Westmore · UDRP DecisionLechat.chat
The Panel ordered transfer of <lechat.chat>. It found that Mistral AI had established unregistered trademark rights in LE CHAT by the time the Complaint was filed and that the domain name was identical to that mark. The Respondent did not rebut the Complainant’s prima facie case on rights or legitimate interests. Bad faith was established based on the timing of registration immediately after media coverage of the LE CHAT launch, the distinctiveness of the term for the Complainant’s service, and the website’s imitation and targeting of the Complainant.
The timeline behind lechat.chat
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 lechat.chat — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
The case illustrates how a complainant may establish unregistered UDRP rights in a recently launched product name through evidence of distinctiveness, substantial media attention, and respondent targeting. It also shows the evidentiary importance of registration timing where a domain is obtained immediately after launch publicity and then used for a site that imitates the complainant.
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 Mistral AI v. Vladislav Zhelkovsky Case No. D2025-5113 1. The Parties The Complainant is Mistral AI, France, represented by Blanche Avocats, France. The Respondent is Vladislav Zhelkovsky, Kazakhstan. 2. The Domain Name and Registrar The disputed domain name <lechat.chat> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 9, 2025. On December 10, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 10, 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 (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 11, 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 12, 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 15, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 4, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 5, 2025. page 2 The Center appointed Knud Wallberg as the sole panelist in this matter on January 8, 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 MISTRAL AI, a simplified joint stock company, registered in April 2023, having its headquarters in Paris, France. The Complainant is a European leader in generative artificial intelligence, specializing in developing and offering large language models (LLMs). The Complainant is the owner of several registrations of the trademark MISTRAL AI and of their logo around the world, such as European Union Trade Mark No. 018942618, registered on February 14, 2024; just as the Complainant is the owner of the many domain names containing its trademark, such as <mistral.ai> and <mistral-ai.com>. In February 2024 the Complainant introduced a multilingual conversational assistant that allows users to interact with the Complainant ́s its various AI models, under the trademark LE CHAT. Several newspapers and websites announced the launching of this platform between February 26 to February 29, 2024 as per the evidence in the case file. The disputed domain name <lechat.chat> was registered on March 1, 2024, and has resolved to a website that featured the Complainant’s mark LE CHAT and the Complainant’s logo, and which appeared as an imitation of the Complainant’s website. The disputed domain name is currently redirected to a third-party website. 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 the Complainant’s earlier well-known mark LE CHAT, that the Respondent has no rights or legitimate use of the term “lechat” in the disputed domain name and that the disputed domain name was registered and has been used in bad faith by the Respondent B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings According to paragraph 15(a) of the Rules the Panel shall decide the Complaint in accordance with the Policy, the Rules and any rules and principles of law that it deems applicable. Paragraph 4(a) of the Policy directs that a complainant must prove each of the following: (i) that the domain name registered by the respondent is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and page 3 (ii) that the respondent has no rights or legitimate interests in respect of the domain name; and (iii) that the domain name has been registered and is being used in bad faith. Paragraph 4(a) of the Policy states that the burden of proving that all these elements are present lies with the Complainant. At the same time, in accordance with paragraph 14(b) of the Rules, if a party, in the absence of exceptional circumstances, does not comply with any provision of, or requirement under, the Rules, or any request from the Panel, the Panel shall draw such inferences therefrom as it considers appropriate. 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 Panel finds that Complainant has put forward evidence that, at the time the complaint was filed, had established unregistered trademark or service mark rights to LE CHAT for the purposes of the Policy. WIPO Overview 3.0, section 1.3. In this regard, the Panel notes: (a) the term LE CHAT is distinctive for a multilingual conversational assistant that allows users to interact with the Complainant’s various AI models, (b) the extensive media coverage of the launch of LE CHAT on the Complainant’s website at “chat.mistral.ai” in February 2024, and (c) the massive, world-wide media overage associated with the launch of LE CHAT as an app on the App Store and on the Google Play Store in February 2025. Moreover, the Respondent’s clear targeting of the Complainant on the website resolving from the disputed domain name further supports the Complainant’s assertions that its mark has achieved significance as a source identifier. The entirety of the mark is reproduced within the disputed domain name. Accordingly, the disputed domain name is identical 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 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. page 4 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. 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. Based on the extensive media coverage of launch of LE CHAT on the Complainant ́s website at “chat.mistral.ai” in February 2024, and the fact that LE CHAT is a distinctive term for a digital multilingual conversational assistant, the Panel finds that it is likely, on the balance of probabilities, that the Respondent was aware of the Complainant and its new service under the LE CHAT mark at the time the disputed domain name was registered. See section 3.8.2 of the WIPO Overview 3.0. Furthermore, between then and until shortly before the commencement of this proceeding, the Respondent’s website made references to services that were identical to those offered by the Complainant, which clearly indicates the Respondent’s awareness of Complainant and of the Complainant’s activities. Noting that the disputed domain name incorporates the Complainant’s trademark LE CHAT in its entirety; that the Respondent has not replied to the Complainant’s contentions; and that there appears to be no conceivable good faith use that could be made by the Respondent of the disputed domain name and considering all the facts and evidence of the case, the Panel finds that the requirements of paragraph 4(a)(iii) of the Policy are also fulfilled in this case 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 <lechat.chat> be transferred to the Complainant. /Knud Wallberg/ Knud Wallberg Sole Panelist Date: January 22, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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