WIPO D2024-0237 · decided 7 April 2024
Alpha Bank S.A. v. Pawel Szablowski, Pawel Szablowski
The parties
- Complainant
- Alpha Bank S.A.
- Respondent
- Pawel Szablowski, Pawel Szablowski
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found alpha.finance confusingly similar to the ALPHA BANK trademark, because "alpha" is the distinctive element of that trademark and the ".finance" ending is disregarded. |
| 4(a)(ii) No rights or legitimate interests | The panel did not decide this element, because Alpha Bank had already failed to prove bad faith under the third element. |
| 4(a)(iii) Registered and used in bad faith | The panel found no bad faith, because "alpha" is a dictionary word used by many businesses and there was no evidence the domain investor targeted Alpha Bank S.A. |
Why does Alpha Bank matter for a complaint today?
Alpha Bank S.A. is a Greek bank with ALPHA BANK trademarks, including UK registration UK00905282918 from August 29, 2006. A Polish domain investor registered alpha.finance on April 28, 2023 and listed it for sale at USD 19,999. Alpha Bank filed a UDRP complaint with the WIPO Arbitration and Mediation Center on January 19, 2024, and the investor filed a Response. The sole panelist, Nick J. Gardner, denied the complaint on April 7, 2024. The panel ran a Google search for "alpha finance" in the UK and found four unrelated businesses in the first results, including Alpha Asset Finance and Alpha Group. The panel also noted that "alpha" has a technical meaning in finance. Alpha Bank works mainly in Greece, Cyprus and the Balkans, and there was no evidence of any reputation in Poland. The asking price did not prove bad faith either. Section 3.1.1 of the WIPO Overview 3.1 says that registering a domain name for resale, including for a profit, is not bad faith by itself. If your trademark is a dictionary word, the trademark does not give you a claim to every domain name that contains it. You need evidence that the registrant was aiming at you.
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 3.1.1: How does a complainant prove that a respondent has registered or acquired a domain name primarily to sell the domain name to the complainant (or its competitor) for valuable consideration in excess of the respondent's costs related to the domain name?
- Section 2.10: Does a respondent have rights or legitimate interests in a domain name comprised of a dictionary word/phrase or acronym?
Who decided the case?
A single panelist, Nick J. Gardner, decided the case on 7 April 2024.
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.
Summarised by Gergana Dimitrova. Checked against the published decision on 23 October 2026.
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