Decision for dispute CAC-UDRP-108810

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

The Complainant relies on several of its registered trademarks, in territories around the world, including:

• EU TM n. 009595356 – “ADOBE” – Nice Cl. 9, 35, 42, (Registration date May 3, 2011);
• US TM n. 1475793 – “ADOBE” – Nice Cl. 9, (Registration date February 9, 1988);
• EU TM n. 018316507 – (Fig.) – Nice Cl. 9, 35, 42, (Registration date March 19, 2021);
• EU TM n. 018316508 – (Fig.) – Nice Cl. 9, 35, 42, (Registration date March 19, 2021);

Further, the Complainant operates its business using its domain name <adobe.com>.

The Complainant is Adobe Inc., a United States technology company established in 1982. It develops and markets a wide range of software and digital media products, including well-known applications such as Adobe Photoshop, Adobe Illustrator, Adobe Creative Cloud and Adobe Document Cloud. The Complainant states that it has more than 30,000 employees worldwide, had US $19.41 billion in revenues for the 2023 fiscal year, and owns an extensive portfolio of trademark registrations for the mark ADOBE in numerous jurisdictions, many of which long predate the registration of the disputed domain names.

The Complainant alleges that both disputed domain names initially resolved to the same commercial website based in Bangladesh. According to the Complainant, the website prominently displays the Complainant's ADOBE trademark and logo, offers software represented as Adobe products, and also advertises unrelated technology products and services. The Complainant further submits that, following receipt of a cease-and-desist notice, the disputed domain name <adobeccpro.com> was redirected to a page offering the domain name for sale.

The Complainant also requests consolidation of the proceeding. It submits that, although the disputed domain names are registered in the names of two different registrants, they are under common control because, amongst other things, both domain names resolved to the same website, displayed the same content and branding, and formed part of the same commercial operation.

Registration of the disputed domain names

The disputed domain names are <adobebazar.com>, registered on April 17, 2025, and <adobeccpro.com>, registered on October 12, 2025.

First UDRP Element – the disputed domain names are Confusingly Similar to the Complainant’s Trademark

The Complainant asserts that it owns numerous trademark registrations for the mark ADOBE around the world, all of which predate the registration of the disputed domain names.

The Complainant submits that the disputed domain names <adobebazar.com> and <adobeccpro.com> each incorporate the ADOBE trademark in its entirety. It contends that the addition of the descriptive terms "bazar" and "ccpro" does not prevent a finding of confusing similarity. The Complainant further submits that the ".com" gTLD should be disregarded for the purposes of the comparison.

Second UDRP Element – The Respondent has no Rights or Legitimate Interests in the disputed domain names

The Complainant asserts that it has not licensed, authorized or otherwise permitted the Respondent to use the ADOBE trademark or to register domain names incorporating that mark.

The Complainant further submits that the Respondent is not commonly known by either of the disputed domain names. According to the Complaint, the disputed domain names resolved to a commercial website prominently displaying the Complainant's ADOBE trademark and logo while offering software represented as Adobe products together with unrelated technology products and services. The Complainant contends that such use is intended to mislead Internet users into believing that the website is affiliated with or authorized by the Complainant and therefore does not constitute a bona fide offering of goods or services or a legitimate non-commercial or fair use of the disputed domain names.

Third UDRP Element – The disputed domain names were Registered and are Being Used in Bad Faith

The Complainant asserts that the ADOBE trademark is well known internationally and had acquired substantial goodwill long before the registration of the disputed domain names.

The Complainant contends that the Respondent deliberately registered domain names incorporating the ADOBE trademark in order to create a false association with the Complainant. It submits that the disputed domain names were used to resolve to the same commercial website, which prominently displayed the Complainant's trademark and logo and purported to offer Adobe software, thereby intentionally attracting Internet users for commercial gain by creating a likelihood of confusion with the Complainant's mark.

