Decision for dispute CAC-UDRP-108887

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 the following registered trademarks:

• The international trademark registration under the Madrid system (IR) "SCHNEIDER ELECTRIC" (figurative) No.715395, registered on March 15, 1999 and protected, inter alia, in Albania, Algeria, Armenia, Austria, the Benelux, Germany, Serbia, Ukraine, the UK, Tajikistan and Zambia;
• the IR "SCHNEIDER S ELECTRIC" (figurative) No.715396, registered on March 15, 1999 and protected, inter alia, in Albania, Algeria, China, Croatia, Egypt, Georgia, Italy, Kazakhstan, Mongolia, Russia, Serbia, Uzbekistan, Ukraine, the UK and Zambia; and
• the European Union (EU) trademark registration "Schneider Electric" (figurative) No.1103803, registered on September 09, 2005.

THE DISPUTED DOMAIN NAME IS IDENTICAL OR CONFUSINGLY SIMILAR TO A TRADEMARK OR SERVICE MARK IN WHICH THE COMPLAINANT HAS RIGHTS 

The Complainant states that it was founded in 1871 and it is a French industrial business trading internationally. It manufactures and offers products for power management, automation, and related solutions. The Complainant is featured on the NYSE Euronext and the French CAC 40 stock market index. The Complainant claims that its revenue amounted to 40 billion Euro in 2025.

The Complainant refers to its trademark registrations ("Trademarks") listed above and to its portfolio of domain names that include the "SCHNEIDER ELECTRIC" mark, including <schneiderelectric.com> registered since April 4, 1996.

The disputed domain name was registered on July 07, 2026 and is passively held (does not resolve to any active site).

The Complainant submits that the disputed domain name is confusingly similar to its Trademarks. The substitution of the letter “i” by the letter “L” in "ELECTRIC" represents a typosquatting practice intended to create confusing similarity between the Complainant’s trademark and the disputed domain name, as confirmed by previous UDRP decisions.

The Complainant contends that the addition of the gTLD “.COM” does not change the overall impression of the designation as being connected to the Complainant’s trademark and does not prevent a likelihood of confusion.

Therefore, the Complainant claims the disputed domain name is confusingly similar to its trademark.

THE RESPONDENT HAS NO RIGHTS OR LEGITIMATE INTERESTS IN RESPECT OF THE DISPUTED DOMAIN NAME 

While the Respondent is identified as "schneiderelectrlc", the Complainant argues that the company "schneiderelectrlc" does not exist and that the Respondent registered the disputed domain name under this name to increase the risk of confusion and to unduly justify the registration of the disputed domain name.

The Complainant contends that the Respondent is not affiliated with nor authorized by the Complainant in any way. The Complainant contends that the Respondent has no rights or legitimate interests in respect of the disputed domain name. The Complainant does not carry out any activity for, nor has any business with the Respondent.

Neither license nor authorization has been granted to the Respondent to make any use of the Complainant’s Trademarks or apply for registration of the disputed domain name by the Complainant.

The Complainant also claims that the disputed domain name is a typosquatted version of the Complainant's trademark. Typosquatting is the practice of registering a domain name in an attempt to take advantage of Internet users’ typographical errors and it demonstrates that the Respondent lacks rights and legitimate interests in the disputed domain name.

Passive holding of the disputed domain name does not create any rights or legitimate interest of the Respondent.

Based on the above, the Complainant claims that the second element of the UDRP has been satisfied.

THE DISPUTED DOMAIN NAME WAS REGISTERED AND IS BEING USED IN BAD FAITH

The Complainant's submissions on the bad faith element can be summarized as follows:

• The Complainant claims that its trademark is well-known and refers to previous decisions of UDRP panels that confirm the well-known character of the Complainant’s trademark. Given the distinctiveness of the Complainant's trademark and its reputation, it is reasonable to infer that the Respondent has registered and used the domain name with full knowledge of the Complainant's trademark;
• The disputed domain name is a misspelling of the Complainant's trademark and this, in the Complainant's view, indicates bad faith registration and use; and
• The Complainant relies on the "passive holding" doctrine as provided in sec. 3.3 of WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”) and submits that it is not possible to conceive of any plausible actual or contemplated active use of the domain name by the Respondent that would not be illegitimate, such as by being a passing off, an infringement of consumer protection legislation, or an infringement of the Complainant’s rights under trademark law.

