Westmore · UDRP decision
WIPO · Case No. D2025-2471

Lci-info.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <lci-info.com>. It found the domain confusingly similar to Complainant’s LCI mark because the mark remained recognizable despite the hyphen and descriptive term “info.” Respondent did not rebut Complainant’s prima facie case on rights or legitimate interests, and the domain had been used for a PPC page containing links to competing websites. Bad faith was established from the earlier LCI rights, the domain’s composition, its targeted PPC use, and the conclusion that its later passive holding did not prevent a bad-faith finding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-08-13
Panelist(s)
Perraki, Marina
Complainant
LA CHAINE INFO
Respondent
Nora Dean
Disputed domain(s)
lci-info.com
Citation weightrelies on 7 authorities
Domain history UDRP Intelligence

The timeline behind lci-info.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 lci-info.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:

Registration → decision → today timeline
Archived Wayback evidence of what the site showed
Registry bad-faith signals
The live current registrant
Available in UDRP Intelligence
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of lci-info.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates how a domain combining an entire trademark with a descriptive term closely aligned with the trademark owner’s activity can support findings across all three UDRP elements. The term “info” did not avoid confusing similarity and, because it corresponded to Complainant’s news business, reinforced implied affiliation and intentional targeting. Prior PPC links to competitors were central, while subsequent inactivity did not cure the bad-faith use.

The three-part test
Identical or confusingly similarMet
Rights or legitimate interestsMet
Registered and used in bad faithMet

Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-08-13
Panel
Perraki, Marina
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION LA CHAINE INFO v. Nora Dean Case No. D2025-2471 1. The Parties Complainant is LA CHAINE INFO, France, represented by AARPI Scan Avocats, France. Respondent is Nora Dean, United States of America. 2. The Domain Name and Registrar The disputed domain name <lci-info.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 June 23, 2025. On June 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On June 23, 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 Complainant on June 24, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting Complainant to submit an amendment to the Complaint. Complainant filed an amended Complaint on June 25, 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified Respondent of the Complaint, and the proceedings commenced on July 1, 2025. In accordance with the Rules, paragraph 5, the due date for Response was July 21, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on July 23, 2025. page 2 The Center appointed Marina Perraki as the sole panelist in this matter on July 30, 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 Complainant is a leading company in the field of TV news channels in France. LCI channel was launched in 1994 by the TF1 group to which Complainant belongs and has been broadcasted since. TF1 group is a leading television company in France, created in 1975, operating, per Complaint, the first and oldest television channel in France. LCI channel has been accessible free of charge since 2016. Complainant contends LCI is today the third largest news channel in France, with audience that may exceed one million live viewers in some cases. LCI is also available live on Complainant’s website which had a traffic of 14 million internet users in May 2022. LCI channel has today 770,000 followers on Twitter; 192,000 followers on Instagram; 2.9 million followers on Facebook; and more than a billion views on YouTube. Under the LCI trademark, Complainant offers news editions, debates, talk shows, columns, and specialized magazines. Complainant owns a number of LCI trademarks including the French trademark registration No. 94523091, LCI (figurative), filed and registered on June 3, 1994, for goods and services in International Classes 9, 26, 35, 38 and 41. The disputed domain name was registered on April 13, 2025. Initially it led to a pay-per-click (“PPC”) webpage including links to competing websites. Currently, it leads to an inactive website. Complainant sent a cease-and-desist letter to Respondent, to which Respondent did not reply. 5. Parties’ Contentions A. Complainant Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. B. Respondent Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy lists the three elements which Complainant must satisfy with respect to the Domain Name: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and (ii) Respondent has no rights or legitimate interests in respect of the disputed domain name; and (iii) the disputed domain name has been registered or is being used in bad faith. page 3 A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (o 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. 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 the mark is incorporated and recognizable within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to Complainant’s mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.7. Although the addition of other terms, here, “info” and a hyphen, may bear on assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0 , section 1.8. The generic Top-Level Domain (“gTLD”) “.com” is disregarded, as gTLDs typically do not form part of the comparison on the grounds that they are required for technical reasons (Rexel Developpements SAS v. Zhan Yequn, WIPO Case No. D2017-0275 ; Hay & Robertson International Licensing AG v. C. J. Lovik, WIPO Case No. D2002-0122). 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 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 Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain name. Respondent has not rebutted 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. On the contrary, the disputed domain name was used to host a parked page with PPC links, including links to competing websites. The Panel finds that it is not unlikely that Respondent received PPC fees from the linked websites and used the disputed domain name for its own commercial gain. The use of a domain name to host a parked page comprising PPC links does not represent a bona fide offering where such links mislead Internet users and trade off the complainant’s trademark (Virgin Enterprises Limited v. LINYANXIAO aka lin yanxiao, WIPO Case No. D2016-2302; WIPO Overview 3.0 , section 2.9). page 4 Furthermore, there is no evidence on record giving rise to any rights or legitimate interests in the disputed domain name on the part of Respondent within the meaning of paragraphs 4(c)(ii) and 4(c)(iii) of the Policy. In addition, the nature of the disputed domain name, entirely incorporating Complainant’s trademark plus the descriptive term “info” carries a risk of implied affiliation. WIPO Overview 3.0 , section 2.5.1. 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. Because the LCI mark had been used and registered before the disputed domain name registration, the Panel finds it more likely than not that Respondent had Complainant’s mark in mind when registering the disputed domain name. Moreover, the similarity of the disputed domain name to Complainant’s mark, and the choice of the descriptive word “info” which coincides with Complainant’s activity, particularly in relation to the LCI channel content of Complainant, reinforces the notion that Respondent was aware of and intentionally targeted Complainant in an attempt to confuse Internet users who were expecting to find Complainant’s website. As regards bad faith use, the disputed domain name directed Internet users to a website displaying links to third-party sites, including websites competing to Complainant, which suggests that, presumably, Respondent received PPC fees from the linked websites that were listed thereon. It has been recognized that such use of another’s trademark to generate revenue from Internet advertising can constitute registration and use in bad faith (McDonald’s Corporation v. ZusCom, WIPO Case No. D2007-1353 ; Volkswagen Aktiengesellschaft v. Robert Brodi, WIPO Case No. D2015-0299; SAP SE v. Domains by Proxy, LLC / Kamal Karmakar, WIPO Case No. D2016-2497; WIPO Overview 3.0, section 3.5). This, in view of the finding that Respondent has no rights to or legitimate interests in the disputed domain name, and in the circumstances of the case, affirms the bad faith (Aygaz Anonim Şirketi v. Arthur Cain, WIPO Case No. D2014-1206; WIPO Overview 3.0 , section 3.1). Moreover, noting the reputation of Complainant’s trademark, and the composition of the disputed domain name, the current passive holding of the disputed domain name does not prevent a finding of bad faith. WIPO Overview 3.0, section 3.3. Under these circumstances and on this record, the Panel finds that Respondent has registered and is using the disputed domain name in bad faith. The Panel finds that 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 <lci-info.com> be transferred to Complainant. /Marina Perraki/ Marina Perraki Sole Panelist Date: August 13, 2025

Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.

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