Westmore · UDRP decision
WIPO · Case No. D2025-5175

Assistance-caisse-epargne.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <assistance-caisse-epargne.com> to BPCE. It found the domain confusingly similar to BPCE's CAISSE D’EPARGNE mark, that the Respondent lacked rights or legitimate interests, and that the domain was registered and used in bad faith. Although the domain was not used for a website or email address, its composition and passive holding supported the bad-faith finding in the circumstances.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-03
Panelist(s)
Belciu, Delia-Mihaela
Complainant
BPCE
Respondent
Bungee, Leonardo JavierBarroso Falcon
Disputed domain(s)
assistance-caisse-epargne.com
Domain history UDRP Intelligence

The timeline behind assistance-caisse-epargne.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 assistance-caisse-epargne.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 assistance-caisse-epargne.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates how a domain combining the recognizable core of a banking mark with a support-related term can satisfy all three UDRP elements even without active website or email use. The result rested on longstanding trademark rights, the domain's targeted composition, the absence of any demonstrated legitimate basis, and passive holding in the specific circumstances.

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
2026-02-03
Panel
Belciu, Delia-Mihaela
Full decision
10 min read · hosted by Westmore

ARBI TRATI O N AND MEDI ATI ON CENTER ADMINISTRATIVE PANEL DECISION BPCE v. Bungee, Leonardo JavierBarroso Falcon Case No. D2025-5175 1. The Parties The Complainant is BPCE, France, represented by KALLIOPE Law Firm, France. The Respondent is Bungee, Leonardo JavierBarroso Falcon, Peru. 2. The Domain Name and Registrar The disputed domain name <assistance-caisse-epargne.com> is registered with Nicenic International Group Co ., Limited (the “Reg istrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 11, 2025. On December 11, 2025, the Center transmitted by email to the Registrar a request f or registrar verif ication in connection with the disputed domain name. On December 12, 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 (not identif ied) and contact inf ormation in the Complaint. The Center sent an email communication to the Complainant on December 15, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant f iled an amended Complaint on December 18, 2025. The Center verif ied that the Complaint together with the amended Complaint satisf ied the f ormal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” o r “UDRP”), the Rules f o r Unif orm Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules f or Unif orm Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center f ormally notif ied the Respondent of the Complaint, and the proceedings commenced on December 19, 2025. In accordance with the Rules, paragraph 5, the due date f or Response was January 8, 2026. The Respondent did not submit any response. Accordingly, the Center notif ied the Respondent’s def ault on January 13, 2026. The Center appointed Delia-Mihaela Belciu as the sole panelist in this matter on January 20, 2026. The Panel f inds that it was properly constituted. The Panel has submitted the Statement of Acceptance and page 2 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 second largest banking group in France, pursuing a f ull range of banking, f inancing and insurance activities, working through its two major cooperative banking networks, namely Banque Populaire and Caisse d’Epargne, as well as through its dif f erent subsidiaries. The Complainant has 105,000 employees, being present in more than 40 countries via its various subsidiaries, serving a total of 36 million customers. The Complainant is the owner of the f ollowing trademarks containing the denomination CAISSE D’EPARGNE: - the French national trademark No. 1658134 f or CAISSE D’EPARGNE, registered on April 26, 1991, f or goods and services in classes 9, 16, 28, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45; - the European Union trademark No. 000637504 for CAISSE D’EPARGNE, registered on April 8, 1999, f o r goods and services in classes 9, 16, 35, 36, 38, 41, 42; - the French national trademark No. 3155888 for LA CAISSE D’EPARGNE, registered on March 27, 2002, f or services in classes 36 and 41. In addition, the Complainant owns the domain names <caisse-epargne.com> registered since October 6, 1998 and <caisse-epargne.fr>, registered since January 16, 2009, the last one corresponding to an active website used by the Complainant’s customer to access online their bank accounts f or remote access and management. The disputed domain name <assistance-caisse-epargne.com> was registered on May 6, 2025, and it is not used in relation to a webpage or an email address. 