Decision for dispute CAC-UDRP-108809

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 is the owner of several trademarks consisting of the terms “ADOBE”, and “PHOTOSHOP”, such as:

• EU TM n. 009595356 – “ADOBE” – Nice 9, 35, 42;
• US TM n. 1475793 – “ADOBE” – Nice 9;
• EU TM n. 018316507 – "" – Nice Cl. 9, 35, 42;
• EU TM n. 018316508 – "" – Nice Cl. 9, 35, 42;
• US TM n. 1901149 – “A ADOBE” – "" – Nice 9;
• WO TM n. 1334389 – “PHOTOSHOP” – Cl. 9, 42;
• WO TM n. 000202549 – “PHOTOSHOP” – Cl. 9, 38, 42;
• EU TM n. 018075339 – “PS”, “” – Cl. 9;
• US TM N. 1850242 – “PHOTOSHOP”, “” – Cl. 9;
• US TM N. 3702607 – “PHOTOSHOP”, “” – Cl. 39; 42;
• US TM N. 74038526 – “ADOBE PHOTOSHOP”, “” – Cl. 9;
• US TM N. 6251927 – “PS”, “” – Cl. 9;
• CN TM N. 573256 – “PHOTOSHOP” - 9;
• CN TM N. 25688909 – “PHOTOSHOP” - 35;
• HK TM No. 1994B07103 – “PHOTOSHOP” – Cl. 9.

Different copies of the trademark certificates were included within the Complaint.

FACTS ASSERTED BY THE COMPLAINANT AND NOT CONTESTED BY THE RESPONDENT:

The Complainant is Adobe Inc., a leading global technology company specializing in the development of software and digital media solutions. Since its establishment in 1982, Adobe has played a pioneering role in shaping the digital content industry, offering innovative tools that enable individuals and businesses to create, manage, and deliver digital content. Over the years, Adobe has established a strong international presence and built a highly recognized and reputable brand associated with innovation, quality, and creativity in the digital space.

The Complainant is a globally active technology company whose products and services are used across multiple markets and industries worldwide.

The Complainant is widely recognized as one of the world’s leading companies in the development of professional software for digital media creation, publishing, and communication. The Complainant offers a comprehensive portfolio of industry-standard applications, including, inter alia, Adobe Photoshop for image editing, Adobe Illustrator for vector graphics, Adobe Premiere Pro and Adobe After Effects for video editing and compositing, and Adobe InDesign for digital publishing. These products are extensively used by professionals, enterprises, and organizations worldwide, and have become indispensable tools within their respective industries. Furthermore, Adobe has played a pivotal and foundational role in the evolution of digital documentation through the development of the Portable Document Format (“PDF”), which has become a globally recognized standard enabling the reliable and consistent exchange of documents across different platforms and operating systems.

Among the Complainant’s principal products, Adobe Photoshop is a widely known software application for digital image editing and manipulation. First developed in the late 1980s and commercially released in 1990, Photoshop has been progressively adopted across a broad range of sectors, including publishing, advertising, web design, film production, and other creative industries. The software provides a comprehensive set of tools for the processing and modification of raster images, including functionalities such as layered editing, image compositing, and advanced color management.

Over time, Photoshop has achieved a particularly high degree of recognition among both professionals and the general public, reflecting its extensive use in everyday digital imaging practices. Its name has entered common language as a reference to image editing processes, which further demonstrates its level of diffusion and public awareness. As a result, Photoshop constitutes a well-established and widely recognized component of the Complainant’s software portfolio, contributing significantly to Adobe’s presence in the global digital media sector-

With more than thirty-five years of continuous commercial use, Adobe Photoshop has become one of the most widely recognized image editing software applications worldwide. Throughout this period, it has been consistently promoted and distributed by the Complainant, contributing to its widespread adoption and public recognition. The high degree of recognition associated with Photoshop is further evidenced by the fact that the term “Photoshop” is frequently used in common language to refer to digital image editing more generally. The Complainant has taken active steps over time to protect and enforce its rights in the PHOTOSHOP mark, ensuring its continued distinctiveness and association with the Complainant’s software products.

In addition, Adobe Photoshop has achieved top‑tier recognition in the field of digital imaging as a result of its long-standing presence and consistent integration across a wide range of professional practices. The software has become closely associated with image processing activities and is routinely used across industries such as publishing, advertising, and digital media production. Its impact extends beyond technical usage, as it has contributed to shaping industry practices and expectations in digital visual content creation, thereby reinforcing the distinctiveness and recognition of the PHOTOSHOP mark.

