Westmore · UDRP DecisionBestmichelinguide.com, Michelinperformance.com, Topmichelinguide.com
The Panel ordered the transfer of all three disputed domain names. It found the MICHELIN mark recognizable in each domain despite the addition of terms such as “best,” “top,” “guide,” and “performance.” The Respondent failed to rebut the Complainant’s prima facie case on rights or legitimate interests. Bad faith was established based on the registration of multiple MICHELIN-formative domains and their prior use for identical pages displaying the MICHELIN mark and Michelin Man logo, which the Panel characterized as impersonation or passing off intended to exploit the Complainant’s goodwill.
The timeline behind bestmichelinguide.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 bestmichelinguide.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
This decision illustrates a straightforward multi-domain targeting case in which the same distinctive mark was combined with descriptive terms and used on matching branded websites. The result rested not merely on incorporation of the mark, but on the combined evidence of simultaneous registrations, reproduction of the word mark and logo, content aligned with the Complainant’s guide activities, and the absence of any rebuttal or legitimate explanation.
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 Etablissements Michelin v. Vajida Umarmia, Enterprise Case No. D2025-4804 1. The Parties The Complainant is Compagnie Générale des Etablissements Michelin, France, represented by Tmark Conseils, France. The Respondent is Vajida Umarmia, Enterprise, Malaysia. 2. The Domain Names and Registrar The disputed domain names <bestmichelinguide.com>, <michelinperformance.com>, and <topmichelinguide.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 November 19, 2025. On November 19, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On November 20, 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 November 24, 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 November 28, 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 December 1, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 21, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on December 26, 2025. page 2 The Center appointed Saisunder Nedungal Vidhya Bhaskar as the sole panelist in this matter on December 31, 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 corporation organized under the laws of France since 1889 that operates business of manufacturing and selling tires for cars and trucks. The Complainant started publishing the travel/gastronomy Michelin Guide in Europe in 1900 to encourage new drivers to take road trips to local attraction and ranks fine dining establishments worldwide by awarding “Michelin Stars”. The Michelin guide now rates over 30,000 establishments in over 30 territories across the world. The Complainant owns trademark registrations for MICHELIN in many jurisdictions around the world related to the tires production and sale as well as road maps and various guide publications in the field of restaurant, some of which are shown below: - International Trademark Registration MICHELIN No.1254506 of December 10, 2014 in classes 9, 35, 38, 39, 41, and 42; - European Union Trademark Registration MICHELIN No.013558366 of April 17, 2015 in classes 9, 35, 38, 39, 41, and 42; and - European Union Trademark Registration MICHELIN No 009914731 of September 27, 2011 in classes 9, 35, 37, 38, 39, 41, 42, and 43. The Complainant owns the <michelin.com> domain name created on December 1, 1993, on the basis of which the sub-domain <guide.michelin.com> was created. All three disputed domain names were registered on November 10, 2025. The Complainant has shown that the disputed domain names resolved to identical pages distinctively displaying the MICHELIN mark and logo (“Michelin Man”), featuring food-related imagery in the background and containing links inviting users to “log in” or “sign up”. Currently the disputed domain names resolve to inactive pages mentioning “This site can’t be reached”. 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 Complainant is the sole legitimate owner of trademark, corporate name, domain name made of/including MICHELIN and the disputed domain names incorporate identically the earlier well-known MICHELIN trademark and corporate name of the Complainant. The addition of the descriptive terms like “top”, “guide”, “performance”, “best” in combination with the Complainant’s well-known trademark MICHELIN, does not prevent a finding of confusing similarity between these disputed domain names and the MICHELIN trademarks. The Respondent registered the disputed domain names, as the Respondent only seeks to take a commercial advantage of the Complainant’s distinctive and famous mark. The Respondent’s reproducing the Complainant’s trademark in its entirety across multiple domain names and using the domain names for pages distinctively displaying the MICHELIN mark in connection with culinary activities, and holding the disputed domain names passively (after the content was taken down upon page 3 the Complainant’s request to the Registrar), constitute a deliberate and systematic attempt to exploit the reputation and goodwill of the MICHELIN mark, thereby resulting in bad faith registrations and use. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings Three elements need to be established by the Complainant under paragraph 4 (a) of the Policy to obtain transfer of the disputed domain names, these are: (i) The disputed domain names are identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) The Respondent lacks rights or legitimate interests in the disputed domain names; and (iii) The disputed domain names were registered and are being used in bad faith by the Respondent. 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 Panel finds the mark is recognizable within the disputed domain names. Although the addition of other terms as prefix and suffix (such as “top”, “best”, “performance”, “guide”) may bear an assessment of the second and third elements, the Panel finds the addition of such terms does not prevent a finding of confusing similarity between the disputed domain names and the trademark MICHELIN 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. page 4 The Respondent was not authorized by the Complainant to use its trademark or register the disputed domain names, and neither made any bona fide use of the disputed domain names (or demonstrable plans for such use), nor any legitimate noncommercial or fair use. Moreover, it is not commonly known by the disputed domain names. 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. In the present case, the Panel notes that it is impossible that the Respondent was unaware of the Complainant’s well-known trademark MICHELIN and that the Respondent registered multiple disputed domain names coincidentally. 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. The reproduction of the Complainant’s trademark and the reference to the Complainant’s mark (including the Michelin Man logo) on the websites at the disputed domain names suggests the awareness of the Complainant’s marks and intent to exploit the Complainant’s goodwill by misleading Internet users. Panels have held that the use of a domain name for an illegal activity, here, impersonation / passing off, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain names constitutes 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 <bestmichelinguide.com>, <michelinperformance.com>, and <topmichelinguide.com> be transferred to the Complainant. /Saisunder Nedungal Vidhya Bhaskar/ Saisunder Nedungal Vidhya Bhaskar Sole Panelist Date: January 14, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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