Westmore · UDRP DecisionMichelinguidedata.com, Michelinguidedataswork.com, Michelinguideworks.com
The Panel ordered the transfer of all three disputed domain names. It found the MICHELIN mark recognizable in each domain, found no rights or legitimate interests based on the unrebutted prima facie case and the domains’ use, and concluded that Respondent registered and used the domains in bad faith through conduct meeting paragraph 4(b)(iv) of the Policy.
The timeline behind michelinguidedata.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 michelinguidedata.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
How each disputed name was decided in this proceeding.
The case illustrates a coordinated multiple-domain registration pattern in which a trademark was combined with terms related to the trademark owner’s established guide activities, and all domains led to substantially matching login pages using the mark and brand imagery. Those combined circumstances were central across the rights-or-legitimate-interests and bad-faith analyses.
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 Compagnie Generale des Etablissements Michelin v. Vajida Umarmia, Enterprise Case No. D2025-5369 1. The Parties Complainant is Compagnie Generale des Etablissements Michelin, France, represented by Tmark Conseils, France. Respondent is Vajida Umarmia, Enterprise, Malaysia. 2. The Domain Names and Registra The Disputed Domain Names <michelinguidedata.com>, <michelinguidedataswork.com> and <michelinguideworks.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 December 19, 2025. On December 23, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the Disputed Domain Names. On December 24, 2025, the Registrar transmitted by email to the Center its verification response confirming that 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 Respondent of the Complaint, and the proceedings commenced on January 5, 2026. In accordance with the Rules, paragraph 5, the due date for Response was January 25, 2026. Respondent did not submit any response. Accordingly, the Center notified Respondent’s default on February 2, 2026. The Center appointed Richard W. Page as the sole panelist in this matter on February 5, 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 Complainant was created in 1889 and operates in the field of tire manufacturing and marketing for cars, trucks, motorcycles, and planes. Complainant is also highly involved in travel publications (maps, guides, atlases, and computerized products), in vehicle racing (Formula One, Motorcycle Grand Prix, and Superbikes), and in rallies. Complainant began publishing the travel/gastronomy Guide in Europe in 1900 to encourage new drivers to take road trips to local attractions. The Guide included anonymous European restaurant reviews that focused on the quality and flavor of the food served, as well as mastery of culinary technique and the personality of the dishes. The Michelin Star is a rating system used by Complainant since 1926 to grade restaurants on their quality. In 1926, the Guide began to award “stars” to fine dining establishments, initially marking them only with a single star. Five years later in 1931, a hierarchy of zero, one, two and three stars was introduced. In 1936, the criteria for the starred ranking were published. According to the Guide, one star signifies “a very good restaurant,” two stars mean “excellent cooking that is worth a detour,” and three stars mean “exceptional cuisine that is worth a special journey.” The listing of starred restaurants is updated once a year and includes major restaurants worldwide. Michelin Guides have become best sellers. The Guide now rates over 30,000 establishments in over 30 countries and territories across the world and more than 30 million Michelin Guides have been sold worldwide since. Complainant owns trademark registrations for MICHELIN (the “MICHELIN Mark”) in many countries around the world related to the production and sale of tires, as well as road maps and various guide publications about restaurants. Complainant is the owner of the following trademarks, without limitation: International Trademark Registration No. 1254506 for MICHELIN registered on December 10, 2014; United States of America Trademark Registration No. 5775734 for MICHELIN registered on June 11, 2019; and European Union Trademark Registration No. 013558366 for MICHELIN registered on April 17, 2015. The MICHELIN Mark covers products and services relating to tourism, hospitality, restaurants and gastronomy, and in particular “multimedia publication in electronic form available online for databases in the fields of travel, tourism, and gastronomy or for services of editing and publication of guides.” In addition, Complainant has registered and used various domain names incorporating the MICHELIN Mark such as <michelin.com> registered on December 1, 1993, and the sub-domain <guide.michelin.com>. These domain names reflect the MICHELIN Mark and relate to Complainant’s activities in the tire industry, as well as the fields of gastronomy and travel. The Disputed Domain Names were registered on December 3, 2025, and resolve to Respondent’s identical login websites containing the MICHELIN Mark and an image of “Michelin Man” (also known as “Bibendum”). page 3 5. Parties’ Contentions A. Complainant Complainant contends that the MICHELIN Mark is without doubt considered as well-known in accordance with Article 6bis of the Paris Convention due to its old and intensive use. Complainant further contends that the MICHELIN Mark has acquired a significant and indisputable reputation. Complainant further contends that it has received several rulings from previous UDRP panels that the MICHELIN Mark is “well-known” or “famous.” Complainant further contends that the Disputed Domain Names are confusingly similar to the MICHELIN Mark. The addition of the term “guide” within the Disputed Domain Names, in combination with the well- known and valuable MICHELIN Mark reinforces the risk of confusion in the minds of Internet users. The Disputed Domain Names could erroneously lead Internet users to believe that Respondent’s websites are referring to catering activities awarded by the famous Michelin Guide and/or that it has been sponsored and approved by the Michelin Guide. Complainant submits that Respondent has no rights or legitimate interests in the Disputed Domain Names. Complainant further submits that it has not authorized Respondent to use the MICHELIN Mark in a domain name or otherwise. Complainant further submits that Respondent is using the Disputed Domain Names to trade off the MICHELIN Mark. Complaint alleges that Respondent has registered and used the Disputed Domain Names in bad faith, pursuant to paragraph 4(b)(iv) of the Policy. Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the Disputed Domain Names. B. Respondent Respondent did not reply to Complainant’s contentions. 