The Complainant holds since decades multiple trademark registrations that include or consist of the terms “ADOBE”, and “PHOTOSHOP” across various jurisdictions.

Among the trademark portfolio of the Complainant, the following are the most notable:

• EU TM n. 009595356 – “ADOBE” – Nice 9, 35, 42;
• US TM n. 1475793 – “ADOBE” – Nice 9;
• EU TM n. 018316507 – "" – Nice Cl. 9, 35, 42;
• EU TM n. 018316508 – "" – Nice Cl. 9, 35, 42;
• US TM n. 1901149 – “A ADOBE” – "" – Nice 9;
• WO TM n. 1334389 – “PHOTOSHOP” – Cl. 9, 42;
• WO TM n. 000202549 – “PHOTOSHOP” – Cl. 9, 38, 42;
• EU TM n. 018075339 – “PS”, “” – Cl. 9;
• US TM N. 1850242 – “PHOTOSHOP”, “” – Cl. 9;
• US TM N. 3702607 – “PHOTOSHOP”, “” – Cl. 39; 42;
• US TM N. 74038526 – “ADOBE PHOTOSHOP”, “” – Cl. 9;
• US TM N. 6251927 – “PS”, “” – Cl. 9;
• CN TM N. 573256 – “PHOTOSHOP” - 9;
• CN TM N. 25688909 – “PHOTOSHOP” - 35;
• HK TM No. 1994B07103 – “PHOTOSHOP” – Cl. 9.

The disputed domain names were registered by the Respondent on November 20, 2025 (<photoshop-ps.top>), and January 2, 2026 (<ps-photoshop.top>), (hereinafter, the “Disputed Domain Names”), without the Complainant’s authorization. The Disputed Domain Names currently resolve to the websites which make unauthorized reference to the Complainant’s “PHOTOSHOP”, and “PS” both word and figurative trademarks. Given that the websites reproduce templates clearly designed to impersonate Complainant’s “PHOTOSHOP”, this use is likely to mislead consumers and create confusion regarding a potential affiliation with the Complainant.

According to Complainant’s non-contested allegations, the Complainant’s trademarks “PS” and “PHOTOSHOP” have been misused in the Disputed Domain Names and throughout the content of the websites associated. The Respondent’s clear intent appears to be to impersonate the Complainant by falsely presenting itself as a partner or affiliate. In particular, given that the Respondent uses the Complainant’s trademarks both within the Disputed Domain Names and throughout the related content of the websites, unsuspecting internet users are likely to be misled into believing that the Disputed Domain Names are affiliated with, or endorsed by, the Complainant.

In light of the Respondent’s abusive registration and use of the Disputed Domain Names – which are confusingly similar to the Complainant’s registered and well-known trademarks – the Complainant instructed its authorized representative to notify the Respondent of the infringement of its trademark rights, formally requesting the immediate cessation of the unauthorized use and the transfer of the Disputed Domain Names.

However, since the Respondent’s contact details were not publicly available, the only means of communication was through the online contact form present on the websites of the Registrar of the Disputed Domain Names.

The Complainant duly submitted a formal notice via this channel on June 18, 2026, with the purpose of requesting the immediate cessation of the unauthorized use of the Complainant’s trademarks and the transfer of the Disputed Domain Names.

In the absence of a reply and failing to comply with the request for transfer of the Disputed Domain Names, the Complainant decided to file the present Complaint in order to obtain the transfer of the Disputed Domain Names under its ownership and control.

For the purpose of this case, the Registrar confirmed that the Respondent is the current registrant of the Disputed Domain Names and that the language of the registration agreement is English.

The facts asserted by the Complainant are not contested by the Respondent.

NO ADMINISTRATIVELY COMPLIANT RESPONSE HAS BEEN FILED.

COMPLAINANT:

First element: Similarity

The Complainant has rights in respect of the “ADOBE”, “PHOTOSHOP”, and “PS” trademarks for the purposes of the Policy, pursuant to section 1.2.1 of the WIPO Overview 3.0.

In the present case, the Disputed Domain Names display confusing similarity to the Complainant’s trademarks, as they incorporate the Complainant’s well-known “PS” and “PHOTOSHOP” trademarks in their entirety within the Disputed Domain Names “photoshop-ps.top” and “ps-photoshop.top”. The association of the element “PS” with the hyphen and the “PHOTOSHOP” mark does not preclude a finding of confusing similarity; on the contrary, it reinforces the association with the Complainant’s products, creating the impression of a direct impersonation of the Adobe-owned trademark.

