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ADORAIntellectual Property

WIPO D2016-0367 · decided 29 April 2016

Accenture Global Services Limited v. Patel Holdings

Transferredaccenturejobs.com
In Accenture Global Services Limited v. Patel Holdings, D2016-0367 (WIPO, 2016), the panel transferred accenturejobs.com, registered in January 2016, although it hosted no website at all. The registrant used the address recruiting@accenturejobs.com to pose as Accenture's recruiters, and the panel held that this email use was bad faith registration and use.

The parties

Complainant
Accenture Global Services Limited
Respondent
Patel Holdings

What did the panel find on each element?

Policy paragraphFinding
4(a)(i) Identical or confusingly similarThe panel found accenturejobs.com confusingly similar to ACCENTURE, a coined mark, and held that adding "jobs" increased the confusion by suggesting a recruitment website for Accenture.
4(a)(ii) No rights or legitimate interestsThe panel found Patel Holdings had no rights or legitimate interests, because it was not commonly known by the name and used recruiting@accenturejobs.com illegitimately.
4(a)(iii) Registered and used in bad faithThe panel found bad faith because ACCENTURE is well known worldwide and the respondent used an email address on the domain illegitimately, although the domain had no active website.

Why does Accenture matter for a complaint today?

Accenture Global Services Limited won the transfer of accenturejobs.com, although the domain showed no website at all. The domain was registered on 22 January 2016. According to Accenture's evidence, the respondent contacted people through LinkedIn about jobs at Accenture, then emailed them from recruiting@accenturejobs.com and asked for GBP 468 before an interview. The panel accepted that evidence. The panel held that this email use, together with the worldwide reputation of ACCENTURE, was bad faith registration and use. The panel also held that the word "jobs" made the domain more confusing, because people would expect a recruitment site for Accenture. Section 3.4 of the WIPO Overview 3.1 cites this case for the rule that using a domain to send deceptive email can be bad faith even with no website. If someone is running a recruitment scam from a domain that contains your trademark, a UDRP complaint is open to you even when the domain looks empty. The limit: Patel Holdings filed no response, and Accenture said it had reports from more than one person who received the emails. Section 2.13.2 of the Overview says panels do not accept wholly unsupported allegations of illegal activity, even when the respondent is in default.

What does the WIPO Overview 3.1 say?

The WIPO Overview 3.1 summarises how WIPO panels decide each issue. These sections cover the same point of law.

  • Section 3.4: Can the use of a domain name for purposes other than hosting trademark-abusive content constitute bad faith? The Overview cites this decision here.
  • Section 1.8: Is a domain name consisting of a trademark and a descriptive or geographical term confusingly similar to a complainant's trademark?

Who decided the case?

A single panelist, Gonçalo M. C. Da Cunha Ferreira, decided the case on 29 April 2016.

Read the decision

The full text is published by the WIPO Arbitration and Mediation Center. We summarise it here; the decision itself is the authority.

WIPO decision D2016-0367

Summarised by Gergana Dimitrova, who worked at the WIPO Arbitration and Mediation Center from 2018 to 2021 and sits as a domain name panelist at the Czech Arbitration Court. Checked against the published decision on 23 October 2026. Full background.

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