Westmore · UDRP decision
WIPO · Case No. D2025-4113

Museofridakahlo.org

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <museofridakahlo.org>. It found the domain confusingly similar to the Complainant’s FRIDA KAHLO mark because it incorporated the mark in its entirety. The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests, while the gaming-related website and advertising were not considered bona fide or fair use. Bad faith was found from the commercial advertising, absence of evidence of good-faith use, use of a privacy service, historical parked pages suggesting the domain might be for sale, and intentional attraction of Internet users through confusion with the mark.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-11-18
Panelist(s)
Jabur, Wilson Pinheiro
Complainant
Frida Kahlo Corporation
Respondent
Dimas Satria
Counsel
Arochi · Lindner, S.C
Disputed domain(s)
museofridakahlo.org
Domain history UDRP Intelligence

The timeline behind museofridakahlo.org

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 museofridakahlo.org — 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 museofridakahlo.org.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how incorporation of a complete personal-name trademark into a domain, combined with unrelated advertising-supported content and an unrebutted record, can satisfy all three UDRP elements. It is also notable because the stated domain registration date was many years before the Complainant’s museum-formative marks, while earlier FRIDA KAHLO registrations did predate the domain. The Panel grounded bad faith in the cumulative circumstances rather than identifying direct evidence of intent at registration.

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.

Case details
Provider
WIPO
Outcome
Transfer
Decision date
2025-11-18
Panel
Jabur, Wilson Pinheiro
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Frida Kahlo Corporation v. Dimas Satria Case No. D2025-4113 1. The Parties The Complainant is Frida Kahlo Corporation, United States of America (“United States”), represented by Arochi & Lindner, S.C., Mexico. The Respondent is Dimas Satria, Indonesia. 2. The Domain Name and Registrar The disputed domain name <museofridakahlo.org> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 8, 2025. On October 8, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 9, 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 (Registration Private) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 10, 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 on October 14, 2025. 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”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on October 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 4, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 7, 2025. The Center appointed Wilson Pinheiro Jabur as the sole panelist in this matter on November 11, 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. page 2 4. Factual Background The Complainant is a corporate entity dedicated to managing and commercializing the intellectual property rights associated with the Mexican artist Frida Kahlo. The Complainant’s official website is available at <fridakahlocorporation.com>. The Complainant is also owner of the following, amongst other, trademark registrations (Annexes 6 and 7 to the Complaint): - Mexico trademark registration No. 786583 for the word mark FRIDA KAHLO, filed on July 2, 2002, registered on April 11, 2003, successively renewed, in class 9; - Mexico trademark registration No. 785991 for the word mark FRIDA KAHLO, filed on July 2, 2002, registered on March 31, 2003, successively renewed, in class 14; - Mexico trademark registration No. 866404 for the word mark FRIDA KAHLO, filed on August 23, 2004, registered on January 28, 2005, successively renewed, in class 43; - Mexico trademark registration No. 2622092 for the word mark MUSEO FRIDA KAHLO RIVIERA MAYA, filed on January 30, 2020, registered on November 7, 2023, in class 41; - Mexico trademark registration No. 2471631 for the word and device mark MUSEO FRIDA KAHLO RIVIERA MAYA, filed on January 30, 2020, registered on November 8, 2022, in class 41; and - United States trademark registration No. 6,896,829 for the word mark FRIDA KAHLO, registered on November 8, 2022, in class 41. The disputed domain name was registered on March 17, 2006, and presently resolves to a webpage displaying information on video games, partially in English, partially in Indonesian, also counting with an advertisement section. In the past, according to the WayBack machine, at times, the disputed domain name resolved to parked webpages indicating that the disputed domain name might be for sale. 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 asserts to have been founded to preserve and promote Frida Kahlo's legacy while ensuring that her image is represented in a way that aligns with her cultural and artistic significance, through strategic partnerships and branding efforts. Furthermore, the Complainant contends that the disputed domain name is confusingly similar to the Complainant’s registered trademarks. The Complainant’s further states that the Respondent has no rights or legitimate interests in respect to the disputed domain name, nor is it making a bona fide offering of goods or services, given that the Respondent is not commonly known by the disputed domain name. It has been used in connection with betting websites and advertisement deals in no way related to the figure of Frida Kahlo or any museum- related services, without any authorization from the Complainant and yet causing great confusion amongst Internet users. The Complainant further contends that the Respondent has registered and used the disputed domain name in bad faith and to intentionally attempt to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s mark, as to the source, sponsorship, affiliation, or endorsement of its website or of the goods or services appearing thereon, in an attempt to deceive individuals. page 3 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Paragraph 4(a) of the Policy sets forth three requirements, which have to be met for this Panel to order the transfer of the disputed domain name to the Complainant: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (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. The Complainant must prove in this administrative proceeding that each of the aforesaid three elements is present in order to obtain the transfer of the disputed domain name. 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 entirety of the mark FRIDA KAHLO is reproduced within the disputed 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. 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. page 4 In that sense, and according to the evidence submitted, the Complainant has made a prima facie case against the Respondent who has not been commonly known by the disputed domain name and is neither authorized, licensed, or been allowed to use the Complainant’s trademark, whether in the disputed domain name, or in any other way. Also, the lack of evidence as to any trademarks registered by the Respondent corresponding to the disputed domain name, corroborates the indication of an absence of rights or legitimate interests in the disputed domain name. Furthermore, the Panel notes that the contents available at the webpage that resolves from the disputed domain name are not indicative of a bona fide offering of goods or services, nor a legitimate noncommercial or fair use of the disputed domain name in these circumstances. Frida Kahlo was one of the most relevant artists of the twentieth century and the disputed domain name does not relate to the artist, her work or museum exhibits, but rather appear to be the contents of a blog on games that counts with an advertisement section. Under these circumstances, the Panel finds that the Respondent does not have rights or legitimate interests with respect to the disputed domain name. 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. This case presents the following circumstances which indicate under the balance of probabilities bad faith registration and use of the disputed domain name: a) the Respondent has provided no evidence whatsoever of any actual or contemplated good faith use by it of the disputed domain name; b) the website available at the disputed domain name counts with an advertisement section; c) the Respondent has selected a privacy protection service so as to conceal his identity; and d) in the past, the disputed domain name resolved to parked webpages indicating that the disputed domain name might be for sale. The Panel finds that the disputed domain name was registered and used to intentionally attempt to attract, for commercial gain, Internet users to the Respondent’s website by creating a likelihood of confusion with the Complainant’s mark, and thus the Complainant has established the third element of the Policy. 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 <museofridakahlo.org> be transferred to the Complainant. /Wilson Pinheiro Jabur/ Wilson Pinheiro Jabur Sole Panelist Date: November 18, 2025

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

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