In Heraeus Kulzer GmbH v Stoll, German company Heraeus Kulzer GmbH, the owner of several VENUS marks for dental products, has failed to obtain the transfer of the domain name 'venussmile.com' under the UDRP. The WIPO panel considered that, although Heraeus had established bad-faith use, it had failed to establish the cumulative requirement of bad-faith registration, thus failing to establish the third limb of the UDRP.