DECISION

 

Google LLC v. Monika Sharma

Claim Number: FA2601002200729

 

PARTIES

Complainant is Google LLC ("Complainant"), represented by Griffin Barnett of Morgan, Lewis & Bockius LLP, District of Columbia, USA. Respondent is Monika Sharma ("Respondent"), India.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The disputed domain name is <googleadstrends.com>, registered with BigRock Solutions Ltd.

 

PANEL

The undersigned certifies that he has acted independently and impartially and to the best of his knowledge have no known conflict in serving as Panelist in this proceeding.

 

Fernando Triana, Esq., as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on January 20, 2026; Forum received payment on January 20, 2026.

 

On January 23, 2026, BigRock Solutions Ltd confirmed by e-mail to Forum that the <googleadstrends.com> domain name is registered with BigRock Solutions Ltd and that Respondent is the current registrant of the name. BigRock Solutions Ltd has verified that Respondent is bound by the BigRock Solutions Ltd 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 27, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 17, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@googleadstrends.com. Also on January 27, 2026, the Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.

 

A timely Response was received and determined to be complete on February 2, 2026.

 

Complainant filed an Additional Submission on February 2, 2026.

 

Respondent filed an Additional Submission on February 2, 2026.

 

On February 2, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Fernando Triana, Esq., as Panelist.

 

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.

 

PARTIES' CONTENTIONS

A.       Complainant

a.       Complainant was founded in 1998 by Larry Page and Sergey Brin.

b.       Complainant is a global technology company headquartered in Mountain View, California. Its trademark GOOGLE is one of the most recognized and valuable brands worldwide. Google operates its primary website at <google.com> and owns numerous domain names incorporating the trademark GOOGLE across multiple top-level domains worldwide.

c.       The trademark GOOGLE has been registered in many jurisdictions since as early as 1999, with first use dating back to 1997. Through extensive global use, advertising, and media recognition, the mark has become famous and is exclusively associated by consumers with Complainant and its services.

d.       Among Complainant's services is Google Ads, an online advertising platform that allows users to create and manage digital advertising campaigns. Google maintains clear trademark guidelines prohibiting unauthorized use of its marks in domain names, business names, or product names.

e.       The disputed domain name redirects users to a website titled "Google Ads Trends," which appears designed to create the false impression that it is affiliated with or authorized by Complainant. The site offers digital marketing, YouTube marketing, and Google Ads-related services for profit. It repeatedly refers to itself as "Google" and uses Google-related branding elements, including the YouTube logo, reinforcing the misleading impression of affiliation. A small disclaimer on the site does not sufficiently prevent consumer confusion.

f.       Complainant sent a cease-and-desist letter requesting cancellation or transfer of the domain name and cessation of unauthorized trademark use. Respondent did not respond. 

g.       The disputed domain name incorporates the trademark GOOGLE in its entirety, merely adding descriptive terms ("Ads" and "Trends") and the ".com" extension. Given the fame and distinctiveness of the trademark GOOGLE, this creates a high likelihood of confusion, particularly as the associated website uses Google's branding and promotes services related to Google Ads. The overall context strongly suggests affiliation or endorsement by Complainant.

h.       Respondent is not licensed or authorized to use the trademark GOOGLE and is not commonly known by that name.

i.       The use of the disputed domain name is commercial and designed to capitalize on Complainant's reputation by suggesting affiliation.

j.       Respondent's conduct does not qualify as fair use. Even if offering services related to Google Ads, incorporating the trademark GOOGLE into a domain name without authorization exceeds permissible nominative use, particularly where the website creates confusion regarding sponsorship or affiliation.

k.       Given Complainant's longstanding and well-known trademark rights, Respondent was clearly aware of the trademark GOOGLE at the time of registration.

l.       The trademark GOOGLE is globally famous and highly distinctive, making it implausible that Respondent registered the domain name innocently.

m.       The disputed domain name fully incorporates the mark and is used to promote services closely related to Complainant's own offerings, indicating intent to exploit the brand's value.

n.       Respondent appears to be intentionally attracting users for commercial gain by creating a likelihood of confusion regarding source, sponsorship, or affiliation. Additional evidence of bad faith includes:

i.       Use of incomplete or inaccurate Whois registration information

ii.       Use of a privacy/proxy service to conceal identity

iii.       Failure to respond to Complainant's demand letter

iv.       Use of a disclaimer insufficient to cure consumer confusion

 

