DECISION

 

HCL CORPORATION PRIVATE LTD. aka HCL CORPORATION LIMITED, HCL AMERICA, INC., and HCL TECHNOLOGIES LTD. v. Narendra Ghimire / Deep Vision Architects

Claim Number: FA2601002200189

 

PARTIES

The Complainants are HCL CORPORATION PRIVATE LTD. aka HCL CORPORATION LIMITED, HCL AMERICA, INC., and HCL TECHNOLOGIES LTD. ("Complainant"), represented by Hope V. Shovein of Brooks Kushman P.C., Michigan, USA. The Respondent is Narendra Ghimire / Deep Vision Architects ("Respondent"), represented by John Berryhill, Pennsylvania, USA.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <hcl.ai>, registered with NameCheap, Inc.

 

PANEL

The undersigned certify that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding.

 

Karen J. Bernstein and Ho-Hyun Nahm as Panelists and Flip Jan Claude Petillion as Chair.

 

PROCEDURAL HISTORY

The Complainant submitted a Complaint to Forum electronically on January 16, 2026; Forum received payment on January 16, 2026.

 

On January 19, 2026, NameCheap, Inc. confirmed by e-mail to Forum that the <hcl.ai> domain name is registered with NameCheap, Inc. and that the Respondent is the current registrant of the name. NameCheap, Inc. has verified that the Respondent is bound by the NameCheap, Inc. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").

 

On January 26, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 23, 2026 by which the Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on the Respondent's registration as technical, administrative, and billing contacts, and to postmaster@hcl.ai. Also on January 26, 2026, the Written Notice of the Complaint, notifying the Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to the Respondent via post and fax, to all entities and persons listed on the Respondent's registration as technical, administrative and billing contacts.

 

A timely Response was received and determined to be complete on February 23, 2026.

 

On March 2, 2026, pursuant to Respondent's request to have the dispute decided by a three-member Panel, Forum appointed Karen J. Bernstein and Ho-Hyun Nahm as Panelists and Flip Jan Claude Petillion as Chair.

 

On March 3, 2026, the Complainant filed an additional submission. On March 11, 2026, the Respondent filed an additional submission.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PRELIMINARY ISSUE: MULTIPLE COMPLAINANTS

UDRP Rule 3(a) and Forum's Supplemental Rule 1(e) govern situations involving multiple complainants. UDRP Rule 3(a) states, "Any person or entity may initiate an administrative proceeding by submitting a complaint." Forum's Supplemental Rule 1(e) defines "The Party Initiating a Complaint Concerning a Domain Name Registration" as a "single person or entity claiming to have rights in the domain name, or multiple persons or entities who have a sufficient nexus who can each claim to have rights to all domain names listed in the Complaint."

 

There are three Complainants in this matter:

- HCL CORPORATION PRIVATE LTD. aka HCL CORPORATION LIMITED;

- HCL AMERICA, INC.; and

- HCL TECHNOLOGIES LTD.

 

Previous panels have interpreted the Forum's Supplemental Rule 1(e) to allow multiple parties to proceed as one party where they can show a sufficient link to each other. See Guess? IP Holder L.P. and Guess?, Inc. v. Jerry Guess, FA 2002904 (Forum Aug. 23, 2022) ("While it appears that a single Complainant filed this proceeding, there are two Complainants in this matter: Guess? IP Holder L.P. and Guess?, Inc. Complainant argues that they have a sufficient nexus to both claim rights in the Trademark GUESS because Guess? IP Holder L.P. is effectively owned by Guess?, Inc. The Panel will accept Complainant's assertion and will treat both Complainants as a single entity."); BFD, Inc. and Barefoot Dreams, Inc. v. kanggeng sheng, FA 1997581 (Forum July 6, 2022) ("There are two Complainants in this matter: BFD, Inc. and Barefoot Dreams, Inc. BFD, Inc. is the owner of the primary mark BFD that is the subject of this complaint, and has exclusively licensed Barefoot Dreams, Inc. to make and sell products under the BFD mark, which it does…. The Panel finds that the evidence in the Complaint is sufficient to establish a sufficient nexus or link between the Complainants, and thus it will treat them as a single entity in this proceeding."); ITT Inc. and ITT Manufacturing Enterprises, LLC v. Thomas Romero, FA 1961339 (Forum Sept. 29, 2021) ("It has been accepted that it is permissible for two complainants to submit a single complaint if they can demonstrate a link between the two entities such as a relationship involving a license, a partnership or an affiliation that would establish the reason for the parties bringing the complaint as one entity.").

 

In the present case, the Panel finds that there is sufficient evidence establishing a clear nexus or link between the Complainants. The Complaint mentions "HCL" trademarks held by two of the three Complainants, and a simple Internet search shows that all three Complainants are entities of the same group. Their shared interest in the "HCL" trademark and their consolidated business operations justify their standing as co-complainants in this proceeding. Moreover, the Respondent does not make any argument contesting the Complainants' standing.

