Decision for dispute CAC-UDRP-108148

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 relies on its registered trademark:

Further, the Complainant operates its business using its domain name <frontline.com>, registered and used since January 28, 1999.

Key aspects of the Complainant’s contentions are summarized below.

Complainant’s Background

The Complainant, Boehringer Ingelheim Animal Health, is a global leader in the animal health industry and forms part of the family-owned company Boehringer Ingelheim, founded in 1885. With more than 9,500 employees serving over 150 markets worldwide, Complainant is one of the largest providers of vaccines, parasiticides and therapeutics, complemented by diagnostics and monitoring platforms.

The Complainant’s product FRONTLINE is a well-known brand used for the treatment and prevention of fleas, ticks, and chewing lice in dogs and cats. It also helps break the flea life cycle by stopping the development of immature stages and supports the control of sarcoptic mange in dogs.

 Registration of the disputed domain name

According to the Complainant and the corresponding WHOIS records, the disputed domain name <frontlineplus-spot-on.com> was registered on November 10, 2025. Based on the screenshot evidence submitted with the complaint, the disputed domain name redirected to an authentication page requesting users to enter an email address and submit it.

COMPLAINANT:

The Complainant’s contentions may be summarized as follows:

The disputed domain name is confusingly similar to the Complainant’s trademark FRONTLINE, as the mark is identically contained. The addition of terms like “PLUS,” “SPOT,” and “ON” reinforces the connection to the Complainant's products and increases the likelihood of consumer confusion because it refers to a specific product commercialized by the Complainant.

The Respondent has no rights or legitimate interests in the disputed domain name. The Complainant has made a prima facie case, noting that the Respondent is not commonly known by the disputed domain name, is not affiliated with the Complainant, and has no authorization to use the FRONTLINE mark. The Complainant claims the disputed domain name resolves to an authentication page, which is not a bona fide offering of services and misleads consumers into believing they are accessing a Complainant-related site.

The disputed domain name was registered and is being used in bad faith. Given that the Complainant's FRONTLINE trademarks are well-known, the Respondent was clearly aware of them upon registration. By using the disputed domain name to direct users to an authentication page, the Respondent intentionally seeks to exploit the Complainant’s reputation and create a likelihood of confusion as to the source or affiliation of the website for commercial gain, potentially to collect personal information.

The Complainant contends that the requirements of the Policy have been met and that the disputed domain name should be transferred to it.

RESPONDENT:

No administratively compliant Response has been filed.

The Complainant has, to the satisfaction of the Panel, shown the disputed domain name is identical or confusingly similar to a trademark 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.

LANGUAGE OF PROCEEDING

According to Rule 11 in the Rules for Uniform Domain Name Dispute Resolution Policy, (the “Rules”) “...the language of the administrative proceeding shall be the language of the Registration Agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the administrative proceeding.”

The Registrar confirmed that the language of the registration agreement is English. As neither party requested otherwise, the Panel determines that the proceeding shall be conducted in English.

THREE ELEMENTS THE COMPLAINANT MUST ESTABLISH UNDER THE POLICY

 According to Paragraph 4(a) of the Policy, the Complainant is required to prove each of the following three elements to obtain an order that a disputed domain name should be transferred or cancelled:

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

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

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

The Panel has examined the evidence available and concludes as follows:

(A) THE COMPLAINANT’S RIGHTS AND CONFUSING SIMILARITY OF THE DISPUTED DOMAIN NAME TO THE COMPLAINANT’S RIGHTS

The Complainant has demonstrated rights in the registered trademark FRONTLINE, which predate the time of registration of the disputed domain name by many years.

The disputed domain name reproduces the Complainant’s mark in its entirety, with the addition of descriptive terms such as “PLUS,” “SPOT,” and “ON”. Prior UDRP Panels have established that the Complainant’s marks, including FRONTLINE and FRONTLINE PLUS, are well-known. See, e.g., CAC Case No. 103184, Merial v. Domain Administrator <frontlineplus.com> (“This is a straightforward case. There is no question about the Complainant’s rights. These are well-known marks [FRONTLINE® and FRONTLINE PLUS®] and have been for many decades. The mark, Frontline Plus, is reproduced in its entirety and can only reference the Complainant’s most famous product.”).

The addition of descriptive terms that relate to specific product variants, such as “SPOT ON,” does not prevent a finding of confusing similarity. In fact, such additions reinforce the risk of confusion, as they suggest the disputed domain name is connected to specific offerings of the Complainant. See, e.g., WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.8 ("Where the relevant trademark is recognizable within the domain name, the addition of other generic, descriptive, or geographical wording is typically insufficient to prevent a finding of confusing similarity.").

Further, the generic Top-Level Domain (gTLD) is a standard technical requirement of registration and is disregarded when assessing confusing similarity. See, e.g., WIPO Overview 3.0, section 1.11.1.