Accordingly, the association between those two trademarks does not materially affect the overall impression conveyed by the Disputed Domain Names, which remains clearly recognizable as containing the Complainant’s trademarks. Rather, it increases the likelihood that Internet users will perceive the Disputed Domain Names as being related to the Complainant or its software offerings.

Panels have consistently held that the complete incorporation of a complainant’s mark into a domain name is sufficient to establish identity or confusing similarity under the Policy. The Complainant’s trademark rights are evidenced by the trademark registration certificates and corresponding database extracts from competent Trademark Offices.

In light of the above, the Complainant respectfully submits that the Disputed Domain Names are confusingly similar to the Complainant’s prior registered trademarks, in accordance with Paragraph 4(a)(i) of the Policy.

Second element: Rights or legitimate interest

As a preliminary observation, it is well established in prior UDRP decisions that the mere registration of a domain name does not, in itself, confer rights or legitimate interests upon the registrant. 

The Respondent is neither a licensee nor an authorized distributor of the Complainant and has received no permission—express or implied—to use the Complainant’s “PS”, and “PHOTOSHOP” trademarks or to register the Disputed Domain Names incorporating them. The Complainant has not granted the Respondent any rights to operate domain names identical or confusingly similar to its trademarks.

The Respondent uses the Disputed Domain Names to promote tools that purport to enable users to download the Complainant’s software, namely Adobe Photoshop, in unauthorized form through the Respondent’s websites. Such use clearly targets the Complainant’s products and is inherently illegitimate, as it is based on the unauthorized distribution and exploitation of the Complainant’s software. Accordingly, such use cannot constitute a bona fide offering of goods or services, nor any legitimate non-commercial or fair use.

Moreover, the websites prominently display the Complainant’s word marks as well as the recognizable “PS” figurative marks associated with Photoshop, thereby further increasing the likelihood of confusion and reinforcing the false impression that the website is affiliated with, endorsed by, or otherwise authorized by the Complainant—none of which is the case.

The Panel has held that the use of a domain name for illegal activity (e.g. phishing, scams, unauthorized account access/hacking, impersonation/passing off, or other types of fraud) can never confer rights or legitimate interests on a respondent (WIPO Overview 3.0, section 2.13.1.).

For all the reasons set out above, the Complainant respectfully submits that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Names in accordance with Paragraph 4(a)(ii) of the Policy.

Third element: Bad faith

As to the assessment of the Respondent’s bad faith at the time of registration, in light of the Complainant’s trademark filings and the widespread use of the “PS” and “PHOTOSHOP” trademarks, it is inconceivable that the Respondent was unaware of the Complainant’s rights when registering the Disputed Domain Names.

On the contrary, in light of the content of the websites, it can reasonably be inferred that the Respondent has, from the outset, intentionally sought to exploit the Complainant’s trademarks and reputation in order to derive an illicit commercial benefit.

Furthermore, the Respondent reinforces the misleading impression of affiliation through the content of the websites associated with the Disputed Domain Names. In particular, the footer of the website at photoshop-ps.top states “© 2025 Photoshop Official Website. All rights reserved”. Such representation, especially when combined with the use of the “©” symbol, falsely suggests that the website is an official source or is otherwise endorsed by the Complainant.

Such misleading statement is clearly intended to create a false appearance of legitimacy and affiliation, thereby inducing Internet users to trust the content of the website. In turn, this may lead users to download software or materials under the mistaken belief that they originate from, or are authorized by, the Complainant, which is not the case. Such conduct constitutes a further attempt to impersonate the Complainant and to exploit its well-known trademarks for deceptive purposes.

In addition, the website includes several references to downloadable versions of Photoshop and repeatedly displays “download” prompts intended to induce users to access unverified and unauthorized links. This conduct not only reinforces the misleading association with the Complainant’s products but also creates a significant risk for users, including exposure to untrustworthy or potentially harmful content.

Notably, the Disputed Domain Names resolve to websites on which the Complainant’s trademarks are prominently and unduly displayed, further demonstrating that the Respondent was fully aware of the Complainant’s brand and deliberately sought to associate its own offerings with it. Such conduct constitutes clear evidence of bad‑faith registration and use under the Policy.