The Complainant further submits that, after receiving a cease-and-desist letter, one of the disputed domain names was redirected to a webpage offering the domain name for sale, which it says provides further evidence of bad faith. The Complainant also relies on the Respondent's failure to reply to its cease-and-desist correspondence as additional support for a finding of bad faith.

The foregoing facts and arguments asserted by the Complainant are uncontested because no Response was filed.

Complainant´s contentions are summarized above.

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

No administratively compliant Response has been filed.

The Complainant has, to the satisfaction of the Panel, shown the disputed domain names are 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 names (within the meaning of paragraph 4(a)(ii) of the Policy).

The Complainant has, 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).

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.

PRELIMINARY ISSUE: CONSOLIDATION

The Complaint has been brought against two named Respondents in respect of the disputed domain names <adobebazar.com> and <adobeccpro.com>. The Complainant requests that the dispute be consolidated on the basis that the disputed domain names are subject to common control.

Paragraph 10(e) of the Rules grants the Panel the power to decide a request to consolidate multiple domain name disputes in accordance with the Policy and the Rules. As reflected in section 4.11.2 of the WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), consolidation may be appropriate where the evidence demonstrates that the disputed domain names or the corresponding websites are subject to common control and where consolidation would be fair and equitable to all parties.

The Panel notes that the disputed domain names are registered in the names of different registrants. However, the record contains several compelling indicators that the disputed domain names are subject to common control. Most significantly, both disputed domain names redirected to the same commercial website based in Bangladesh under the .bd country code top-level domain featuring the Complainant's ADOBE word and figurative trademarks and branding. In the Panel's view, this is the strongest indicator that the disputed domain names are under common control. Further, according to the Registrar verification, both Respondents share a geographic location because the provided contact addresses are both located in Bangladesh (Sirajganj and Dhaka). Finally, the temporal proximity of the registration dates further supports consolidation, because the disputed domain names were registered only a few months apart, on April 17, 2025, and October 12, 2025.

Taking these factors together, the Panel is satisfied that consolidation is procedurally efficient, fair and equitable to all parties. The request for consolidation is therefore granted. Accordingly, for the purposes of this Decision, the Panel will refer to the named Respondents collectively as the "Respondent".

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 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 to it and has come to the following conclusions concerning the satisfaction of the three elements of paragraph 4(a) of the Policy in these proceedings:

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

The Complainant has demonstrated registered trademark rights in the mark ADOBE in numerous jurisdictions around the world. These trademark rights substantially predate the registration of the disputed domain names.

A registered trademark constitutes sufficient evidence of rights for the purposes of paragraph 4(a)(i) of the Policy. The Panel therefore finds that the Complainant possesses rights in the ADOBE trademark.

Each of the disputed domain names incorporates the Complainant's ADOBE trademark in its entirety. The addition of the terms "bazar" and "ccpro" does not prevent the Complainant's trademark from remaining clearly recognizable within the disputed domain names. On the contrary, the Panel notes that the letters "CC" could be associated with the Complainant's Creative Cloud software suite, reinforcing rather than diminishing the association with the Complainant.

It is well established that where a domain name wholly incorporates a complainant's trademark, the addition of descriptive or other non-distinctive terms will generally not prevent a finding of confusing similarity.

The ".com" gTLD is generally disregarded for the purposes of the confusing similarity assessment as it is a technical requirement of domain name registration.

Accordingly, the Panel concludes that the disputed domain names are confusingly similar to a trademark in which the Complainant has rights and that the Complainant has satisfied paragraph 4(a)(i) of the Policy.

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

The second element of the Policy requires the Complainant to establish that the Respondent has no rights or legitimate interests in the disputed domain names.

The Panel accepts that the Complainant has established a prima facie case. The burden of production therefore shifts to the Respondent to demonstrate rights or legitimate interests in the disputed domain names. As no Response has been filed, the Panel may draw appropriate inferences from the Respondent's default.

