Circus-casinos.com

The timeline behind circus-casinos.com

Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.

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 Gambling Management S.A. v. Geoffrey CUVELIER Case No. D2025-5226 1. The Parties The Complainant is Gambling Management S.A., Belgium, represented by COGITUS SRL, Belgium. The Respondent is Geoffrey CUVELIER, Spain. 2. The Domain Name and Registrar The disputed domain name <circus-casinos.com> (the “Domain Name”) is registered with Hosting Concepts B.V. d/b/a Registrar.eu. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 15, 2025. On December 16, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Domain Name. On December 17, 2025, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the Domain Name which differed from the named Respondent (Whois Privacy Protection Foundation, Whois Privacy Protection Foundation) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 17, 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 19, 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 22, 2025. In accordance with the Rules, paragraph 5, the due date for Response was January 11, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 12, 2026. page 2 The Center appointed Mathias Lilleengen as the sole panelist in this matter on January 16, 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 to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant operates a Belgian gambling and sports betting website. It is one of a limited number of licensed gambling operators in Belgium. The Complainant operates its official online casino website from “www.circus-casino.be”. The Complainant is the licensee of numerous trademark registrations globally consisting of or incorporating the elements CIRCUS and CIRCUS CASINO, such as European Union Trade Mark registration No. 018025773 (figurative) for CIRCUS (registered on October 20, 2020) and Swiss trademark registration No. 785512 (figurative) for CIRCUS CASINO CRANS MONTANA (registered on August 18, 2022), owned by Circus Belgium S.A. who expressly authorized the Complainant to file the present Complaint – referred to below as “Complainant’s trademarks”. The CIRCUS trademark has been successfully defended before the European Union Intellectual Property Office in numerous opposition and cancellation proceedings in the gambling and betting sector. The Domain Name was registered by the Respondent on October 17, 2025. The Domain Name resolves to a webpage that copies the Complainant’s official sites and targets the same services. It uses the Complainant’s trademark and claims to have a Belgian license. The Respondent’s webpage has links to unlicensed “black market” casino webpages. 5. Parties’ Contentions A. Complainant The Complainant provides evidence of trademark registrations and that its trademark is well-known in the gambling industry. The Domain Name is confusingly similar to the Complainant’s trademarks. The Complainant argues that the Respondent has no rights or legitimate interests in respect of the Domain Name. The Respondent has no relation with the Complainant and its trademark. The Complainant argues that it implausible that the Respondent could have been unaware of the Complainant’s rights when registering and using the Domain Name in the same sector of online casino services. The use of the Domain Name proves that the Respondent has intentionally attempted to attract, for commercial gain, Internet users to another 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 and the services offered thereon. The impersonation of the Complainant, the misrepresentation of a Belgian license, the copying of the Complainant’s branding and legal notices, and the redirection of users to an unlicensed offshore casino are all incompatible with any claim of good-faith registration or use. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar The first element functions primarily as a standing requirement. The standing (or threshold) test for page 3 confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the Domain Name. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition, (“WIPO Overview 3.0”), section 1.7. Noting the express authorization of Circus Belgium S.A., the Complainant has established that it has rights in the CIRCUS and CIRCUS CASINO formative marks for the purpose of the Policy. WIPO Overview 3.0, section 1.4. The Domain Name incorporates the Complainant’s trademark CIRCUS with the addition of the term “-casinos”. The addition does not prevent a finding of confusing similarity between the Domain Name and the trademark. WIPO Overview 3.0, section 1.8. For the purpose of assessing under paragraph 4(a)(i) of the Policy, the Panel may ignore the generic Top-Level Domain (“gTLD”). See WIPO Overview 3.0, section 1.11.1. The Panel finds that the Domain Name is confusingly similar to a trademark in which the Complainant has rights in accordance with paragraph 4(a)(i) of the Policy. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which a respondent may demonstrate rights or legitimate interests in a disputed domain name. While 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 often impossible 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. If the respondent fails to come forward with such relevant evidence, the Complainant is deemed to have satisfied the second element. See WIPO Overview 3.0, section 2.1. Based on the evidence, the Respondent is not affiliated with or related to the Complainant. There is no evidence that the Respondent has registered the Domain Name as a trademark or acquired trademark rights. There is no evidence of the Respondent’s use of, or demonstrable preparations to use, the Domain Name or a name corresponding to the Domain Name in connection with a bona fide offering of goods or services. On the contrary, the use of the Domian Name is done in bad faith, see below. Moreover, the Panel finds that the composition of the Domain Name carries a risk of implied affiliation with the Complainant. The Panel finds that the Respondent has no rights or legitimate interests in respect of the Domain Name in accordance with paragraph 4(a)(ii) 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. The Respondent knew of the Complainant when it registered the Domain Name. It follows from the composition and use of the Domain Name. As mentioned, the Domain Name has been used for a website that uses the Complainant’s trademark (and gaming operator license) without authorization to impersonate the Complainant and redirect to unlicensed casino websites. The Panel agrees that the Respondent has registered and used the Domain Name to attract, for commercial gain, Internet users to another 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 and the services offered thereon. This is clear evidence of bad faith under the Policy. page 4 Based on the available record, 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 the Domain Name <circus-casinos.com> transferred to the Complainant. /Mathias Lilleengen/ Mathias Lilleengen Sole Panelist Date: January 21, 2026

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