one factor that may lead to suspect common control but it is not enough, as the composition of domain names consisting of trademark + descriptor is frequently used. The fact that Respondents are all American is not enough on itself, though it is striking that two of them are from Texas, but the third of them is not. The technical details with respect to the hosting provider, names and addresses are, though an important factor.

 In the Registrar Verification, the Panel reads that all three disputed domain names were transferred to and registered with GoDaddy.com on the same day and time: with respect to <talendmarket.com> and <talendcode.com>, namely on 9/19/2025 1:54:16 pm and <talendapp.com> differs only one second, namely on 9/19/2025 1:54:17 pm. This (almost) simultaneous transfer, followed by the fact that all three disputed domain names resolve to the same type of parking website with pay-per-click links cannot be a coincidence.

These last factors thus, are, according to the Panel crucial, for the conclusion that all three disputed domain names are centrally controlled. Thus it would be procedurally efficient and fair and equitable to all parties to consolidate in one procedure.

Therefore the consolidation request, namely the request to decide on all three disputed domain names with three different Respondents in one Complaint, is accepted.

The Panel is satisfied that all procedural requirements under UDRP were met and there is no other reason why it would be inappropriate to provide a decision.