Decision for dispute CAC-UDRP-108621

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

The Complainant, Teva Pharmaceutical Industries Ltd., is the owner of numerous trademark registrations for the mark TEVA in multiple jurisdictions worldwide.

These include, for example:

• Israeli trademark TEVA No. 41075, registered on July 5, 1977;
• United States trademark TEVA No. 1567918, registered on November 28, 1989;
• European Union trademark TEVA No. 000115394, registered on April 29, 1998;
• International trademark TEVA No. 1319184, registered on June 15, 2016;
• International device trademark TEVA No. 1829734, registered on September 10, 2024.

These trademark registrations predate the registration of the disputed domain name <tevabg.com>.

The Complainant also operates domain names incorporating its TEVA mark, including <tevapharm.com> and <teva.bg>, which it uses in connection with its business activities.

The Panel notes that the TEVA mark has been recognized in prior UDRP decisions as a well-known trademark.

The Complainant is an international pharmaceutical company founded in Israel in 1944. It is one of the world’s leading producers of generic medicines and is engaged in the development, manufacture and commercialization of pharmaceutical products worldwide. According to its 2024 annual report, the Complainant generated revenues exceeding USD 16.5 billion and employed approximately 37,000 people globally.

The Complainant maintains a significant international presence, including in Bulgaria, where it operates manufacturing facilities in Dupnitsa and Troyan and maintains a commercial office in Sofia.

The Complainant maintains an established online presence through, inter alia, its principal website at <tevapharm.com>, which was registered on June 14, 1996, and through its Bulgarian website at <teva.bg>, which has been in use since 2012. The Complainant is also active on major social media platforms.

The disputed domain name <tevabg.com> was registered on March 20, 2026.

At the time of filing of the Complaint, the disputed domain name resolved to an inactive website. The evidence further shows that the disputed domain name previously redirected Internet users to the Complainant’s Bulgarian website at <teva.bg>.

COMPLAINANT:

1. The disputed domain name is confusingly similar to the Complainant’s trademark

The Complainant submits that it has established rights in the TEVA trademark through its extensive portfolio of registered trademarks, which significantly predate the registration of the disputed domain name.

According to the Complainant, the disputed domain name <tevabg.com> incorporates the TEVA trademark in its entirety and merely adds the letters “bg”, which are commonly understood as a reference to Bulgaria.

The Complainant contends that the addition of a geographical abbreviation does not prevent a finding of confusing similarity, as the TEVA trademark remains clearly recognizable within the disputed domain name.

The Complainant further submits that the letters “bg” increase rather than diminish the likelihood of confusion, as they correspond directly to Bulgaria, where the Complainant maintains significant business operations and operates the domain name <teva.bg>.

The Complainant relies on established UDRP practice, as reflected in WIPO Overview 3.1, section 1.8, according to which the addition of descriptive or geographical terms does not prevent a finding of confusing similarity where the relevant trademark remains recognizable.

The Complainant also notes that the generic Top-Level Domain “.com” is a standard registration requirement and should be disregarded when assessing confusing similarity.

Accordingly, the Complainant submits that the disputed domain name is confusingly similar to its TEVA trademark within the meaning of paragraph 4(a)(i) of the Policy.

2. The Respondent has no rights or legitimate interests in the disputed domain name

The Complainant submits that the Respondent has no rights or legitimate interests in the disputed domain name.

The Complainant states that it has not licensed, authorized, or otherwise permitted the Respondent to use the TEVA trademark in any manner, including in the disputed domain name. According to the Complainant, there is no evidence that the Respondent is commonly known by the disputed domain name or owns any corresponding trademark rights.

The Complainant further contends that the Respondent is not making any bona fide offering of goods or services under the disputed domain name, nor any legitimate noncommercial or fair use thereof.

According to the Complainant, the disputed domain name currently resolves to an inactive website and there is no evidence of any legitimate use or preparations for legitimate use by the Respondent.

The Complainant further notes that the disputed domain name previously redirected Internet users to the Complainant’s Bulgarian website at <teva.bg>. According to the Complainant, such conduct demonstrates that the Respondent was aware of the Complainant and its business and cannot establish rights or legitimate interests in the disputed domain name.

The Complainant therefore submits that the Respondent has no rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy.

3. The disputed domain name was registered and is being used in bad faith

The Complainant submits that the disputed domain name was registered and is being used in bad faith.

According to the Complainant, the TEVA trademark is well known internationally and has been extensively used for decades prior to the registration of the disputed domain name. The Complainant contends that, given the reputation of the TEVA mark and its longstanding presence in Bulgaria, the Respondent must have been aware of the Complainant and its trademark rights when registering the disputed domain name.

The Complainant further argues that the composition of the disputed domain name demonstrates targeting of the Complainant, as it combines the TEVA trademark with the geographical abbreviation “bg”, directly corresponding to Bulgaria, where the Complainant maintains substantial operations and uses the domain name <teva.bg>.

The Complainant also relies on evidence showing that the disputed domain name previously redirected Internet users to the Complainant’s Bulgarian website. According to the Complainant, such redirection demonstrates actual knowledge of the Complainant and its Bulgarian operations and is inconsistent with any good-faith use of the disputed domain name.

The Complainant further submits that, although the disputed domain name currently resolves to an inactive website, passive holding does not prevent a finding of bad faith where the surrounding circumstances demonstrate targeting of the Complainant and an absence of any plausible good-faith use.

The Complainant relies on established UDRP practice, including the doctrine of passive holding as reflected in WIPO Overview 3.1, section 3.3.

Accordingly, the Complainant submits that the disputed domain name was registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy.

Therefore, the Complainant contends that the requirements of the Policy have been met and requests transfer of the disputed domain name.

RESPONDENT:

No administratively compliant Response has been filed.

