Westmore · UDRP DecisionBuraeuveritasc.com
The Panel ordered transfer of <buraeuveritasc.com> to Bureau Veritas. It found the domain confusingly similar to the BUREAU VERITAS mark because it inverted two letters in “bureau,” added a final “c” after “veritas,” and otherwise preserved the recognizable mark. The Respondent did not rebut the Complainant’s prima facie showing on rights or legitimate interests. Evidence that an email address using the domain impersonated an employee of the Complainant’s Indian subsidiary and requested payment to a different bank account supported findings of fraudulent use and bad-faith registration and use.
The timeline behind buraeuveritasc.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind buraeuveritasc.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates that an inactive website does not neutralize evidence of abusive domain use where the domain functions as the basis for deceptive email. A close typographical variation of a mark, combined with employee impersonation, logo use, and attempted payment diversion, supplied a direct evidentiary path across all three UDRP elements.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Bureau Veritas v. canropye alterte, canopy ltd Case No. D2025-0393 1. The Parties The Complainant is Bureau Veritas, France, represented by Dennemeyer & Associates S.A., France. The Respondent is canropye alterte, canopy ltd, Nigeria. 2. The Domain Name and Registrar The disputed domain name <buraeuveritasc.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on January 31, 2025. On January 31, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 3, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (“Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf”) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 4, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amended Complaint on February 6, 2025. The Center verified that the Complaint together with the amended 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on February 13, 2025. In accordance with the Rules, paragraph 5, the due date for Response was March 5, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 10, 2025. The Center appointed Roger Staub as the sole panelist in this matter on March 17, 2025. 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 The Complainant submits that it was founded in 1828 and that it is a world leader in testing, inspection, and certification services (TICS) with several subsidiaries. The Complainant’s group employs over 82,000 people in more than 1,600 offices and laboratories worldwide. According to the Complainant’s website <group.bureauveritas.com>, it generated in 2024 revenues in the amount of EUR 6.2 billion. The Complainant owns numerous trademark registrations consisting of, or containing, the term “BUREAU VERITAS”. The Complainant’s portfolio of BUREAU VERITAS trademark registrations includes, inter alia, the following trademark registrations: - European Union Trade Mark No. 004518544 BUREAU VERITAS, registered on June 1, 2006, in Classes 38 and 42; - International trademark registration No. 311819 BUREAU VERITAS, registered on April 4, 1966, in Classes 01, 02, 06-14, 16-9, 22, 24 and 42, covering, inter alia, Japan, Republic of Korea, Türkiye, Benelux, Germany, Italy and Switzerland; - United States of America figurative mark No. 3425827 BUREAU VERITAS 1828, registered on May 13, 2008, in Class 37. The disputed domain name was registered on January 20, 2025, and is inactive. At the time of filing the Complaint, there was a message saying “Désolé, impossible d’accéder à cette page. L’adresse IP du serveur www.buraeuveritasc.com est introuvable.”; in English: “Sorry, it is impossible to access to this webpage. The IP address of the server www.buraeuveritasc.com is untraceable”. The Complainant’s uncontested evidence demonstrates the disputed domain name has been used to impersonate the Complainant through a phishing e-mail scheme. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant submits the following arguments: First, the disputed domain name is confusingly similar to the Complainant’s trademark BUREAU VERITAS. The disputed domain name reproduces the two verbal elements “bureau” and “veritas” of the Complainant’s trademarks. The inversion of the vowels “e” and “a” in “bureau” and the final addition of the letter “c” in “veritas” have no effect on the reproduction of the Complainant’s mark. The fact that the two terms are linked has no effect on their visual, aural, and conceptual perception by the public. The attached terms remain perfectly identifiable and understandable by the public. Therefore, the Complainant submits that it is a clear case of typo squatting. page 3 Second, the Respondent has no rights or legitimate interests in the BUREAU VERITAS mark, or the disputed domain name, because the Respondent is in no way linked to the Complainant. The Respondent has never been authorized by the Complainant to register a domain name similar to its trademark registration. The Respondent has been using the disputed domain name to create e-mail addresses impersonating at least one of the Complainant’s employees in order to claim payment of false invoices. Third, the disputed domain name was registered and is being used in bad faith. Given the circumstances of the case, it is inconceivable that the Respondent registered the disputed domain name without prior knowledge of the Complainant and the Complainant’s mark. The Respondent is using the disputed domain name to create e-mail addresses impersonating at least one of the Complainant’s employees. The registration of a domain name that is identical or confusingly similar (i.e., comprising typos) to a famous or widely known trademark by an unaffiliated entity can by itself create a presumption of bad faith. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to the Policy, to qualify for a cancellation or transfer, the Complainant must prove each of the following: First, the disputed domain name is identical or confusingly similar to a trademark or service mark to which the Complainant has rights. Second, the Respondent has no rights or legitimate interests in respect of the disputed domain name. Third, the disputed domain name has been registered and is being used in bad faith. Since the Respondent did not submit a reply, the Panel may choose to accept the reasonable contentions of the Complainant as true. This Panel will determine whether those facts constitute a violation of the Policy that is sufficient to order the transfer of the disputed domain name (see Joseph Phelps Vineyards LLC v. NOLDC, Inc., Alternative Identity, Inc., and Kentech, WIPO Case No. D2006-0292 ). A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0 ”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.2.1. The Panel finds that the disputed domain name is confusingly similar to the Complainant’s BUREAU VERITAS mark, from which it differs only in the inversion of the letters “a” and “e” in the word “bureau”, the addition of the letter “c” after “veritas” and the generic Top-Level Domain (“gTLD”) “ .com”. The disputed domain name could readily be typed by mistake instead of a domain name identical to this mark apart from the gTLD or misread as that domain name. Accordingly, the disputed domain name is confusingly similar to the mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.7. page 4 The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.0 , section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. Panels have held that the use of a domain name for illegal activity (here, claimed impersonation/phishing and other types of fraud) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0 , section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. In the present case, the Panel notes that the Complainant has submitted evidence showing that the disputed domain name has been used to create an e-mail address impersonating an employee of the Complainant’s Indian subsidiary. This e-mail address has been used in emails bearing the Complainant’s logo in the signature line and requesting the recipient to make payments to a bank account different from the bank account of the Complainant’s group company. The Panel considers this to be a clear indication of f raudulent use of the disputed domain name. Paragraph 4(b) of the Policy sets out a list of non-exhaustive circumstances that may indicate that a domain name was registered and used in bad faith, but other circumstances may be relevant in assessing whether a respondent’s registration and use of a domain name is in bad faith. WIPO Overview 3.0 , section 3.2.1. In this regard, the Panel notes the distinctiveness and reputation of the Complainant’s trademark, and the composition of the disputed domain name, support a finding of bad faith under the Policy. Panels have held that the use of a domain name for illegal activity (here, claimed impersonation/phishing, and other types of fraud) constitutes bad faith. WIPO Overview 3.0 , section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. page 5 The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <buraeuveritasc.com> be transferred to the Complainant. /Roger Staub/ Roger Staub Sole Panelist Date: March 31, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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