Westmore · UDRP decision
WIPO · Case No. D2025-5404

Ag2rlamondlale.com

TransferWIPO-indexed · informational, not legal advice

The Panel ordered transfer of <ag2rlamondlale.com>. It found the domain confusingly similar to the Complainant’s AG2R LA MONDIALE mark despite replacing the letter “i” with “l”; found no rights or legitimate interests after the Respondent failed to rebut the Complainant’s prima facie case; and found bad-faith registration and use based on the mark’s reputation, the typosquatting composition, pay-per-click use, configured MX servers, the parties’ location in France, and the ongoing risk of phishing or fraud. The domain’s passive holding at the time of the decision did not prevent a bad-faith finding.

Outcome
Transfer
At a glance
Provider
WIPO
Outcome
Transfer
Decision date
2026-02-05
Panelist(s)
Buchman, Louis-Bernard
Complainant
GIE AG2R
Respondent
Patrick Juan
Disputed domain(s)
ag2rlamondlale.com
Citation weightrelies on 8 authorities
Domain history UDRP Intelligence

The timeline behind ag2rlamondlale.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 ag2rlamondlale.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 ag2rlamondlale.com.
Reverse Domain Name Hijacking
No RDNH raised.
Westmore Insight

The decision illustrates a conventional typosquatting case strengthened by two technical or commercial indicators: pay-per-click monetization and configured MX servers. It also shows that cessation of active website use before the decision does not neutralize prior use or prevent application of the passive-holding doctrine where the broader circumstances support bad faith.

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
2026-02-05
Panel
Buchman, Louis-Bernard
Full decision
10 min read · hosted by Westmore

ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION GIE AG2R v. Patrick Juan Case No. D2025-5404 1. The Parties The Complainant is GIE AG2R, France, represented by Scan Avocats AARPI, France. The Respondent is Patrick Juan, France. 2. The Domain Name and Registrar The disputed domain name <ag2rlamondlale.com> is registered with NameCheap, Inc. (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on December 26, 2025. On December 26, 2025, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On December 26, 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 (Redacted for Privacy, Privacy service provided by Withheld for Privacy ehf) and contact information in the Complaint. The Center sent an email communication to the Complainant on December 29, 2025, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant did not file an amendment. 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 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 27, 2026. The Center appointed Louis-Bernard Buchman as the sole panelist in this matter on January 29, 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 the management and administrative services entity of the French insurance group AG2R LA MONDIALE, founded in 1905, which is one of the major providers of personal and property insurance and pension asset management in France, with currently more than 12 million policyholders and protected beneficiaries and more than 383,000 corporate clients (i.e. one in four companies in France). The Complainant is the holder of a portfolio of trademarks, including inter alia the French trademark AG2R LA MONDIALE No. 3661597 registered on December 24, 2009, and the European Union trademark AG2R LA MONDIALE No. 008261166 registered on March 1, 2010 (together hereinafter referred to as: “the Mark”). The Complainant is also the registrant of several domain names, including in particular <ag2rlamondiale.com>, registered on February 16, 2007. The disputed domain name <ag2rlamondlale.com> was registered on December 19, 2025. The Complainant has submitted evidence that the disputed domain name was resolving to a parking page displaying pay-per-click links and that MX servers were configured under it. At the time of this Decision, the disputed domain name does not resolve to any active website. 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 reproduces the Mark, in which the Complainant has rights, and is confusingly similar to the Mark insofar as the disputed domain name contains the Mark, which remains recognizable in the disputed domain name; (ii) it never authorized the Respondent to use the Mark in any manner and it never had any affiliation with the Respondent, who has no rights or legitimate interests in respect of the disputed domain name; (iii) the Respondent has registered and is using the disputed domain name in bad faith; in particular, the Respondent had knowledge of the Mark when registering the disputed domain name, and by fraudulently creating confusion with the Mark, the Respondent is using the disputed domain name in bad faith. The Complainant requests that the disputed domain name be transferred to the Complainant. B. Respondent The Respondent did not reply to the Complainant’s contentions. page 3 6. Discussion and Findings 6.1. Procedural Aspects - Failure to Respond Under the Rules, paragraphs 5(f) and 14(a), the effect of a failure to submit a formal response by the Respondent is that, in the absence of exceptional circumstances, the Panel shall proceed to a decision on the basis of the Complaint. Under paragraph 4(a) of the Policy, it is the Complainant’s burden to establish that all three of the required criteria for a transfer of the disputed domain name have been met, even in the absence of a formal response. Under paragraph 14(b) of the Rules, the Panel is empowered to draw such inferences from the Respondent’s failure to file a formal response as it considers appropriate under the circumstances. In this case, the Panel finds that the Respondent has failed to rebut any of the reasonable factual assertions that are made and supported by evidence submitted by the Complainant. In particular, by failing to respond, the Respondent has failed to offer the Panel any of the types of evidence set forth in paragraph 4(c) of the Policy or otherwise, from which the Panel might conclude that the Respondent has any rights or legitimate interests in the disputed domain name, such as making legitimate noncommercial or fair use of the disputed domain name. Moreover, as discussed below, the Respondent has failed to provide any exculpatory information or reasoning that might have led the Panel to question the Complainant’s arguments that the Respondent has acted in bad faith. 6.2. Three Elements under Paragraph 4(a) of the Policy 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 notes that, as aforesaid, the Respondent did not rebut these assertions and finds that despite the replacement of the letter “i” in the Mark by the letter “l”, the Mark is recognizable within the disputed domain name. Although such substitution of one letter by another may bear on the assessment of the second and third elements, the Panel finds that it 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 1.9. Accordingly, the disputed domain name is confusingly similar to the Mark for the purposes of the Policy. WIPO Overview 3.0, section 1.7. Regarding the generic Top-Level-Domain (“gTLD”) “.com” in the disputed domain name, it is well established that a gTLD does not generally affect the assessment for the purpose of determining identity or confusing similarity. WIPO Overview 3.0, section 1.11.1. The Panel finds the first element of the Policy has been established. page 4 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 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. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith 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. Panels have found that the non-use of a domain name (including a blank or “coming soon” page) 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 distinctiveness or reputation of the Mark, which several prior UDRP panels have recognized to be well-known (see for instance GIE AG2R v debaba samir, WIPO Case No D2025-1068 and GIE AG2R v. julien rossi, WIPO Case No. D2025-1734), as well as the typosquatting composition of the disputed domain name, which strongly suggests an intent to take advantage of the Mark’s reputation. Considering in addition the size of the Complainant’s operations and the apparent location of the Respondent in France where the Complainant is headquartered, the Panel finds that the Respondent was necessarily aware of the Mark when it registered the disputed domain name. Regarding the implausibility of any good faith use, the Panel notes that the Complainant’s activity takes place in th e highly regulated insurance industry, and that the Respondent used the disputed domain name to intentionally attempt to attract Internet users, for commercial gain, by creating a likelihood of confusion with the Mark and to configure MX servers, thus creating for the Complainant a present and ongoing risk of phishing or fraudulent use. The Panel finds that in the circumstances of this case, the current passive holding of the disputed domain name does not prevent a finding of bad faith under the Policy. Finally, some UDRP panels have held that in certain circumstances, registrants of domain names would have a duty to abstain from registering and using a domain name, which is either identical or confusingly similar to a prior trademark held by others and which would infringe upon or otherwise violate the rights of a third party. See Policy, paragraph 4(b); Nike, Inc. v. B. B. de Boer, WIPO Case No. D2000-1397; Nuplex page 5 Industries Limited v. Nuplex, WIPO Case No. D2007-0078; Mobile Communication Service Inc. v. WebReg, RN, WIPO Case No. D2005-1304; BOUYGUES v. Chengzhang, Lu Ciagao, WIPO Case No. D2007-1325; Media General Communications, Inc. v. Rarenames, WebReg, WIPO Case No. D2006-0964; and mVisible Technologies, Inc. v. Navigation Catalyst Systems, Inc., WIPO Case No. D2007-1141. The Panel finds that the Respondent has clearly not abided by such duty. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. 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 that the disputed domain name <ag2rlamondlale.com> be transferred to the Complainant. /Louis-Bernard Buchman/ Louis-Bernard Buchman Sole Panelist Date: February 5, 2026

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

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