Westmore · UDRP decision
WIPO · Case No. D2025-5357

Bvlgari.love

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <bvlgari.love> after finding all three UDRP elements established. The domain was identical to the Complainant’s registered BVLGARI mark. The Respondent lacked authorization, was not commonly known by the domain, and presented no evidence of bona fide or fair use. Bad faith was established from the mark’s distinctiveness and reputation, the domain’s prior use for a login page impersonating the Complainant, its subsequent passive holding, and the Respondent’s failure to provide an explanation.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-13
Panelist(s)
Bardales Mendoza, Enrique
Complainant
Bulgari S.p.A.
Respondent
Hettinger Edgar
Disputed domain(s)
bvlgari.love
Citation weightCited by 2 later decisions · relies on 1 authority
Domain history UDRP Intelligence

The timeline behind bvlgari.love

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 bvlgari.love — 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 bvlgari.love.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

This decision illustrates how prior impersonation followed by passive holding can collectively support findings under both the second and third UDRP elements. The exact match between a distinctive trademark and the second-level domain, coupled with a login page displaying the mark and an unexplained default, left no plausible legitimate use apparent from the record.

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.

Related decisions
Case details
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-13
Panel
Bardales Mendoza, Enrique
Full decision
12 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Bulgari S.p.A. v. Hettinger Edgar Case No. D2025-5357 1. The Parties The Complainant is Bulgari S.p.A., Italy, represented by SafeNames Ltd., United Kingdom. The Respondent is Hettinger Edgar, United States of America. 2. The Domain Name and Registrar The disputed domain name <bvlgari.love> is 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 December 22, 2025. On December 22, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 23, 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 and contact information in the Complaint. The Center sent an email communication to the Complainant on December 23, 2025, p roviding 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 26, 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 January 6, 2026. In accordance with the Rules, paragraph 5, the due date for Response was January 26, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on January 28, 2026. The Center appointed Enrique Bardales Mendoza as the sole panelist in this matter on January 30, 2026. The Panel finds 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 an Italian company founded in 1884 by Sotirios Voulgaris. The Complainant operates in the luxury goods and hotel markets, and is particularly known for its high-end jewellery including but not limited to watches, rings, necklaces, and fragrance products. The Complainant has more than 320 retail locations worldwide. The name “BULGARI” derives from the surname of the Complainant’s founder, “Voulgaris”. The Complainant’s trademark is used internationally in both its classic Latin alphabet form, “BVLGARI”, and its modern alphabet form, “BULGARI”. The Complainant owns numerous trademark registrations for BVLGARI and BULGARI in multiple jurisdictions, covering a wide range of classes, as detailed in the table below. Trademark Jurisdiction Registration Number Registration Date Classes Covered BULGARI China 341625 March 10, 1989 25 BULGARI China 15659745 December 28, 2015 3 BULGARI Australia 338663 October 5, 1979 14 BULGARI International 452694 May 15, 1980 11, 14, 20, 21 BULGARI Mexico 503494 March 28, 1996 25 BVLGARI Singapore T8405225G December 30, 1989 9 BVLGARI United States of America 1694380 June 16, 1992 18 BVLGARI Canada TMA312178 March 14, 1986 14, 21, 26 BVLGARI International 494237 July 5, 1985 3, 8, 11, 14, 16, 18, 20, 21, 25, 34 BVLGARI Italy 0000984147 November 18, 2005 25, 34, 38, 41 BVLGARI European Union 007138101 June 3, 2009 35, 36, 41, 43 The Complainant registered the domain name of its official website, “www.bulgari.com”, on February 17, 1998, and has had a strong web presence since that date. The Complainant’s official website, which receives over 2 million visits per month from users around the world, enables users to access all product lines: jewellery, watches, fragrances, leather goods, and accessories. The BULGARI brand is also reflected in the Complainant’s <bulgari.com> domain name, which redirects to its official website. Internet users are also able to locate the Complainant’s stores and authorized retailers worldwide. The Complainant has stores in multiple cities across Africa, Asia, Europe, the Middle East, the Americas, and Australia. Furthermore, the Complainant utilizes the BVLGARI/BULGARI trademark as part of their brand logo, and as a part of their social media presence. The disputed domain name was registered on November 24, 2025, through Gname.com Pte. Ltd. According to the evidence on record, the disputed domain name does not currently resolve to an