The Complainant's contentions are summarized in the Factual Background section above.

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.

A. Identical or confusingly similar

The Complainant provided evidence of its Trademark registrations protected in various jurisdictions.

As confirmed by WIPO Overview 3.1: “where the complainant holds a nationally or regionally registered trademark or service mark, this prima facie satisfies the threshold requirement of having trademark rights for purposes of standing to file a UDRP case” (see sec. 1.2.1).

Therefore, the Complainant proved it has trademark rights.

The test for confusing similarity under the UDRP is relatively straightforward and typically involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name. 

The disputed domain name is an obvious misspelling of the Complainant's Trademarks (their word elements) and the Panel agrees with the consensus view provided in sec. 1.9 of WIPO Overview 3.1: "A domain name which consists of a variation of a trademark (typically a common, obvious, or intentional misspelling, referred to as typosquatting) is considered by panels to be confusingly similar to the relevant mark for purposes of the first element".

The Trademarks are recognizable within the disputed domain name.

The gTLD “.com” is to be disregarded under the confusing similarity test as it does nothing to eliminate confusion.

Therefore, the Panel finds that the first requirement of the Policy has been satisfied. 

B. Rights or Legitimate Interests

The general rule is the following:

(i) a complainant is required to make out a prima facie case that the respondent lacks rights or legitimate interests; and

(ii) once such prima facie case is made, the burden shifts to the respondent who has to demonstrate his rights or legitimate interests in respect of the domain name under paragraph 4 (c) of the Policy. 

If the respondent fails to do so, the second element of the Policy is satisfied, see Julian Barnes v. Old Barn Studios, WIPO Case No. D2001-0121; Belupo d.d. v. WACHEM d.o.o., WIPO Case No. D2004-0110.

The Respondent did not respond.

While failure to respond does not per se demonstrate that the Respondent does not have rights or legitimate interests, it allows the Panel to draw such inferences as it considers appropriate, see paragraph 14(b) of the Rules and CAC Case No. 101284: “A respondent is not obliged to participate in a proceeding under the Policy, but if it fails to do so, reasonable inferences may be drawn from the information provided by the complainant”.

The Complainant has made a prima facie case of the Respondent’s lack of rights or legitimate interests.

The disputed domain name does not resolve to any page with content and is passively held.

There are no circumstances in this dispute that would demonstrate any rights or legitimate interest of the Respondent.

The Panel notes that the Respondent's organization is identified as "schneiderelectrlc". When a name of Respondent's company/organization corresponds to the disputed domain name, this could give rise to rights or legitimate interest of the Respondent provided that this company/organization is real and is engaged in bona fide and genuine activities.

There is no evidence in this dispute that the Respondent's alleged "schneiderelectrlc" company/organization actually exists. Based on the facts and evidence available in this dispute and based on the Panel's own independent research conducted under par. 10 of the UDRP Rules, there is no such organization, and this appears to be just a typosquatted version of the Complainant's company name and the Trademarks.

The Panel therefore agrees with Complainant's statement that this name was chosen to "unduly justify the registration of the disputed domain name" and this name appears to be false.

The nature of the disputed domain name is such that it creates an association with the Complainant and its business, it includes a misspelled version of the Complainant’s trademark and its company name.

Previous UDRP panels noted that in such circumstances respondent does not have rights or legitimate interests, see e.g. CAC Case No. 104298: “The disputed domain names are typosquatted versions of its trademark which is further proof that the Respondent has no rights or legitimate interests under the Policy…” and CAC Case No. 108152: “The Panel notes that the disputed domain name is clearly a typosquatting of the Complainant’s trademark, so that this Panel finds it most likely that employing a misspelling in this way signals an intention on the part of the Respondent to confuse users seeking or expecting the Complainant”.

Typosquatting does not create any rights or legitimate interests of the Respondent, in particular taking into account the circumstances of this case such as the use of a false organization name and passive holding of the disputed domain name.

Therefore, the Panel finds that the Complainant has satisfied the second element of the Policy. 

