DECISION
Sabre GLBL Inc. v. Igor Gabrielan
Claim Number: FA2601002202348
PARTIES
Complainant is Sabre GLBL Inc. ("Complainant"), represented by John P. McCormick of Fish & Richardson P.C., Massachusetts, USA. Respondent is Igor Gabrielan ("Respondent"), represented by John Berryhill, Pennsylvania, USA.
REGISTRAR AND DISPUTED DOMAIN NAME
The domain name at issue is <sabre.ai>, registered with Zenaida.cate.ai.
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 Panelists in this proceeding.
Richard W. Hill and Assen Z. Alexiev as Panelists and Alan L. Limbury as Chair.
PROCEDURAL HISTORY
Complainant submitted a Complaint to Forum electronically on January 28, 2026. Forum received payment on January 28, 2026.
On January 30, 2026, Zenaida.cate.ai confirmed by e-mail to Forum that the <sabre.ai> domain name is registered with Zenaida.cate.ai and that Respondent is the current registrant of the name. Zenaida.cate.ai has verified that Respondent is bound by the Zenaida.cate.ai 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 February 3, 2026, Forum served the Complaint and all Annexes, including a Written Notice of the Complaint, setting a deadline of February 27, 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@sabre.ai. Also on February 3, 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 27, 2026.
On March 6, 2026, Complainant submitted to Forum an unsolicited additional submission.
On March 10, 2026, pursuant to Respondent's request to have the dispute decided by a three-member Panel, Forum appointed Richard W. Hill and Assen Z. Alexiev as Panelists and Alan L. Limbury as Chair.
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
Complainant, Sabre GLBL Inc., is a leading provider of comprehensive technological solutions that power the global travel, transportation, and hospitality industries, with its origin dating back to the early 1960s.
Complainant, through its predecessors in interest, adopted and began to use the SABRE trademark for its technology solutions and services at least as early as 1964, and has continuously used this trademark in United States commerce since that time. In addition to its longstanding common law rights in the SABRE mark, Complainant owns incontestable United States federal trademark registrations for the mark and over 550 registrations for the SABRE mark and marks containing the SABRE mark around the world, including in Ukraine.
Respondent's <sabre.ai> domain name is confusingly similar to the SABRE mark.
Respondent has no rights or legitimate interests in the <sabre.ai> domain name. Respondent has never been known as or referred to as SABRE or any variation thereof; is not authorized or licensed to use the SABRE or SABRE-formative marks; has not used the domain name in connection with a bona fide offering of goods or services; and is not making a non-commercial fair use of the domain name. Rather, the disputed domain name directs to a forum page listing countless domain names for sale (including the subject domain name), wherein Respondent notes that he is now requiring an exorbitant purchase price. Thus, Respondent only uses the domain name to unfairly exploit the SABRE trademark and associated goodwill.
Respondent registered and uses the <sabre.ai> domain name in bad faith. Respondent registered the domain name in order to resell it at an excessive amount. Complainant secured its first federal registration for the SABRE mark in 1982, almost four decades prior to the date that Respondent registered the domain name. Given Complainant's longstanding use of SABRE and its prevalence around the world, it is clear that Respondent registered the domain name with full knowledge of Complainant's rights in the SABRE trademark, thus warranting a finding of bad faith. Additionally, SABRE is neither a generic nor a descriptive term. Rather, "SABRE" is not an American English word. See The American Heritage Dictionary of the English Language. Respondent has provided no evidence of any actual or contemplated good faith use of the domain name since registering it in December 2020, and instead, is allowing it to sit for sale.
B. Respondent
Respondent accepts that Complainant has satisfied the first element.
As to the second element, Respondent is well known as a top registrant of .ai domain names and has obtained attention in domain industry blogs. He is not hiding anything about his substantial interest in that regard. The Complaint asserts that what is clearly a dictionary word at issue here is not "American English", which may be technically correct, but irrelevant to standard English as understood by Respondent, who is not American.
