WIPO Arbitration and Mediation Center ADMINISTRATIVE PANEL DECISION Banco Inter S.A. v. Anderson Santos, Case No. D2018-1926 1. The Parties

Complainant is Banco Inter S.A. of Belo Horizonte, Brazil, represented by Alexandre Atheniense Advogados - SIA, Brazil.

Respondent is Anderson Santos, of Sao Caetano do Sul, Brazil, self-represented. 2. The Domain Name and Registrar

The disputed domain name is registered with GoD, LLC (the “Registrar”). 3. Procedural History

The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on August 24, 2018. On the same day, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On August 24, 2018, the Registrar transmitted by email to the Center its verification response confirming that Respondent is listed as the registrant and providing the contact details.

The Center verified that the Complaint satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”).

In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on August 30, 2018. In accordance with the Rules, paragraph 5, the due date for Response was September 19, 2018. The Response was filed with the Center on September 17, 2018.

The Center appointed Eduardo Machado as the sole panelist in this matter on October 4, 2018. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background

Complainant is established in Brazil as Banco Inter S.A., also doing business as “Banco Intermedium” or “Banco Inter”. Complainant is a financial services company that operates an online bank in Brazil, registered with the Brazilian Central Bank, with clients throughout the Brazilian territory. Complainant also claims, in its website, to be the first 100% paperless bank in Brazil, relying solely on Internet-based services.

Complainant registered the domain name on May 10, 2017, and also owns other domain names such as , and . Complainant also operates a “Banco Inter” mobile application, or “app”, which is directed to its banking clients and is available for download on both Google Inc.’s “Google Play” store (for mobile devices using the Android operational system) and Apple Inc.’s “App Store” (for devices using the iOS operational system).

Complainant has filed trademark applications in Brazil for the composite mark BANCO INTER, and, as per the information attached to the Complaint (see Annex 7 of the Complaint), has been using the unregistered trademark BANCO INTER in commerce since June 2017 to identify his financial/banking services to Brazilian customers.

Respondent is an individual based in Brazil. Given the registrant information provided by the Registrar and available on record, the Panel infers that Respondent runs a technology company engaged in information security services, using the domain name ”.

Respondent registered the disputed domain name on May 8, 2018. The generic Top-Level Domain (“gTLD”) “.app” is operated by Google Inc. since May 2018. The disputed domain name is not used in connection with an active website. 5. Parties’ Contentions A. Complainant

Complainant states that the disputed domain name is confusingly similar to the BANCO INTER unregistered trademark, as well as to the domain names previously registered by Complainant.

Complainant also argues that Respondent intentionally registered the disputed domain name, which is identical to Complainant’s trademark, making use of unfair practices known as “cybersquatting” and “domain name parking”.

Complainant also alleges that Respondent has no rights or legitimate interests in the disputed domain name, since there is no actual use of the disputed domain name , no webpage related to Respondent’s services and no reference to Respondent’s activities in the banking industry. Moreover, Complainant affirms that Respondent has no relationship whatsoever with Complainant and is not involved in banking activities, reasons why the registration of the disputed domain name was for the sole purpose of later selling it, considering its commercial value, to Complainant, expecting to receive an unproportionate profit.

Complainant claims that Respondent’s bad faith in registering the disputed domain name is further evidenced by the fact that Respondent was prepared to offer the disputed domain name for sale to Complainant, for more than Respondent's out-of-pocket costs. Complainant argues that Respondent stated that he would not sell the disputed domain name for less that USD 12,000 and that Respondent ended negotiations. This conduct would evidence that Respondent registered the disputed domain name primarily for the purposes of selling it to Complainant. B. Respondent

Respondent states that the disputed domain name was purchased and registered through a public process announced in the press to the general public, and open to anyone interested. Moreover, Respondent argues that, at the time of registration of the disputed domain name, there was no indication that Complainant tried to obtain the same domain name under the “.app” gTLD, which has international scope and is not limited to Brazil.

Respondent also argues that both “banco” and “inter” are terms commonly used in several countries and languages, and reasons why it would not be possible to associate it in a specific way with Complainant. Furthermore, Respo