Accordingly, the Panel finds that the disputed domain name is confusingly similar to the Complainant’s FRONTLINE trademark and that paragraph 4(a)(i) of the Policy is satisfied.

(B) THE RESPONDENT’S LACK OF RIGHTS OR LEGITIMATE INTERESTS IN THE DISPUTED DOMAIN NAME

The second element of the Policy requires that the Complainant establishes that the Respondent has no rights or legitimate interests in the disputed domain name. The generally adopted approach, when considering the second element, is that if a complainant makes out a prima facie case, the burden of proof shifts to the respondent to rebut it; see, for example, WIPO Overview 3.0, section 2.1 (“While 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 often impossible 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. If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element.”).

However, the burden of proof still remains with the complainant to make out its prima facie case on a balance of probabilities. Moreover, the wording of paragraph 4(a)(ii) of the Policy requires a complainant to establish that the respondent has no rights or legitimate interests in the domain name in issue. Simply establishing that the complainant also has rights in the domain name in issue is insufficient.

Paragraph 4(a)(ii) of the Policy contemplates an examination of the available facts to determine whether a respondent has rights or legitimate interest in the domain name. Paragraph 4(c) sets out a list of circumstances through which a respondent may demonstrate that it does have such rights or interests.

The first circumstance, under Paragraph 4(c)(i), is where “before any notice to you of the dispute, your 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”. Here, according to screenshot evidence submitted by the Complainant, the disputed domain name resolves to an authentication page requesting users to enter an email address and submit it. In accordance with its powers under Rule 10(a) of the Rules, the Panel has undertaken limited factual research into matters of public record to help assess the case merits. To this end, on December 10, 2025, the Panel accessed the website associated with the disputed domain name in order to better understand its current use. According to the Panel’s investigation, the disputed domain name resolves to a website, operating under the name “FRONTLINEPLUS,” including:

• a commercial storefront purporting to sell FRONTLINE branded animal health products;
• product packaging and labelling visually very similar or identical to the Complainant’s FRONTLINE SPOT-ON packaging;
• an integrated ordering and payment gateway;
• a login portal and contact page; 
• a Gmail address (frontlineplus09@gmail.com) for correspondence;
• an “About Us” section including the text, “At FrontlinePlus-Spot-On, we believe that every pet deserves a life free from discomfort, irritation, and harmful parasites...“; and
• evidence that the website is incomplete or illegitimate such as the Featured Products section showing a graphic of a T-shirt and the label “Example Product Title £15.99“.

In WIPO Case No. D2001-0903, Oki Data Americas, Inc. v. ASD, Inc. <okidataparts.com> (“Oki Data“), the panel in that case proposed four cumulative requirements through which a reseller could show legitimate interest in a domain name.  Following this Oki Data-style analysis, the Panel applied the four conditions typically considered to assess whether a respondent has rights or legitimate interests in a domain name, namely:

• whether the respondent is actually offering the goods or services at issue;
• whether the respondent uses the site to sell only the trademarked goods or services;
• whether the site accurately and prominently discloses the registrant’s relationship with the trademark holder; and
• whether the respondent is attempting to “corner the market” in domain names reflecting the trademark.

The website superficially suggests a commercial operation, however the Panel finds the Respondent does not meet the commulative Oki Data conditions because there is no disclosure of any relationship with the Complainant rather the website purports to be operated by “FrontlinePlus-Spot-On“, or “frontlineplus“. This falsely implies that the site is operated by the Complainant rather than a legitimate third-party reseller. Accordingly, the Panel finds no evidence of a bona fide offering or goods or services or demonstrable preparations to use per Policy 4(c)(i).

The second circumstance, under Paragraph 4(c)(ii), concerns cases where the respondent is commonly known by the domain name. Here, according to the registrar verification, the Respondent's name is “Rashid Munir” and this name has no similarity or connection to the disputed domain name. Given the highly distinctive and well-known nature of the FRONTLINE mark and the lack of evidence that the Respondent is commonly known by the disputed domain name, this second circumstance of legitimate rights or interests under the Policy is not applicable to the Respondent.

Regarding the third circumstance, under Paragraph 4(c)(iii) of the Policy, there is no evidence that the Respondent is making a legitimate non-commercial or fair use of the disputed domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the Complainant’s FRONTLINE trademark. According to the Complainant, the disputed domain name was used to host an authentication page with the apparent intent to confuse and potentially capture data from the Complainant’s customersPanel’s subsequent investigation of the disputed domain name found that it currently resolves to a website purporting to offering Complainant’s products at steeply discounted prices (e.g.
FRONTLINE Plus Flea & Tick Treatment for Medium Dogs - 6 Pipettes product is offered for £15.99, reduced from £50.90).  As such, none of the accepted categories of fair use - such as news reporting, commentary, political speech, education etc – are found to apply and the Panel concludes there is no legitimate non-commercial or fair use on the part of the Respondent.