"Sabre" is a well-known English word (albeit spelled differently in American English) with a variety of applications and is widely used among many commercial entities, for example: Sabre.realestate - a real estate brokerage; Sabre.com.sg - an Asian electronic parts maker; Sabre.sk - a Slovak mechanical firm; Sabre.us - a forward to Sabre Integrated, a New York security systems firm; Sabre.paris - a forward to sabre-paris.com a French cutlery maker; Sabre.fit - a fitness system and community of some kind; Sabre.ie - an Irish security firm; Sabre.app - home of the Special Activity Broadcast Receiving Engine open protocol; Sabre.org.au - home of Sabre Sailing Australia; Sabre.cz - a Czech design firm; Sabre.com.au - an Australian architectural fittings firm; Sabre.technology - home of some kind of European cybersecurity initiative; Sabre.capital - a real estate investment firm; Sabre.run - a chain of French business services; Sabre.net.au - home of Sabre Connect, an Australian IT provider; Sabre.co.za - a South African paint brand; Sabre.ca - a Canadian technical services firm; Sabre.education - a UK education NGO; Sabre.website - an organization protesting solar farms in the UK; Sabre.life - a real estate and business consulting firm; Sabre.co.uk - a UK insurance company; Sabre.store - a quirky artwork creator; Sabre.dk - Danes with swords up to something rotten in Denmark; Sabre.nz - a forward to Sabre Tactical, a Kiwi defense products provider; Sabre.io - a repository site for a software project of some kind; and Sabre.graphics - a UK graphic arts firm.
Apart from its status as a dictionary word, a widely and concurrently used mark, and a popular single-word domain name in a wide range of industries, "SABRE" is also a widely used acronym, with some twenty definitions to be found in the acronym dictionary AcronymFinder.com.
Respondent's acquisition of the <sabre.ai> domain name was consistent with Respondent's business as a domain investor. Respondent has a portfolio of .ai dictionary word domain names consisting of words suggestive of topics involving the use of weapons or militaria, such as: <airforce.ai>, <arms.ai>, <miltech.ai> and <navy.ai>, along with likewise being consistent with Respondent's registration of five letter dictionary word domain names generally, such as: <award.ai>, <choir.ai>, <court.ai>, <forum.ai>, <guard.ai>, <lunar.ai>, <payer.ai>, <pizza.ai>, <puppy.ai>, <sport.ai>, <stove.ai> and <suite.ai>.
The mere general offer for sale of a non-exclusive and non-distinctive term does not implicate or violate Complainant's limited rights. Respondent has made no infringing or illegitimate use of the domain name, and Complainant does not point to one millisecond in the entire history of the domain name during which it was used for any purpose having to do with the limited range of goods or services within the scope of Complainant's rights. Accordingly, there has been no illegitimate use of the domain name.
Respondent has registered and subsequently offered a dictionary word domain name for public sale for any that might want to use it for purposes having nothing to do with Complainant. Respondent has a well-established record and pattern of such activity. Complainant has failed to show that Respondent lacked or lacks any right to do so or that Respondent's use of the domain name has any connection with Complainant's narrow claim of rights.
As to bad faith, the Complaint contains not a single particularized allegation establishing that Respondent's registration and use of the domain name was premised on Complainant's rights. There is not a single enumerated factor of the "passive holding" doctrine which favors Complainant here. Complainant's allegations boil down to a raw assertion that attempting to sell a dictionary domain name is per se illegitimate, which is simply not consistent with the weight of authority in relation to this sort of UDRP proceeding. See Patricks Universal Export Pty Ltd. v. David Greenblatt, WIPO Case No. D2016-0653 and Voys B.V., Voys United B.V. v. Thomas Zou, WIPO Case No. D2017-2136.
Complainant has provided no evidence showing any actual use of the domain name by Respondent which can be objectively understood to have been predicated on Complainant's particular services, industry or channels of trade.
Accordingly, Respondent submits that on the basis of the context of the "SABRE" trademark landscape in which Complainant's claim more accurately is "one of many"; the obvious and apparent widespread use of "SABRE", a dictionary word, in a wide variety of single-word domain names which, magically, do not confuse or divert consumers to the sole exclusion of Respondent's <sabre.ai>; and the absence of any evidence on which a claim that Respondent has somehow targeted or premised registration on Complainant in particular, the full record demonstrates that Complainant has failed to show, by a preponderance of evidence, the domain name to have been registered and used in bad faith.
