Westmore · UDRP decision
WIPO · Case No. D2025-4922

Engie-recouvrement.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <engie-recouvrement.com> to ENGIE. It found the domain confusingly similar to the ENGIE mark because the mark remained recognizable despite the addition of the French term “recouvrement.” The Respondent lacked rights or legitimate interests because the unrebutted record showed impersonation, phishing, and fraudulent payment solicitation. The same conduct demonstrated that the Respondent targeted ENGIE and registered and used the domain in bad faith.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-21
Panelist(s)
Haas, Marie-Emmanuelle
Complainant
ENGIE
Respondent
Paul Delow, Harmonie engie
Counsel
Ebrand France
Disputed domain(s)
engie-recouvrement.com
Domain history UDRP Intelligence

The timeline behind engie-recouvrement.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 engie-recouvrement.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 engie-recouvrement.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates a straightforward UDRP application where a recognizable trademark is combined with a service-related term and then used in payment-focused impersonation. The phishing evidence connected both the domain’s composition and its use directly to ENGIE, supporting findings on legitimate interests and bad faith without reliance solely on the passive parking page.

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
2026-01-21
Panel
Haas, Marie-Emmanuelle
Full decision
11 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION ENGIE v. Paul Delow, Harmonie Engie Case No. D2025-4922 1. The Parties The Complainant is ENGIE, France, represented by Ebrand France, France. The Respondent is Paul Delow, Harmonie engie, France. 2. The Domain Name and Registrar The disputed domain name <engie-recouvrement.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on November 26, 2025. On November 26, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 26, 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 (Withheld for Privacy Purposes) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 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 amended Complaint on December 11, 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 12, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 1, 2026. [The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 2, 2026. page 2 The Center appointed Marie-Emmanuelle Haas as the sole panelist in this matter on January 7, 2026. 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 the French company ENGIE is specializing in energy transition services and distribution of electricity, natural gas, nuclear power and renewable energies. It is operating on a worldwide basis. ENGIE, formerly known as GDF Suez, was formed in 2015 from the merger between Gaz de France, founded in 1946, and Suez, founded in 1858. The ENGIE Group is established in 31 countries and had 96,454 employees at the end of December 2022 with a turnover of EUR 52.8 billion in September 2025. It has 190,000 B2B customers, with a turnover of EUR 22.5 million in B2C energy supply and service contracts. The Complainant is the owner of the following trademarks: - European Union word and device trademark ENGIE No 014063747, registered on February 20, 2016, in classes 1, 4, 7, 9, 11, 35, 36, 37, 38, 39, 40, 41, 42, and 45, duly renewed; - French word and device trademark ENGIE No 4171999, registered on July 31, 2015, in classes 1, 4, 7, 9, 11, 35, 36, 37, 38, 39, 40, 41, 42, and 45, duly renewed; - French word and device trademark ENGIE No 4171997, registered on July 31, 2015, in classes 1, 4, 7, 9, 11, 35, 36, 37, 38, 39, 40, 41, 42, and 45, duly renewed. The Complainant claims to be the registrant of the following domain names: - <engie.com>, registered on September 30, 2003, which resolves to its main official website; - <engie.fr>, registered on February 23, 2015, as proved by the produced WhoIs data; - <recouvrement-engie.fr>, registered on November 19, 2024, as proved by the produced WhoIs data. Two subdomains redirect to ENGIE’s recovery services in France: <reglement.particuliers.engie.fr> and <paiement.particuliers.engie.fr>. The disputed domain name <engie-recouvrement.com> was registered on October 23, 2024, using a privacy WhoIs service. According to the contact details that were disclosed by the Registrar, it appears that the Respondent is an individual, with an address in France. The disputed domain name resolves to a parking webpage. It is used as well to send fraudulent emails for phishing purposes. Such an email is produced, it impersonates the Complainant and is asking for the payment of an invoice. page 3 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 contends the following: On confusing similarity: The Complainant has prior rights to the ENGIE trademark. The disputed domain name <engie-recouvrement.com> incorporates the ENGIE trademark with the addition of the French dictionary word “recouvrement”, meaning “recovery” in English. Therefore, the disputed domain name is considered as confusingly similar with the ENGIE trademark. On the absence of right or legitimate interest: The Respondent does not own any ENGIE trademark. A search on the internet on “engie recouvrement” provide results, which are all related to the Complainant and to its ENGIE trademark. Therefore, the registrant of the disputed domain name is not commonly known by the domain name and has not acquired a trademark or service mark under that name. By registering this disputed domain name, with the aim of reproducing the ENGIE trademark and of impersonating the Complainant to collect sensitive data from Internet users the Respondent is not using the domain name in connection with a bona fide offering of goods or services. Therefore, there is no evidence of the Respondent’s use of the disputed domain name in connection with bona fide offering of goods or services. It is therefore blatant that the Respondent has absolutely no rights or legitimate interests in the disputed domain name <engie-recouvrement.com>. On bad faith registration and use: By reproducing the ENGIE trademark and adding the word “recouvrement”, the Respondent wanted to attract Internet users and make them believe they are receiving official emails from the Complainant regarding the payment of their invoice. By directing the disputed domain name to a parking page that contains pay-per-click links, the Respondent is attempting to attract users for commercial gain by creating a likelihood of confusion as to the source, sponsorship, or affiliation of the disputed domain name with the Complainant. This constitutes use in bad faith. The Complainant asserts that “By using the domain name, the Registrant has intentionally attempted to attract, for commercial gain, Internet users to their website or other on-line location, by creating a likelihood of confusion with the Complainant's trademark as to the source, sponsorship, affiliation, or endorsement of the Respondent’s web site or location or of a product or service on the Respondent’s web site or location”. page 4 B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings 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 addition of the French dictionary term “recouvrement”, which in this context means “debt recovery” in English, does not prevent a finding of confusing similarity between the disputed domain name and the mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The Panel finds the mark is recognizable 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 Pursuant to paragraph 4(c) of the Policy, the Respondent may establish rights or legitimate interests in the disputed domain name by demonstrating any of the following: (i) before any notice to it of the dispute, 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 bona fide offering of goods or services; or (ii) the Respondent has been commonly known by the disputed domain name, even if it has acquired no trademark or service mark rights; or (iii) the Respondent is making a legitimate noncommercial or fair use of the disputed domain name, without intent for commercial gain, to misleadingly divert consumers, or to tarnish the trademark or service mark at issue. 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 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. Panels have held that the use of a domain name for illegal activity, like here impersonation, phishing and fraudulently obtaining online payments, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith Paragraph 4(b) of the Policy sets out examples of circumstances that will be considered by a Panel to be evidence of bad faith registration and use of the disputed domain name. It provides that: For the purposes of paragraph 4(a)(iii), the following circumstances, in particular but without limitation, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith: (i) circumstances indicating that the respondent has registered, or the respondent has acquired the domain name primarily for the purpose of selling, renting, or otherwise transferring the domain name registration to the complainant who is the owner of the trademark or service mark or to a competitor of that complainant, for valuable consideration in excess of the respondent’s documented out-of-pocket costs directly related to the domain name; or (ii) the respondent has registered the domain name in order to prevent the owner of the trademark or service mark from reflecting the mark in a corresponding domain name, provided that the respondent has engaged in a pattern of such conduct; or (iii) the respondent has registered the domain name primarily for the purpose of disrupting the business of a competitor; or (iv) by using the domain name, the respondent has intentionally attempted to attract, for commercial gain, Internet users to the Respondent’s website or other online location, by creating a likelihood of confusion with the complainant’s mark as to the source, sponsorship, affiliation, or endorsement of the respondent’s website or location or of a product or service on the respondent’s website or location. In the present case, the Panel notes that the Respondent, with an address in France, could not ignore the Complainant’s rights of the ENGIE well-known trademark. The fact that the Respondent impersonated the Complainant using its trademark, contact details and links to its official website when sending emails for phishing purposes proves that it targeted the Complainant when registering the disputed domain name. 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. page 6 Panels have held that the use of a domain name for an illegal activity, like in this case, impersonation, phishing, and other types of fraud, 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 name 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 name <engie-recouvrement.com> be transferred to the Complainant. /Marie-Emmanuelle Haas/ Marie-Emmanuelle Haas Sole Panelist Date: January 21, 2026

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

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