Decision for dispute CAC-UDRP-108993

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 has established that it owns the following registered trademarks:

• the International trademark for FRONTLINE, registered number 621912, registered with WIPO on June 9, 1994;
• the International trademark for FRONTLINE, registered number 1245236, registered with WIPO on January 30, 2015;

(collectively the “FRONTLINE trademark“).

The Complainant, Boehringer Ingelheim Animal Health France, is a French company that is a global leader in the animal health industry and part of the family-owned Boehringer Ingelheim group, founded in 1885. Its FRONTLINE trademark is indicated professionally in its industry for the treatment and the prevention of fleas, ticks and chewing lice in dogs and cats, breaking the life cycle of those infestations and aiding in the control of sarcoptic mange in dogs.

The Complainant provides its goods and services under the FRONTLINE trademark.

As well as the FRONTLINE trademark, the Complainant registered the domain name <frontline.com> on January 28,1999 which it uses in its business to promote its goods and services under the FRONTLINE trademark on the internet and to enable its customers to avail themselves of the Complainant's goods and services.

It has come to the notice of the Complainant that, without any permission to do so, and well after the Complainant had acquired its aforesaid trademark rights, the Respondent registered the domain name <frontline-spot-on.store> ("the Disputed Domain Name") on July 27, 2026 which consists of the FRONTLINE trademark, the generic words “spot” and “on”, some minor punctuation and the Top Level Domain “.store.” It has also come to the notice of the Complainant that the Respondent has caused the Disputed Domain Name to resolve to a website that purports to sell the Complainant’s FRONTLINE products. The Complainant maintains that this is a clear infringement of its FRONTLINE trademark and the Policy.

The Complainant has therefore come to the conclusion that it should institute this proceeding under the Uniform Domain Name Dispute Resolution Policy ("the Policy") to protect its trademark rights and to protect innocent internet users who may be induced to believe that the Disputed Domain Name and the website to which it resolves are genuine, whereas the Complainant maintains that they are entirely illegal. The Complainant therefore brings this proceeding to obtain the transfer of the Disputed Domain Name to itself.

The Complainant seeks to have the Disputed Domain Name transferred on the grounds that it is confusingly similar to the FRONTLINE trademark, that the Respondent has no rights or legitimate interests in it and that the Respondent has registered and used it in bad faith. 

COMPLAINANT

1. The Complainant, Boehringer Ingelheim Animal Health France, is a French company that is a global leader in the animal health industry and part of the family-owned Boehringer  Ingelheim group, founded in 1885.
2. The Complainant has acquired trademark rights in FRONTLINE by its aforesaid registration of the FRONTLINE trademark.
3. The Complainant uses and has for many years used its FRONTLINE trademark to provide its goods and services which are used and widely recognised to be used for the treatment and prevention of fleas, ticks and chewing lice in dogs and cats, breaking the life cycle of those infestations, and aiding in the control of sarcoptic mange in dogs.
4. The Respondent registered the Disputed Domain Name on July 27, 2026.
5. The Disputed Domain Name is confusingly similar to the FRONTLINE trademark because it includes the entirety of the FRONTLINE trademark, with the addition of the generic words “spot” and “on”, some minor punctuation, and the addition of the Top Level Domain “.store.” In particular, the Complainant submits that internet users would take the Disputed Domain Name to be a domain name of the Complainant or one that is authorized by it. Moreover, the Complainant submits that the presence of the words “spot”and “on” would not result in the negation of that conclusion, but that their inclusion reinforces the risk of confusion with specific products of the Complainant being offered by the Complainant under its FRONTLINE trademark and brand. 
6. As a consequence, it is submitted that the Disputed Domain Name would be understood by internet users to be invoking the Complainant and its trademark, although the Respondent had no authority to do so.
7. The Respondent has no rights or legitimate interests in the Disputed Domain Name. That is submitted on the following grounds, namely that:

• the Respondent is not commonly known by the Disputed Domain Name within the meaning of paragraph 4(c)(ii) of the Policy;
• there is no affiliation, business or other relationship between the Complainant and the Respondent;
• the Disputed Domain Name has been used by the Respondent to resolve to a website purporting to sell the Complainant’s FRONTLINE products;
• the aforesaid use of the Disputed Domain Name evinces the intention of the Respondent to trade on the reputation of the Complainant’s FRONTLINE trademark suggesting, as it does, that the aforesaid website is an official and genuine website of the Complainant, which it is not;
• the Respondent has not used the Disputed Domain Name for a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy;
• the Respondent has not made a legitimate noncommercial or fair use of the Disputed Domain Name within the meaning of paragraph 4(c)(iii) of the Policy; and
• there is no other ground on which it could conceivably be argued that the Respondent has a right or legitimate interest in the Disputed Domain Name.