C. Complainant's additional submission
The Panel exercises its discretion pursuant to Forum's Supplemental Rule 7 to consider Complainant's additional submission.
Complainant submits that Respondent has identified himself as a prominent domain investor, which imparts an affirmative obligation to avoid the registration of trademark-abusive domain names. Had Respondent done a cursory search of the Ukrainian National Office for Intellectual Property and Innovations' trademark database, he would have identified Complainant's registrations for the SABRE mark as the only SABRE or SABRE formative filings active with that trademark office. Respondent's willful blindness to Complainant's rights does not constitute legitimate rights or interests in the <sabre.ai> domain name.
FINDINGS
Complainant has failed to establish all the elements entitling it to relief.
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.
Identical and/or Confusingly Similar
Complainant has shown that it has rights in the service mark SABRE, including USPTO Registration No. 1,219,417, registered on December 7, 1982 for inter alia providing hotel reservations by means of a computer, in International Class 42.
The Panel finds Respondent's <sabre.ai> domain name to be identical to Complainant's SABRE mark, since the inconsequential ".ai" country code top-level domain ("ccTLD") may be ignored under this element. See Dell Inc. v. Protection of Private Person, FA 1681432 (Forum Aug. 1, 2016) ("A TLD (whether a gTLD, sTLD or ccTLD) is disregarded under a Policy ¶ 4(a)(i) analysis because domain name syntax requires TLDs"); see also Abbott Labs v. Whois Svc., FA 1254682 (Forum May 14, 2009) ("the addition of a gTLD is irrelevant in distinguishing a disputed domain name from a registered mark"); see also Twitter, Inc. v. Jie, FA 1919786 (Forum Dec. 9, 2020) ("The Panel considers the disputed domain name [<twitter.luxe>] to be identical to Complainant's registered [TWITTER] trademark").
Complainant has established this element.
Rights or Legitimate Interests
Paragraph 4(c) of the Policy provides that any of the following circumstances, in particular but without limitation, if found by the Panel to be proved based on its evaluation of all evidence presented, shall demonstrate Respondent's rights or legitimate interests to a domain name for purposes of Paragraph 4(a)(ii):
(i) before any notice to Respondent of the dispute, the use by Respondent 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 Respondent has 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 customers or to tarnish the trademark or service mark at issue.
The <sabre.ai> domain name was registered on December 11, 2020, many years after the registration of Complainant's SABRE mark. It redirects to an Internet forum website listing ".ai" domain names available for sale, including the <sabre.ai> domain name. Complainant enquired as to the sales price of the domain name and was quoted $300,000 net.
WIPO Overview 3.1, ¶ 2.1 states: "Over the course of many UDRP cases, panels have acknowledged further grounds that, although not specifically articulated in the UDRP, may establish respondent rights or legitimate interests in a domain name. For example, generally speaking, panels have accepted that aggregating and holding domain names (usually for resale) consisting e.g., of acronyms, dictionary words, common phrases, or unique/catchy or memorable terms (alone or in combination) can be bona fide and is not per se illegitimate under the UDRP where the respondent can show that the purpose of the registration was not to target a trademark."
Respondent has shown that the word "sabre" is a common English dictionary word (albeit spelled differently in American English); that there are many owners of trademarks and many registrants of domain names comprising or incorporating that word; and that Respondent is a domain name reseller who has registered many ".ai" domain names. As in Montane Ltd. v. Orion Global Assets, WIPO Case No. D2017-0309, cited in the Response, there is no evidence that, in setting a price of $300,000 for the sale of the domain name to the general public, Respondent was targeting Complainant.
