Published Works | World Trademark Review | 14 November 2023

Targeting is essential for a transfer under the UDRP

Laboratoire Terravita sought the transfer of ‘terravita.shop’ under the UDRP, relying on the passive holding doctrine.

The panel found that factor (ii) of the passive holding doctrine was the only factor in the complainant’s favour

The domain name resolved to a parking page which did not appear to target the complainant or its users in any way.