Westmore · UDRP decision
WIPO · Case No. D2025-4116

Michelinhasjobs.com, Michelinjobhub.com, Michelinjobsite.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered the transfer of all three disputed domain names. It found them confusingly similar to the Complainant’s MICHELIN trademark because each reproduced the mark in full with job-related terms. The Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. Bad faith was established from websites displaying the Complainant’s marks and logo, creating a misleading appearance of association and requiring login data, together with the Respondent’s pattern of registering domain names incorporating the MICHELIN mark.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2025-12-06
Panelist(s)
Soerensen Garcia, Mario
Complainant
Compagnie Générale des Établissements Michelin
Respondent
Phil Howard, Kithcen 47
Counsel
Tmark Conseils
Disputed domain(s)
michelinhasjobs.com, michelinjobhub.com, michelinjobsite.com
Citation weightrelies on 2 authorities
Domain history UDRP Intelligence

The timeline behind michelinhasjobs.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 michelinhasjobs.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
Outcome by domain

How each disputed name was decided in this proceeding.

michelinhasjobs.comTransferred
michelinjobhub.comTransferred
michelinjobsite.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of michelinhasjobs.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The case combines several recurring UDRP indicators: full reproduction of a well-established mark, job-related wording, multiple simultaneous registrations, use of the complainant’s logo, login functionality, respondent default, and prior proceedings involving the same parties or mark. The decision is particularly useful for its treatment of branded login sites as evidence supporting awareness, impersonation or passing off, possible commercial gain, and potential fraud, while avoiding a finding that actual fraud was completed.

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
2025-12-06
Panel
Soerensen Garcia, Mario
Full decision
8 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Compagnie Générale des Établissements Michelin v. Phil Howard, Kithcen 47 Case No. D2025-4116 1. The Parties The Complainant is Compagnie Générale des Établissements Michelin, France, represented by Tmark Conseils, France. The Respondent is Phil Howard, Kithcen 47, United Kingdom. 2. The Domain Names and Registrar The disputed domain names <michelinhasjobs.com>, <michelinjobhub.com>, and <michelinjobsite.com> are registered with Gname.com Pte. Ltd. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 8, 2025. On October 9, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On October 10, 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 the Complainant on October 14, 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 October 16, 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 the Respondent of the Complaint, and the proceedings commenced on October 22, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 11, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on November 14, 2025. page 2 The Center appointed Mario Soerensen Garcia as the sole panelist in this matter on November 22, 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 is a global company headquartered in France. Founded in 1889, the Michelin Group provides tires to many countries as well as road maps and various guide publications on gastronomy and the restaurant fields. The Complainant is the owner of several MICHELIN trademarks registered before the registration of the disputed domain names, such as: 1) International Trademark Registration MICHELIN No. 1254506 of December 10, 2014, in classes 9, 35, 38, 39, 41, and 42; 2) United States of America Trademark Registration MICHELIN No. 5775734 of June 11, 2019, in classes 9, 39, and 42; and 3) European Union Trademark Registration MICHELIN No. 013558366 of April 17, 2015, in classes 9, 35, 38, 39, 41, and 42. The Complainant also owns numerous domain names comprising the trademark MICHELIN, including the domain name <michelin.com>, registered on December 1, 1993. The Respondent is Phil Howard, Kithcen 47, from the United Kingdom. The disputed domain names <michelinhasjobs.com>, <michelinjobhub.com>, and <michelinjobsite.com> were registered on October 2, 2025, and currently resolve to inactive pages. However, at the time of the Complaint, the disputed domain names resolved to virtually identical websites that displayed the MICHELIN mark and the Michelin Bibendum logo, claimed to “offer a top-rated experience that helps retailers promote their brands” and required credentials to log in (Annex 8 to the Complaint). 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 names. Notably, the Complainant contends that the disputed domain names are confusingly similar to the trademark in which it has rights, that the Respondent has no rights or legitimate interests with respect to the disputed domain names, and that the disputed domain names were registered and are being used in bad faith. In particular, the Complainant contends that the Respondent has been involved in previous cases filed by the Complainant, including Compagnie Generale des Etablissements Michelin v. Phil Howard, Kithcen 47, WIPO Case No. D2025-3315 and Compagnie Generale des Etablissements Michelin v. Phil Howard, WIPO Case No. D2025-2532. The Complainant requests a transfer of the disputed domain names. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings In accordance with paragraph 4(a) of the Policy, the Complainant must prove that each of the three following elements is satisfied: (i) the disputed domain names are identical or confusingly similar to the trademarks or service marks in which the Complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain names; and (iii) the disputed domain names have been registered and are 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 names. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 1.7. Based on the available record, the Panel finds 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 entirety of the MICHELIN trademark is reproduced within the disputed domain names. Accordingly, the disputed domain names are confusingly similar to that trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. While the addition of other terms, such as “hasjobs”, “jobhub”, and “jobsite”, may bear on the assessment of the second and third elements, the Panel finds that the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the trademark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. 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 names. 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 names, such as those enumerated in the Policy or otherwise. The Panel finds the second element of the Policy has been established. page 4 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 finds that the Respondent was clearly aware of the MICHELIN mark as the websites under the disputed domain names displayed the Complainant’s trademarks and logo, intentionally misleading users into believing that there might be an association between the Complainant and the websites, attempting to attract Internet users to the disputed domain names for possible commercial gain by creating a likelihood of confusion with the Complainant’s marks, which constitutes bad faith under paragraph 4(b)(iv) of the Policy. 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. Panels have held that the use of a domain name for illegal activity, here, claimed as applicable to this case: impersonation/passing off, or other types of potential fraud noting the websites require personal data to log in, constitutes bad faith. WIPO Overview 3.0, section 3.4. In addition, the Panel finds that the Respondent has established a pattern of bad faith conduct by repeatedly registering the domain names incorporating the Complainant’s trademark and was involved in other cases filed by the Complainant. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitute bad faith under 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 names <michelinhasjobs.com>, <michelinjobhub.com>, and <michelinjobsite.com> be transferred to the Complainant. /Mario Soerensen Garcia/ Mario Soerensen Garcia Sole Panelist Date: December 6, 2025

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

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