Decision for dispute CAC-UDRP-108017

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

The Complainant owns a number of trade marks consisting of or incorporating the name EURO 2024, including the UK national word trade mark UEFA EURO 2024, registration number UK00917929120, first registered on 27 November 2018 in international classes 16, 25, 28, 32, 38, 41, and 43; and the UK national word trade mark EURO 2024, registration number UK00911322351, first registered on 20 March 2013 in international classes 3, 4, 9, 12, 14, 16, 18, 25, 28, 32, 35-39, and 41-43. The Complainant’s trade mark registrations predate the registration of the disputed domain name. The Panel accepts the Complainant’s submission that the Complainant’s trade marks are extensively used, widely recognised, and have accrued significant reputation and goodwill in connection with European football, and that they are distinctive and well-known internationally.  

The Complainant submits that it also owns the domain name <uefa.com>, which is connected to the main operating website used by the Complainant to provide news, information, updates and features relating to UEFA competitions and related services, including to the UEFA online store for purchasing merchandise. It is unclear from the Complainant’s submission when the domain <uefa.com> was first registered and used, and what direct bearing it has on the matter, given that it does not contain the name Euro 2024. Furthermore, the Complainant is active on social media and has generated a significant level of endorsement with more than 6,1 million followers on Instagram, more than 2,8 million followers on Facebook, and more than 2,1 million followers on X.

The Complainant was founded on 15 June 1954 and is the umbrella organisation for the 55 national football associations across Europe. Since 1995, it is headquartered in Nyon, Switzerland. The Complainant runs national and club competitions, including the UEFA European Championship, UEFA Nations League, UEFA Champions League, UEFA Europa League and UEFA Super. It controls the prize money, regulations and media rights to those competitions. The UEFA European Championship is a European football tournament which has been held every four years since 1960 and takes place in the even-numbered year between World Cup tournaments. The UEFA European Championship is the primary association football competition contested by the senior men's national teams of the members of UEFA, determining the continental champion of Europe. As early as 1984, the UEFA European Football Championship has been commercially identified as “EURO”, combined with the year of the event. In the case of the 1984 tournament, the form this name took was “EURO 84”, and in subsequent years the names used have been “EURO 88”, “EURO 92”, “EURO 96”, “EURO 2000”, “EURO 2004”, “EURO 2008”, “EURO 2012”, “EURO 2016”, “EURO 2020”, and ‘’EURO 2024’’. In each case, the name was used to refer to the tournament many years prior to the date of the tournament itself. The EURO 2024 Championship took place in Germany and reached a global cumulative TV audience of some 5 billion viewers.

The disputed domain name <euro2024volunteers.com> was registered on 20 April 2025. As at the date of this decision, the disputed domain name resolves to a domain hosting what appears to be a sports and football betting and streaming website.

The Complainant contends that all three elements of the UDRP have been fulfilled and it therefore requests the transfer of the disputed domain name to the Complainant.

The Complainant has, to the satisfaction of the Panel, shown the disputed domain name is identical or confusingly similar to a trade mark or service mark in which the Complainant has rights (within the meaning of paragraph 4(a)(i) of the Policy).

The Complainant has, to the satisfaction of the Panel, shown the 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).

The Complainant has, to the satisfaction of the Panel, shown the disputed domain name has been registered and is being used in bad faith (within the meaning of paragraph 4(a)(iii) of the Policy).

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.

With regard to the first UDRP element, the Panel finds that the disputed domain name is confusingly similar to the Complainant's trade mark EURO 2024. Indeed, the disputed domain name incorporates the Complainant's trade mark in its entirety but adds the generic and descriptive term "volunteers” as a suffix to the Complainant's trade mark. The Panel follows in this respect the view established by numerous other decisions that a domain name which wholly incorporates a complainant's registered trade mark may be sufficient to establish confusing similarity for the purposes of the UDRP (see, for example, WIPO Case No. D2003-0888, Dr. Ing. h.c. F. Porsche AG v. Vasiliy Terkin <porsche-autoparts.com>). The Panel further considers it to be well established that the addition of a generic or descriptive term does not allow a domain name to avoid confusing similarity with a trade mark (see, for example, WIPO Case No. D2019-2294, Qantas Airways Limited v. Quality Ads <qantaslink.com>; and CAC Case No. 102137, Novartis AG v. Black Roses <novartiscorp.com>). Other panels have previously found that “[W]here 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” (see WIPO Overview 3.0, section 1.8; and, for example, WIPO Case No. D2023-2542, Merryvale Limited v. tao tao <wwbetway.com>; and WIPO Case No. D2020-0528, Philip Morris Products S.A. v. Rich Ardtea <global-iqos.com>). Against this background, the Panel finds that the addition of the generic term "volunteers” is not sufficient to alter the overall impression of the designations as being connected with the Complainant's trade mark and does not prevent a likelihood of confusion between the disputed domain name and the Complainant and its trade marks. To the contrary, the disputed domain name rather adds to the likelihood of confusion because the Complainant has continuously relied on large-scale volunteer programmes in relation to its flagship tournaments, including for the EURO 2024 Championships, where it engaged 16,000 volunteers across the tournament’s host cities. The addition of the generic term "volunteers” in conjunction with the Complainant's trade mark Euro 2024 therefore implies that the disputed domain name links to an official website of the Complainant concerned with its volunteer programme for Euro 2024.