In its Additional Submission, Complainant cites WIPO Overview 3.1 ¶ 3.2.3 on "Willful Blindness" to argue that Respondent, being a domain name investor, was under an obligation to check whether SABRE was a trademark. The Panel does not agree. The closest equivalent to a legislative history for the UDRP is the April 30, 1999 Final Report of the WIPO Internet Domain Name Process. The question of whether a registrant should be expected to conduct a trademark search is discussed in ¶¶ 103-105 of that report; ¶ 105 states: "It is not recommended that domain name registrations be made conditional upon a prior search of potentially conflicting trademarks, but it is recommended that the domain name application contain appropriate language encouraging the applicant to undertake voluntarily such a search."
Under the circumstances of the instant case, the Panel finds that Respondent was under no obligation to conduct a trademark search. Thus, the Panel finds that, contrary to Complainant's additional submission, the <sabre.ai> domain name is not a trademark abusive domain name registration in the sense of the Policy, see 5B Investments, Inc. v. RareNames, WebReg, D2008-0146 (WIPO Mar. 24, 2008) ("…a number of panels have concluded that a respondent has a right to register and use a domain name to attract Internet traffic based on the appeal of a commonly used descriptive phrase, in the absence of circumstances indicating that the respondent is seeking to profit from and exploit the complainant's trademark"). The above finding is of course without prejudice to whatever rights Complainant may invoke under national trademark laws.
Accordingly, the Panel finds that, before any notice to Respondent of this dispute, in offering the domain name for sale to the general public Respondent, a domain name investor, has used the domain name in connection with a bona fide offering of services. This demonstrates Respondent's rights and legitimate interests to the domain name for purposes of Policy Paragraph 4(a)(ii). See Academy, Ltd. v. Ramesh Singh, FA 2026883 (Forum Feb. 21, 2023) ("Respondent shows that he is a domain investor. Complaint Exhibit G and Response Annex II are lists of many domain names in addition to the Domain Name involved in this proceeding that Respondent has acquired as inventory, or stock in trade. Investing in common-word domain names is a perfectly legitimate business and can qualify as a bona fide offering of goods or services so long as the Respondent did not target a specific complainant or protected mark with a particular domain name."); see also Vulf Records LLC v. Domain Admin / This Domain is For Sale / HugeDomains.com, FA 1771089 (Forum Mar. 30, 2018) ("Respondent is in the business of registering, holding, and selling domain names. It has produced evidence of numerous such sales. The Panel finds that Respondent's reselling of domain names constitutes a bona fide offering of goods or services.").
Complainant has failed to establish this element.
Registration and Use in Bad Faith
Paragraph 4(a)(iii) of the Policy is expressed in the conjunctive: "the domain name has been registered and is being used in bad faith" and Paragraph 4(b) sets out four illustrative circumstances, which, though not exclusive, shall be evidence of the registration and use of a domain name in bad faith for purposes of paragraph 4(a)(iii), namely:
(i) circumstances indicating that you have registered or you have 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 your documented out-of-pocket costs directly related to the domain name; or
(ii) you have 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 you have engaged in a pattern of such conduct; or
(iii) you have registered the domain name primarily for the purpose of disrupting the business of a competitor; or
(iv) by using the domain name, you have intentionally attempted to attract, for commercial gain, Internet users to your web site 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 your web site or location or of a product or service on your web site or location.
Complainant relies on Paragraph 4(b)(i). However, the Panel is not persuaded that, in quoting a selling price of $300,000 net (presumably to Complainant) in December 2025, Respondent registered the dictionary word domain name in 2020 with the intention of selling it to Complainant for an excessive amount.
Further, the Panel is not satisfied that Respondent was or should have been aware of Complainant and its mark when registering the domain name. The widespread use of similar marks and similar domain names contradicts Complainant's assertion that "Given Complainant's longstanding use of SABRE and its prevalence around the world, it is clear that Respondent registered the domain name with full knowledge of Complainant's rights in the SABRE trademark, thus warranting a finding of bad faith". See also the discussion under "Rights or Legitimate Interests" above.
Complainant has failed to establish this element.
DECISION
Complainant having not established all three elements required under the ICANN Policy, the Panel concludes that relief shall be DENIED.
Accordingly, it is Ordered that the <sabre.ai> domain name REMAIN WITH Respondent.
Alan L. Limbury, Chair
Richard W. Hill and Assen Z. Alexiev, Panelists
Dated: March 12, 2026
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