Moreover, considering that the Disputed Domain Names incorporate the Complainant’s trademarks in their entirety, it is untenable to suggest that the Respondent was unaware that it was making unauthorized use of the Complainant’s mark in both the Disputed Domain Names and the associated websites’ content. Despite this, the Respondent never sought authorization from the Complainant to use the trademark within the Disputed Domain Names. On the contrary, the Respondent sought to exploit the mark’s notoriety without permission and subsequently failed to respond when contacted by the Complainant in an effort to explore an amicable resolution.

With reference to the above, the Complainant highlights that it has been stated in various decisions that the registration of a domain name with the knowledge of the complainant’s trademarks is evidence of bad faith.

The Respondent’s registration of the Disputed Domain Names occurred at a time when the Complainant’s PHOTOSHOP brand had already gained notable visibility. The Respondent’s decision to register domain names identical to the Complainant’s distinctive mark cannot be reasonably viewed as coincidental. Instead, it reflects a calculated attempt to benefit from the Complainant’s growing reputation and to mislead users by appropriating a brand that has already achieved recognition in the relevant commercial and technological landscape. This conduct is carried out with the intent of obtaining a commercial advantage by inducing unsuspecting Internet users to access the websites and click on unverified and potentially harmful links, under the false impression that they may obtain a free version of Adobe Photoshop, thereby exposing them to significant security and reliability risks.

In light of the extensive evidence submitted and the significant commercial presence of the “PS”, and “PHOTOSHOP” trademarks, its well‑established and widely recognized notoriety is unequivocal.

Further support for this conclusion is provided in paragraph 3.2.1 of the WIPO Overview, which identifies factors Panels may consider in assessing bad faith, including whether the domain names are an exact match of a well‑known mark, the timing of the registration, and the content of the websites. Here, the Disputed Domain Names reproduce the Complainant’s “PS”, and “PHOTOSHOP” trademarks in their entirety, with only the addition of a hyphen “-“ between them. Both Disputed Domain Names and the associated content therefore directly reference the Complainant’s Photoshop programme.

Taken together, these circumstances clearly demonstrate that the Respondent registered and is using the Disputed Domain Names in bad faith, with the intent to exploit the Complainant’s brand recognition and goodwill. The factual context leaves little doubt that the Respondent was aware of the Complainant’s activities and deliberately sought to benefit from its commercial success.

In its decisions, Panels have held that the use of a domain name for illegal activity (e.g., the sale of counterfeit goods or illegal pharmaceuticals, phishing, distributing malware, unauthorized account access/hacking, impersonation/passing off, or other types of fraud) constitutes bad faith (see WIPO Overview 3.0, section 3.4.).

When the Complainant became aware of the registration and use of the Disputed Domain Names by the Respondent, it instructed the Legal Representative to serve the Respondent with cease and desist letter in order to formally notify the Respondent of the infringement of the Complainant’s trademark rights, requesting the immediate cease of any use, and the transfer of the Disputed Domain Names to the Complainant.

Finally, the Respondent never sought authorization from the Complainant to use “PS”, and “PHOTOSHOP” trademarks within the Disputed Domain Names. On the contrary, when the Complainant attempted to engage the Respondent through the available contact form in an effort to pursue an amicable resolution, the Respondent failed to reply.

This absence of cooperation, combined with the Respondent’s refusal to respond to official communications, further underscores its bad-faith intent and its failure to demonstrate any bona fide basis for the registration or use of the Disputed Domain Names. The Complainant firmly believes that the Disputed Domain Names were registered in bad faith and are currently being used in bad faith, in full satisfaction of this paragraph.

RESPONDENT

Respondent did not reply to the Complaint.

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.

1. Preliminary Issue: Consolidation of Complaint consolidated against multiple respondents

Paragraph 10(e) of the UDRP Rules grants a Panel the power to consolidate multiplate domain name disputes. At the same time, paragraph 3(c) of the UDRP Rules provides that a complaint may relate to more than one domain name, provided that the domain names are registered by the same domain-name holder. 

In assessing whether a complaint can be filed against multiple respondents, panels look at whether (i) the domain names or corresponding websites are subject to common control, and (ii) the consolidation would be fair and equitable to all parties. Procedural efficiency would also underpin panel consideration of such a consolidation scenario.

See paragraph 4.11.2 of the WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition 3.1 (“WIPO Jurisprudential Overview 3.1.”).

