The Complainant, PaySend Group is a global Fin Tech company engaged in the provision of international card-to-card transfers allowing connection between individual card holders in many countries and it has been so engaged since 2017. It is renowned internationally, has its headquarters in London and has over 10 million customers to whom it provides its services under the PAYSEND trademark.<\/p>\n
As well as the PAYSEND trademark, the Complainant owns various domain names, most notably <paysend.com>, which it uses in its business to promote its products under its PAYSEND trademark and brand.<\/p>\n
It has come to the notice of the Complainant that on August 25, 2025, without any permission and many years after the Complainant acquired its aforesaid trademark rights, the Respondent registered the domain name <paysend-order.com> (\"the Disputed Domain Name\") which includes the PAYSEND trademark in its entirety, with the addition of a hyphen, the generic word “order” and the Top Level Domain “.com.” The Respondent has then caused the Disputed Domain Name to resolve to a website that uses the PAYSEND trademark, impersonates and passes itself off as the Complainant and attempts to perpetrate a fraud.<\/p>\n
The Disputed Domain Name and the website to which it resolves pose a very concerning threat to the Complainant’s business and the PAYSEND trademark and brand. That is because the Complainant submits that the Disputed Domain Name and the use made of it by the Respondent constitute an infringement of the PAYSEND trademark, give rise to a likelihood of confusion in the minds of internet users between the trademark and the Disputed Domain Name and pose the threat of a fraud being perpetrated on the Complainant and its customers if the Respondent retains registration of the Disputed Domain Name. <\/p>\n
The Complainant maintains that the Disputed Domain Name is confusingly similar to its trademark, that registering the Disputed Domain Name and having it resolve to the aforesaid website cannot give rise to a right or legitimate interest in the Disputed Domain Name and that the Disputed Domain Name has been registered and used in bad faith.<\/p>\n
The Complainant has therefore brought this proceeding under the Uniform Domain Name Dispute Resolution Policy to obtain a transfer of the Disputed Domain Name to itself and thus the cessation of the improper use which it submits the Respondent has made of it.<\/p>", "other_legal_proceedings": "
The Panel is not aware of any other legal proceedings which are pending or decided and which relate to the disputed domain name.<\/p>", "no_response_filed": "
COMPLAINANT:<\/p>\n
The Complainant made the following contentions.<\/p>\n
(i) The Disputed Domain Name is confusingly similar to a trademark or service mark in which the Complainant has rights.<\/p>\n
The Complainant owns the trademark for PAYSEND set out above and which was registered many years before the Respondent registered the Disputed Domain Name on August 25, 2025.<\/p>\n
The Disputed Domain Name <paysend-order.com> incorporates the Complainant’s PAYSEND trademark in its entirety with the addition of a hyphen and the generic word “order” and the Top Level Domain “.com.” The trademark is clearly recognizable in the Disputed Domain Name. The addition of the hyphen is of such minor significance that it could have no effect on the interpretation given to the Disputed Domain Name. The addition of generic words such as the word “order” in the present case, is now well established as being not sufficient to negate a finding of confusing similarity with a trademark. In the present case, the presence of the word \"order\" has the effect that the Disputed Domain Name is invoking the notion of orders being submitted for the transfer of funds by the Complainant under its processes conducted under the PAYSEND trademark.<\/p>\n
Thus, the Disputed Domain Name is confusingly similar to the PAYSEND trademark.<\/p>\n
(ii) The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name.<\/p>\n
As is universally accepted, the Complainant is first required to make out a prima facie case that the Respondent has no rights or legitimate interests in the Disputed Domain Name and, if such a prima facie case is made out, the onus of proof is then transferred to the Respondent to rebut any such prima facie case that has been established.<\/p>\n
The Complainant submits that, for the following reasons, it can make out its prima facie case.<\/p>\n
First, the Complainant has not given any permission or authority to the Respondent to register or use the Disputed Domain Name and there is no affiliation, business or other relationship between the Complainant and the Respondent.<\/p>\n
Secondly, the Respondent has registered the Disputed Domain Name and caused it to resolve to a website that prominently displays the Complainant’s PAYSEND trademark, and impersonates and passes itself off as the Complainant.<\/p>\n
Thirdly, the Respondent has copied the Complainant’s corporate purple colour on its website.<\/p>\n
Fourthly, the Respondent has provided false contact details.<\/p>\n
Fifthly, the foregoing features indicate that the Respondent has intended to initiate a fraudulent activity by means of using the Disputed Domain Name and the Respondent’s aforesaid website.<\/p>\n
Accordingly, the Complainant submits that it has made out a prima facie case that the Respondent has no rights or legitimate interests in the Disputed Domain Name.<\/p>\n
(iii) The Disputed Domain Name was registered and is being used in bad faith.<\/p>\n
The Complainant submits on the following grounds that the Disputed Domain Name was registered and is being used in bad faith.<\/p>\n
First, the Respondent has taken the Complainant’s well-known PAYSEND trademark and without permission or authority has entirely incorporated it in the Disputed Domain Name which is confusingly similar to the trademark.<\/p>\n
Secondly, the Respondent registered the Disputed Domain Name many years after the Complainant acquired its aforesaid trademark rights and after they had acquired wide recognition.<\/p>\n
Thirdly, the content of the aforesaid website shows that the Respondent has set about obtaining and has obtained considerable knowledge of the Complainant and its trademarks to take unfair advantage of it.<\/p>\n
Fourthly, the Respondent has clearly embarked on impersonating and passing itself off as the Complainant and shown that it may well be engaging in a fraud.<\/p>\n
Fifthly, that conclusion is enhanced by the provision of false contact information by the Respondent and by the fact that although the Respondent apparently resides in Russia, it has not provided a street address, has supplied a manifestly non-existent email address and has clearly spread random characters around instead of providing accurate contact details.<\/p>\n
Sixthly, all the circumstances show that the Respondent must have been and was aware of the Complainant and its trademark when it, the Respondent, registered the Disputed Domain Name.<\/p>\n
In registering and using the Disputed Domain Name, the Respondent has sought to generate confusion between the Complainant and the Respondent and their respective websites within the meaning of paragraph 4(b)(iv) of the Policy.<\/p>\n
Accordingly, the Complainant submits that the Respondent has registered and used the Disputed Domain Name in bad faith.<\/p>\n
The Complainant thus submits that it has established all of the elements it is required to prove under the Policy and that it is therefore entitled to the relief that it seeks.<\/p>", "rights": "
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).<\/p>", "no_rights_or_legitimate_interests": "
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).<\/p>", "bad_faith": "
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).<\/p>", "procedural_factors": "
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.<\/p>", "decision": "Accepted", "panelists": [ "Neil Brown" ], "date_of_panel_decision": "2025-12-04 00:00:00", "informal_english_translation": "
The evidence has established that the Complainant is the owner of a portfolio of registered trademarks including:<\/p>\n
(a) the International trademark registration for PAYSEND, No.1284999 registered on October 13, 2015; and<\/p>\n
(b) numerous other International registrations for PAYSEND and derivatives protected in many jurisdictions,<\/p>\n
(collectively \"the PAYSEND trademark\").<\/p>\n
<\/p>", "decision_domains": { "paysend-order.com": "TRANSFERRED" }, "panelist": null, "panellists_text": null }