Westmore · UDRP DecisionIdf-regularisation.com, Iledefrance-moblites.com, Iledefrance-mobllites.com
The Panel ordered transfer of all three disputed domain names. It found the two typo domains virtually identical to the ILE-DE-FRANCE MOBILITES mark and found <idf-regularisation.com> confusingly similar in light of “IDF” as a short-form reference to Île-de-France, the term “regularisation,” and the domain's associated impersonation use. Respondent lacked rights or legitimate interests because the domains carried a risk of implied affiliation and were used in a phishing campaign. Registration and use in bad faith were established by the domains' targeting of Complainant, their use to impersonate Complainant in phishing, and Respondent's pattern of adverse UDRP findings involving similar conduct.
The timeline behind idf-regularisation.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 idf-regularisation.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The decision illustrates how contextual evidence of targeting and impersonation can support confusing similarity where a domain uses an abbreviation rather than reproducing the full trademark. It also presents a consolidated pattern involving typo domains, a service-related term, copied website content, and phishing directed at customer accounts.
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 Ile -De-France Mobilités v. Host Master, Njalla Okta LLC Case No. D2025-2504 1. The Parties Complainant is Ile -De-France Mobilités, France, represented by De Gaulle Fleurance & Associés, France. Respondent is Host Master, Njalla Okta LLC, Saint Kitts and Nevis. 2. The Domain Names and Registrar The disputed domain names <idf-regularisation.com>, <iledefrance-moblites.com>, and <iledefrance-mobllites.com> are registered with Tucows Domains Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on June 25, 2025. On June 25, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On June 25, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain names which differed from the named Respondent (Redacted for Privacy) and contact information in the Complaint. The Center sent an email communication to Complainant on June 26, 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 30, 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 18, 2025. In accordance with the Rules, paragraph 5, the due date for Response was August 7, 2025. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on August 8, 2025. page 2 The Center appointed Georges Nahitchevansky as the sole panelist in this matter on August 14, 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, Ile -De-France Mobilités (formerly known as “Syndicat Des Transports D’Île de France”) is the French governmental authority that controls and coordinates the different public transport companies operating in Paris and the rest of Île-de-France. Complainant owns and uses the mark ILE-DE-FRANCE MOBILITES in connection with its services and owns two registrations in France for the mark, as follows: (1) ILE-DE-FRANCE MOBILITES word mark (Registration No. 4351425), which issued to registration on July 28, 2017; and (2) a figurative version of ILEDEFRANCE MOBILITES (Registration No. 4359694) which issued to registration on August 25, 2017. Complainant also owns and uses the domain names <iledefrance-mobilites.fr> and <iledefrance-mobilites.com> for a website concerning Complainant and its services and which allows users to create and access personal accounts in order to manage their transportation subscriptions and travel preferences. Respondent who appears to be based in Saint Kitts and Nevis registered the disputed domain names between January 29 and March 7, 2025. Since then, Respondent has used at least one of the three disputed domain names to link to a copy of Complainant’s official website. Additionally, Respondent appears to have used the disputed domain names for a phishing campaign in which emails have been sent impersonating Complainant. Currently, the <iledefrance-mobllites.com> disputed domain name when inputted returns a “Dangerous Site” ahead page from Google and the other two disputed domain names do not resolve to an active website or web page. 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 names. Notably, Complainant contends that it has rights in the ILE-DE-FRANCE MOBILITES mark by virtue of its use and registration of such in France. Complainant asserts that the <iledefrance-moblites.com> and <iledefrance-mobllites.com> disputed domain names are confusingly similar to its ILE-DE-FRANCE MOBILITES mark and trade name as they are merely typo versions of that mark and name. Complainant also asserts that the <idf-regularisation.com> disputed domain name is confusingly similar to its ILE-DE-FRANCE MOBILITES mark and trade name as “the term ‘idf ’ is the usual diminutive of the term ‘Île -de-France’, classically used on a regular basis by any French speaking person”. Complainant further argues that the addition of the common term “regularization” at the tail of the disputed domain name does not prevent a finding confusing similarity as such term is used by Complainant as part of a phishing campaign to have customers update their personal information and bank details on their personal accounts. Complainant contends that Respondent does not have any rights or legitimate interests in the disputed domain names as Respondent (i) owns no trademark rights in the ILE-DE-FRANCE MOBILITES mark, (ii) is not authorized to use Complainant’s ILE-DE-FRANCE MOBILITES mark, and (ii i) has not made any legitimate or bona fide use of the disputed domain names and has instead acted in bad faith as detailed in the bad faith section of the Complaint. page 3 Lastly, Complainant argues that Respondent has registered the disputed domain names in bad faith given the reputation and renown of Complainant as the public transport service in Paris and given Respondent's registration of multiple confusingly disputed domain names to mislead consumers into accessing a website unconnected to Complainant. Complainant also argues that Respondent is using the disputed domain names in bad faith to impersonate Complainant and to