With regard to the second UDRP element, there is no evidence before the Panel to suggest that the Respondent has made any use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services. Neither is there any indication that the Respondent is making legitimate non-commercial or fair use of the disputed domain name. The Panel follows in this regard the view established by numerous other decisions that use of a domain name incorporating a well-known trade mark to redirect to third-party commercial content is not a bona fide offering of goods or services (see WIPO Overview 3.0, section 2.5.3) where this competes with or seeks to capitalise on the reputation and goodwill of the complainant’s trade mark, or otherwise mislead Internet users. Indeed, internet users will be accessing the disputed domain name under the assumption that it is in some way related to volunteering services for the Complainant’s UEFA EURO 2024 Championship. The disputed domain name, by incorporating the Complainant’s trade mark EURO 2024 in its entirety, creates a false impression of affiliation with the Complainant and cannot constitute fair use if it effectively impersonates or suggests sponsorship or endorsement by the trade mark owner (see WIPO Overview 3.0, section 2.5.1; and, for example, CAC Case No. 104875, UEFA v. Wei Wnag <uefa2017.com> and <2016uefa.com>). The Panel further finds that the Respondent is not affiliated with or related to the Complainant in any way and is neither licensed nor otherwise authorised to make any use of the Complainant’s trade marks or to apply for or use the disputed domain name. Additionally, the Whois information for the disputed domain name does not suggest that the Respondent is commonly known by the disputed domain name <euro2024volunteers.com>. Past panels have held that a respondent was not commonly known by a disputed domain name if the Whois information was not similar to the disputed domain name, as is equally not the case here (see, for example, Forum Case No. FA 1781783, Skechers U.S.A., Inc. and Skechers U.S.A., Inc. II v. Chad Moston / Elite Media Group <bobsfromsketchers.com> (“Here, the WHOIS information of record identifies Respondent as “Chad Moston / Elite Media Group.” The Panel therefore finds under Policy ¶ 4(c)(ii) that Respondent is not commonly known by the disputed domain name under Policy ¶ 4(c)(ii).”)). Against this background, and absent any response from the Respondent, or any other information indicating the contrary, the Panel concludes that the Respondent has no rights or legitimate interests in respect of the disputed domain name.

With regard to the third UDRP element, it is reasonable to infer that the Respondent either knew, or should have known, that the disputed domain name would be confusingly similar to the Complainant's trade marks, and that the Respondent registered the disputed domain name in full knowledge of the Complainant's trade marks. Indeed, if the Respondent had carried out a Google search for the term “EURO 2024”, the search results would have yielded immediate results related to the Complainant and the UEFA Euro 2024 Championships. Indeed, it is likely that the disputed domain name would not have been registered if it were not for the Complainant's trade marks (see, for example, WIPO Case No D2004-0673 Ferrari Spa v. American Entertainment Group Inc <ferrariowner.com>). The Panel considers that the disputed domain name was intentionally designed to be confusingly similar with the Complainant’s trade mark. Furthermore, the disputed domain name resolves to a website hosting commercial sports and football content. Based on the decisions of other panels in similar cases, the Panel regards this as an attempt by the Respondent to divert and attract Internet users for commercial gain to its own website based on the Complainant’s trade marks, and as further evidence of bad faith (see, for example, WIPO Case No D2018-0497, StudioCanal v. Registration Private, Domains By Proxy, LLC / Sudjam Admin, Sudjam LLC <studiocanalcollection.com> (“In that circumstance, whether the commercial gain from misled Internet users is gained by the Respondent or by the Registrar (or by another third party), it remains that the Respondent controls and cannot (absent some special circumstance) disclaim responsibility for, the content appearing on the website to which the disputed domain name resolve […] so the Panel presumes that the Respondent has allowed the disputed domain name to be used with the intent to attract Internet users for commercial gain, by creating a likelihood of confusion with the Complainant's trademark as to the source, affiliation, or endorsement of the Respondent's website to which the disputed domain name resolves. Accordingly, the Panel finds that the disputed domain name was registered and is being used in bad faith.”)). Indeed, there is no plausible reason for registering a domain including the name “EURO 2024” other than to target the Complainant. It is further difficult to conceive of any plausible actual or contemplated active use of the disputed domain name by the Respondent that would not be illegitimate on the grounds that it would constitute passing off, an infringement of consumer protection legislation, or an infringement of the Complainant’s rights under trade mark law under circumstances where that disputed domain name corresponds to the Complainant’s trade marks currently used by the latter to promote its goods and services. Absent any response from the Respondent, or any other information indicating the contrary, the Panel therefore also accepts that the Respondent has registered and is using the disputed domain name in bad faith.