B.       Respondent

a.       Although the disputed domain name incorporates the term "GOOGLE," it is used descriptively to identify the subject matter of the services offered—specifically, analysis of trends within the Google Ads platform. The addition of the terms "Ads" and "Trends" creates a descriptive phrase aimed at a specialized professional audience, rather than suggesting that the website is operated by or affiliated with Google.

b.       The disputed domain name is used for a bona fide consultancy business. The reference to "Google Ads" is presented as a necessary nominative use to identify the advertising platforms being managed.

c.       Respondent states that the business has operated continuously since the domain was registered in December 2019, nearly six years before receiving the Complainant's demand letter.

d.       Respondent denies any intent to exploit the value of the trademark GOOGLE. According to Respondent, the disputed domain name was selected for its descriptive relevance to consultancy services focused on "Google Ads Trends." The website also includes a disclaimer intended to clarify that it is not affiliated with Google and to reduce the likelihood of consumer confusion.

 

C.       Additional Submissions

a.       Complainant's Additional Submission

i.       Complainant rejects Respondent's claim that the disputed domain name uses the trademark GOOGLE merely in a descriptive manner. The disputed domain name incorporates the trademark GOOGLE in its entirety, with only the addition of the descriptive terms "Ads" and "Trends." Because the mark is fully included and highly distinctive, this is sufficient to render the disputed domain name confusingly similar, regardless of the added terms.

ii.       Respondent claims to operate a legitimate consultancy business and argues that its reference to "Google Ads" is a necessary nominative use to identify the services provided. However, Complainant contends that even if Respondent offers services related to Google Ads, this does not entitle Respondent to incorporate the Trademark GOOGLE into a domain name without authorization.

iii.       Additionally, Respondent's website offers broader digital marketing services beyond Google Ads, undermining the argument that the mark is used solely in a limited, descriptive manner. For these reasons, Complainant maintains that Respondent lacks any rights or legitimate interests in the domain name.

iv.       Respondent denies acting in bad faith and points to a disclaimer on the website as evidence of good faith. Complainant argues that the disclaimer is insufficient to prevent confusion, particularly because the trademark GOOGLE is prominently used in the domain name and branding, creating the impression of affiliation.

v.       Further evidence of bad faith includes Respondent's offer to sell the domain name to Google for USD$15,000—an amount significantly exceeding ordinary registration costs—suggesting an intent to profit from the trademark's value.

vi.       Complainant emphasizes that an offer to sell an infringing domain name for an amount exceeding the registrant's out-of-pocket costs is strong evidence of bad faith. In this case, Respondent's offer to sell the disputed domain name supports the conclusion that it was registered and used in bad faith.

vii.       Accordingly, Complainant reiterates that the disputed domain name is confusingly similar to the famous trademark GOOGLE, that Respondent lacks any rights or legitimate interests in it, and that the disputed domain name was registered and used in bad faith. Complainant therefore requests that the Panel order transfer of the domain name.

 

b.       Respondent's Additional Submission

i.       By "domain value," Respondent refers to the standalone commercial value of the disputed domain name, considering factors such as its descriptive structure, memorability, longevity, and organic search visibility. The disputed domain name has been registered for over eight years and has developed measurable SEO value through indexing and search traffic. Based on third-party valuation benchmarks and comparable market data, its estimated value exceeds USD 15,000.

ii.       Respondent expresses willingness to discuss the matter amicably and without prejudice, while maintaining their rights as registrant. Respondent also states that the disputed domain name was registered without intent to target or exploit Complainant's trademark and has not been used to falsely suggest affiliation with Complainant or its services.

 

FINDINGS

A.       Among several others around the world, Complainant owns the trademark GOOGLE in the United States of America, since 2012 with first use in 2000, in international class 35, with registration No. 4,123,471. Since 2004, with first use in 1997, in international classes 38 and 42, with registration No. 2,806,075. Since 2005, with first use in 1999, in international classes 9, 11, 12, 16, 18, 21, 25, 28 and 35, with registration No. 2,954,071.

B.       Respondent knew or should have known Complainant's trademark GOOGLE since Complainant is known worldwide, yet Respondent incorporated said trademark in the disputed domain name. Thus, Respondent used the trademark GOOGLE to create a likelihood of confusion aimed at diverting consumers to Respondent's offered services.

