WIPO D2024-2275 · decided 19 August 2024
Mangels Industrial S.A. v. Mira Holdings, Inc.
The parties
- Complainant
- Mangels Industrial S.A.
- Respondent
- Mira Holdings, Inc.
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found mangels.com identical to the MANGELS word trademark, registered in Brazil on October 18, 1968, once the ".com" ending is disregarded. |
| 4(a)(ii) No rights or legitimate interests | The panel did not decide this element, because the complaint failed on bad faith and the panel found it neither necessary nor appropriate to reach a view. |
| 4(a)(iii) Registered and used in bad faith | The panel found no bad faith, because MANGELS is used by others and as a surname, the registrations have limited geographical scope, and nothing showed Mira Holdings knew of Mangels. |
Why does Mangels matter for a complaint today?
The panel in Mangels Industrial S.A. v. Mira Holdings, Inc., D2024-2275, denied the complaint on August 19, 2024 and found Reverse Domain Name Hijacking (RDNH). Mangels, a Brazilian maker of steel cylinders and wheels, had once owned mangels.com and failed to renew it. Mira Holdings, which describes itself as a professional domain name investor, registered it on March 29, 2019 and said it paid USD 2,956 at auction. In April 2023 Mangels made two offers of about USD 950. The Registrar told Mangels it would need to pay at least USD 61,750. Mangels then filed a UDRP complaint. The panel found no evidence that Mira Holdings knew of or targeted the MANGELS trademark. It said Mangels was legally represented and should have been advised that its claim had no reasonable prospect of success. The UDRP is not a way to recover a domain name you let lapse, or to avoid a dealer's price. Section 4.16 of the WIPO Overview 3.1 lists, among RDNH grounds, filing a complaint after an unsuccessful attempt to buy the domain name without a plausible legal basis. It also notes that some panels hold a represented complainant to a higher standard.
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 4.16: In what circumstances will panels issue a finding of Reverse Domain Name Hijacking (RDNH)?
- 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? The Overview cites this decision here.
Who decided the case?
A three-member panel decided the case on 19 August 2024: Steven A. Maier (presiding), Jonathan Agmon, Matthew Kennedy.
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, 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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