WIPO DEU2023-0021 · decided 3 August 2023
airSlate, Inc., airSlate Ireland Limited v. Aria Pour, Bynaric Ltd
The parties
- Complainant
- airSlate, Inc., airSlate Ireland Limited
- Respondent
- Aria Pour, Bynaric Ltd
What did the panel find on each element?
| Element | Finding |
|---|---|
| Identical or confusingly similar to a protected name | The panel found signnow.eu identical to the SIGNNOW EU trademark, registered on December 30, 2021, and held that the trademark being registered after the domain did not matter for this element. |
| Registered without rights or legitimate interest | The panel found no rights or legitimate interest, because Bynaric Ltd produced no evidence of use or preparation before the complaint and did not explain its USD 250,000 sale offer. |
| Or registered or used in bad faith | The panel did not decide bad faith. Having found no rights or legitimate interest, it held the third condition unnecessary and did not address it. |
Why does airSlate matter for a complaint today?
airSlate sells electronic signature software and has used the SIGNNOW name since at least 2011. Bynaric Ltd, an Irish company that sells housing management software, registered signnow.eu on April 24, 2020, before the SIGNNOW EU trademark was registered on December 30, 2021. The panel, Nick J. Gardner, held that the later trademark date did not matter for the first element, because the .eu ADR Rules only need a right that exists when the complaint is filed. Bynaric Ltd said it had plans for the domain but produced no documents. The domain had pointed to a competitor's website, and Bynaric Ltd had offered to sell it to airSlate for USD 250,000. That was enough to find no rights or legitimate interest. For a business owner, the point is the shape of the .eu test. Paragraph B(11)(d)(1) of the ADR Rules lists lack of rights or legitimate interest and bad faith as alternatives, while the UDRP needs both. The panel stopped after the second element and never ruled on bad faith. The domain went to airSlate Ireland Limited, which the panel found meets the eligibility criteria in Article 3 of Regulation (EU) 2019/517 because it is located in Ireland.
Who decided the case?
A single panelist, Nick J. Gardner, decided the case on 3 August 2023.
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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