 

The Panel will treat the Complainants as a single entity for purposes of this proceeding.

 

PRELIMINARY ISSUE: ADDITIONAL SUBMISSIONS

Before entering into the merits of the case, the Panel addresses the matter of the unsolicited supplemental filings submitted by the parties. It follows from paragraphs 10 and 12 of the Rules and Rule 7 of Forum's Supplemental Rules that the Panel, in its sole discretion, may determine the admissibility, relevance, materiality, and weight of the evidence, insofar as both parties are treated with equality and are given a fair opportunity to present their case.

 

Unsolicited supplemental filings are generally discouraged. When doing so, a party is usually required to prove that the supplemental filing is of utmost importance to the case and it could not have provided the information within its initial complaint or response.

 

In the present case, the Panel finds that the parties' Additional Submissions do not add essential information impacting the Panel's decision and therefore decides not to consider these.

 

PARTIES' CONTENTIONS

A. Complainant

The Complainant claims that the <hcl.ai> domain name (hereafter, the "Disputed Domain Name") is identical to its HCL trademarks.

 

The Complainant further contends that the Respondent should be considered as having no rights or legitimate interests in respect to the Disputed Domain Name. In summary, according to the Complainant: 

 

-       the Complainant has not authorized or licensed the Respondent to use any of its HCL marks and the Respondent is not and has not been commonly known by the Disputed Domain Name; and

-       the Respondent's acquisition and offering for sale of the Disputed Domain Name, a domain name identical to the Complainant's distinctive and well-known HCL trademark and paired with the ".ai" gTLD directly relevant to the Complainant's business, does not constitute a bona fide offering of goods or services or a legitimate noncommercial or fair use.

 

Finally, the Complainant alleges that the Disputed Domain Name should be considered to have been registered and used in bad faith because, in summary, according to the Complainant: 

 

-       the Respondent intentionally and willfully misrepresented to the Registrar that the registration of the Disputed Domain Name did not interfere with or infringe upon the rights of any third parties;

-       the Respondent had actual knowledge or was reasonably aware of the Complainant's rights in the HCL marks when the Respondent registered the Disputed Domain Name. This is evident given the HCL brand's notoriety. It is highly improbable that the Respondent, an experienced domain investor who frequently participates in UDRP proceedings, was unaware of the Complainant and its HCL trademark at the time of registration;

 

-       the Respondent is likely profiting commercially by diverting internet users searching for the Complainant's website, as these users "may find Respondent's website due to the confusingly similar domain name and become confused regarding Complainant's affiliation with, or sponsorship of, the domain name and featured content";

 

-       the Respondent's bad faith is further evidenced by the fact that the Disputed Domain Name has been listed for sale. The 2022 sales listing reflects an asking price of approximately USD $9,488, an amount that far exceeds any reasonable out-of-pocket costs associated with registering or maintaining the Disputed Domain Name; and

 

-       the Respondent's bad faith is further evidenced by its pattern of registering domain names that are identical to third-party trademarks, considering that the Respondent has been named in numerous other UDRP proceedings.

 

B. Respondent

In summary, the Respondent asserts it has legitimate rights in the Disputed Domain Name as:

 

-       in cases involving short, acronymic domain names, it is a well-established principle that the Complainant has a higher burden to show that the Respondent's use has somehow been illegitimately premised on the Complainant's limited scope of rights in particular, against a background of generic meanings and concurrent use. Here, the "three letter acronym" at issue is a generic term in itself. The Complainant is far from being the only, or indeed prominent, user among the existing and potential future users of this three-letter acronym as a domain name;

 

-       The mere registration and offer for sale of the Disputed Domain Name cannot be understood as in any manner trading on the Complainant's limited goodwill in its claimed mark; and

 

-       it is legitimate to acquire a domain name to resolve to a web page which includes an offer to sell the domain name based entirely on its value as a generic acronym and, in this instance, what is probably one of the most recognizable chemical compounds after H2O.

 

The Respondent also claims the Disputed Domain Name was not registered or used in bad faith as:

 

-       the Disputed Domain Name cannot be understood to be inherently associated with the Complainant's asserted mark, nor has it been used in any way suggesting a predatory intent in relation to the Complainant's mark. The Respondent had never heard of the Complainant prior to this dispute, and acquired the Disputed Domain Name in the belief that it has yet higher value as a generic three-letter domain name, consistent with the Respondent's established business practices and consistent with a pattern of registration of three-letter domain names as such;

 

-       the Complainant points to behavior of the Disputed Domain Name in 2022 as evidence of use in bad faith. However, the Respondent was not the registrant of the Disputed Domain Name at that time. The Respondent acquired the Disputed Domain Name in June 2024 through a public auction of expired domain names. Whatever the prior registrant may have done with the Disputed Domain Name is irrelevant;

 

-       the Complainant has noted that the Respondent did not prevail in two prior cases, and calls this a "pattern". However, the Respondent prevailed in at least 5 cases;

 

-       it is obvious that the Respondent is not "profiting commercially" from a non-revenue generating "domain for sale" page; and

 

-       Internet users are not likely to be confused by the Disputed Domain Name.

 

FINDINGS

The Complainant is a global technology group of companies offering an integrated portfolio of products, solutions, services, and IP built around digital, IoT, cloud, automation, cybersecurity, analytics, infrastructure management and engineering services, amongst others. The business, goods and services under the HCL trademark has generated annual revenues of over US $10 billion with more than 200,000 employees across the globe. The Complainant has been operating for over 50 years and is currently ranked at 764 on the Forbes 2024 Global 2000 list, which ranks the largest companies in the world. The Complainant's HCLTech brand is also ranked number 262 on the Brand Finance list of the world's top 500 most valuable brands in 2025.

 

The Complainant is the owner of numerous trademarks, including the following:   

-       HCL, USA stylized mark registered under No. 3258113 on July 3, 2007, in classes 9, 35 and 42; and

-       HCL, Indian word mark filed under No. 1183584 on March 17, 2003, in class 9.

 

The Respondent is a dealer in domain names, including dictionary terms and short names, with a particular focus on the .ai ccTLD. According to the Respondent's evidence, it acquired the Disputed Domain Name in June 2024.

 

The Disputed Domain Name resolves to a registrar parking page mentioning that the Disputed Domain Name is for sale.

 

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."

 

Paragraph 4(a) of the Policy requires that the Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

(1)       the Disputed Domain Name registered by the Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

 

(2)       the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and

 

(3)       the Disputed Domain Name has been registered and is being used in bad faith.

 

Identical and/or Confusingly Similar

The Policy ¶ 4(a)(i) requires Complainant to show that the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which Complainant has rights.  

 

Registration of a mark with the USPTO suffices to establish the rights under the Policy. See DIRECTV, LLC v. The Pearline Group, FA 1818749 (Forum Dec. 30, 2018). ("Complainant's ownership of a USPTO registration for DIRECTV demonstrate its rights in such a mark for the purposes of Policy ¶ 4(a)(i)"). The Complainant provided evidence that it owns trademarks for HCL in the US and India, which is not contested by the Respondent.

 

The Panel notes that the Disputed Domain Name corresponds to the Complainant's HCL trademark, except for the ".ai" ccTLD which is generally disregarded under the first element confusing similarity test.

 

Therefore, the Panel finds that the Disputed Domain Name is identical to the Complainant's mark per Policy ¶ 4(a)(i). 

 

Rights or Legitimate Interests

The Policy ¶ 4(a)(ii) requires the Complainant to show that the Respondent has no rights or interests in respect of the Disputed Domain Name. Once Complainant establishes a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Name, the burden of production shifts to the Respondent to show that it has rights or legitimate interests in respect of the Disputed Domain Name. See WIPO Overview 3.1 at ¶ 2.1 and Google LLC v. Alex Xavier/ Alexander Xavier / Sustineri Foresight Ltd, FA 28296 (Forum  Mar. 15, 2023).  

 

The Complainant provided evidence that it owns trademark registrations for HCL before the Disputed Domain Name was registered and acquired by the Respondent. The Complainant is not affiliated with, nor has it licensed or otherwise permitted the Respondent to use the Complainant's trademark. The Respondent is not commonly known by the Disputed Domain Name. In view of the nature of the Disputed Domain Name and the fact that it is offered for sale, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in respect of the Disputed Domain Name.

 

The Respondent essentially relies on the value of the Disputed Domain Name as a generic acronym, which refers to a common chemical, hydrochloric acid, amongst other meanings. The Respondent claims "it is legitimate to acquire a domain name to resolve to a web page which includes an offer to sell the domain name based entirely on its value as a generic acronym and, in this instance, what is probably one of the most recognizable chemical compounds after H2O".

 

The Panel is not convinced by the Respondent's arguments.

 

Panels have held that merely registering a domain name comprised of a dictionary word or phrase would not by itself automatically confer rights or legitimate interests on a respondent. Mere arguments that a domain name corresponds to a dictionary term/phrase or acronym may not be sufficient, and panels will consider the overall facts and circumstances of the case when assessing such arguments. This includes factors such as the status and fame of the relevant mark.

 

For a respondent to have rights or legitimate interests, in particular for a domain name comprising an acronym, the respondent's evidence supporting its explanation for its registration (and any use) of the domain name should indicate a credible intent which does not capitalize on the reputation and goodwill inherent in a complainant's mark. See WIPO Overview 3.1 at ¶2.1 and 2.10.