C.       Respondent has never been commonly known by the disputed domain name or the trademark GOOGLE.

D.       Respondent is not affiliated with Complainant in any way: Complainant has never authorized, contracted, licensed or otherwise permitted Respondent to use the trademark GOOGLE, nor is Respondent an authorized supplier of Complainant's services.

E.       Respondent's use of the disputed domain name is not in connection with a bona fide offering of goods or services.

F.       Respondent has the intention to attract, for commercial gain, Internet users by creating a likelihood of confusion with the Complainant's trademark due to the services offered in its website.

 

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 Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

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

(2)       Respondent has no rights or legitimate interests in respect of the domain name; and

(3)       the domain name has been registered and is being used in bad faith.

 

This discussion, based on the evidentiary support submitted by the parties, will be developed as follows:

 

First of all, the Panel will determine whether or not the disputed domain names are identical or confusingly similar to the mark in which Complainant has rights. Secondly, the Panel will verify if Respondent has any rights or legitimate interests in respect of the disputed domain names; and finally, the Panel will establish whether or not the disputed domain names have been registered and are being used in bad faith by Respondent.

 

Identical and/or Confusingly Similar

Complainant contends to be the owner of the trademark GOOGLE to identify goods and services of international classes 9, 11, 12, 16, 18, 21, 25, 28, 35, 38 and 42.

 

a)       Existence of a trademark or service mark in which the Complainant has rights

Firstly, it is important to point out that Paragraph 4(a) of the Policy requires the existence of a trademark or a service mark. The industrial property rights are only acquired by registration before the competent office in a number of many jurisdictions of the world.

 

The worldwide-accepted definition of a trademark involves the concept of distinctive force as the most relevant element. Said force gives the sign the capability to identify the products or services of its owner and differentiate them from the product and services of other participants in the market.

 

When a sign is registered as a mark, it is surrounded by a presumption of sufficient distinctive force, and the owner is granted with an exclusive right over the mark, which entitles him to prevent any third party from using the registered sign or any other sign confusingly similar to it.

 

However, the UDRP does not discriminate between registered and unregistered trademarks¹ and thus, it is well established that a Complainant does not require owning a registered trademark to invoke the Policy. It is sufficient in certain common law jurisdictions, such as the United States of America, that Complainant has rights over an unregistered trademark as to deserve legal protection, based solely on its use in commerce.

 

In this case, Complainant proved its rights in the trademark GOOGLE by means of the numerous registrations around the world including but not limited to: in the United States of America, since 2012 with first use in 2000, in international class 35, with registration No. 4,123,471. Since 2004, with first use in 1997, in international classes 38 and 42, with registration No. 2,806,075. Since 2005, with first use in 1999, in international classes 9, 11, 12, 16, 18, 21, 25, 28 and 35, with registration No. 2,954,071.

 

This information appears to be incontestable and conclusive evidence of Complainant's ownership of the cited mark and the exclusive right to use them in connection with the stated services. The registration of a mark is prima facie evidence of validity, which creates a rebuttable presumption that the mark is inherently distinctive².

 

Thus, Complainant established its rights in the trademark GOOGLE since at least 2004.

 

Therefore, the Panel concludes that Complainant has demonstrated rights in the trademark GOOGLE for purposes of Paragraph 4(a)(i) of the Policy.

 

b)       Identity or confusing similarity between the Disputed Domain Name and the Complainant's trademark

Complainant alleges that Respondent's disputed domain name is confusingly similar to Complainant's trademark as it uses the trademark GOOGLE and add the descriptive, non-distinctive terms "ads" and "trends," along with the ".com" or ".net" generic top-level domain ("gTLD").

 

In the first place, before establishing whether or not the disputed domain name is confusingly similar to Complainant's trademark GOOGLE, the Panel wants to point out that the addition of generic top-level domain (gTLD), i.e., ".com," ".net," ".biz," ".edu," ".org", cannot be considered when determining if the registered domain name is identical or confusingly similar to the registered trademark³ as the insertion of a gTLD has a distinctive function⁴.

 

UDRP Panels have unanimously accepted that the inclusion of the ".com" and ".net" (gTLD), in the disputed domain name is not a factor in analyzing whether a disputed domain name is identical or confusingly similar to the mark in which Complainant asserts rights. In the Wal-Mart Stores, Inc. v. Walsucks, D2000-0477 (WIPO July 20, 2000), the Panel stated that:

 

"[T]he addition of the generic top-level domain (gTLD) name '.com' is without legal significance since use of a gTLD is required of domain name registrants, '.com' is one of only several such gTLDs, and '.com' does not serve to identify a specific enterprise as a source of goods or services."

