WIPO D2026-0268 · decided 19 March 2026
Neurocrine Biosciences, Inc. v. Host Master, Njalla Okta LLC
The parties
- Complainant
- Neurocrine Biosciences, Inc.
- Respondent
- Host Master, Njalla Okta LLC
What did the panel find on each element?
| Policy paragraph | Finding |
|---|---|
| 4(a)(i) Identical or confusingly similar | The panel found neurocrinesso.com confusingly similar to the NEUROCRINE trademark, because the trademark is reproduced in full and the added letters "sso" do not prevent confusing similarity. |
| 4(a)(ii) No rights or legitimate interests | The panel found Host Master, Njalla Okta LLC had no rights or legitimate interests, because the respondent filed no response and offered no evidence to rebut the prima facie case. |
| 4(a)(iii) Registered and used in bad faith | The panel found bad faith under the passive holding doctrine, given the reputation of NEUROCRINE and the "sso" ending, although the phishing claims came with no evidence. |
Why does Neurocrine matter for a complaint today?
Neurocrine Biosciences, Inc. is a pharmaceutical company founded in 1992 with over 1,900 employees. It owns NEUROCRINE trademarks such as United States Trademark Registration No. 5762521, registered on May 28, 2019. The domain name neurocrinesso.com was registered on December 29, 2025. Neurocrine said the site showed a login screen for Okta, an identity management company. It said callers using a spoofed number matching its own sent three users to the site, one user entered credentials, and those credentials were used to access its systems. The panel, Miguel B. O'Farrell, noted that Neurocrine provided no evidence of the credential harvesting. The panel transferred the domain name anyway on March 19, 2026. The panel applied the passive holding doctrine in section 3.3 of the WIPO Overview 3.1 and relied on the reputation of NEUROCRINE, the "sso" ending and the respondent's default. Section 3.3 says the more distinctive a trademark is, the less plausible a good faith use of it. Section 2.13.2 of the Overview says panels will not accept "merely conclusory or wholly unsupported allegations of illegal activity", even when the respondent is in default. If your company is hit by phishing, take screenshots of the page before it disappears.
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 3.3: Can the "passive holding" of a domain name support a finding of bad faith?
- Section 2.13: How do panels treat complainant claims of illegal activity in relation to potential respondent rights or legitimate interests?
- 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, Miguel B. O'Farrell, decided the case on 19 March 2026.
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.
Someone has taken a domain that uses your brand?
The first assessment is free and comes back within 24 hours. If the case is weak we say so rather than take the fee.