The Respondent nevertheless submitted an informal communication through the CAC platform on May 20, 2026. In that communication, the Respondent stated that the disputed domain name had been registered solely for educational and testing purposes while learning how to create and manage domain names and websites. The Respondent denied any intention to infringe third-party rights and indicated that he would not object to the transfer of the disputed domain name.

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 the UDRP have been met.

No administratively compliant Response was submitted by the Respondent. The CAC accordingly notified the Parties that the Respondent was in default and that the Panel may draw such inferences from that default as it considers appropriate.

The Panel notes, however, that on May 20, 2026, the Respondent submitted an informal communication through the CAC platform. Although this communication does not constitute a formal Response within the meaning of the Rules, the Panel has considered its contents to the extent relevant to the issues in dispute.

There is no other reason why it would be inappropriate to proceed to a decision in this case.

The UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY of the Internet Corporation for Assigned Names and Numbers (ICANN) (the “Policy”) provides that a complainant must prove each of the following to obtain transfer or cancellation of a domain name:

1. that respondent’s domain name is identical or confusingly similar to a trademark or service mark in which complainant has rights; and

2. that respondent has no rights or legitimate interests in respect of the domain name; and

3. the domain name has been registered and is being used in bad faith.

1) The disputed domain name is confusingly similar to a trademark in which the Complainant has rights (Para. 4(a)(i) of the Policy)

The Panel is satisfied that the Complainant holds valid trademark rights in the TEVA mark.

The disputed domain name <tevabg.com> incorporates the Complainant’s TEVA trademark in its entirety together with the letters “bg”.

The Panel notes that “bg” is commonly understood as an abbreviation for Bulgaria. The addition of this geographical term does not prevent a finding of confusing similarity. On the contrary, given the Complainant’s established operations in Bulgaria and its use of the domain name <teva.bg>, the additional term reinforces the association with the Complainant.

It is well established that where a complainant’s trademark is recognizable within the disputed domain name, the addition of geographical or other descriptive terms does not prevent a finding of confusing similarity (WIPO Overview 3.1, section 1.8).

The generic Top-Level Domain “.com” is a standard registration requirement and is disregarded for the purpose of assessing confusing similarity (WIPO Overview 3.1, section 1.11.1).

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

2) The Respondent lacks rights or legitimate interests in the disputed domain name (Para. 4(a)(ii) of the Policy)

Under the Policy, the Complainant is required to establish a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. Once such case is made, the burden of production shifts to the Respondent (WIPO Overview 3.1, section 2.1).

The Panel notes that the Complainant has not authorized, licensed, or otherwise permitted the Respondent to use the TEVA trademark. There is no evidence that the Respondent is commonly known by the disputed domain name.

The Respondent submitted an informal communication stating that the disputed domain name had been registered for educational and testing purposes while learning how to create and manage domain names and websites. The Panel does not find this explanation persuasive.

The disputed domain name incorporates the Complainant’s distinctive trademark in its entirety together with the geographical abbreviation “bg”, directly corresponding to the country in which the Complainant operates and uses the domain name <teva.bg>. The composition of the disputed domain name therefore carries a risk of implied affiliation with the Complainant and is not consistent with a legitimate use of the disputed domain name (WIPO Overview 3.1, section 2.5.1).

Moreover, the evidence shows that the disputed domain name previously redirected Internet users to the Complainant’s Bulgarian website at <teva.bg>. Such conduct is inconsistent with a bona fide or legitimate use of the disputed domain name.

The Respondent has provided no evidence of any bona fide offering of goods or services or any legitimate noncommercial or fair use of the disputed domain name.

In light of the above, the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy.

3) The disputed domain name was registered and is being used in bad faith (Paragraph 4(a)(iii) of the Policy)

The Panel finds that the Complainant’s TEVA trademark significantly predates the registration of the disputed domain name and enjoys substantial recognition internationally, including in Bulgaria.

Given the distinctiveness of the TEVA mark and the composition of the disputed domain name, the Panel considers it more likely than not that the Respondent was aware of the Complainant and its trademark at the time of registration.

The disputed domain name incorporates the Complainant’s trademark in its entirety and combines it with the geographical abbreviation “bg”, directly corresponding to the country in which the Complainant maintains substantial operations and uses the domain name <teva.bg>. The Panel finds that such composition is not coincidental and reflects a deliberate targeting of the Complainant.

Most significantly, the evidence shows that the disputed domain name previously redirected Internet users to the Complainant’s Bulgarian website at <teva.bg>. In the Panel’s view, such redirection demonstrates actual knowledge of the Complainant and its Bulgarian operations and constitutes compelling evidence that the disputed domain name was registered with the Complainant in mind.

The Respondent contends that the disputed domain name was registered for educational and testing purposes. The Panel is not persuaded by this explanation. The Respondent has provided no explanation as to why a domain name incorporating the Complainant’s well-known trademark and the geographical abbreviation corresponding to the Complainant’s Bulgarian operations was selected for that purpose, nor how such explanation can be reconciled with the demonstrated redirection to the Complainant’s website.

At the time of filing of the Complaint, the disputed domain name resolved to an inactive website. However, panels have consistently held that passive holding does not prevent a finding of bad faith where the surrounding circumstances demonstrate targeting of a complainant and the absence of any plausible good-faith use (WIPO Overview 3.1, section 3.3). In the present case, the prior redirection to the Complainant’s website, the composition of the disputed domain name, and the lack of any credible explanation from the Respondent support such a finding.

Taking all circumstances into account, including the composition of the disputed domain name, the Respondent’s awareness of the Complainant, the prior redirection to the Complainant’s Bulgarian website, and the absence of any plausible good-faith explanation for the registration, the Panel concludes that the disputed domain name was registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy.