Westmore · UDRP decision
WIPO · Case No. D2025-4943

Tityaravyparis.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <tityaravyparis.com>. It found the domain confusingly similar to the Complainant’s TITYARAVY trademark because it incorporated the mark in full with the geographic term “paris.” The Respondent lacked rights or legitimate interests because the unrebutted record showed no authorization, no evidence that the Respondent was commonly known by the domain, and prior use for a website reproducing the Complainant’s mark and website elements without a clear affiliation disclaimer. The Panel found bad-faith registration and use based on deliberate targeting and an intentional attempt to attract Internet users for commercial gain through confusion. The domain’s subsequent passive holding did not prevent a bad-faith finding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-01-23
Panelist(s)
Cappai, Andrea
Complainant
TITYARAVY
Respondent
Nikos Kalouris
Counsel
Tmark Conseils
Disputed domain(s)
tityaravyparis.com
Domain history UDRP Intelligence

The timeline behind tityaravyparis.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 tityaravyparis.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 tityaravyparis.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining an entire distinctive mark with the trademark owner’s city can reinforce evidence of targeting rather than reduce confusing similarity. The case also shows the evidentiary importance of a commercial website reproducing a complainant’s mark, product presentation, and legal text without a prominent non-affiliation disclosure. Later inactivity did not cure or outweigh the prior use.

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
2026-01-23
Panel
Cappai, Andrea
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION TITYARAVY v. Nikos Kalouris Case No. D2025-4943 1. The Parties The Complainant is TITYARAVY, France, represented by Tmark Conseils, France. The Respondent is Nikos Kalouris, United States of America. 2. The Domain Name and Registrar The disputed domain name <tityaravyparis.com> is registered with Spaceship, 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 27, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On November 27, 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 (Redacted for Privacy Purposes, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 1, 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 4, 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 9, 2025. In accordance with the Rules, paragraph 5, the due date for Response was December 29, 2025. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 7, 2026. The Center appointed Andrea Cappai as the sole panelist in this matter on January 9, 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. page 2 4. Factual Background The Complainant is a French company organised as a société par actions simplifiée, with its registered office in Paris, France. According to the record, the Complainant has been active for several years in the design and commercialisation of jewellery and related products, operating under the TITYARAVY mark through its own website and other commercial channels. The Complainant is the owner of the following trademark registrations: - TITYARAVY – France – No. 4690471 – registered February 26, 2021; - TITYARAVY – European Union – No. 018937319 – registered April 12, 2024; and - TITYARAVY – International Registration – No. 1785503 – registered January 17, 2024. The Complainant is also the owner of the domain name <tityaravy.com>. According to the record, this domain name is used in connection with the Complainant’s official website and for its business email communications. The record further indicates that the Complainant maintains an active presence on social media platforms. The disputed domain name was registered on March 6, 2025. According to the record, the disputed domain name previously resolved to a website offering jewellery products and displaying the TITYARAVY mark in various sections of the website, including product pages and terms and conditions. It also referred to the Complainant in the “Identification of the Seller” section. The disputed domain name currently does not resolve to an active web page. The Respondent is the registrant of the disputed domain name. No further information about the Respondent appears on the record. 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 that the disputed domain name is confusingly similar to its TITYARAVY trademark, corporate name, and domain name, as it reproduces the mark in its entirety with the addition of the geographical term “paris”, which, according to the Complainant, does not prevent a finding of confusing similarity and may reinforce an association with the Complainant. The Complainant further submits that the Respondent has no rights or legitimate interests in the disputed domain name, as it has not been authorised to use the TITYARAVY mark, and the disputed domain name has been used in connection with a website reproducing elements of the Complainant’s own website, including the use of identical images and product names, Terms and Conditions, and offering products whose appearance and presentation corresponded to those of the Complainant’s products, at significantly lower prices. Finally, the Complainant argues that the disputed domain name was registered and is being used in bad faith, asserting that the Respondent was aware of the Complainant and its trademark at the time of registration and alleging that the disputed domain name is used to create a false impression of association for commercial gain. page 3 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 entirety of the mark 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. Although the addition of other terms, here “paris”, may bear on assessment of the second and third elements, the Panel finds the addition of such term 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 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 recognised 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. Based on the available record, the Respondent has not been authorised by the Complainant to use the TITYARAVY trademark, and there is no evidence that the Respondent has been commonly known by the disputed domain name. The disputed domain name incorporates the Complainant’s trademark in its entirety together with the geographical term “paris”. The record indicates that the disputed domain name previously resolved to a website displaying the TITYARAVY mark and reproducing elements of the Complainant’s website, including product presentation and terms and conditions. The record does not show that the website clearly and page 4 prominently disclosed that it is not affiliated with the Complainant. In these circumstances, the Panel considers that such use does not support a finding of a bona fide offering of goods or services or a legitimate noncommercial or fair use. In the absence of any Response or other evidence demonstrating rights or legitimate interests on the part of the Respondent, the Panel finds that the Complainant has established the second element of the Policy. 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 the Respondent registered the disputed domain name incorporating the Complainant’s trademark in its entirety together with the geographical term “paris”, which corresponds to the city where the Complainant is established. In this context and having regard to the distinctiveness of the Complainant’s trademark, the composition of the disputed domain name, the timing of its registration, and the use to which it has been put, the Panel finds it reasonable to infer that the Respondent was aware of the Complainant and its trademark at the time of registration and deliberately targeted the Complainant. The Panel further notes that the disputed domain name was used in connection with a website displaying the TITYARAVY mark and reproducing elements of the Complainant’s website, including product images, product names, and terms and conditions. The record does not show that the website clearly and prominently disclosed that it was not affiliated with the Complainant. In light of the composition of the disputed domain name and the manner in which it was used, these elements, taken together, support the conclusion that the Respondent intentionally attempted to attract, for commercial gain, Internet users to its website by creating a likelihood of confusion with the Complainant’s trademark as to the source, sponsorship, affiliation, or endorsement of the website. The current passive holding of the disputed domain name does not prevent a finding of bad faith. 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 <tityaravyparis.com> be transferred to the Complainant. /Andrea Cappai/ Andrea Cappai Sole Panelist Date: January 23, 2026

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

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