Decision for dispute CAC-UDRP-109004

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 owns numerous registrations for the trademark NOVARTIS in jurisdictions worldwide, all of which predate the registration of the disputed domain name. These registrations include, inter alia:

• International Trademark NOVARTIS No. 663765, registered on 1 July 1996;
• International Trademark NOVARTIS No. 1249666, registered on 1 July 1996;
• International Trademark NOVARTIS No. 1349878, registered on 29 November 2016;
• International Trademark NOVARTIS No. 1544148, registered on 29 June 2020;
• European Union Trademark NOVARTIS No. 13393641, registered on 17 March 2015;
• United States Trademark NOVARTIS No. 2336960, registered on 4 April 2000; and
• United States Trademark NOVARTIS No. 4986124, registered on 28 June 2016.

The Complainant is the holding company of the Novartis Group, a global pharmaceutical and healthcare group headquartered in Switzerland. The Complainant was created in 1996 through the merger of Ciba-Geigy and Sandoz.

The Novartis Group develops and commercializes innovative medicines and healthcare solutions worldwide. According to the evidence submitted by the Complainant, the Novartis Group achieved net sales of USD 54.5 billion in 2025, reported net income of USD 14 billion, and employed more than 75,000 employees globally as of 31 December 2025.

The Complainant has established a substantial international presence and conducts business in numerous countries worldwide, including Nigeria, where it operates through Novartis Nigeria Limited. The evidence further shows that the Novartis Group participates in healthcare initiatives in Sub-Saharan Africa, including programs relating to sickle cell disease.

The Complainant also offers employment, career development and training opportunities through its corporate recruitment channels.

The Complainant further owns numerous domain names incorporating its NOVARTIS trademark, including <novartis.com>, <novartis.ch>, and <novartispharma.com>, which are used in connection with the Complainant's official online presence and the promotion of its products, services, career opportunities and corporate information. The Complainant also maintains an active presence on various social media platforms.

Based on the WHOIS record provided by the Registrar, the Respondent appears to be based in Nigeria.

The disputed domain name was registered on 10 September 2026.

The Complainant contends that the requirements of the Policy have been met and that the disputed domain name 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 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 relies upon its trademark registrations for NOVARTIS. The registration of a trademark is sufficient to establish rights in a mark for the purposes of paragraph 4(a)(i) of the Policy. See Avast Software s.r.o. v. Milen Radumilo, 102384 (CAC 2019-03-12). The Panel therefore finds that the Complainant has established rights in the NOVARTIS trademark. 

The Complainant claims that the disputed domain name incorporates the Complainant's NOVARTIS mark in its entirety. The addition of the descriptive term "recruitment" does not prevent a finding of confusing similarity. On the contrary, the added term may increase the likelihood that Internet users will associate the disputed domain name with the Complainant, particularly given that recruitment and career opportunities are activities commonly conducted by large multinational corporations such as the Complainant.

It is well established that where a complainant's trademark is clearly recognizable within the disputed domain name, the addition of descriptive or dictionary terms does not avoid confusing similarity. Likewise, the generic Top-Level Domain (".com") is generally disregarded for the purpose of comparison under the first element of the Policy.

Accordingly, the Panel finds that the disputed domain name is confusingly similar to a trademark in which the Complainant has rights.

For the foregoing reasons, the Panel finds that the Complainant has satisfied 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). More specifically, the Complainant must first make a prima facie case that the Respondent lacks rights and legitimate interests in the disputed domain name, and the burden of proof then shifts to the Respondent to show it does have rights or legitimate interests. See PepsiCo, Inc. v Smith power production, 102378, (CAC 2019-03-08) ("The Panel finds that the Complainant has made out a prima facie case that arises from the considerations above. All of these matters go to make out the prima facie case against the Respondent. As the Respondent has not filed a Response or attempted by any other means to rebut the prima facie case against it, the Panel finds that the Respondent has no rights or legitimate interests in the disputed domain name.").

The Complainant states that it has never authorized the Respondent to use the NOVARTIS trademark or to register any domain name incorporating that mark. There is no evidence before the Panel suggesting that the Respondent is commonly known by the disputed domain name or has acquired trademark rights corresponding to it.

The disputed domain name consists of the Complainant's distinctive trademark together with the term "recruitment", a combination that strongly suggests an affiliation with the Complainant's employment or hiring activities. Such composition carries a significant risk of implied affiliation.

The evidence further shows that the disputed domain name is not being used for an active website. The Respondent has failed to submit any explanation or evidence demonstrating preparations for a bona fide offering of goods or services, legitimate non-commercial use, or any other rights or legitimate interests contemplated under paragraph 4(c) of the Policy.

The Panel finds that these submissions are sufficient to establish a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The burden of production therefore shifts to the Respondent to rebut that prima facie case by demonstrating rights or legitimate interests in the disputed domain name. 

The Respondent has not filed a Response and has not otherwise participated in these proceedings. There is no evidence before the Panel of any circumstances that would establish rights or legitimate interests on the part of the Respondent within the meaning of paragraph 4(c) of the Policy.

For the foregoing reasons, the Panel finds that the Complainant has satisfied 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 Complainant submits that the NOVARTIS trademark is well known internationally and has been extensively used in connection with its pharmaceutical and healthcare business for many years. The Complainant further asserts that it maintains a substantial presence in Nigeria, where the Respondent is located, and that it offers career and recruitment opportunities through its official websites and online platforms. The Complainant therefore contends that the Respondent must have been aware of the Complainant and its NOVARTIS trademark when registering the disputed domain name.

The Panel finds that the Respondent was more likely than not aware of the Complainant and its NOVARTIS trademark when registering the disputed domain name. The NOVARTIS trademark is highly distinctive, well known internationally, and long predates the registration of the disputed domain name. The disputed domain name incorporates the NOVARTIS trademark in its entirety together with the term “recruitment”, which directly relates to the Complainant's recruitment and career activities. The Panel therefore considers that the disputed domain name was intentionally chosen to target the Complainant and create an impression of association with the Complainant.

Although the disputed domain name does not resolve to an active website, passive holding does not prevent a finding of bad faith. In the present case, the Panel notes the reputation of the NOVARTIS trademark, the absence of any Response or evidence of good-faith use, the composition of the disputed domain name suggesting an affiliation with the Complainant, and the existence of active MX records associated with the disputed domain name. Taken together, these circumstances support a finding 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. 

For the foregoing reasons, the Panel finds the Complainant has satisfied 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.