8. The Respondent has registered and used the Disputed Domain Name in bad faith on the grounds that:

• the Respondent registered the Disputed Domain Name which is confusingly similar to the Complainant’s FRONTLINE trademark and which was registered long after the Complainant acquired its aforesaid trademark rights;
• the Respondent had actual knowledge of the FRONTLINE trademark and the Complainant's rights in it when it, the Respondent, registered the Disputed Domain Name;
• the Respondent has used the Disputed Domain Name to resolve to a website that purports to offer the Complainant’s products for sale;
• the aforesaid conduct of the Respondent has the potential to disrupt the Complainant’s business within the meaning of paragraph 4 (b)(iii) of the Policy;
• the aforesaid conduct of the Respondent has the potential to generate confusion within the meaning of paragraph 4 (b)(iv) of the Policy; and
• there is no plausible ground on which it could be argued that the Disputed Domain Name was registered and used otherwise than in bad faith.

Accordingly, it is submitted that the Complainant will be able to establish all of the elements it is required to prove and that it is entitled to the relief that is seeks, namely transfer of the Disputed Domain Name to itself.

RESPONDENT

The Respondent is in default and did not file a Response in this proceeding.

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.

This is a mandatory administrative proceeding pursuant to Paragraph 4 of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”) of the Internet Corporation for Assigned Names and Numbers (“ICANN”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the CAC Supplemental Rules.

1. Administrative requirements

On September 15, 2026, the CAC conducted the required Complaint Check in the Administrative Proceeding and advised the Complainant of the following administrative deficiencies, namely that the Complaint did not provide the name of the Respondent (domain–name holder) and all information (including any postal and e-mail addresses and telephone and fax numbers) known to Complainant regarding how to contact Respondent or any representative of Respondent, including contact information based on pre-complaint dealings, in sufficient detail to allow the CAC to send the Complaint as described in Paragraph 2(a) [Rules, Paragraph 3(b)(v)]. The Complainant was requested in accordance with Paragraph 4 (d) of the Rules, to correct the above-mentioned deficiencies and submit an amended Complaint within five (5) days of receiving that notification. On September 15, 2026, the Complainant filed the amended Complaint which was admitted to proceed further in the proceeding. Accordingly, the formal date of commencement of the Administrative Proceeding in accordance with Paragraph 4(f) of the Rules was September 15, 2026.

2. Substantive matters

Paragraph 15 of the Rules provides that the Panel is to decide the Complaint on the basis of the statements and documents submitted and in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. In that regard, the Panel also notes that the onus is on the Complainant to make out its case, and past UDRP panels have consistently said that a complainant must show that all three elements of the Policy have been made out before any order can be made to transfer a domain name.

The Panel therefore turns to discuss the various issues that arise for decision on the facts as they are known.

For the Complainant to succeed it must prove, within the meaning of Paragraph 4(a) of the Policy, that:

   (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 will therefore deal with each of these requirements in turn.

1. Identical or Confusingly Similar.

The first issue that arises is whether the Complainant has a trademark on which it may rely in this proceeding. In that regard, the Panel finds that the Complainant has adduced evidence that the Panel accepts, that it is the registered owner of the FRONTLINE trademark, particulars of which are set out above. That evidence is in documentary form that the Panel has examined and finds to be in order and that the FRONTLINE trademark was registered well prior to the date on which the Respondent registered the Disputed Domain Name and that it is current. The Panel therefore finds that the Complainant has established its trademark rights and hence it is standing to bring this proceeding.

The next issue is whether the Disputed Domain Name is confusingly similar to the FRONTLINE trademark. The Panel finds that the Disputed Domain Name is confusingly similar to the FRONTLINE trademark for the following reasons.

The evidence has established that on July 27, 2026, the Respondent registered the Disputed Domain Name which includes the entirety of the FRONTLINE trademark as its first and most dominant feature. As a consequence, the Disputed Domain Name would be understood by internet users to be invoking the Complainant and its trademark and as being a domain name of the Complainant or one that had been registered with its permission, neither of which is the case.