C. Registered and Used in Bad Faith 

Paragraph 4(b) of the Policy lists non-exhaustive circumstances indicating registration and use in bad faith.

These circumstances are non-exhaustive and other factors can also be considered.

It is well established that bad faith under the UDRP is broadly understood to occur where a respondent takes unfair advantage of or otherwise abuses a complainant’s mark (see 3.1 of WIPO Overview 3.0). Targeting with the intent to take unfair commercial advantage is important in establishing bad faith under the UDRP.

As stated in UDRP Perspectives on Recent Jurisprudence ("UDRP Perspectives"), updated on June 02, 2025, sec. 3.3: “targeting can be established by either direct evidence (e.g. content of the website) or circumstantial evidence such as strength of the mark and nature of a disputed domain name (e.g. mark plus a term describing Complainant’s business), timing of registration of a domain name and timing of trademark registration, geographic proximity of the parties”.

Targeting is "a key factor in determining bad faith. Targeting a mark or having it in mind with a preformed intention of capitalizing on its market value is the basic factor for determining bad faith..." (see “The Clash of Trademarks and Domain Names on the Internet”,  Volume 1, Gerald M. Levine 2024, “Legal Corner Press”, page 466).

Here, evidence indicates that the Respondent targeted the Complainant and such targeting was with intent to profit commercially from the Complainant’s Trademarks.

The Panel finds that the disputed domain name was registered and is being used in bad faith based on the following:

1. The nature of the disputed domain name (“typosquatting”) and the timing of the registration of the disputed domain name – July 7, 2026, many years after the registration of the Trademarks and launch of Complainant's business under the same name; 
2. The strength and reputation of the Complainant’s trademark. The Complainant alleges that its mark is well-known and refers to previous UDRP decisions. The Panel notes that the Complainant provided only limited evidence of the well-known character of the Trademarks (only screenshots of its own website and references to previous UDRP decisions). Normally, more evidence is required to establish that a trademark is well-known/ has a strong reputation (e.g. evidence of awards, publications by independent sources, etc.). However, this is not fatal to the Complainant in the present dispute. The Panel indeed finds that the mark is widely known despite limited evidence provided by the Complainant. Panel’s own limited independent research of publicly available sources also confirmed the well-known character of the Complainant’s trademark (exercising its powers under par. 10 of the UDRP Rules), such as “Wikipedia” article and publications about the Complainant and its activities in different countries.

3. Passive holding of the disputed domain name in the circumstances of this case indicates both registration and use in bad faith.

   WIPO Overview 3.1 states that “from the inception of the UDRP, panelists have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding”. The Panel notes that passive holding per se does not indicate bad faith and the totality of the circumstances is important, see sec. 3.3 of WIPO Overview and sec. 3.7 of UDRP Perspectives. However, the totality of circumstances of this dispute demonstrates bad faith of the Respondent, in particular: i) strength of the Complainant’s mark, ii) failure of the Respondent to respond and take part in this proceeding, iii) use of false or inaccurate contact details (use of a false company name in this case) and iv) the implausibility of any good faith use to which the domain name may be put – the Panel does not find any circumstances under which the Respondent could legitimately use the disputed domain name that is so closely associated with the Complainant and is a typosquatted version of the Trademarks and Complainant's name. Any possible explanation of a potential legitimate use is solely within the Respondent’s knowledge, and the Respondent failed to respond and provide any explanations.

   The Panel finds that this is a clear case of targeting and an attempt to take unfair advantage of the Complainant’s trademark and reputation by the Respondent. There are no rights or legitimate interests of the Respondent taking into account the evidence and facts of this case, and the only apparent reason for registration of the disputed domain name is the intent of the Respondent to take advantage of the Complainant’s mark and business reputation.

   Based on the above, the Panel finds that Respondent’s behavior falls within, at least, par. 4 b (iv) of UDRP and the Respondent by using the disputed domain name has intentionally attempted to attract, for commercial gain, Internet users to his web site, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement and that the Respondent targeted the Complainant with intent to take unfair advantage of the Complainant’s mark and that, in itself, demonstrates bad faith registration and use.

   The Panel holds that the third requirement of the Policy has been satisfied.