 

Furthermore, the Panel considers that the reproduction of the trademark GOOGLE, by the disputed domain name, is sufficient ground to establish that the disputed domain name is confusingly similar to the trademark⁵. Especially since the disputed domain name reproduces entirely Complainant's trademark GOOGLE without any other distinctive elements.

 

In fact, the words "ads" and "trends", do not add any distinctiveness they are descriptive of the service offered within the website to which the disputed domain name resolves.

 

Consequently, consumers will assume that the owner of the disputed domain name is the owner of the trademark or at least that the disputed domain name is linked in some way with Complainant.

 

In consequence, as per this reasoning, the Panel finds that, in the present case, the disputed domain names are confusingly similar to Complainant's mark and thus, the requirement set forth in Paragraph 4(a)(i) of the Policy is duly complied with.

 

Rights or Legitimate Interests

a)  Prima Facie Case.

Regarding this second element of Paragraph 4(a) of the Policy, UDRP Panels have unanimously consented that requiring the Complainant to prove the lack of rights or legitimate interests of the Respondent in the disputed domain name is often an impossible task: it is not only a negative but also demands access to information that is mostly within the knowledge of the Respondent⁶.

 

In Julian Barnes v. Old Barn Studios Ltd., D2001-0121 (WIPO Mar. 30, 2001), the Panel stated that:

 

"Is the Respondent required to adduce any such evidence, if the onus is on the Complainant to prove the three elements of paragraph 4 of the Policy? While the overall burden of proof is on the Complainant, this element involves the Complainant proving matters, which are peculiarly within the knowledge of the Respondent. It involves the Complainant in the often impossible task of proving a negative. In the Panel's view the correct approach is as follows: the Complainant makes the allegation and puts forward what he can in support (e.g. he has rights to the name, the Respondent has no rights to the name of which he is aware, he has not given any permission to the Respondent). Unless the allegation is manifestly misconceived, the Respondent has a case to answer and that is where paragraph 4(c) of the Policy comes in. If the Respondent then fails to demonstrate his rights or legitimate interests in respect of the Domain Name, the complaint succeeds under this head".

 

Therefore, a Complainant is required to make a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Once this prima facie case is made, the burden of production shifts to Respondent, who must come forward with concrete evidence of its rights or legitimate interests⁷. If Respondent fails to do so, Complainant is deemed to have met the second element of Paragraph 4(a) of the Policy.

 

Complainant asserts that Respondent has no rights or legitimate interests in the disputed domain name because of the following: i) Respondent knew or should have known of the existence and use of the trademark GOOGLE, when including them within the disputed domain name; ii) Respondent was not authorized by Complainant to use the trademark GOOGLE within his domain name; iii) Neither Respondent nor the services offered by Respondent on the website to which the disputed domain names resolved are affiliated with, associated with, or otherwise endorsed by Complainant; iv) Respondent is not commonly known by the disputed domain name; v) Complainant has not authorized, licensed, or otherwise permitted Respondent to use its trademarks within the website to which the disputed domain name resolved; and vi) Respondent does not use the disputed domain name in connection with a bona fide offering of goods or services or legitimate noncommercial or fair use. Rather, Respondent uses the disputed domain name in connection with a website that gives the false impression that users have reached a Complainant's affiliate.

 

The Panel accepts these assertions as a prima facie case made by Complainant that shifts the burden of production to Respondent.

 

b)  Respondent's rights or legitimate interests in the disputed Domain Name.

Paragraph 4(c) of the Policy includes an enunciative listing of circumstances that prove Respondent's rights or legitimate interests in a disputed domain name:

 

(i) before any notice of the dispute, Respondent's use of, or demonstrable preparations to use, the domain name or a name corresponding to the domain name in connection with a bona fide offering of goods or services; or

 

(ii) Respondent (as an individual, business, or other organization) has been commonly known by the domain name, even if you have acquired no trademark or service mark rights; or

 

(iii) Respondent is making a legitimate noncommercial or fair use of the domain name, without intent for commercial gain to misleadingly divert consumers or to tarnish the trademark or service mark at issue.