The Disputed Domain Name also includes the generic words “spot” and “on” and some minor punctuation inserted immediately after the trademark. It has long been held that in considering the issue of confusing similarity, such an addition of generic words and minor punctuation does not negate a finding of confusing similarity where the domain name is clearly identifiable, which it is in the present case. Internet users would therefore conclude that the Disputed Domain Name was invoking the notion of FRONTLINE identified goods and services that are offered under the trademark in the sense of their being colloquially “spot on” or directly sold.

The Disputed Domain Name also includes the Top Level Domain “.store", but this cannot influence how a domain name is interpreted, as all domain names must have such an extension. In any event, even if it were taken into consideration as is sometimes so, in the case of the new range of Top Level Domains, the result would be the same. That is because internet users would assume that the Disputed Domain Name was invoking the FRONTLINE goods and services of the Complainant sold in a store or shop.

Putting these considerations together, the Panel finds that the Disputed Domain Name is confusingly similar to the Complainant’s FRONTLINE trademark; it is similar to the trademark because its first and dominant element is the trademark itself, and it is confusingly similar because internet users would conclude that it was an official and genuine domain name of the Complainant, invoking its goods and services offered under the trademark in a store or other outlet and a domain name that was registered by or with the authority of the Complainant.

The Complainant has therefore established the first element that it must show under Paragraph 4(a)(i) of the Policy.

2. Rights or Legitimate Interests.

Under Paragraph 4(a)(ii) of the Policy, the Complainant has the burden of establishing that the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name.

But by virtue of Paragraph 4(c) of the Policy, it is open to a respondent to establish its rights or legitimate interests in a domain name, among other circumstances, by showing any of the following elements:

(i) before any notice to you [the respondent] 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; or

(ii) you [the respondent] (as an individual, business, or other organization) have been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or

(iii) you [the respondent] are making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

Thus, if a respondent proves any of these elements or indeed anything else that shows that it has a right or legitimate interest in the Disputed Domain Name, the complainant will have failed to discharge its onus and the complaint will fail. It is also well-established that a complainant is required first to make out a prima facie case that the respondent lacks such rights or legitimate interests and that when such a prima facie case is made out, the respondent carries the burden of demonstrating rights or legitimate interests in the domain name. If the respondent cannot do so, a complainant is deemed to have satisfied Paragraph 4(a)(ii) of the Policy.

The Panel, after considering all of the evidence in the Complaint, finds that the Complainant has made out a strong prima facie case that the Respondent has no rights or legitimate interests in the Disputed Domain Name. The case is made stronger by the Complainant’s having adduced relevant documentary evidence which the Panel accepts, and by the Complainant's citation of previously decided UDRP cases which support its contentions.

The Panel will address each of the grounds relied on by the Complainant in the order in which they have been submitted by the Complainant. There is obviously some overlap between the various grounds relied on and the Panel will therefore discuss the substance and thrust of the Complainant’s submissions as a whole.

The Panel finds as follows:

• the Respondent is not commonly known by the Disputed Domain Name within the meaning of paragraph 4(c)(ii) of the Policy; there is no evidence that the Respondent is known by the Disputed Domain Name, commonly or otherwise, and there is no evidence that it is known by any name other than its own, which is jason roy; that conclusion is of course supported, as the Complainant contends, by the fact that the applicable WHOIS registration shows no similarity to the Disputed Domain Name;
• there is no affiliation, business or other relationship between the Complainant and the Respondent; the evidence is that the Complainant has not given any permission or authority to the Respondent to register or use the Disputed Domain Name and there is no evidence of any affiliation, business or other relationship between the Complainant and the Respondent; that being so, it could not be said that the Disputed Domain Name was registered with anything like the consent of the Complainant, which might then show a right or legitimate interest if made out on the evidence; in the present case, there is no such evidence;
• the Disputed Domain Name has been used by the Respondent to resolve to a website purporting to sell the Complainant’s products; this is shown by Annex 6, which clearly shows a website that advertises the same products as those that the evidence has demonstrated are the products of the Complainant; the products on display are undoubtedly being held out to be the Complainant’s products, and are described as being offered under that name and as having the same functions and benefits as those of the Complainant; there is thus no doubt that the Respondent is using the Disputed Domain Name to resolve to a website that is being used to offer the Complainant’s products under the FRONTLINE trademark and brand;
• the evidence shows that the aforesaid use of the Disputed Domain Name evinces the intention of the Respondent to trade on the reputation of the Complainant’s FRONTLINE trademark suggesting, as it does, that the aforesaid website is an official and genuine website of the Complainant, which it is not; in the light of the evidence as to how the Respondent has used the Disputed Domain Name, there can be no doubt but that the Respondent has intended to trade on the Complainant’s reputation in purporting to sell the Complainant’s products which it clearly is not entitled to do;
• the Respondent has not used the Disputed Domain Name for a bona fide offering of goods or services within the meaning of paragraph 4(c)(i) of the Policy; it cannot be bona fide to take another party’s trademark without permission and then use it to purport sell the Complainant’s trademarked goods and pretend that they are genuine when they are not; it also cannot be bona fide to use the Disputed Domain Name to resolve to a website that an examination of some Annex shows is also being used to phish for personal information from internet users, which is shown by the website inviting internet users to contact it;
• the same considerations show that the Respondent has not made a legitimate noncommercial or fair use of the Disputed Domain Name within the meaning of paragraph 4(c)(iii) of the Policy; the Respondent’s aforesaid machinations were clearly illegitimate, clearly commercial and clearly not fair, either to the Complainant or to internet users in general; and
• there is no other ground on which it could conceivably be argued that the Respondent has a right or legitimate interest in the Disputed Domain Name.