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: (i) the disputed domain name is confusingly similar to the CAISSE D’EPARGNE mark as it contains the CAISSE D’EPARGNE mark, with the addition of the term “assistance”; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name f or a number of reasons, among which that, (1) the Respondent has no trademarks corresponding to the disputed domain name, (2) the Complainant has not granted any license nor any authorisation for the Respondent to use its CAISSE D’EPARGNE mark including in the disputed domain name; (iii) the disputed domain name was registered and is being used in bad f aith f or a number of reasons, among which that, (1) the Complainant’s CAISSE D’EPARGNE mark pre-date the registration of the disputed domain name, (2) the Complainant and its subsidiaries are well-known in France f or the f inancial and banking market consumers, (3) the Complainant’s trademarks are well-known, (4) the disputed domain page 3 names resolves to an inaccessible website, (5) the data about the Respondent in the Who Is database is anonymous, being hidden by the Registrar, which did not allow the Complainant to identif y clearly and to contact the Registrant. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings In order f or the Complainant to succeed, such must prove, according to paragraph 4(a) of the Policy, that: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the Complainant has rights; and (ii) the Respondent has no rights or legitimate interests with respect to the disputed domain name; and (iii) the disputed domain name has been registered and is being used in bad f aith. In case all three elements above have been fulfilled, the Panel is able to grant the remedy requested by the Complainant. Thus, the Panel will deal with each of the requirements in turn. 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 f inds that the Complainant’s CAISSE D’EPARGNE mark is reproduced within the disputed domain name without the particle “d’”, the word elements of the mark being separated by hyphens, with the addition in front of it of the descriptive term “assistance”, term commonly used in banking, financing and insurance activities, aspects which do not prevent a f inding that the disputed domain name is conf usingly similar to the Complainant’s CAISSE D’EPARGNE mark. Accordingly, the disputed domain name is conf usingly similar to the mark f or the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms, in this case “assistance”, 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. In what concerns the addition of the generic Top-Level Domain (“gTLD”) “.com” in relation to the disputed domain name, such is viewed as a standard registration requirement, and is disregarded under the f irst element conf using similarity test. WIPO Overview 3.0, section 1.11.1. Based on the available record, the Panel f inds that the f irst 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. page 4 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 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. Thus, based on the available evidence, the Respondent does not appear to be commonly known by the name “Caisse d’Epargne” o r “Caise Epargne”. Based on the available evidence, the Respondent is not a licensee of , nor has any kind of business relationship with the Complainant. The Complainant has never authorised the Respondent to make use of its CAISSE D’EPARGNE trademark in the disputed domain name. Moreover, the disputed domain name is not used in relation to a website or an email address. 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 the Complainant’s rights in the CAISSE D’EPARGNE mark predate the registration date of the disputed domain name. In light of the above, the Panel finds that it is not conceivable that the Respondent registered the disputed domain name without knowledge of the Complainant’s CAISSE D’EPARGNE mark, which supports a finding of bad f aith registration. WIPO Overview 3.0, section 3.2.2. 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 disputed domain name is not used in relation to a website or an email address. UDRP panels have found that the non-use of a domain name would not prevent a finding of bad faith under the doctrine of passive holding. WIPO Overview 3.0, section 3.3. Having reviewed the available record, the Panel notes the composition of the disputed domain name which reproduces the Complainant’s CAISSE D’EPARGNE mark without the particle “d’”, with the addition of the descriptive term “assistance”, term commonly used in banking, financing and insurance activities, and finds that in the circumstances of this case the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy and finds that the Complainant has established the third element of the Policy. page 5 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 <assistance-caisse-epargne.com> be transferred to the Complainant. /Delia-Mihaela Belciu/ Delia-Mihaela Belciu Sole Panelist Date: February 3, 2026

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

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