 

In the present case, the Panel finds two elements to be of particular relevance:

 

-       the combination of the three-letter acronym and the ".ai" ccTLD; and

 

-       the reputation of the Complainant's mark.

According to the Complainant's evidence and the Panel's limited independent search of publicly available information, the Complainant's mark was widely recognized within the IT industry and among relevant consumers when the Respondent acquired the Disputed Domain Name in June 2024.

 

Apart from the Complainant's size and the global nature of its IT business, the Panel observes the following in particular:

 

-       the Complainant has actively promoted its artificial intelligence ('AI') capabilities well before the Respondent's acquisition of the Disputed Domain Name, including through a link on its homepage and a dedicated page on its website; and

 

-       various press articles dated before the Respondent's acquisition of the Disputed Domain Name report on the Complainant's business in the AI field.

 

Therefore, the Panel finds it very difficult, if not impossible, for the Respondent to maintain that the Disputed Domain Name would not capitalize on the reputation and goodwill of the Complainant's mark when the Disputed Domain Name is registered in the ".ai" ccTLD, even if there are no restrictions on who may register a domain name under this TLD. The Disputed Domain Name is identical to the Complainant's trademark and it is registered in a TLD which is strongly connected to the Complainant's business. In these circumstances, the Panel finds the risk of deception and confusion is extremely high. See Fifth Street Capital LLC v. Fluder (aka Pierre Olivier Fluder), WIPO Case No. D2014-1747.  

 

The Panel therefore concludes that the Respondent has no rights or legitimate interests in the Disputed Domain Name.   

 

Registration and Use in Bad Faith

Particular circumstances panels may take into account in assessing whether the respondent's registration of a domain name is in bad faith include the nature of the domain name and the chosen top-level domain (e.g., particularly where corresponding to the complainant's area of business activity or natural zone of expansion). See WIPO Overview 3.1 at ¶3.2.1.

 

In circumstances where a complainant's mark is widely known (including in its sector) or highly specific and a respondent cannot credibly claim to have been unaware of the mark (particularly in the case of domainers), panels have been prepared to infer that the respondent knew, or have found that the respondent should have known, that its registration would be identical or confusingly similar to a complainant's mark. Further factors including the nature of the domain name, the chosen top-level domain, any use of the domain name, or any respondent pattern, may obviate a respondent's claim not to have been aware of the complainant's mark.

 

On the other hand, where the complainant's mark is not inherently distinctive and it also corresponds to a dictionary term or is otherwise inherently attractive as a domain name (e.g., it is a short combination of letters), if a respondent can credibly show that the complainant's mark has a limited reputation and is not known or accessible in the respondent's location, panels may be reluctant to infer that a respondent knew or should have known that its registration would be identical or confusingly similar to the complainant's mark. See WIPO Overview 3.1 at ¶3.2.2. (emphasis added).

 

Panels have held that respondents, especially domainers undertaking bulk purchases or automated registrations, have an affirmative obligation to avoid the registration of trademark-abusive domain names. Panelists will look to the facts of the case to determine whether such respondent has undertaken good faith efforts to screen such registrations against readily-available online databases to avoid the registration of trademark-abusive domain names.

 

Noting the possibility of co-existence of trademarks across jurisdictions and classes of goods and services, and the fact that trademarks which may be inherently distinctive in one context may be generic in another, the mere fact of certain domain names proving identical or confusingly similar to third-party trademarks pursuant to a search does not, however, mean that such registrations cannot as such be undertaken or would automatically be considered to be in bad faith. See WIPO Overview 3.1 at ¶3.2.3.

 

In the present case, as explained in the Panel's assessment under the second element, the Panel finds that there is sufficient evidence of the reputation of the Complainant's mark in the IT sector and in connection with AI at the time the Respondent acquired the Disputed Domain Name, including in the USA where the Respondent is located. Moreover, as a dealer in domain names with a particular focus on the .ai ccTLD, the Panel finds that the Respondent knew or at least should have known of the Complainant and its rights in the HCL mark, which supports a finding of bad faith registration of the Disputed Domain Name.

 

The Panel accepts that the acronym, "HCL", may have inherent value and various generic meanings. However, in the Panel's view, the combination of this term with the ".ai" TLD creates a likelihood of confusion with the Complainant's mark.

 

In the above circumstances, the Panel finds that the Respondent's offering for sale of the Disputed Domain Name indicates an intent to capitalize on the value of the Complainant's mark, which supports a finding of bad faith use.

 

On the balance of probabilities, the Panel finds that the Complainant has established the third element of the Policy. 

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <hcl.ai> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Flip Jan Claude Petillion, Chair

Karen J. Bernstein, Panelist

Ho-Hyun Nahm, Panelist

Dated: March 16, 2026