The Complainant has therefore made out its prima facie case. The Respondent has not rebutted the prima facie case as it is in default and has not filed a Response.

The Complainant has therefore made out the second of the three elements that it must establish under Paragraph 4(a)(ii) of the Policy.

3. Registration and Use in Bad Faith.

The Complainant must prove on the balance of probabilities both that the Disputed Domain Name was registered in bad faith and that it is being used in bad faith.

Paragraph 4(b) of the Policy sets out four circumstances, any one of which is evidence of the registration and use of a domain name in bad faith, although other circumstances may also be relied on, as the four circumstances are not exclusive. The four specified circumstances are:

 (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 finds that the Complainant has shown that the Respondent registered and used the Disputed Domain Name in bad faith on all of the grounds relied on by the Complainant. 

The Panel will deal with each of those grounds in the order in which they have been raised by the Complainant. In so doing, the Panel relies on the evidence and particularly on the foregoing evidence that the Respondent lacks a right or legitimate interest in the Disputed Domain Name, which is equally applicable to the issue of bad faith and which it is not necessary to repeat.

The Panel finds that:

• the evidence has already shown that the Respondent registered the Disputed Domain Name which is confusingly similar to the Complainant’s FRONTLINE trademark and which was registered long after the Complainant acquired its trademark rights; that, by itself, is clearly an act of bad faith registration;
• the evidence shows that the Respondent had actual knowledge of the FRONTLINE trademark and the Complainant's rights in it when the Respondent registered the Disputed Domain Name; the presence of such a well-known trademark in a domain name indicates that the Respondent was well-aware of the Complainant and its trademark, knew its target and hence registered the Disputed Domain Name in bad faith; indeed, the Respondent could not have carried out its subterfuge unless it had actual knowledge of the Complainant, its trademark, well-known brand and goods and services;
• the evidence shows that the Respondent has used the Disputed Domain Name to resolve to a website that offers the Complainant’s products for sale without permission; this has long been recognised as bad faith use of a domain name;
• the aforesaid conduct of the Respondent has the potential to disrupt the Complainant’s business within the meaning of paragraph 4 (b)(iii) of the Policy; there can be no doubt but that the Respondent’s machinations were designed to induce internet users to buy products via its website rather than via the Complainant’s official and genuine website, which by definition is disruptive of the Complainant’s business;
• likewise, the aforesaid conduct of the Respondent has the potential to generate confusion within the meaning of paragraph 4 (b)(iv) of the Policy; clearly the intention of the Respondent has been to confuse internet users into believing that its use of the Disputed Domain Name was legitimate when it was not; the Respondent has clearly sought to generate confusion between the Complainant and the Respondent within the meaning of paragraph 4(b)(iv) of the Policy by registering the Disputed Domain Name which is confusingly similar to the FRONTLINE trademark and by impersonating and passing itself off as the Complainant; the Respondent’s subterfuge was devised for one reason, namely to give the impression that it was the Complainant or was authorized by it, which was false; all of this amounted to generating confusion and this ground of bad faith is therefore made out; and
• the evidence shows that there is no plausible ground on which it could be argued that the Disputed Domain Name was registered and used otherwise than in bad faith.

The Complainant has therefore made out the third of the three elements that it must establish under Paragraph 4(a)(iii) of the Policy.

The Complainant has thus established all of the elements it is required to prove under the Policy and has done so by the evidence.

The Complainant is therefore entitled to the relief that it seeks, namely transfer of the Disputed Domain Name.