{ "case_number": "CAC-UDRP-108956", "time_of_filling": "2026-08-28 09:51:52", "domain_names": [ "adobeacrbats.com", "adobeacrobats.com" ], "case_administrator": " Iveta Špiclová (Czech Arbitration Court) (Case admin)", "complainant": [ "Adobe Inc. " ], "complainant_representative": "Convey srl", "respondent": [ "Zara Narang" ], "respondent_representative": null, "factual_background": "

THE DISPUTED DOMAIN NAMES ARE IDENTICAL OR CONFUSINGLY SIMILAR TO A TRADEMARK OR SERVICE MARK IN WHICH THE COMPLAINANT HAS RIGHTS <\/strong><\/p>\n

The Complainant states that it is a leading global technology company specializing in the development of software and digital media solutions. Since its establishment in 1982, it has played a leading role in shaping the digital content industry, offering innovative tools that enable individuals and businesses to create, manage, and deliver digital content.<\/p>\n

The Complainant submits that it is widely recognized as one of the world’s leading companies in the development of professional software for digital media creation, publishing, and communication.<\/p>\n

Its trademarks, including \"Adobe\" and \"Acrobat\", are highly distinctive and widely recognized in the fields of digital media, software development, photography, and creative content production, and are uniquely associated with the Complainant and its products worldwide.<\/p>\n

The Complainant relies on the various \"Adobe\" and \"Acrobat\" trademark registrations, including the ones provided above (\"Trademarks\").<\/p>\n

The Complainant submits the disputed domain names are confusingly similar to its Trademarks since they incorporate the Complainant’s well-known Trademarks in their entirety and one disputed domain name is a misspelled version of the \"Acrobat\" mark:<adobeacrbats.com>.<\/p>\n

The association of the two trademarks “Adobe” and “Acrobat” 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 trademarks.<\/p>\n

Therefore, the Complainant submits that the disputed domain names are confusingly similar to its Trademarks.<\/p>\n

THE RESPONDENT HAS NO RIGHTS OR LEGITIMATE INTERESTS IN RESPECT OF THE DISPUTED DOMAIN NAMES<\/strong><\/p>\n

The Complainant submits that 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 Trademarks or to register the disputed domain names incorporating them.<\/p>\n

The Complainant has not granted the Respondent any rights to operate the disputed domain names identical or confusingly similar to its Trademarks.<\/p>\n

The Respondent has been using the disputed domain names to promote tools that purport to enable users to unlawfully download the Complainant’s software “Adobe Acrobat Reader” through the Respondent’s websites.<\/p>\n

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.<\/p>\n

Based on the above, the Complainant claims that the second element of the UDRP has been satisfied.<\/p>\n

THE DISPUTED DOMAIN NAMES WERE REGISTERED AND ARE BEING USED IN BAD FAITH<\/strong><\/p>\n

The Complainant's submissions on the bad faith element can be summarized as follows:<\/p>\n