The Complainant requested this Panel to analyze the possibility that the Disputed Domain Names and the named Respondent should be consolidated in a single UDRP proceeding. The Registrar’s disclosure dated July 3, 2026 has confirmed that the Disputed Domain Names were registered by same person so there is no need to analyze in more detail this specific aspect.

2. Substantive Issues 

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 the Disputed Domain Names should be transferred or cancelled:

(i) the Disputed Domain Names are 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 Disputed Domain Names; and

(iii) the Disputed Domain Name have been registered and are being used in bad faith.

The Panel has reviewed in detail 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.

Paragraph 4(a)(i) of the Policy establishes the obligation of Complainant to demonstrate that the Disputed Domain Names is identical or confusingly similar to a trademark or service mark in which the Complainant has rights.

The Complainant submitted copies of different trademarks registrations pertaining the terms “PHOTOSHOP”, and “PS” for computer software for creating, viewing, manipulating, editing, managing, indexing, cataloguing, sorting, organizing, storing, transferring, synchronizing, printing, and exchanging digital photographs, digital and graphic images, data, text, audio, video, multimedia and interactive documents and works, text documents, and recorded information, among many others products and services.

The Complainant’s trademarks were registered prior to 2025, the first year of the creation date of the oldest of the Disputed Domain Names.

The disputed domain names were registered by the Respondent on November 20, 2025 (<photoshop-ps.top>), and January 2, 2026 (<ps-photoshop.top>).

In the current case, the Disputed Domain Names are composed of the trademarks “PHOTOSHOP”, and “PS” with a hyphen in the middle; i.e. photoshop-ps.top & ps-photoshop.top.

In assessing confusing similarity, the Panel finds the Disputed Domain Names are confusingly similar to the Complainant’s trademark, as it incorporates the entirety of the

“PHOTOSHOP”, and “PS” trademarks plus a hyphen in the middle of the composition of the Disputed Domain Names. In this regard, UDRP panels agree that 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 - see paragraph 1.8. of the WIPO Jurisprudential Overview 3.1.

UDRP panels agree that the TLD may usually be ignored for the purpose of determination of identity or confusing similarity between a domain name and the Complainant’s trademark as it is technical requirement of registration. See paragraph 1.11.1 of WIPO Jurisprudential Overview 3.0.

Therefore, the Panel concludes that the Complainant has satisfied the requirement under paragraph 4(a)(i) of the Policy and the Disputed Domain Names are confusingly similar to Complainant’s “PHOTOSHOP” and “PS” trademarks.

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

The second element of the Policy requires that the Complainant establishes that the Respondent has no rights or legitimate interests in the Disputed Domain Names. 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 with relevant evidence demonstrating rights or legitimate interests in the domain name; see, for example, CAC Case No. 102333, Amedei S.r.l. v sun xin. If the Respondent fails to do so, the Complainant is deemed to have satisfied paragraph 4(a)(ii) of the Policy (see e.g. WIPO case no. D2003-0455, Croatia Airlines d.d. v. Modern Empire Internet Ltd.).

In this regard, Paragraph 4 (c) provides with circumstances which could prove rights or legitimate interest in the Disputed Domain Name on behalf of the Respondent such as:

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

(ii) The Respondent (as an individual, business, or other organization) has been commonly known by the Disputed Domain Name, even if the Respondent has acquired no trademark or service mark rights; or

(iii) The Respondent is making a legitimate noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

For the present case, the Complainant has confirmed in the Complaint that the Disputed Domain Names are not connected with or authorized by the Complainant in any way.

From the information provided by the Complainant, there is no evidence or reason to believe that the Respondent (as individual, business or other organization) has been commonly known by the Disputed Domain Names. 

The Respondent’s name “jiang jiang” is all what it links the Disputed Domain Names with the Respondent. Absent of any other evidence such as a personal name, nickname or corporate identifier, the Panel is of the opinion that the Respondent is not commonly known by the Disputed Domain Names.

The Complainant indicates that they have not granted authorization to the Respondent to use their “PHOTOSHOP”, and “PS” trademarks.

In terms of the evidence provided by the Complainant, the websites connected to the Disputed Domain Names offer non-authorized versions of Complainant’s products and for this purpose, the Complainant presented a screenshot of the websites connected to the Disputed Domain Names where the use of the Complainant´s trademarks can be seen.