intentionally attract for commercial gain Internet users to Respondent’s websites. Complainant also notes that Respondent has used the disputed domain names as part of a phishing campaign in which emails are sent to consumers impersonating Complainant and advising that their accounts with Complainant have been suspended or requesting them verify payment details. The emails then provide links to websites operated by Respondent at the disputed domain names. Finally, Complainant maintains that Respondent’s name is fictitious and that Respondent has an established pattern from prior UDRP decisions of having been found to have registered and used domain names in bad faith. B. Respondent Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Under paragraph 4(a) of the Policy, to succeed Complainant must satisfy the Panel that: (i) the disputed domain names are identical or confusingly similar to a trademark or service mark in which Complainant has rights; (ii) Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) the disputed domain names were registered and are being used in bad faith. A. Identical or Confusingly Similar Ownership of a trademark registration is generally sufficient evidence that a complainant has the requisite rights in a mark for purposes of paragraph 4(a)(i) of the Policy. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”) at section 1.7. Complainant has provided evidence that it owns trademark registrations for the ILE-DE-FRANCE MOBILITES mark (which were registered well before Respondent registered the disputed domain names). 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. Id. Here, the entirety of the ILE-DE-FRANCE MOBILITES mark is recognizable within the <iledefrance- moblites.com> and <iledefrance-mobllites.com> disputed domain names, which fully incorporate a typo version of the ILE-DE-FRANCE MOBILITES mark and thus are virtually identical to Complainant’s ILE-DE- FRANCE MOBILITES mark. WIPO Overview 3.0, section 1.9. With regard to the <idf-regularisation.com> disputed domain name, such plays upon Complainant’s ILE-DE- FRANCE MOBILITES as “IDF” in the context of the disputed domain name and associated use of such is a short form reference to ILE-DE-FRANCE. Given that Complainant has used the term “regularisation” on its website and given Respondent’s action as noted in the second and third elements (particularly signing off in one of the phishing emails as “L’équipe IDF-Mobilités” – “the IDF-Mobilities team” - informing the email recipient that its “Île de France Mobilités” account has been suspended), it is obvious that this disputed domain name is expressly meant to conjure up and target Complainant and its ILE-DE-FRANCE MOBILITES mark. As such, under the circumstances, the Panel finds that the <idf-regularisation.com> disputed domain name is confusingly similarly to Complainant’s mark for purposes of the first element. page 4 The Panel thus finds that 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 a 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 that Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the disputed domain names. 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 names such as those enumerated in the Policy or otherwise. Here, the disputed domain names (two of which are typo domains) are clearly based on Complainant’s ILE- DE-FRANCE MOBILITES mark and name, or in the case of the <idf-regularisation.com> disputed domain name, meant to conjure up Complainant and its services. As such, the disputed domain names are more than likely to be mistakenly be seen by consumers as related to Complainant and its transportation services. In all, the disputed domain names <iledefrance-moblites.com> and <iledefrance-mobllites.com> effectively impersonate Complainant as Internet users may not notice the subtle difference between these disputed domain names and Complainant’s ILE-DE-FRANCE MOBILITES mark and thus, on their face, carry a risk of implied affiliation. The same would apply to the disputed domain name <idf-regularisation.com> particularly considering its use as described above. As such, it is hard to see how Respondent could have any rights or legitimate interests in the disputed domain names. Moreover, given that Respondent has used the disputed domain names as part of a phishing campaign, there can be no basis for Respondent to claim a legitimate interest in or bona fide use of the disputed domain names. Panels have consistently held that the use of a domain name for illegal activity, here impersonating Complainant to mislead consumers into providing personal account information or to elicit payments, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel thus 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 view of Respondent’s actions, and failure to appear in this proceeding, it is easy to infer that Respondent’s registration and use of the disputed domain names, which prominently play upon Complainant’s ILE-DE- FRANCE MOBILITES mark and name has been done opportunistically and in bad faith for the benefit or profit of Respondent. The disputed domain names were registered well after Complainant had established rights in its ILE-DE-FRANCE MOBILITES mark and name, and have been used as part of a phishing scheme by impersonating Complainant. page 5 That Respondent has acted in bad faith is also supported by the fact that Respondent has a pattern of having been found to have registered and used domain names in bad faith based on the marks and names of others for similar phishing purposes. Such pattern is established by at least six UDRP decisions finding that Respondent acted in bad faith. These decisions confirm that Respondent’s likely intent here is to likewise deceive consumers by taking advantage of Complainant’s reputation and rights for the profit of Respondent. 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 names <idf-regularisation.com>, <iledefrance-moblites.com>, and <iledefrance-mobllites.com> be transferred to Complainant. /Georges Nahitchevansky/ Georges Nahitchevansky Sole Panelist Date: August 28, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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