Lastly, the Complaint confirms that the Respondent is not licensed, nor has any relationship with or authority to represent the Complainant in any way.

Accordingly, the Complainant has sufficiently made out its prima-facie case on the second element of the Policy. Thus, the burden of proof is shifted to the Respondent to rebut the Complainant’s case. Here, because the Respondent has not participated in these proceedings, there is no such rebuttal to consider, and the Complainant prevails.

The Panel therefore concludes that neither the Respondent nor the evidence establishes that the Respondent has any right or legitimate interest in the disputed domain name. The Complainant has therefore also satisfied the requirement under paragraph 4(a)(ii) of the Policy.

(C) BAD FAITH REGISTRATION AND USE OF THE DISPUTED DOMAIN NAME

The Panel finds that the Complainant has shown that the Respondent registered and used the disputed domain name in bad faith under paragraph 4(a)(iii) of the Policy for the reasons as set out below.

Paragraph 4(b) of the Policy sets out a non-exhaustive list of four circumstances, any one of which may be evidence of the registration and use of a domain name in bad faith:

 (i) circumstances indicating that the respondent has registered or 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 the respondent’s documented out-of-pocket costs directly related to the domain name; or

(ii) the 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 the respondent has engaged in a pattern of such conduct; or

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

(iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the respondent’s website 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 the respondent’s website or location or of a product or service on the site or location.

The Panel has considered these circumstances and the totality of the evidence in the record, including the Complainant’s submissions and the Panel’s own contemporaneous check of the disputed domain name on  December 10, 2025.

The Complainant’s FRONTLINE trademark is distinctive and enjoys considerable reputation within the animal health industry. According, it is therefore 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 trademarks and that they registered the disputed domain name with knowledge of the Complainant's trademarks.

There is no credible evidence that the Respondent is commonly known by the disputed domain name and the Complainant asserts that the Respondent has never been authorized or licensed by the Complainant to use the Complainant’s trademark(s) and/or register the disputed domain name, nor is there any business or other association between the Complainant and the Respondent.

There is compelling evidence of targeting by Respondent. The disputed domain name comprises Complainant’s mark, with the addition of the product specific term “PLUS” and “SPOT ON”. The disputed domain name resolves to a website where Complainant branded products are purportedly offered for sale.  The Panel finds that the products sold via the disputed domain name have the potential to be counterfeit, as such products are offered at a disproportionately low price below claimed market value, i.e. less than half the price.

Respondent’s subsequent use of the disputed domain name for the website purporting to sell Complainant’s products demonstrates that Respondent had actual notice of the Complainant’s trademark when registering the disputed domain name. It has regularly been held that to copy a trademark in a domain name, or use it with a slight variation, knowing that the disputed domain name is based on the trademark of another party, constitutes bad faith registration and use of the disputed domain name according to the Policy. The Panel makes that finding in the present case.

Even if the goods sold via the website associated with the disputed domain name are not counterfeit – which is unlikely given the below market prices of the goods on offer - the present case fails the “Oki Data test” for establishing legitimate interest because the pages submitted as evidence do not appear to contain any information about the Respondent nor do they disclose the Respondent’s relationship with the Complainant. There is no clear and prominent disclaimer that could support a finding that the Respondent has taken reasonable steps to avoid confusing consumers about the provenance of the website. Further, cases applying the Oki Data test usually involve a domain name comprising the trademark plus a descriptive term such as “parts” or “repairs”. In the instant case there is no such descriptive term, but rather the inclusion of the product terms “PLUS” and “SPOT ON” implies that the website associated with the disputed domain name is an authorized or official site, which is not the case.

By using the disputed domain name as noted above, the Respondent is clearly intending to attract internet users for commercial gain, in a manner which would generate confusion as to the source, sponsorship, affiliation or endorsement of the site to which the disputed domain name resolves. Such conduct constitutes bad faith case within the provisions of paragraph 4(b) (iv) of the Policy

As a final point, the Panel draws a negative inference from Respondent’s silence though these proceedings.

This present case has similarities to  WIPO Case No. D2015-1466 Prada S.A. v. Chen Minjie, where it was held, “The Respondent's registration of a domain name which incorporates the whole trade mark, PRADA, the use thereof for the purpose of selling what appears to be counterfeit PRADA products, and the creation of a web site which is intended to pass off as the authentic or official web site of the Complainant, are obvious signs of bad faith registration and use. This is the very kind of cybersquatting and illegitimate activity that the Policy is intended to address and deal with”

In light of the above analysis, the Panel concludes that the Complainant has made out its case that the disputed domain name was registered and is being used in bad faith and thus has satisfied the requirements under paragraph 4(a)(iii) and 4b. of the Policy.