Westmore · UDRP decision
WIPO · Case No. D2025-5176

Michelindiningguide.com, Michelinfoodcritic.com, Michelinfoodrating.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of all three disputed domain names. It found them confusingly similar to the Complainant’s MICHELIN trademark because each reproduced the mark in full. The Complainant established an unrebutted prima facie case that the Respondent lacked rights or legitimate interests. Evidence that identical websites used the Michelin Man logo, the MICHELIN mark with a registered trademark symbol, and fine-dining imagery supported the finding that the domains were used to imitate or impersonate the Complainant and mislead consumers, establishing bad-faith registration and use.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-08
Panelist(s)
Newell, Aaron
Complainant
Compagnie Generale des Etablissements Michelin
Respondent
Vajida Umarmia, Enterprise
Counsel
Tmark Conseils
Disputed domain(s)
michelindiningguide.com, michelinfoodcritic.com, michelinfoodrating.com
Domain history UDRP Intelligence

The timeline behind michelindiningguide.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 michelindiningguide.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
Outcome by domain

How each disputed name was decided in this proceeding.

michelindiningguide.comTransferred
michelinfoodcritic.comTransferred
michelinfoodrating.comTransferred
Verified public record
Outcome & remedy
Complaint granted. Panel ordered transfer of michelindiningguide.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how a domain-name portfolio combining a well-known mark with terms closely aligned to the trademark owner’s business can support all three UDRP elements when accompanied by impersonating website content. The case was not based solely on incorporation of MICHELIN: use of the Michelin Man logo, the registered trademark symbol, and fine-dining imagery provided direct contextual evidence of targeting and deceptive affiliation.

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
2026-02-08
Panel
Newell, Aaron
Full decision
9 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Compagnie Generale des Etablissements Michelin v. Vajida Umarmia, Enterprise Case No. D2025-5176 1. The Parties The Complainant is Compagnie Generale 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 <michelindiningguide.com>, <michelinfoodcritic.com>, and <michelinfoodrating.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 25, 2025. On December 11, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain names. On December 12, 2026, the Registrar transmitted by email to the Center its verification response confirming that the Respondent is listed as the registrant and providing the contact details. The Center verified that the 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 19, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 8, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 19, 2026. The Center appointed Aaron Newell as the sole panelist in this matter on January 23, 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 well-known French company that manufactures tires and also produces the Michelin Guide publication which assesses restaurants based on a system of coveted “Michelin Stars”. The Complainant has used the MICHELIN trademark since the late 1800’s and began publishing the Michelin Guide as a travel and gastronomy guide in Europe in order to encourage motor travel. The Complainant began developing the Michelin Star rating system in 1926 as a feature of its guide. It has sold over 30 million Michelin Guides and presently assesses over 30,000 hospitality establishments in over 30 countries around the world. Its activities under the MICHELIN name are promoted variously online, including on social media. The Complainant has protected its MICHELIN name with a number of trademark registrations around the world, including: i) United States of America Trademark Registration No. 5775734 for the mark MICHELIN (registered June 11, 2019) in classes 9, 39, and 42; ii) European Union Trademark Registration No. 13558366 for the mark MICHELIN (registered April 17, 2015) in classes 9, 35, 38, 39, 41, and 42; and iii) European Union Trademark Registration No. 9914731 for the mark MICHELIN (registered September 27, 2011) in classes 9, 35, 37, 38, 39, 41, 42, and 43. The Complainant has succeeded in a number of UDRP disputes between 2001 and the present, and in which its MICHELIN trademark has variously been acknowledged by panels as being well known. The disputed domain names were registered on November 3, 2025. There is evidence in the case file that the disputed domain names have been used to load identical websites featuring a “Michelin Man” logo that is associated with the Complainant, depictions of food in a fine dining setting, use of the term MICHELIN with the registered trademark symbol, and the phrase “We offer a top- rated experience that helps retailers promote their brands.” At the time of writing this decision no websites loaded at the disputed domain names. The Complainant has provided evidence that it filed a complaint with the Registrar seeking deletion of the respective DNS zone files on the basis that the websites infringed the Complainant’s rights, and that the Registrar complied. The Respondent did not file a response to the Complaint or otherwise engage with the proceedings. 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: i) the disputed domain names are confusingly similar to its registered trademarks because the disputed domain names contain its MICHELIN trademark in its entirety and the inclusions of the words “dining”, “food”, “critic”, “rating”, and “guide” increase the risk of confusion with the Complainant’s trademark because they relate to the Complainant’s business; page 3 ii) the Respondent does not have rights or legitimate interests in the disputed domain names because the Complainant’s rights in its MICHELIN trademark arose prior to the Respondent’s registration of the disputed domain names and the Respondent has taken advantage of the Complainant’s commercial interest in its MICHELIN trademark; iii) the disputed domain names were registered and are being used in bad faith because the Respondent had prior knowledge of the Complainant and its trademark rights in the MICHELIN name, the Respondent could not have registered the disputed domain names by coincidence and without reference to the Complainant, the Respondent provided inaccurate contact details when registering the disputed domain names, and the Respondent used the disputed domain names to impersonate the Complainant and its business. B. Respondent The Respondent did not reply to the Complainant’s contentions and did not engage with the Center or these proceedings. 6. Discussion and Findings Under paragraph 4(a) of the Policy, the Complainant carries the burden of proving: i) that the disputed domain names are identical or confusingly similar to a trademark or service mark in which it has rights; ii) that the Respondent has no rights or legitimate interests in respect of the disputed domain names; and iii) that the disputed domain names have been registered and are being used in bad faith. The Respondent's default does not automatically result in a decision in favor of the Complainant. Paragraph 5(f) of the Rules does however provide that if the Respondent does not submit a response, in the absence of exceptional circumstances, the Panel shall decide the dispute based upon the Complaint. Further, according to paragraph 14(b) of the Rules, the Panel may draw such inferences from the Respondent’s failure to submit a response 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 names. 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 MICHELIN mark is reproduced within the disputed domain names. Accordingly, the disputed domain names are 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 “diningguide”, “foodcritic” and “foodrating”) may bear on 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 mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. page 4 Accordingly, 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. Further, panels have held that the use of a domain name for illegitimate or illegal activity (here claimed to be the intentionally-confusing imitation of the Complainant’s business) can never confer rights or legitimate interests on a respondent. WIPO Overview 3.0, section 2.13.1. Again, the Respondent has not engaged with the proceedings and has not rebutted the Complainant’s allegations and related supporting evidence in respect of the Respondent’s conduct. The Panel finds that 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. As noted above, the Complainant has asserted and provided compelling evidence that the Respondent has used the disputed domain names, which are confusingly similar to the Complainant’s prior registered and well-known trademark, to imitate and/or impersonate the Complainant and mislead consumers by creating the impression that the Respondent’s websites at the disputed domains name are the Complainant’s website, or are connected with the Complainant, when they are not. 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 use of a domain name for per se illegitimate activity such as the intentional impersonation of the complainant and/or conduct that is intended to mislead or deceive consumers is manifestly considered evidence of bad faith. WIPO Overview 3.0, section 3.1.4. The Panel 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 names <michelindiningguide.com>, <michelinfoodcritic.com>, and <michelinfoodrating.com> be transferred to the Complainant. /Aaron Newell/ Aaron Newell Sole Panelist Date: February 8, 2026

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

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