active website, but previously resolved to a login webpage displaying the Complainant’s BVLGARI trademark. page 3 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 submits that the disputed domain name is identical to its well-known BVLGARI trademark. The disputed domain name reproduces the trademark in its entirety, without any alteration, addition, or distinguishing element. In accordance with well-established UDRP jurisprudence, the generic Top-Level Domain (“gTLD”) “.love” constitutes a mere technical registration requirement and is therefore irrelevant for the purpose of assessing identity or confusing similarity under paragraph 4(a)(i) of the Policy. Consequently, the Complainant maintains that the disputed domain name is identical to a trademark in which it holds longstanding and well-established rights. According to the Complainant, the Respondent lacks any rights or legitimate interests in the disputed domain name for the following reasons: (i) there is no relationship, license, authorization, or consent of any kind between the Complainant and the Respondent permitting the latter to use the BVLGARI trademark or to register a domain name incorporating it; (ii) the Respondent has never been commonly known by the name “BVLGARI,” nor does it own any registered or unregistered trademark rights corresponding to that term. Furthermore, the Respondent has not made, nor demonstrated preparations to make, any bona fide offering of goods or services under the disputed domain name, which has instead been held passively or used in a manner inconsistent with legitimate noncommercial or fair use; (iii) the Respondent’s registration and use of a domain name identical to a globally renowned and highly distinctive trademark evidences an intent to take unfair advantage of the Complainant’s reputation, to mislead Internet users as to the source or affiliation of the website, and to prevent the Complainant from reflecting its trademark in a corresponding domain name. In light of the foregoing, the Complainant asserts that it has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name within the meaning of paragraph 4(a)(ii) of the Policy, and that the burden of production therefore shifts to the Respondent. B. Respondent The Respondent did not reply to the Complainant’s contentions 6. Discussion and Findings According to paragraph 4(a) of the Policy, the Complainant must prove that the following three elements are present in order to obtain the transfer or cancellation of the disputed domain name: (i) the disputed domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; (ii) the Respondent has no rights or legitimate interests in respect of the disputed domain name; and, (iii) the disputed domain name has been registered and is being used in bad faith. page 4 Since in the present case there was no response from the Respondent to the Complaint filed by the Complainant, the Panel can take as true those supported assertions of the Complainant that it considers reasonable, see Joseph Phelps Vineyards LLC v. NOLDC, Inc., Alternative Identity, Inc., and Kentech, WIPO Case No. D2006-0292. A. Identical or Confusingly Similar It is well accepted that the first element under paragraph 4(a)(i) of the Policy functions primarily as a standing requirement. The test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. In this regard, the Panel refers to section 1.7 of the WIPO Overview 3.0. The Panel finds that the Complainant has established rights in respect of a trademark for the purposes of the Policy. The evidence on record demonstrates that the Complainant owns numerous valid and subsisting trademark registrations for BVLGARI and BULGARI in multiple jurisdictions worldwide, many of which significantly predate the registration of the disputed domain name. Accordingly, the Complainant has shown rights in a trademark within the meaning of paragraph 4(a)(i) of the Policy, consistent with section 1.2.1 of the WIPO Overview 3.0. Turning to the comparison between the trademark and the disputed domain name, the Panel observes that the disputed domain name reproduces the Complainant’s BVLGARI trademark in its entirety, without any alteration, misspelling, or additional distinguishing element. As such, the trademark is clearly recognizable within the disputed domain name. The Panel further notes that the generic Top-Level Domain (“gTLD”) “.love” is a standard registration requirement and, in accordance with section 1.11 of the WIPO Overview 3.0, is disregarded for the purposes of assessing identity or confusing similarity under the first element of the Policy. In these circumstances, the Panel finds that the disputed domain name is identical to the Complainant’s trademark for the purposes of paragraph 4(a)(i) of the Policy. Accordingly, the Panel concludes that the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy sets out a non-exhaustive list of circumstances by which a respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings rests with the complainant, panels have consistently recognized that proving a respondent lacks rights or legitimate interests may involve the difficult task of proving a negative. Accordingly, where a complainant establishes a prima facie case that the respondent lacks rights or legitimate interests, the burden of production shifts to the respondent to come forward with relevant evidence demonstrating such rights or legitimate interests, as reflected in section 2.1 of the WIPO Overview 3.0. Having reviewed the record, the Panel finds that the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. In particular, the evidence shows that the Respondent has not been authorized, licensed, or otherwise permitted to use the BVLGARI trademark, nor to register a domain name incorporating it. There is no evidence that the Respondent has been commonly known by the disputed domain name, nor that it owns any trademark or service mark corresponding to the term “BVLGARI”. The Panel further notes that the disputed domain name does not currently resolve to an active website and that there is no evidence of use, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services prior to notice of the dispute, within the meaning of page 5 paragraph 4(c)(i) of the Policy. Rather, the disputed domain name previously resolved to a website impersonating the Complainant. Nor is there any indication that the Respondent has made a legitimate noncommercial or fair use of the disputed domain name, as contemplated under paragraph 4(c)(iii) of the Policy. On the contrary, the circumstances of this case involve prior impersonation of the Complainant and current passive holding of the disputed domain name identical to the Complainant’s highly distinctive and well-known trademark, which does not confer rights or legitimate interests on a respondent. The Respondent has not submitted any response in these proceedings and has therefore failed to rebut the Complainant’s prima facie case or to provide any evidence demonstrating rights or legitimate interests in the disputed domain name, whether under paragraph 4(c) of the Policy or otherwise. In light of the foregoing, the Panel concludes that the Respondent has no rights or legitimate interests in respect of the disputed domain name. Accordingly, the second element of the Policy has been established. C. Registered and Used in Bad Faith For the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy sets out a non-exhaustive list of circumstances which, 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 considers that the circumstances of the registration and use of the disputed domain name support a finding of bad faith, even though the disputed domain name does not currently resolve to an active website. The Panel notes that the Complainant’s BVLGARI trademark is highly distinctive and enjoys a strong international reputation, having been used for many decades in connection with luxury goods and extensively promoted through physical retail locations, official websites, and social media channels. The Panel finds it implausible that the Respondent registered the disputed domain name without knowledge of the Complainant and its trademark rights. The registration of a domain name that is identical to a well-known trademark by an unaffiliated entity, without authorization and without any plausible legitimate explanation, constitutes compelling evidence of bad faith. This is consistent with section 3.1 of the WIPO Overview 3.0, which recognizes that bad faith may be found where a respondent takes unfair advantage of, or otherwise abuses, a complainant’s trademark. With respect to use, the Panel observes that the disputed domain name previously resolved to a login webpage impersonating the Complainant. Panels have held that use of a domain name for illegitimate activity, here claimed impersonation and phishing, constitutes bad faith. WIPO Overview 3.4. Currently, the disputed domain name is being passively held and does not resolve to an active website. However, panels have consistently found that the non-use of a domain name, including a blank or inactive page, does not prevent a finding of bad faith under the doctrine of passive holding. As reflected in section 3.3 of the WIPO Overview 3.0, the assessment of bad faith in such cases depends on the totality of the circumstances. Having reviewed the available record, the Panel notes in particular: (i) the distinctive character and reputation of the Complainant’s trademark; (ii) the fact that the disputed domain name is identical to that trademark; (iii) the absence of any evidence of actual or contemplated good-faith use by the Respondent; and (iv) the Respondent’s failure to submit any response or to provide any explanation for its registration of the disputed domain name. In these circumstances, the Panel finds that the passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. page 6 In light of the foregoing, the Panel concludes that the disputed domain name was registered and is being used in bad faith within the meaning of paragraph 4(a)(iii) of the Policy. Accordingly, the Panel finds that the third element of the Policy has been established. 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 <bvlgari.love> be transferred to the Complainant /Enrique Bardales Mendoza/ Enrique Bardales Mendoza Sole Panelist Date: February 13, 2026

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

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