6. Discussion and Findings Paragraph 15(a) of the Rules instructs the Panel as to the principles the Panel is to use in determining the dispute: “A Panel shall decide a complaint on the basis of the statements and documents submitted in accordance with the Policy, these Rules, and any rules and principles of law that it deems applicable.” Even though Respondent has failed to file a Response or to contest Complainant’s assertions, the Panel will review the evidence proffered by Complainant to verify that the essential elements of the claims are met. WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition (“WIPO Overview 3.0”), section 4.3. Paragraph 4(a) of the Policy directs that Complainant must prove each of the following three elements: i) that the Disputed Domain Names registered by Respondent are identical or confusingly similar to the MICHELIN Mark in which Complainant has rights; and ii) that 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. page 4 A. Identical or Confusingly Similar WIPO Overview 3.0, section 1.2.1 states that registration of the MICHELIN Mark is prima facie evidence of Complainant having enforceable rights in the MICHELIN Mark. Complainant has shown rights in respect of the MICHELIN Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.2.1. 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 MICHELIN Mark and the Disputed Domain Names. WIPO Overview, section 1.7. The Panel finds the MICHELIN Mark is recognizable within the Disputed Domain Names. Accordingly, the Disputed Domain Names are confusingly similar to the MICHELIN Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Although the addition of other terms “guide,” “data,” and “works,” 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 MICHELIN Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.8. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy allows three nonexclusive methods for the Panel to conclude that Respondent has rights or a legitimate interest in the Disputed Domain Names: (i) before any notice to you [Respondent] of the dispute, your use of, or demonstrable preparations to use, the Disputed Domain Names or a name corresponding to the Disputed Domain Names in connection with a bona fide offering of goods or services; or (ii) you [Respondent] (as an individual, business, or other organization) have been commonly known by the Disputed Domain Names, even if you have acquired no trademark or service mark rights; or (iii) you [Respondent] are making a legitimate noncommercial or fair use of the Disputed Domain Names, without intent for commercial gain to misleadingly divert consumers or to tarnish the MICHELIN Mark. Although the overall burden of proof in UDRP proceedings is on Complainant, panels have recognized that proving Respondent lacks rights or legitimate interests in the Disputed Domain Names may result in the difficult task of “proving a negative,” requiring information that is often primarily within the knowledge or control of Respondent. As such, where Complainant makes out a prima facie case that Respondent lacks rights or legitimate interests, the burden of production on this element shifts to Respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the Disputed Domain Names (although the burden of proof always remains on Complainant). If Respondent fails to come forward with such relevant evidence, Complainant is deemed to have satisfied the second element. WIPO Overview 3.0, section 2.1. Complainant submits that Respondent is intentionally trading off the goodwill of the MICHELIN Mark. The Panel finds that such use can be neither bona fide nor legitimate. The Panel further finds no evidence in this record that Respondent has been commonly known by the Disputed Domain Names. Having reviewed the available record, the Panel finds Complainant has established a prima facie case that Respondent lacks rights or legitimate interests in the Disputed Domain Names. Respondent has not rebutted 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. page 5 Panels have held that the use of the Disputed Domain Names for illegitimate activity, here claimed as impersonation/passing off, can never confer rights or legitimate interests on Respondent. WIPO Overview 3.0, section 2.13.1. 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 the Disputed Domain Names in bad faith. Paragraph 4(b) of the Policy sets forth the following four nonexclusive criteria for Complainant to show bad faith registration and use of the Disputed Domain Names: (i) circumstances indicating that you [Respondent] have registered or you have acquired the Disputed Domain Names primarily for the purpose of selling, renting, or otherwise transferring the Disputed Domain Names’ registration to Complainant who is the owner of the MICHELIN Mark or to a competitor of Complainant, for valuable consideration in excess of your documented out-of-pocket costs directly related to the Disputed Domain Names; or (ii) you [Respondent] have registered the Disputed Domain Names in order to prevent the owner of the MICHELIN Mark from reflecting the MICHELIN Mark in a corresponding domain name, provided that you have engaged in a pattern of such conduct; or (iii) you [Respondent] have registered the Disputed Domain Names primarily for the purpose of disrupting the business of a competitor; or (iv) by using the Disputed Domain Names, you [Respondent] have intentionally attempted to attract, for commercial gain, Internet users to your website or other online location, by creating a likelihood of confusion with the MICHELIN Mark as to the source, sponsorship, affiliation, or endorsement of your website or location or of a product on your website or location. The Panel finds that the activities of Respondent meet the criteria of paragraph 4(b)(iv) of the Policy. 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 Panels further finds that Respondent knew or should have known of Complainant’s rights in the MICHELIN Mark at the time the Disputed Domain Names were registered and used. Nor can Respondent rely upon willful blindness of Complainant’s rights in the MICHELIN Mark. WIPO Overview 3.0, sections 3.2.2 and 3.2.3. Panels have held that the use of a domain name for illegitimate activity, here claimed as impersonation/ passing off, constitutes bad faith. WIPO Overview 3.0, section 3.4. Having reviewed the record, the Panel finds Respondent’s registration and use of the Disputed Domain Names constitute bad faith under the Policy. The Panel finds that the Complainant has established the third element of the Policy. page 6 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 <michelinguidedata.com>, <michelinguidedataswork.com> and <michelinguideworks.com> be transferred to Complainant. /Richard W. Page/ Richard W. Page Sole Panelist Date: February 16, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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