 

Respondent states that the disputed domain name is used for a bona fide consultancy business. The reference to "Google Ads" is presented as a necessary nominative use to identify the advertising platforms being managed.

 

Nonetheless, the Policy is clear as to establish that the use must be in connection with a bona fide offering of goods and services. Hence, the mere use of a domain name does not indicate rights or legitimate interests. The burden is higher, said use must be done in good faith.

 

Moreover, the use since 2019 does not convert a bad faith use, legitimize the use or grant rights over a domain name that controverts the Policy.

 

This Panel believes that Respondent failed to prove its rights or legitimate interests in the disputed domain names, as Respondent's use of the disputed domain name is not a bona fide offering of goods or services or a legitimate noncommercial or fair use, since the disputed domain name resolve to a website that purports to provide services related to Complainant's services. The website prominently displays a look and feel imitating Complainant's logos and font, which is directed to capitalize Complainant's trademark GOOGLE goodwill by attracting internet users to its disputed domain names where Respondent offers unauthorized software⁸.

 

Moreover, Complainant has never authorized Respondent to use the trademark GOOGLE or any logo similar to Complainant's look and feel.

 

Furthermore, Respondent never explained the reason for choosing the expression GOOGLE to be part of its domain name, when it is obvious from the Response, that Respondent has never been commonly known by the disputed domain name as an individual, business or organization.

 

Consequently, Respondent knew or should have known of Complainant's trademark GOOGLE since Complainant's trademark are included in the resolving website. Yet Respondent incorporated said trademark in the disputed domain name, instead of using a different and unrelated name to GOOGLE. Thus, Respondent used the trademark GOOGLE to create a likelihood of confusion aimed to divert consumers to Respondent's offered services.

  

Therefore, the second requirement of paragraph 4(b) of the Policy is met.

 

Registration and Use in Bad Faith

According to paragraph 4(b) of the Policy, the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith:

 

(1)   Circumstances indicating that Respondent has registered or has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of Respondent's documented out-of-pocket costs directly related to the domain name; or

 

(2)   Respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that Respondent has engaged in a pattern of such conduct; or

 

(3)   Respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or

 

(4)   By using the domain name, Respondent has intentionally attempted to attract, for commercial gain, Internet users to his/her website or other on-line location, by creating a likelihood of confusion with the complainant's mark as to the source, sponsorship, affiliation, or endorsement of his/her website or location or of a product or service on his/her website or location.

 

This Panel deems that the mere fact of knowingly incorporating a third-party's trademark in a domain name constitutes registration in bad faith⁹. See Aktiebolaget Electrolux v. Jorgeariel Figueroa Rodríguez, WIPO Case No. D2011-1311, where the panel found: "The selection of this word is certainly not a random decision; the Panel finds that it is a consequence of Respondent's prior knowledge of the mark. This fact, by itself, is registration in bad faith in the Panel's opinion".

 

Moreover, since Complainant's trademark are used in the disputed domain names "it is reasonable to conclude that many Internet users would suppose that the website, to which the disputed domain name resolves, has a connection with the Complainant"¹⁰. This conclusion might disrupt Complainant's business. Thus, the unauthorized use of Complainant's trademark amounts to bad faith registration and use. In fact, the services described in Respondent's response take advantage of the services provided by Complainant.

 

Respondent's use falsely suggests sponsorship and/or endorsement by Complainant of Respondent's website and use of the disputed domain name.

 

Respondent lack of response to a cease and desist letter, suggests bad faith registration and use of the disputed domain name.

 

Respondent's request for USD $15,000 for the disputed domain name also suggests bad faith registration and use of the disputed domain name, as it is clearly an out-of-pocket cost directly related to the domain name, specially that it would not have said price if it did not include Complainant's trademark.

 

Hence, Respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor and it is indicative of bad faith registration and use pursuant to Policy ¶ 4(a)(iii).

 

Furthermore, Respondent is profiting from its use of the trademark GOOGLE in the disputed domain name by attracting Internet users to the resolving website. Respondent has created confusion as to Complainant's affiliation or sponsorship of the disputed domain names and website in order to offer its services. This is indicative of bad faith under Policy ¶ 4(b)(iv)¹¹.

 

Therefore, the three elements of the Policy 4(a) are satisfied in the present case in respect to Respondent of the disputed domain names.

 

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 <googleadstrends.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

 

Fernando Triana, Esq., Panelist

Dated: February 16, 2026