Past panels have recognized that resellers, distributors, or service providers using a domain name containing the complainant’s trademark to undertake sales or repairs related to the complainant’s goods or services may be making a bona fide offering of goods and services and thus have a legitimate interest in such domain name provided the following cumulative requirements (“Oki Data test”) are taken into account: 

(i) the respondent must actually be offering the goods or services at issue;

(ii) the respondent must use the site to sell only the trademarked goods or services;

(iii) the site must accurately and prominently disclose the registrant’s relationship with the trademark holder; and 

(iv) the respondent must not try to “corner the market” in domain names that reflect the trademark. 

See paragraph 2.8 of WIPO Jurisprudential Overview 3.1. 

From the evidence presented by the Complainant and not contested by the Respondent, it is clear that the Respondent is offering the Complainant’s products without disclosing the Respondent’s relationship via a proper disclaimer of explanation with the Complainant. In fact, in the footer of the website connected to the Disputed Domain Name <photoshop-ps.top> states “© 2025 Photoshop” – which wrongly suggests that the website is an official source or is otherwise endorsed by the Complainant. Furthermore, the Respondent is also using the Complainant’s trademarks at the top of the websites without proper authorization. This use does not meet the criteria laid down in the Oki Data Test and, therefore, the Respondent cannot be considered as acting with goodwill since the current use makes the Panel to believe that the Disputed Domain Names were registered with intent for commercial gain to misleadingly divert consumers or to tarnish the trademarks or service marks at issue.

Therefore, the Panel neither finds a bona fide offering of goods and service nor legitimate non-commercial or fair use of the Disputed Domain Names.

The fact that Respondent did not reply to the Complaint gives an additional indication that the Respondent lacks rights or legitimate interest since the Respondent did not provide with evidence of the types specified in paragraph 4 (c) of the Policy, or of any circumstances, giving rise to rights or legitimate interests in the Disputed Domain Names.

Therefore, the Panel concludes that neither the Respondent nor the evidence establishes that the Respondent has any right or legitimate interest to the Disputed Domain Names. 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 NAMES.

For the current case, the evidence at hand confirms that Complainant’s “PHOTOSHOP” trademark is distinctive and it has a strong reputation in the in the fields of digital media, software development, photography, and creative content production. In addition, the Complainant’s trademarks “PHOTOSHOP” and “PS” were registered long before the Disputed Domain Names were created. Based on those elements, the Panel is of the opinion that Respondent knew or should have known that the registration of the Disputed Domain Names would be confusingly similar to the “PHOTOSHOP” AND “PS” trademarks.

Furthermore, the Complainant provided with evidence showing that the Disputed Domain Names were set up by the Respondent to create websites which offers non authorized versions of Complainant’s products with the purpose of misleading internet consumers who are attempting to purchase authorized products through the Disputed Domain Names. In this sense, the Complainant has confirmed that no authorization was granted to the Respondent to register the Disputed Domain Names, and no counterargument has been submitted by Respondent. This is a clear indication that the Disputed Domain Names were set up with the only intention to attract 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. 

A last element refers to the sending of abuse reports or Cease & Desist (“C&D”) letters by Complainant to the Respondent. In both cases, the Complaint provided with evidence about sending a “C&D” letter to Respondents on June 18, 2026 without receiving any reply by Respondent. The failure of the Respondent to answer the Complainant’s Complaint and take any part in these proceedings as well as the C&D letter sent by Complainant also suggests in combination with other factors bad faith on the part of the Respondent. See for instance, UDRP WIPO Case Nr. 2016-1695 International Business Machines Corporation vs Adam Stevenson, Global Domain Services concerning the domain ibmresearchgroup.com, where the Panel indicated the following: „The longstanding use of the IBM mark by Complainant is further evidence of the requisite bad faith insofar as such fact strongly suggests that Respondent was aware of Complainant’s mark as of the time it registered the disputed domain name. Respondent’s failure to respond to Complainant’s “cease and desist” letters is further evidence of bad faith“. 

In light of the evidence presented to the Panel, including: a) the likelihood of confusion between the Disputed Domain Names and the Complainant’s “PHOTOSHOP” and “PS” trademarks, b) the lack of reply to this Complaint by Respondent incl. the C&D letter sent by Complainant to Respondent, and c) the fact that the Disputed Domain Names were being used for a website offering non authorized products of the Complainant’s  with the purpose to mislead internet consumers, the Panel draws the inference that the Disputed Domain Names were registered and are being used in bad faith.