On 23 June 2026, a WIPO panelist denied the UDRP complaint filed by Polyco Healthline Limited against the domain name coshield.com. At first sight, Polyco Healthline Limited v. David Beatson (WIPO Case No. D2026-1893) had all the hallmarks of a classic dispute involving a trademark and a domain name. That is precisely what makes the case interesting: not every dispute involving both necessarily amounts to cybersquatting.
SHIELD vs COSHIELD
Polyco has marketed personal protective equipment under the SHIELD trademark since 1997 and owns, among others, a UK trademark registered in 1998.
The domain name coshield.com, created in 2014, was used from 2020 onwards to market personal protective equipment under the COSHIELD sign. The parties were therefore operating in the same sector.
The dispute had, moreover, already moved beyond the purely commercial sphere. In 2021, Polyco and Coshield Global Ltd entered into a settlement agreement under which the latter undertook, among other things, to cease using COSHIELD and any sign identical or similar to SHIELD in relation to certain products.
Polyco argued, in particular, that the subsequent use of coshield.com breached that agreement and infringed its trademark rights.
What is the relevant date for assessing bad faith?
A first difficulty concerned the relevant date for assessing bad faith registration.
Coshield.com had indeed been created in December 2014. However, the panelist’s research revealed that it had probably been sold in May 2020. The sale coincided with changes in registrar and DNS servers, followed a few months later by the emergence of the CoShield business.
Under the UDRP, a transfer of a domain name to a new holder generally constitutes a new registration. May 2020 therefore became the probable relevant date of acquisition.
And with it came the central question in the case: why had the domain name been acquired at that particular time?
“Finely balanced” evidence
There was no shortage of potentially relevant indicators. By 2020, Polyco had been using SHIELD for 23 years, had generated substantial turnover under the trademark, and operated in the same sector as CoShield, including in overlapping territories. More strikingly, the CoShield website had offered certain products under the SHIELD trademark itself.
The story, however, could also be told differently.
CoShield appeared to be a genuine commercial operation conducted over several years, rather than a mere façade intended to conceal cybersquatting. More importantly, the business had been launched at the beginning of the COVID-19 pandemic. According to the panelist, “Co” could evoke COVID-19, while “Shield” naturally conveyed the idea of protection. The term was also used descriptively on the website and appeared in the names of other businesses operating in the sector.
Finally, apart from the “shield” element, CoShield had not adopted other elements of Polyco’s visual identity. Nor was there any direct evidence of an intention to create confusion or evidence of actual confusion.
Trademark infringement and cybersquatting: two paths that do not necessarily converge
This is where the decision becomes particularly interesting.
The panelist did not exclude the possibility that the facts might raise issues of trademark infringement or breach of the settlement agreement. But conduct that may be legally objectionable on either of those grounds does not necessarily satisfy the requirements of the UDRP.
It still had to be shown that coshield.com had been acquired in bad faith.
The evidence was, in the panelist’s words, “finely balanced”. Polyco ultimately failed to establish, on the balance of probabilities, that it was more likely than not that the domain name had been acquired with Polyco in mind. The third element of the UDRP was therefore not established.
The distinction matters. The UDRP does not ask only what a domain name holder does with a domain name. It also, and sometimes above all, requires us to return to the moment of acquisition and consider the intention behind it. It is within that sometimes narrow space that the boundary emerges between a trademark dispute involving a domain name and cybersquatting.