The Complainant states that it has not authorized, licensed or otherwise permitted the Respondent to use the ADOBE trademark or to register domain names incorporating that mark.

There is also no evidence before the Panel that the Respondent has been commonly known by either of the disputed domain names within the meaning of paragraph 4(c)(ii) of the Policy.

The evidence submitted by the Complainant shows that both disputed domain names resolved to the same commercial website prominently displaying the Complainant's ADOBE trademark and logo while purporting to offer software represented as Adobe products together with other well-known software and services such as Microsoft Office, Capcut Pro, Gemini AI Pro and Coursera. Such use is plainly intended to create the impression of an association with the Complainant and does not constitute a bona fide offering of goods or services within the meaning of the Policy. Nor does it constitute a legitimate non-commercial or fair use of the disputed domain names.

The Panel has also considered whether the Respondent's use of the disputed domain names could give rise to rights or legitimate interests under the principles established in Oki Data Americas, Inc. v. ASD, Inc., WIPO Case No. D2001-0903. The evidence before the Panel does not support such a finding on the contrary, the Panel finds that the Respondent fails the Oki Data criteria on several grounds. Firstly, the Respondent's website prominently displayed the Complainant's ADOBE trademark and logo without showing any disclaimer explaining the absence of an official affiliation, thereby creating a false impression of sponsorship or endorsement. Secondly, the website offers unrelated third-party products alongside purported Adobe software. Such use falls well outside the circumstances enumerated in Oki Data in which a reseller may establish rights or legitimate interests under the Policy.

Accordingly, the Panel concludes that the Respondent has no rights or legitimate interests in the disputed domain names and that the Complainant has satisfied paragraph 4(a)(ii) of the Policy.

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

The Panel finds that the Complainant's ADOBE trademark had acquired a substantial international reputation long before the registration of the disputed domain names in 2025.

The disputed domain names each incorporate the Complainant's distinctive ADOBE trademark in its entirety. In the case of <adobeccpro.com>, the inclusion of the letters "CC", could be understood as a reference to Adobe Creative Cloud which is listed as a product for sale on the resolving website, further reinforces the association with the Complainant. Whereas, in <adobebazar.com>, the addition of "bazar" (referencing a marketplace in the Respondent's local region), clearly demonstrates targeted awareness of the Complainant and its product ecosystem. The Panel therefore finds it inconceivable that the Respondent registered the disputed domain names without knowledge of the Complainant and its trademark rights.

The evidence further demonstrates that both disputed domain names resolved to the same commercial website prominently displaying the Complainant's ADOBE trademark and logo and offering software represented as Adobe products. The Panel finds that the Respondent intentionally sought to create the false impression that the website was operated by, affiliated with, or authorized by the Complainant. Such conduct falls squarely within paragraph 4(b)(iv) of the Policy, namely intentionally attempting to attract Internet users for commercial gain by creating a likelihood of confusion with the Complainant's trademark as to the source, sponsorship, affiliation or endorsement of the Respondent's website.

The Panel also notes that, following receipt of the Complainant's cease-and-desist letter, <adobeccpro.com> was redirected to a webpage offering the domain name for sale. While not determinative on its own, this conduct provides further support for a finding of bad faith in the circumstances of this case.

Considering the totality of the circumstances, including:

i) the distinctive and well-known nature of the Complainant's ADOBE trademark;

ii) the incorporation of that trademark in its entirety in both disputed domain names;

iii) the Respondent's use of the disputed domain names to redirect Internet users to the same commercial website prominently displaying the Complainant's trademark and branding;

iv) the Respondent's use of the disputed domain names to create the false impression of an association with the Complainant for commercial gain;

v) the subsequent offer to sell one of the disputed domain names; and

vi) the Respondent's failure to participate in this proceeding,

the Panel concludes that the disputed domain names were registered and are being used in bad faith.

The Complainant has therefore satisfied paragraph 4(a)(iii) of the Policy.