Westmore · UDRP decision
WIPO · Case No. D2025-3520

Frenchconinection.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <frenchconinection.com>. It found the domain confusingly similar to the Complainant’s FRENCH CONNECTION mark because it merely inserted an additional letter “i” into “connection.” The Respondent lacked rights or legitimate interests because the domain was used for impersonation/phishing emails and no rebuttal was submitted. Bad-faith registration and use were established by the deliberate misspelling, the much earlier trademark rights, and emails impersonating the Complainant’s purchasing manager while displaying the Complainant’s trademark and corporate contact details.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-11-03
Panelist(s)
Dernbach, Peter J.
Complainant
French Connection Limited
Respondent
王国灿 (wang guo can)
Disputed domain(s)
frenchconinection.com
Citation weightrelies on 1 authority
Domain history UDRP Intelligence

The timeline behind frenchconinection.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 frenchconinection.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 frenchconinection.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case illustrates that a typosquatting domain can satisfy all three UDRP elements when used primarily for email impersonation rather than an active website. The deliberate one-letter variation, employee impersonation, and use of authentic-looking trademark and corporate details tied confusing similarity directly to a fraudulent purpose.

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
2025-11-03
Panel
Dernbach, Peter J.
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION French Connection Limited v. 王国灿 (wang guo can) Case No. D2025-3520 1. The Parties The Complainant is French Connection Limited, United Kingdom (“UK”), represented by Sonder & Clay IP Limited, UK. The Respondent is 王国灿 (wang guo can), China. 2. The Domain Name and Registrar The disputed domain name <frenchconinection.com> (the “Disputed Domain Name”) is registered with Alibaba Cloud Computing Ltd. d/b/a HiChina (www.net.cn) (the “Registrar”). 3. Procedural History The Complaint was filed in English with the WIPO Arbitration and Mediation Center (the “Center”) on August 29, 2025. On September 1, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Name. On September 2, 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 (unknown) and contact information in the Complaint. The Center sent an email communication to the Complainant on September 2, 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 amendment to the Complaint in English on September 15, 2025. On September 2, 2025, the Center informed the Parties in Chinese and English, that the language of the Registration Agreement for the disputed domain name is Chinese. On September 15, 2025, the Complainant confirmed its request that English to be the language of the proceeding. The Respondent did not submit any comment on the Complainant’s submission. The Center verified that the Complaint together with the amendment to 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”). page 2 In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent in Chinese and English of the Complaint, and the proceedings commenced on September 16, 2025. In accordance with the Rules, paragraph 5, the due date for Response was October 6, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on October 10, 2025. The Center appointed Peter J. Dernbach as the sole panelist in this matter on October 21, 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, a UK company founded in 1972, operates as a global retailer of clothing, accessories, and homeware. The Complainant distributes its products via retail stores, wholesale channels, and its e- commerce website at “www.frenchconnection.com”. As of the date of this Decision, the Complainant is the owner of a series of trademarks registered in the UK (see Complaint, Annex 3), including: (i) Registration No. UK00001074992, registered on February 28, 1977, for the word mark FRENCH CONNECTION, covering goods in class 25; and (ii) Registration No. UK00002017775, registered on June 21, 1996, for the word mark FRENCH CONNECTION, covering goods in classes 3, 9, 14, 18, 24, and 25. The Disputed Domain Name was registered on July 14, 2025. Evidence indicates its use in sending emails impersonating the Complainant (see Complaint, Annex 4). At the time of drafting the decision, the Disputed Domain Name resolves to an error page. The Respondent appears to be an individual located in China. 5. Parties’ Contentions A. Complainant The Complainant requests that the Disputed Domain Name be transferred to the Complainant, arguing that it has met all the elements required under paragraph 4(a) of the Policy: (i) The Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights. The Complainant asserts that the Disputed Domain Name is virtually identical to its FRENCH CONNECTION mark, differing only by the insertion of the letter “i” between the two “n”s in the word “connection”. The Complainant contends this variation is minimal and difficult to identify. (ii) The Respondent has no rights or legitimate interests in respect of the Disputed Domain Name. The Complainant asserts the Respondent has no rights or legitimate interests in the Disputed Domain Name and there is no supporting evidence showing of/that: - the Respondent’s use of, or demonstrable preparations to use the Disputed Domain Name, or a name corresponding to the Disputed Domain Name in connection with a bone fide offering of goods or services; - the Respondent being commonly known by the Disputed Domain Name; page 3 - the Respondent having acquired any trademark registration signifying an intention to use the Disputed Domain Name in trade; and - the Respondent is making a legitimate, noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain misleadingly to divert consumers or to tarnish the Complainant’s trademarks. In contrast, the Complainant provides evidence that the Respondent has made active, commercial use of the Disputed Domain Name for potential financial gain. (iii) The Disputed Domain Name has been registered and is being used in bad faith. The Complainant further contends that the Disputed Domain Name was registered and is being used in bad faith. The Complainant notes the Disputed Domain Name was registered almost 50 years after the Complainant first registered its FRENCH CONNECTION mark. The Disputed Domain Name includes a deliberate misspelling that is confusingly similar to the Complainant’s mark, for the purpose of misleading consumers for commercial gain. The Complainant also contends that the Respondent has used the Disputed Domain Name to mislead consumers, suppliers, and manufacturers, including sending emails from a person claiming to be the Complainant’s purchasing manager (at “[...]@frenchconinection.com”) using the Complainant’s trademarks, corporate information, and website. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 6.1. Language of the Proceeding Notwithstanding that Chinese is the language of the Registration Agreement, the Panel, in exercising its discretion under paragraph 11(a) of the Rules, determines that the language of the proceeding should be English, after considering all relevant circumstances. Paragraph 11(a) of the Rules provides that, “[u]nless otherwise agreed by the Parties, or specified otherwise in the Registration Agreement, the language of the administrative proceeding shall be the language of the Registration Agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the administrative proceeding”. In addition, paragraphs 10(b) and 10(c) of the Rules require the Panel to “ensure that the Parties are treated with equality and that each Party is given a fair opportunity to present its case”, and to “ensure that the administrative proceeding takes place with due expedition”. The Panel notes that the Complaint was filed in English and the Complainant requested English to be the language of the proceeding on the grounds that neither the Complainant nor its representative is able to understand and communicate in Chinese. The evidence submitted by the Complainant demonstrates that the Disputed Domain Name was used to send emails in English, suggesting that the Respondent understands and communicates in English. The Respondent was given the time and opportunity to express its opinion regarding the language of the proceeding, but failed to submit any comment. Accordingly, the Panel believes conducting the proceeding in English will not result in unfairness to the Respondent, but will serve to expedite the proceeding and avoid unnecessary costs for the Parties. Having considered the above, using its discretion under paragraph 11(a) of the Rules, the Panel concludes that it is appropriate to conduct the proceeding in English. page 4 6.2. Analysis of Substantive Issues Pursuant to paragraph 4(a) of the Policy, the Complainant must prove all the three following requirements are met, so as to prevail in this administrative proceeding and obtain the requested relief (in this case, transfer of the Disputed Domain Name): (i) the Disputed Domain Name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the Disputed Domain Name; and (iii) the Disputed Domain Name has been registered and is being used in bad faith. 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 Panel finds that the Complainant has successfully demonstrated its rights in the FRENCH CONNECTION marks for the purposes of the Policy. The Panel further finds the Disputed Domain Name <frenchconinection.com> to be confusingly similar to the Complainant’s FRENCH CONNECTION mark. Apart from the Top-Level Domain “.com”, the difference lies solely in the inclusion of the letter “i” between the two “n”s in the word “connection”, which does not prevent a finding of confusing similarity with the Complainant’s FRENCH CONNECTION mark. Previous panels have considered a domain name which consists of a common, obvious, or intentional misspelling of a trademark to be confusingly similar to the relevant mark for purposes of the first element. WIPO Overview 3.0, section 1.9; Fuji Photo Film U.S.A., Inc. v. LaPorte Holdings, WIPO Case No. D2004-0971 (<fuijifilm.com>). The situation in this case is another clear example of typosquatting, which does not prevent a finding of confusing similarity with the Complainant’s trademark. Therefore, 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. page 5 Having reviewed the available record, the Panel observes that the Complainant has highlighted the lack of evidence showing of/that: (i) the Respondent’s use of, or demonstrable preparations to use the Disputed Domain Name, or a name corresponding to the Disputed Domain Name in connection with a bone fide offering of goods or services; (ii) the Respondent being commonly known by the Disputed Domain Name; (iii) the Respondent having acquired any trademark registration signifying an intention to use the Disputed Domain Name in trade; and (iv) the Respondent is making a legitimate, noncommercial or fair use of the Disputed Domain Name, without intent for commercial gain misleadingly to divert consumers or to tarnish the Complainant’s trademarks. Furthermore, the record shows that the Disputed Domain Name has been used to send emails to another corporation, where the sender pretended to be the Complainant’s purchasing manager (see Complaint, Annex 4). This is an act of impersonation/phishing — an illegal activity which can never confer rights or legitimate interests on a respondent, as panels have long held. WIPO Overview 3.0, section 2.13.1. The Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the Disputed Domain Name. Hence, the burden of production shifts to the Respondent. The Respondent 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. Therefore, 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. Panels also have held that the use of a domain name for purposes other than to host a website may constitute bad faith, including sending email, phishing, identity theft, or malware distribution. WIPO Overview 3.0, section 3.4. In the present case, the Panel notes that the Complainant's FRENCH CONNECTION mark has been registered in the UK since 1977, nearly five decades prior to the creation of the Disputed Domain Name in 2025. The mark has also been used to run the Complainant’s e-commerce website under its domain name <frenchconnection.com>. Given the near global reach of the Internet and search engines, the Panel finds it highly likely that the Respondent already knew or should have known the existence of the Complainant’s trademarks and website when registering the Disputed Domain Name. WIPO Overview 3.0, section 3.2.2. The fact that the nature of the Disputed Domain Name is an obvious misspelling of the Complainant’s FRENCH CONNECTION mark and has been used for sending fraudulent emails shows the Respondent’s knowledge of the Complainant and its trademarks. The Panel finds that this evidence shows that the Disputed Domain Name has been registered in bad faith. The Panel also notes the uncontested evidence submitted by the Complainant demonstrats that the Disputed Domain Name has been used to send emails from “[...]@frenchconinection.com” to another business, where the sender claimed to be the Complainant’s purchasing manager (see Complaint, Annex 4). The Panel finds that, in the signature block of the sender, one of the Complainant’s registered trademarks was displayed along with reference made to the Complainant’s official website, address, and phone number. The Panel finds that this act of impersonation/phishing was conducted in an attempt to mislead and attract Internet users for commercial gain, which shows that the Disputed Domain Name has also been used in bad faith. page 6 Therefore, 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 <frenchconinection.com> be transferred to the Complainant. /Peter J. Dernbach/ Peter J. Dernbach Sole Panelist Date: November 3, 2025

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

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