Westmore · UDRP DecisionCasamichelin.com
The Panel ordered transfer of <casamichelin.com>. It found the domain confusingly similar to the Complainant’s MICHELIN mark because it incorporated the mark in its entirety with the added term “casa.” The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests. The Panel also found bad faith under paragraph 4(b)(iv), concluding that the domain was likely registered with knowledge of the well-known MICHELIN mark and used for a recipe website to attract Internet users for potential gain by creating confusion. The Respondent’s offer to sell the domain reinforced the bad-faith finding.
The timeline behind casamichelin.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 casamichelin.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The decision illustrates how content associated with a trademark owner’s secondary field of reputation can strengthen findings under the second and third UDRP elements. Although MICHELIN is prominently associated with tires, its culinary guides made the Respondent’s recipe-focused use particularly significant. The case also shows that an asserted phrase-based interpretation of a domain is unlikely to establish legitimacy when it is linguistically incomplete, unsupported by evidence, and inconsistent with the respondent’s own name. An offer to sell made in the course of the dispute may further reinforce an existing bad-faith record.
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 Compagnie Générale des Établissements Michelin v. Rahi Raj, Synergiqio Case No. D2025-4267 1. The Parties The Complainant is Compagnie Générale des Établissements Michelin, France, represented by Tmark Conseils, France. The Respondent is Rahi Raj, Synergiqio, United States of America (“United States”). 2. The Domain Name and Registrar The disputed domain name <casamichelin.com> is registered with PDR Ltd. d/b/a PublicDomainRegistry.com (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on October 17, 2025. On October 20, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On October 21, 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 (Domain Admin / Privacy Protect, LLC (PrivacyProtect.org)) and contact information in the Complaint. The Center sent an email communication to the Complainant on October 22, 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 23, 2025. The Center verified that the Complaint together with 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 28, 2025. In accordance with the Rules, paragraph 5, the due date for Response was November 17, 2025. The Respondent sent an email communication to the Center on October 26, 2025. The Respondent did not submit any formal response. page 2 The Center appointed Rebecca Slater as the sole panelist in this matter on November 24, 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 leading tire company founded in 1889. It is headquartered in France. The MICHELIN brand enjoys a strong reputation in the field of tire manufacturing for cars, trucks, motorcycles and planes. The Complainant also produces the best-selling MICHELIN Guides, which rate over 30,000 establishments in over 30 territories around the world. Over 30 million MICHELIN Guides have been sold worldwide. The Complainant has a portfolio of registrations for the MICHELIN word mark, including International Trade Mark Registration No. 816915 (registered August 27, 2003), International Trade Mark Registration No. 1245891 (registered December 10, 2014), United States Trade Mark Registration No. 0892045 (registered June 2, 1970) and European Union Trade Mark Registration No. 013558366 (registered April 17, 2015) (the “Trade Mark”). The Complainant is also the registrant of the <michelin.com> domain name (registered December 1, 1993). The Respondent is an individual, apparently located in the US. The Respondent did not submit a formal response, but emailed the Center (copying the Complainant) stating “Casa michel in – Michel’s house for recipes. I paid for the domain and built a site which has meaningful recipes”. The Respondent also offered to sell the disputed domain name stating “Do you guys want to buy the domain from me? If so, quote a price and we can transfer if the offer is good”. The Respondent registered the disputed domain name on March 28, 2025. At the time the Complaint was submitted, the disputed domain name resolved to a website with recipe searching functionality (“RecipeFinder”). The dispute domain name does not currently resolve to an active website. 5. Parties’ Contentions The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. A. Complainant Notably, the Complainant contends that: - The disputed domain name is confusingly similar to the Trade Mark. It consists of the entirety of Trade Mark preceded followed by the term “casa”. The use of this term does not detract from the immediate association with the Complainant, as “casa” could be a reference to a place where food is served. - The Respondent has no rights or legitimate interests in respect of the disputed domain name. The Respondent is not affiliated with the Complainant in any way and has not been authorized by the Complainant to use the Trade Mark. There is no legitimate reason why the Respondent would incorporate the Trade Mark in the disputed domain name. - The disputed domain name was registered and is being used in bad faith by the Respondent. There is no chance that the Respondent registered the disputed domain name by coincidence. The Respondent registered the disputed domain name to exploit the Complainant’s goodwill in its Trade page 3 Mark and mislead Internet users. The disputed domain name resolves to a website with recipe searching functionality. This impersonates the Complainant and is being used as part of a dishonest and fraudulent scheme to make the Internet users believe that the website has been created or approved by the Complainant. B. Respondent The Respondent did not provide a formal response. The Respondent advised in an email communication to the Center that: - the disputed domain name is “Casa michel in”, meaning Michel’s house; - the website at the disputed domain name has “meaningful” recipes; and - the Respondent is willing to transfer the disputed domain name if an “offer is good”. 6. Discussion and Findings To succeed, the Complainant must demonstrate that all the elements enumerated in paragraph 4(a) of the Policy have been satisfied, namely: - the disputed domain name is identical or confusingly similar to a trade mark or service mark in which the Complainant has rights; - the Respondent has no rights or legitimate interests in respect of the disputed domain name; and - the disputed domain name has been registered and is being used in bad faith. The onus of proving these elements is on the Complainant. 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 trade mark 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 trade mark or service mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. The entirety of the Trade Mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is confusingly similar to the Trade Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms (here, “casa”) may bear on assessment of the second and third elements, the Panel finds the addition of this term does not prevent a finding of confusing similarity between the disputed domain name and the Trade Mark 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 page 4 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. Specifically: - The Respondent does not explain the additional term “in” in the disputed domain name (noting that the translation of “Michel’s house” to “Casa michel” (ie. from English to Spanish, Italian or Portuguese) does not include the “in”). - The Respondent makes statements about the origin of the disputed domain name but does not provide any evidence that it has been commonly known by the disputed domain name. - The Respondent’s name has no resemblance to “Michel”. - The Complainant has not authorized the Respondent to use the Trade Mark. The evidence provided by the Complainant (i.e., screenshots of the website to which the disputed domain name historically resolved) indicates that the disputed domain name has been used to provide recipes, which may confuse the Internet users that these recipes are endorsed by the Complainant. Previous panels have consistently held that such use of a domain name does not represent a bona fide offering because it capitalizes on the reputation and goodwill of a complainant’s trade mark. 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. 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. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. Under paragraph 4(b)(iv) of the Policy, there is evidence of registration and use of the disputed domain name in bad faith where a respondent has used the disputed domain name to intentionally attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the complainant’s trade marks as to the source, sponsorship, affiliation or endorsement of the website. The Panel finds it unlikely that the disputed domain name was registered without knowledge of the Complainant and the Trade Mark, given: (a) the worldwide reputation of the Complainant and the Trade Mark, especially in the culinary sector; and (b) the composition of the disputed domain name, which includes the Trade Mark and the term “casa”, which could reference a place where food is served. The Respondent’s goal in registering and using the disputed domain name appear to be to attract Internet users for potential gain, taking unfair advantage of the Trade Mark. This finding is reinforced by the Respondent’s offer to sell the disputed domain name. page 5 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 <casamichelin.com> be transferred to the Complainant. /Rebecca Slater/ Rebecca Slater Sole Panelist Date: December 9, 2025
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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